Disclosures of 10b5-1(c) trading plans and other stock trading information

There is no explicit requirement to disclose Rule 10b5-1(c) trading plans. Nevertheless, some disclosure may be advisable in order to anticipate questions about insider sales and increase the likelihood that the existence of a plan will be noticed in a securities class action lawsuit. Increasingly, issuers and their officers and directors are choosing to make disclosure about trading plans or other stock sale-related circumstances. Other issuers are publishing their corporate insider trading policies.

This tables lists the disclosures I have found to date so as to provide a resource for persons considering such disclosure. Note that there are no som many references to 10b5-1(c) trading plans in Form 4s that I have stopped recording those dislcosures. As Internet links tend to disappear over time, I have switched to all PDF files or HTML files. Where a link is blank, it is to a file I am converting to PDF for upload. References to Internet pages sometimes will pull a PDF file; this reflects that when the link on the company's Internet page is called, it points to a PDF file.

Disclosures of the adoption of individual officer, director, or other insider trading plans

Disclosures that officer, director, or other insider's sales were made pursuant to a trading plan

Disclosures of the termination, modification, or completion of an individual officer, director, or other insider trading plan

Disclosures of issuer trading plans

Disclosures of trading plans by other shareholders

Disclosures of issuer insider trading policies

Other disclosures regarding stock sales

Adoption of Individual Trading Plans
Issuer

 Industry
Date Type of Document Disclosure
7-Eleven

Retail (food)

9/3/04

  Press release
Senior VP has adopted trading plan to increase holdings by exercising options scheduled to expire over next two years, and then selling only what is required to pay taxes
Abington Bancorp

Banking

2/8/03

Press release
Chairman \ CEO has adopted trading plan to diversify holdings; parameters set forth, which will leave seller with 85% of holdings
Accredited Home Lenders Holding 

Mortgage banking

12/8/04

Press release
President \ COO has adopted trading plan; number of shares and remaining holdings disclosed
Actuant

 Industrial products

10/1/04

 Press release
CFO has adopted trading plan to sell options that must be exercised over next 10 months, and represent 11% of total holdings
Acxiom 

Marketing services

4/14/04

Press release
Leader has adopted trading plan to sell up to identified number of shares (18% of total holdings) over 14 month period to retire personal debt
Advance Auto Parts

Retail (automotive)

5/27/04

Press release
Chairman \ CEO has adopted trading plan to sell up to identified number of shares in six month period subject to unidentified target prices, on financial advisors' recommendation as a way of achieving prudent diversification
AirTran Holdings

Transportation

3/19/04

Press release
Chairman \ CEO has adopted trading plan to exercise unidentified number of options and sell shares for next six months, subject to renewal
AirTran Holdings

Transportation

8/27/04

Press release
Chairman \ CEO has extended previously announced trading plan for additional six months
Alaris Medical Systems

 Medical devices

11/4/03

Press release
Several executives, including President \ CEO, have adopted trading plans to allow prudent and gradual diversification, as most financial advisers recommend; number of shares and % of holdings disclosed
Allstate 

Insurance

 8/4/04

 Press release
Chairman \ CEO has adopted trading plan involving exercise of options as they approach expiration or reach unidentified target prices, for diversification and estate planning goals while minimizing market effect of sales by spreading them out over time; CEO intends to increase holdings over time
American Superconductor 

Energy products

3/17/04

Press release
CEO has adopted trading plan to sell up to 15% of shares, to diversify portfolio and allow for orderly exercise of vested options (including ones that will expire shortly); earlier this week, CEO had exercised options that were scheduled to expire in closed trading window
AmericanWest Bancorporation 

Banking

 3/1/04

Press release
President \ CEO has adopted trading plan to sell up to 9% of holdings over next 9 months as part of personal financial / tax planning, his first significant sale in 25 years
America's Car Mart

Retail (automotive)

6/14/04

Press release
Chairman \ CEO has adopted trading plan to sell up to identified number of shares per month over next year upon unidentified market conditions as part of long-term diversification and liquidity strategy
AMIS Holdings

Semiconductors

9/17/04

Press release
Senior VP has adopted trading plan to sell identified number of shares in upcoming month (13% of total holdings) for diversification purposes
Amkor 

Semiconductor manufacturing services

12/17/03

Press release
"Company" has adopted trading plan in which officers and directors can participate in order to monetize options and spread sales that otherwise would be made only during open windows; Chairman \ CEO has elected not to, and participants collectively will sell 0.7% of company's total outstanding stock
Angiodynamics 

Medical devices

2/18/05

Form 8-K
Two directors, CEO, and unspecified other officers have adopted trading plans; some share amounts disclosed
Apple Computer 

Computers

2/12/05
 Form 10-Q at 12 Certain officers have adopted trading plans during prior quarter
ATI Technologies 

Graphics chips

11/5/03

Press release
President \ COO has adopted trading plan to sell up to identified number of shares, leaving him with same number, for estate planning and investment diversification purposes
Autodesk

 Software

 5/19/04

 Proxy statement (DEF 14A)
CEO has entered into plan that provides for exercise of options and automatic sale of the underlying shares; formula not set forth
Bank of Bermuda

Banking

12/13/02

Press release
CEO has "implemented" trading plan to sell identified number of shares over next year, as part of company's effort to ensure that senior management's sales are independent of company news and market effect of sales is minimized
bebe stores

