Rule frozen 2026-09-11, before the 2022–2025 timeline was verified. Resolved the same day.
Walking the verified 2022–2026 primary timeline date by date, the frozen rule fires on the first disclosure available:
2026-09-11 → 2022-12-28 — Board authorization filing (JPX/TDnet, primary source) discloses the 10th Series stock acquisition rights: paid options for directors and employees, an initial pool of 46,000,000 shares with a stated design target of ~20% of fully diluted shares post-financing, plus an adjustment mechanism tying the pool to the fully diluted share count as it changes.
Leg (a), size: 20% ≥ 10% threshold. Independently checkable: 46M / ~227.7M fully diluted ≈ 20.2%. Leg (b), structure: the insider percentage is contractually protected while public holders dilute — the company’s own August 2026 retrospective confirms the original provision went “beyond the customary technical adjustments made for stock splits, stock consolidations and similar events.”
The mechanism did exactly what the rule feared. The pool grew from 46M to 319.6M shares via the ratchet. In August 2026 the company froze the provision; the CEO’s exercise converted 92,000 rights into 64,032,000 shares. Lead time from the earliest warning date to the governance fix: about three years and eight months.
The contemporaneous primary disclosure contained the computable fact — the 46M pool, the ~20%-of-fully-diluted target, the adjustment mechanism, the director/employee holders. A reader of the actual December 2022 filing could have done the math.
Sources: JPX/TDnet board authorization filing, 2022-12-28 (primary); company retrospective notice on Series 10 terms, 2026-08-18 (primary). Timeline gaps (20 access gaps, incl. unrecovered Series 1–8 terms) do not affect the trigger, which fires on the first row.