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the benefit from his suggestion.The SEC also found Vorapin sold 318,500 TUCC shares in her own securities trading account during July 27-28, 2011 in such a way that taking advantage of others by using
securities trading account of another person for her own or others? benefits in such a way that taking advantage of others. The selling was made by using material non-public information concerning a 129.83
November 11, 2014 Charin, then PAP independent director, arranged a sale of 147,000 PAP shares in which he had a stake held in the trading account of another person. In so doing, he took advantage of the non