Retail (clothing)

 2/19/04

 Press release
Chairman has adopted trading plan; number of sales and remaining shares held disclosed
Belo

Media

11/30/01
 Press release Chairman \ CEO has adopted trading plan; formula set forth, which allows sale of less than 2% of holdings over year
Biopure

Pharmaceuticals

1/11/02

Press release
Certain officers (for example, the CEO, who will sell up tp 6% of holdings in upcoming year) have adopted trading plans following company's amendment of insider trading policy to allow such plans
Calpine

Energy

2/28/02

Press release
Chairman \ CEO is exercising identified number of options scheduled to expire at end of year during open trading window, and intends to sell shares pursuant to trading plan
Calpine

Energy

2/3/04

 Press release
Chairman \ CEO is exercising identified number of options scheduled to expire by end of year during open trading window, and intends to sell pursuant to trading plan on same days (1st and 15th of each mnonth) the number of shares required to cover exercise price and pay taxes
CardioDynamics

Biotechnology

Ongoing

Internet page
Six unidentified members of management team have adopted trading plans to (collectively) sell less than identified number of shares representing approximately 1% to 7% of holdings; company anticipates that others may establish plans in future
CardioDynamics

Biotechnology

5/3/04

Form 8-K
Six identified officers adopted trading plans on this date, as allowed by company policy; sales will commence after identified date, will made made only during open windows, and will constitute approximately 7% of holdings
Central Garden & Pet

Consumer products

8/8/03

Press release
President \ CEO has adopted trading plan to sell up to identified number of shares under options scheduled to expire in nezt year subject to unidentified price target, on recommendation of advisor to find an orderly way to deal with the options
Central Garden & Pet

Consumer products

5/28/04

Press release
President \ CEO has adopted another trading plan tosell up to identified number of shares under options scheduled to expire in nezt year subject to unidentified price target, on recommendation of advisor to find an orderly way to deal with the options
Chartered Semiconductor Manufacturing

 Semiconductor assembly

 7/31/01

 Press release
Chairman \ CEO has adopted trading plan that will sell shares but result in net increase in holdings due to exercise of options
Check Point Software 

 Software

 4/21/05

Press release
CEO and Senior VP have adopted trading plans to cover expiring options; number of shares disclosed
Chico's FAS

 Retail (clothing)

12/26/02

Press release
Limited parternership managed by CEO has adopted plan to sell identified number of shares during open window periods if unidentified target prices hit, in continuation of long held family plan in anticipation of retirement and to allow orderly sales
Chiron 

 Pharmaceuticals

 10/2/03

Press release
Chairman has adopted trading plan to sell a substantial portion of vested options; with sales up to an identified number of share on a daily basis, subject to unidentified price target; to diversify portfolio in orderly manner in anticipation of announced retirement in 8 months
Chordiant Software

Software

 3/28/03

Form 10-K
Company has been advised that certain directors and officers, five of which were named, have entered into trading plans
Cirrus Logic

Semiconductors

6/1/04
  Press release CEO has adopted trading plan to sell up to identified number of shares over next month; portion of proceeds will be used to repay company loan
Compass Minerals

Materials

2/16/05

Press release
CEO, CFO and general counsel have adopted trading plans; number of shares disclosed
Crane

Industrial products
7/26/01 Press release Chairman has adopted trading plan; formula substantially disclosed (maximum number of shares in four month period, or approximately 16% of holdings)
CTS 

Electronic components

6/18/01

Press release
Chairman has adopted trading plan to exercise options and sell; number of shares disclosed
CyberSource

 Electronic payment systems

 2/19/04

Press release
Chairman \ CEO has adopted trading plan to sell less than 15% of holdings for diversification purposes
Daleen Technologies

Software

12/14/00

Schedule 13D
Holding company for Chairman\CEO sold shares under trading plan, apparently because seller received margin calls; trading plan (instruction letter to broker) set forth in full
deCode

Biotechnology

7/2/04

Press release
President \ CEO has adopted trading plan to sell up to 12% of holdings in next year, for diversification purposes
Digital Insight 

 Internet transaction services

8/23/04

Press release
Director has adopted trading plan to sell up to identified number of shares for asset diversification and liquidity purposes
Education Management

Education

9/30/02

Press release
Chairman has adopted trading plan to sell up to identified number of shares during next year as part of ongoing diversification
Echelon

Hardware integration

8/23/04

Press release
CFO has adopted trading plan to sell unidentified number of shares over next year
Egghead.com

Internet commerce

11/13/00

Form 8-K
Co-chairman has adopted trading plan to sell identified numebr of shares
El Paso Electric

 Energy

 2/26/01

 Press release
CEO has adopted trading plan to sell identified numebr of shares
EXACT Sciences

Biotechnology
4/12/01 Proxy statement Insider trading policy allows trading plans and one officer (VP) has adopted a plan; no disclosure of formula
Exelixis

 Pharmaceuticals

 10/9/03

Press release
CEO has adopted trading plan to sell approximate number of shares per year, and also completed sales to repay a loan from the company
E-Z-EM

 Biotechnology

 6/16/04

Press release
Chairman has adopted trading plan to sell up to specified number of shares per month for next two years, for diversification purposes
E-Z-EM

