Rule 10b5-1, Form 144 and blackout windows exist because there is a public market and an information asymmetry to police. A private Ontario company has neither, and importing the machinery would be theatre. The transferable residue is weaker and more general than it sounds on the page: deciding the size and timing of a disposal in writing, in advance, before you have a view on price — which is worth something at a shareholder-agreement level, and nothing at a securities-law level.