Sjostrom on the 500 Equity Holder Trigger

Questioning the 500 Equity Holder Trigger, by William K. Sjostrom Jr., University of Arizona - James E. Rogers College of Law, was recently posted on SSRN.  Here is the abstract:

The article provides a brief overview of Section 12(g) of the Securities Exchange Act of 1934 and argues that the SEC should adopt a new rule exempting from its application private companies with no active secondary trading in their securities, regardless if they have 500 or more shareholders.