 Biotechnology

 5/4/05

Form 8-K
Two directors have adopted trading plans, one of which is limited in amount by a tax ruling
Ferro 

Industrial chemicals

3/8/04

Press release
Chairman \ CEO has adopted trading plan to sell up to identified number of shares (existing and by exercise of options) approximately over next year, for purposes of financial planning, allowing orderly sales, and avoiding any concerns about timing; ownership interest will remain roughly unchanged at end of plan period
Fifth Third Bancorp

Banking

6/30/04

Form 8-K
Personal financial advicors of President \ CEO have advised company that he plans to adopt trading plan for tax planning, charitable and estate planning purposes; plan will identified number of shares of CEO and wife (less than 5% of holdings), and CEO also will enter into prepaid forward contract to deliver up to identified number of shares. Company expects that others will adopt plans, but disclaims duty to disclose them or to disclose termination or operation of CEO's plan
Garmin

Navigation and communication devices

7/31/02

Press release
Trust and director have adopted and/or executed trading plans; general counsel quoted in press release
Garmin

Navigation and communication devices

2/12/03

Press release
Trusts of two insiders directors and spouses have adopted trading plans under which the trustees will sell up to identified number of shares over 34 week period; sales will increase public float and hence liquidity of company's shares
Gentiva Health Services 

Healthcare services

3/23/04

Press release
Director has adopted trading plan to sell up to 1 million shares for estate planning and diversification purposes
Gilead Sciences 

Biotechnology

8/17/04

Press release
Chairman has adopted trading plan to sell over next year; precise details of number of shares and target prices disclosed
Given Imaging

Medical devices

8/6/02 

Press release
President \ CDEO has adopted trading plan to sell up to identified number of shares (less than 15% of total holdings) on weekly basis for approximately one year, to repay loan from company and diversify assets
Harvard Bioscience 

 Biotechnology

 6/9/04

 Press release
President has established trading plan; may sell up to 20% of holdings under plan, which was adopted when he was not in possession of material nonpublic information
HCA 

Healthcare

2/2/06

Press release
Chairman \ CEO has adopted trading plan, which will cover optiosn expiring in next few years, for diversification purposes; he and wife also have donated stock
HealthExtras

Healthcare benefits management

5/28/04

 Press release
CEO and CFO intend to participate in plan adopted by company; senior executives collectively may sell up to identified number of shares per year, and neither participating executive will sell more than 10% of holdings in the plan year
Hologic

Medical devices

8/5/04

Press release
CFO and Chairman \ CTO have adopted trading plans to sell shares from exercise of expiring options, some above market price and some at market price, and existing shares as part of long-term diversification and liquidity strategy
Hyperion

 Software

 6/15/04

 Comments in third party article
Reported executive sales made pursuant to trading plans, and are not connected with company buy-backs; company required top 5 executives to adopt trading plans
Isis Pharmaceuticals

Pharmaceuticals

4/2/02

Press release
Several unidentified insiders whose options are scheduled to expire have adopted trading plans to facilitate sales in an orderly fashion
JDS Uniphase

Fiber optics equipment

12/8/00
Form 8-K Listed directors and officers have adopted trading plans; no details of plans
Jo-Ann Stores 

Retail (clothing)

9/13/04

Press release
Chairman \ President \ CEO has adopted trading plan for up to 9% of shares held by family partnerships and family trust over 8 momnths, to satisfy tax and other obligations and diversify for estate planning purposes, and with overall goal of spreading out sales over time rather than limiting to open window periods
John H. Harland

Software and printed products

5/17/05

Press release
CEO \ Chairman and division president have adopted trading plans; number of shares and remaining holdings disclosed
Kirby

Petrochemicals

2/6/03
Press release Chairman has adopted trading plan to sell identified number of shares (and percentage of holdings)
Knight Capital Group

Financial services

8/23/04

Form 8-K
Director has informed company that a chritable trust of which he is a trustee has adopted a trading plan
Krispy Kreme Doughnuts

Retail (food)

Ongoing

Internet page
Five key senior executives have agreed to adopt trading plans; some details disclosed as transactions made
Kulicke & Soffa

Semiconductor assembly

11/21/01

Press release
Chairman \ CEO has adopted trading plan, which allows trades outside of windows but not more than 10% of holdings over year
Ligand Pharmaceuticals 

Pharmaceuticals

12/13/04

Form 8-K
Chairman \ CEO has adopted trading plan; trading plan disclosed as Exhibit
Lincare 

Healthcare services

4/22/04

Press release
Chairman \ CEO has adopted trading plan to sell identified number of shares over next 17 months
LivePerson 

Software

9/26/03

Form 8-K
Director and brokerage firm with which he is affiliated have jointed adopted trading plan during open trading window, to sell identified number of shares at identified target price or higher, through end of current blackout period. Company disclaimed duty to disclose adoption or termination of plans
Lone Star Steakhouse & Saloon 

Retail (food)

8/24/04

Form 8-K
Director has adopted plan to sell up to identified number of shares issuable upon exercise of options that soon will expire; Senior Vice President previously adopted plan that will sell similarly situated shares in upcoming two month period
LookSmart

Internet services

9/20/04

Press release
Directors \ founders have adopted trading plans to sell up to identified number of shares in upcoming year
McKesson HBOC

