The 4.99% limitation is precisely why, in the single scenario I painted, GHS converts only half of the Meadows transfer note. However, it’s not much of a limitation when the entire note could be converted in 2 tranches. Further, I gave a clear elucidation as to why I thought the GHS selling of the converted shares would likely be done in a staged, stealthy manner.

We appear to agree on our understanding and interpretation of the EFA.