buggs: There is a key statement in that lawyer's web page. Since Benz is SK legal counsel,  I'm now fairly well convinced that SK has not repurchased shares as of the last report (Q3). In other words, even if they could do it sub rosa, they most likely wouldn't.

"Even if a company is not a reporting issuer, following the safe harbor is clearly the most effective way for the company to avoid liability for manipulating its own stock price. Therefore, we generally recommend that Rule 10b-18 be followed by all public issuers, even those whose stock is traded on the Pink Sheets."
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"Beginning with their first periodic report required to be filed for a period ending on or after March 15, 2004, and each quarterly thereafter, issuers must publicly report in Form 10-Q, Form 10-K or Form 20-F the total number of shares they repurchase." (SEC on repurchase)