Healthcare management

6/1/01
Press release Chairman has adopted plan for tax planning and asset diversification purposes; total number of shares disclosed
Medarex

Biotechnology

 5/3/02

 Press release
Chairman \ CEO has adopted plan; formula set forth
Medicines Company 

Pharmaceuticals

Ongoing

Internet page
Comments by senior executives who have adopted or traded under trading plans; comments reflect trading goals such as investing in family projects, and use of prepaid forward contracts
Metropolitan Health Networks 

 Healthcare management

10/1/04

Press release
Director has adopted trading plan to sell up to identified number of shares (6% of holdings) starting 30 days after adoption, for diversification purposes
Moldflow 

Software

3/11/04

Press release
Executive VP \ General Manager has adopted trading plan to diversify portfolio through sale of portion of shares he received in connection with acquisition
Monsanto

Chemicals and agricultural products

7/14/04

Press release
Chairman \ President \ CEO has adopted trading plan in order to satisfy requirement to hold five times salary in stock; plan will exercise options and sell shares to pay taxes and fees, and once requirement met will sell shares for diversification purposes
Montpelier Re

Insurance

 3/4/04

Press release
Chairman \ CEO has adopted trading plan
MRV Communications

Fiber optics components
8/3/01 Press release Chairman \ CTO and CEO have adopted trading plans; partial disclosure of formulas (amounts per day, approximately 10% of holdings)
MTC Technologies 

Engineering and management services

12/2/02

Press release
President \ CEO has adopted trading plan to exercise identified number of options per month and sell all shares provided that unidentified target price hit, over next 12 months
Multi-Fineline Electronics

Computer component manufacturing

12/21/04

Press release
Two officers and director have adopted trading plans; number of shares disclosed
Mykrolis 

Semiconductor manufucturing services

11/12/03

Press release
Certain officers (including CEO) have adopted trading plans, which will spread sales more than if made under trading windows
Navteq

Digital map information
12/17/04

Press release
CEO has adopted trading plan, which will start trading after lock up expires; unnamed other officers also have adopted plans
Neoware Systems 

Software

9/10/02

Press release
CEO has adopted trading plan upon company's amendment of insider trading policy to allow same; plan may result in sale of identified number of shares (of exercised options) if unidentified price targets hit, and there will be other sales outside of plan; proceeds will be used to buy more shares, thus resulting in greater holdings
NetScout Systems 

Software

12/2/04

Press release
Co-founders and other unnamed officers have adopted trading plans, each transferring less than 10% of holdings to a blind trust
Omega Protein

Food

8/19/04

Form 8-K
CFO has adopted trading plan; plan attached as Exhibit
On2 Technologies

 Video software and hardware

 10/31/03

 Press release
Chairman \ CEO has adopting trading plan; maximum number of shares reported, officer quoted to effect that close to 100% of net worth is in stock
Optical Communication Products

 Networking

 5/25/01
 
Press release
 Chairman \ CEO, CTO, and CFO have adopted trading plans; formulas substantially disclosed (number of shares per day, and less than 10% of holdings)
Oracle

Software

 1/30/04

Press release
Chairman and CEO have adopted trading plans as part of long term strategy to diversify assets and obtain liquidity; amount of sales and remaining holdings disclosed
Oracle

Software

 3/26/04

Press release
President has adopted trading plans as part of long term strategy to diversify assets and obtain liquidity; amount of sales and remaining holdings disclosed
Oracle

Software

 4/30/04

Press release
Executive VP has adopted trading plan as part of long term strategy to diversify assets and obtain liquidity; amount of sales and remaining holdings disclosed
Papa John's 

Retail (food)

5/27/04

Press release
Chairman \ CEO has adopted trading plan to sell identified number of shares over next year for ongoing tax planning and asset diversification purposes; officer also may sell or gift outside of plan
Peabody Energy 

Energy

8/6/04

Press release
Chairman \ CEO has adopted trading plan to sell up to 40% of holdings during identified time period to diversify asset portfolio, provide for long-term financial security, and offer transparency to shareholders
PEC Solutions

Internet services

3/22/02

Press release
Director \ CTO has adopted two trading plans, one that will purchase identified number of shares at unspecified times over next year, and the other than will sell identified number of shares at unspecified times over next year
PEC Solutions

 Internet services

6/11/02

Press release
CEO \ director has adopted trading plan for himself and family trust; number of shares disclosed
Pediatrix Medical Group

Healthcare services

2/19/04

Press release
President \ CEO and wife have adopted trading plan involving forward sales of identified number of shares from expiring options and holdings, with maximum sales per month above identified target price, for estate planning objectives
Plantronics

Communications products

12/31/01

Press release
Unidentified executive officer adopted trading plan to sell unidentified limited number amounts of holdings
Premiere Global Services 

Software and services

2/23/05

Form 8-K
CEO \ Chairman and two business unit presidents have adopted trading plans; CEO's plan sells shares that were not sold under a previous, expired plan; number of shares and remaining holdings disclosed
Presstek

Printer products

9/20/04

Press release
Director has adopted trading plan to sell up to identified number (small portion of holdings) of shares during identified time period, for liquidity management purposes
Procter & Gamble

Consumer products

11/26/02

Form 8-K
Company has been advised that Chairman \ President \ CEO, during open trading window, has adopted trading plan to sell identified number of shares over current year at unidentified prices. Company disclaims duty to disclose others' trading plans or to disclose termination or operation of any plan
Progressive

