No idea but I’m certain his financial advisor an

No idea but I’m certain his financial advisor and CPA were screaming at him to take a tax loss on his concentrated stock position to use against the gains he envisions down the road. I’d bet they recommended taking him just below the level for reporting as an insider, because he didn’t dump more than that. The normal tools for dealing with a concentrated stock position aren’t available on the OTC. What he did was very prudent.