Definitions
For purposes of determining the blackout period, “date of the offering” means the later of the effective date or the date the security was bona fide offered to the public.
FINRA defines “public appearance” to mean any participation in any conference call, seminar, public or interactive electronic forum, or any other public speaking activity with an audience of (1) 15 or more persons or (2) at least one press representative. The appearance may be live, telephonic, or via the web. Note that under this definition, participation at an