Insurance

4/26/04

Press release
Chairman has adopted trading plan to sell up to identified number (12% of holdings) of shares, as part of ongoing tax planning and asset diversification
Qwest Communications

Telecommunications
2/16/01 Press release CEO has adopted trading plan at request of Board; formula for plan disclosed (sales per day until options expire)
R.J. Reynolds Tobacco Holdings

Tobacco

12/4/03

Press release
Executive VP and President \ COO have adopted trading plans to sell restricted shares that will vest in amounts set by long-term incentive plan; first officer also adopted plan to sell existing shares; after plans, both officers will continue to meet company's requirement to hold shares
R.J. Reynolds Tobacco Holdings

Tobacco

12/18/03

Press release
Two senior VPs have adopted trading plans to sell restricted shares that will vest in amounts set by long-term incentive plan; both plan to continue to meet company's requirement to hold shares
R.J. Reynolds Tobacco Holdings

Tobacco

12/23/03

Press release
Senior VPs has adopted trading plan to sell restricted shares that will vest in amounts set by long-term incentive plan; after sales, officer will to continue to meet company's requirement to hold shares
Radio Shack

Retail

 3/14/04

Press release
Chairman \ CEO has adopted trading plan on advice of financial advisers, which enables him to diversify assets while remaining aligned with shareholders; amount of sales and percentage of holdings disclosed
Red Hat

Software
Ongoing Internet page A page titled "Approved Trading Plans" that is a menu selection from the Investor Relations page lists all trading plans currently in effect; partial disclosure of formulas (total amount of sales during time frame)
Reinsurance Group of America

Insurance
8/6/01 Press release CEO and COO have adopted trading plans for option shares; formulas not disclosed
Renovis

Pharmaceuticals

11/22/04

Press release
CEO has adopted trading plan
Right Management Consultants

Management consulting services

 12/23/02

Press release
CEO and former officer (both directors) have adopted trading plans for purposes of portfolio diversification; maximum number of shares to be sold if unidentified target prices hit disclosed
RTW

 Compensation management

 8/30/04

Press release
Founder \ director has adopted trading plan for specified number of shares to be sold if stock is trading above unidentified target price
S & T Bancorp

Banking

 8/29/03

Press release
President \ CEO has adopted trading plan; number of remaining holdings disclosed
SCS Transportation 

Truansportation

5/6/04

Press release
Chairman \ President \ EEO has adopted trading plan for tax and financial planning strategy and to protect options from expiring; intent is to divide net proceeds between cash and purchase of additional shares
Semtech

Semiconductor

7/7/04

 Form 8-K
Chairman has informed company that he has adopted trading plan; amount of sales within unidentified price ranges and remaining holdings disclosed
Sherwin-Williams

Home products

2/11/04

Press release
Chairman \ CEO has adopted trading plan to sell up to identified number of shares subject to market price, for financial planning purposes and to allow orderly sales; total holdings will increase over the next year notwithstanding plan
Silicon Image

Video and computer components

 8/6/04

Form 8-K
Two officers have adopted trading plans; number of shares disclosed
SpectraLink

Telecommunications
Previously ongoing Internet page "Officers \ Executive Management" page from Investor Relations section had noted that one officer (CEO) has adopted a plan; formula not disclosed; this has since been discontinued (or no officers have plans)
SPX

Industrial products and services

1/2/04

Press release
Chairman \ President \ CEO has adopted trading plan for diversification and estate purposes
Startek 

 Management and personnel services

3/26/04

Form 8-K
President \ CEO has adopted trading plan for sale of up to identified number of shares subject to unidentified limitations in order to obtain diversification and liquidity in his portfolio
Steiner Leisure 

 Home products

12/31/01

Press release
Chairman \ CEO has adopted trading plan; number of shares disclosed
Sykes Enterprises

Management consulting services

12/2/03

Press release
Chairman \ CEO and family limited partnership have adopted trading plan, under which latter will sell up to identified number of shares over next 3 years (some under prepaid forward contracts, where counterparty will then hedge) as part of family's overall financial and tax planning
Tessera

Semiconductor packaging

Ongoing

Internet page
Governance Highlights page has link to 10b5-1 Plans
Third Wave Molecular Dynamics

Medical devices

12/3/0/03

Press release
Co-founder \ director has adopted trading plan to sell less than 10% of holdings at unidentified prices significantly higher than current stock price, to diversify a small portion of holdings in orderly, prearranged manner
TransAct

Printers

 3/10/04

Press release
CFO has adopted trading plan to sell identified number of shares per month over 12 months upon financial advisor's advice to prepare for upcoming retirement
TWP Worldwide 

Personnel services

11/9/01

Press release
Chairman \ CEO has adopted trading plan to sell up to identified number of shares, with no termination date, for diversification, estate planning and charitable purposes and to minimize market impact; large sale already made outside the plan, but during next year all sales will be made under plan
UniquiTel 

Telecommunications

5/21/04

Press release
Chairman \ President \ CEO has adopted trading plan to sell up to identified number of shares (less than 20% of total holdings) by exercise of vested options as part of long-term diversification and liquidity strategy; some proceeds also will be used to buy shares
UnionBanCal

Banking

5/14/04

Press release
Vice Chairman has adopted trading plan for sale of up to identified number of shares (to be issued as a result of previously granted options) per month
United Therapeutics 

Biotechnology

3/15/04

Press release
CFO, General Counsel, and spouse of CEO, have adopted trading plans; precise disclosures of timing, amount, and limit prices of sales
United Therapeutics 

Biotechnology

Ongoing

Internet page
Company allows trading plans, and is aware of five current plans; precise disclosures of timing, amount, and limit prices of sales
Universal Stainless & Alloy Products

Steel

8/16/04

Press release
President \ CEO has adopted trading plan to sell up to identified total (18% of holdings) and weekly number of shares per week, with unsold shares rolling over
Verilink

Networking

 9/19/03

 Press release
Executive officers have adopted trading plans to facilitate their sales of stock bonuses given (and also announced) by company
Virage Logic

Semiconductor

1/24/02

Press release
Two co-founders \ officers have adopted trading plans; sales, but not formulas, disclosed
Vyyo

Networking

12/2/03

Press release
CEO \ Chairman expected to adopt trading plan, now allowed by amended insider trading policy
Water Pik Technologies 

Home products

6/15/04

Form 8-K
Two officers have adopted trading plans under which restricted shares under option grants will automatically tendered to company to fulfill tax obligations as they become due, with no open market sales; form of plan attached as exhibit
Weight Watchers International

 Health services

 5/22/03

Press release
CEO and General Counsel have adopted trading plans; CEO will sell less than 20% of holdings via plan, which represents his first exercise of options and sales ever
Westmoreland Coal 

Energy

1/3/02
Press release Company has "adopted" (allowed) trading plans, which a number of unspecified officers have adopted
Willis Group Holdings

Insurance brokerage

 5/4/05

 Press release
Chairman \ CEO has adopted trading plan; number of shares and remaining holdings disclosed
Xicor

 Semiconductor

11/7/03

Press release
President \ CEO has adopted trading plan; number of shares and length of plan set forth, and existence of limit price disclosed
Xilinx 

Semiconductor

5/20/02

Press release
Certain officers (including CEO) have adopted trading plans; CEO's plan will sell shares from exercise of expiring options, still leaving him with many options
Yahoo!

Internet services

5/28/04

Form 8-K
Director \ co-founder has established trading plan during the current trading window, under which disclosed number of shares transferred to blind trust with complete discretion to sell over the next year
Yellow Roadway 

Transportation

8/13/04

Press release
CEO has adopted trading plan to exercse and sell up to identified number of options, as part of overall tax and financial planning strategy designed for enhanced liquidity diversification
Post-Sales Disclosures of Individual Trading Plans
Abbott Laboratories

Pharmaceuticals

6/21/05

Form 4
Insider's reported sales were made pursuant to a trading plan 
BEA Systems

 Software

 3/29/04

 Comments in third party article
CEO, CFO, and director's sales were part of trading plans; number of remaining shares held reported
Calpine

Energy

7/16/02

Press release
In response to today's article in a financial newspaper, the recent Form 144 filing of the Chairman \ CEO is in accordance with a previously announced trading plan
Centex

Homebuilding

10/28/03

Form 4
Insider's reported sales were made pursuant to a trading plan
First Commonwealth Financial 

Banking

2/12/02

Form 4
Insider's reported sales were made pursuant to a trading plan
Fisher Scientific International

Laboratory equipment

 6/17/05

Form 4
Insider's reported sales were made pursuant to a trading plan
Hyperion

 Software

 10/6/03

 Annual report \ proxy statement
All stock sales of listed officers were made under trading plans "pursuant to the safe harbor provisions of Rule 10b5-1"
InVision Technologies

 Security systems

 2/19/04

 Form 4
Insider's reported sales were made pursuant to a trading plan
InVision Technologies

 Security systems

 3/15/04

 Form 4
Insider's reported sales were made pursuant to a trading plan
iPass

Network services

5/18/05

Form 4
Insider's reported sales were made pursuant to a trading plan
National Penn Bancshares 

Banking

11/12/02

Form 10-Q
Insider's reported sales were made pursuant to a trading plan
PeopleSoft 

Software 

 3/20/04

Proxy statement
Some sales during prior years by director were made pursuant to trading plan; formula (number of shares on specified day each week) disclosed
PETsMART

Retail (pet supplies)

5/9/05

Proxy statement
Some sales during prior year by director were made pursuant to trading plan
Ryland Group

Home construction

 10/27/03

Form 4
Insider's reported sales were made pursuant to a trading plan
Siebel Systems

Software

2/11/04

Form 4
Director's reported sales were made pursuant to a trading plan
Sirius Satellite Radio 

 Entertainment

6/1/05

Form 4
Insider's reported sales were made pursuant to a trading plan
Storage Technology 

 Networking

9/16/03

Form 4
Insider's reported sales were made pursuant to a trading plan
Sunrise Telecom 

Communications measurement

12/7/04

Form 4
Insider's reported sales were made pursuant to a trading plan
Walt Disney

 Entertainment

 5/23/05

Form 4
Officer's reported sales were made pursuant to a trading plan
Winnebago

Automotive

11/9/04

Press release
Company informed that family trust of late founder has completed sales under trading plan
Yahoo!

Internet services

10/4/04

Comments in third party article
CFO sales were part of trading plan
Yum! Brands

Retail (food)

6/1/05

Form 4
 Insider's reported sales were made pursuant to a trading plan
Termination, Modification, or Completion of Individual Trading Plans
Administaff

Management and personnel services
 12/10/03

Press release
Chairman \ CEO has modified previously announced trading plan to increase target price (identified) and number of shares sold (identified)
AirTran Holdings 

Transportation

8/27/04

Press release
Chairman \ CEO has extended previously announced trading plan to exercise unidentified number of options and sell shares for next six months
Calpine

Energy

10/14/02

Press release
Chairman \ CEO has cancelled previously announced trading plan
Circle Group Holdings 

Venture services

5/24/05

Press release
CEO has suspended trading plan because, notwithstanding corporate initiatives, stock is trading at 10% of previous price
Crane

Industrial products
9/27/01

Press release
Chairman has terminated previously announced trading plan after 2/3 of contemplated sales made because pre-determined target prices are now substantially above current market prices
Embarcadero Technologies

Software

8/11/04

Press release
President \ CEO has terminated plan; no reason provided
eResearch Technology

Medical technology and services

10/29/04

Press release
Chairman, CEO and CFO have terminated their trading plans effective immediately; no reasons provided
i2

Software
9/18/01 Press release Founder \ Chairman has terminated plan that had governed his sales in 2001 (and had sold 0.33% of holdings per month)
Immucor

Medical devices

3/30/04

Press release
Chairman \ CEO suspended previously announced trading plan shortly before recent pre-anouncement of quarterly results to prevent sales that would have been made
Immucor

Medical devices

8/12/04

Press release
Chairman \ CEO has resumed trading plan, again for diversification purposes
Irvine Sensors 

 Semiconductors

 6/23/04

Press release
President \ CEO has terminated his trading plan in conjunction with agreeing to a contractual lock-up accompanying a private placement by the company
Lone Star Steakhouse & Saloon 

Retail (food)

8/24/04

Form 8-K
Vice President of subsidiary previously adopted a trading plan, which has now expired
MRV Communications

Fiber optics components
3/8/02

Press release
Chairnabd and President \ CEO have cancelled previously announced trading plans; number of shares sold under plans disclosed
Procter & Gamble

Consumer products

9/1/04

Form 8-K
Company has been advised that Chairman \ President \ CEO has extended previously disclosed plan to sell identified number of shares over current year at unidentified prices. Company disclaims duty to disclose others' trading plans or to disclose termination or operation of any plan
Qwest Communications

Telecommunications
3/2/01 Press release CEO has terminated trading plan due to unrealistic and volatile stock price
Reebok

Athletic apparel

4/4/03
Press release Chairman \ CEO and his wife have completed sales under previously announced plan (in form of forward contract), their first sales in 9 years
Royal Gold  Precious metal royalty

12/30/04

Form 8-K
Insider has modified his trust's plan; modification disclosed
TransAct

Printers

 9/8/04

Press release
CEO has modified trading plan to sell shares from exercise of options set to expire, in order to sell in orderly manner, pay taxes, and allow for diversification
Issuer Trading Plans
Cutter & Buck 

Clothing

9/20/04 

Press release
Company has adopted trading plan to repurchase shares, as authorized by Board in earlier disclosure
Essex Property Trust

 REIT

 7/31/02

 Press release
Company has adopted repurchase plan; disclosure included in quarterly earnings release
Fossil

Consumer products

9/30/04

Press release
Company has adopted trading plan to repurchase up to identified number of shares (1% of total shares) in privately negotiated transactions over next year
HCA

Healthcare

12/8/05

Press release
Company has adopted trading plan as part of previously announced shares repurchase plan; exact number of shares disclosed
HealthExtras

Healthcare benefits management

5/28/04

Press release
CEO and CFO intend to participate in plan adopted by company; senior executives collectively may sell up to identified number of shares per year, and neither participating executive will sell more than 10% of holdings in the plan year
InVision Technologies

 Security systems

 12/30/03

Press release
Company has adopted trading plan to repurchase its shares; limit price (no purchases unless stock falls below named price) disclosed
Kronos

Software 

3/18/03

Press release
Company has adopted trading plan to repurchase its stock
PepsiAmericas

Soft drink bottling

 3/4/05

Form 8-K
Company has adopted trading plan as part of previously announced shares repurchase plan; exact number of shares and price target disclosed; trading plan attached as Exhibit 10.1
SonicWALL

Network services

5/16/05

Form 10-Q, Exhibit 10.1
Issuer has terminated trading plan component of repurchase plan
Other Shareholders' Trading Plans
AMIS Holdings

Semiconductors

8/23/04

Press release
Significant shareholder \ long term investor (Nippon Mining) has adopted trading plan in order to reap benefits of its business relationship following issuer's IPO
FBL Financial Group 

Insurance

3/16/04

Press release
Majority shareholder (Iowa Farm Bureau Federation) has adopted trading plan that may result in no sales if unidentified price targets not met; sales will increase limited public float of shares and allow for investments in other projects in Iowa
Insider Trading Policies
Alcoa

Materials

Ongoing
 Internet page Insider trading policy (as part of broader Business Conduct Policy)
Baxter International

 Pharmaceuticals

 8/02

Internet page
Securities trading policy; allows trading outside of windows if trading plan adopted
Chordiant Software

 Software

 3/28/03

 Form 10-K
Company has amended insider trading policy to allow trading plans
Churchill Downs 

Entertainment

Ongoing

Internet page
Insider trading policy, which allows trading plans (provided that they are amended only once)
E-centives

 Internet marketing

 Ongoing

Internet page
Insider trading policy, which allows trading plans
HEI (Hawaiian Electric Industries, Inc.)

 Energy

 Ongoing

 Internet page
Insider trading policy, which allows trading plans
IMPAX Labs

Pharmaceuticals

8/8/02
Internet page Insider trading policy
Krispy Kreme Doughnuts

 Retail (food)

Ongoing

Internet page
As part of company policy, the five key senior executives have agreed that any sales will be made under trading plans
MedImmune 

 Biotechnology

 Ongoing

Press release
Company has amended insider trading policy to allow trading plans, which require at least 30 days before first sale may be made
Microchip

Semiconductors

6/3/05

Internet page
Insider trading policy, which allows trading plans
MSC Software

Software

3/19/04

Internet page
Insider trading policy, which allows trading plans but requires pre-clearance to terminate them
Netflix

 Internet commerce

 Ongoing

 Internet page
Insider trading policy, which allows trading plans
Radian 

Financial services

Ongoing

Internet page
Insider trading policy (part of Code of Conduct and Ethics); insiders may trade outside of windows if trading plan filed with General Counsel
Radio Shack

Retail (electronics)

 8/10/04

Internet page
Insider trading policy; allows trading outside of windows if trading plan adopted
Red Hat

Software
7/3/01 Press release Board has authorized trading plans and will identify all approved and implemented plans
ScanSoft 

Software

9/20/02

Press release
Company has adopted policy requiring insiders to adopt trading plans (during open trading window) at least 6 months before any sales, as "the only way to ensure equal access to information by all shareholders"
Scientific Technologies  

Safety products

1/30/03

Internet page
Insider trading policy; allows trading outside of windows if trading plan adopted
Sonic Innovations 

Medical devices

5/6/04

Internet page
Insider trading policy
Sprint Nextel

Telecommunications

8/05

Internet page
Securities law compliance policy; extensive discussion of 10b5-1(c)
Threshold Pharmaceuticals

Pharmaceuticals 

4/04

Internet page
Insider trading policy
Vyyo

Networking

 12/2/03

Press release
Company has amended insider trading policy to allow trading plans
Willis Group Holdings

Insurance brokerage

 3/14/05

 Proxy statement (DEF 14A) at 28
Compensation Committee has encouraged CEO and other officers to consider regularly disposing portions of their stock in order to diversify assets
Yum! Brands

 Retail (food)

6/6/03

Press release
Company has encouraged officers to adopt trading plans; announces several plans
Other Stock Trading Disclosures
Able Energy

Energy services
5/15/03 Press release CEO plans to purchase stock from company in next 12 months
Airgas

Gases and welding products

1/29/02

Press release
CEO has entered into prepaid variable forward contract to sell up to disclosed numebr of shares over next three years
Airgas

Gases and welding products

1/13/05

Press release
CEO will transfer stock as settlement of expiring forward contract entered into and disclosed three years previously
Alcoa

Materials
8/6/01 Press release CEO exercised options and did not sell all acquired shares, thus increasing total share ownership
Drexler Technology

Optical memory

11/12/02
 Press release Chairman \ CEO exercising options due to expire, also consistent with selling plan in anticipation of retirement
First Data

Electronic commerce

2/22/00

Press release
President \ CEO exercised options scheduled to expire
Gemstar

Interactive media

4/4/02
Press release Chairman \ CEO has entered into pre-paid forward transactions covering 7 million shares to retire debts and pay taxes on options
Green Mountain Coffee

 Coffee

ongoing

Internet page
Investor relations FAQ explains why CEO and others sometimes sell stock; refers to trading plans as mechanism officers sometimes use
NN

Industrial products

12/14/01

Press release
Four original founders and certain family members have informed company of intention to divest their holdings so as to diversify
Non-Invasive Monitoring Systems

Medical testing devices

7/11/02
Press release Media report that CEO had sold almost all his stock is incorrect
RFS Hotal Investors

REIT
7/11/01 Press release CEO and COO exercised options in June 2001 and did not sell all acquired shares, thus increasing total share ownership
RFS Hotal Investors

REIT

8/28/00
Press release CFO and VP exercised options in August 2001 and did not sell all acquired shares, thus increasing total share ownership
RFS Hotal Investors

REIT

9/19/01
Press release CEO and COO have purchased stock
RFS Hotal Investors

REIT

9/25/01
Press release Several officers and directors have purchased stock
Probex

Petrochemicals

4/5/02
Press release Director has "worked with the Company" to sell <10% of his stock to existing major shareholder and two other directors
Taser International

Law enforcement

12/21/04

Press release
Clarifying statement regarding option grant to new director and subsequent exercise
Telkonet

Network equipment

1/2/03
Press release Founders retiring shares in exchange for repayment of note, which realigns capital structure of company
Tweeter Home Entertainment Group

Retail

2/11/03
Press release Senior officers and directors have purchased stock
Websense

Software

12/5/01

Press release
Third party report (Thomson Financial Services) of CEO's trades is incorrect