SEAWELL A BROOKE

SeaWell A. Brooke’s recent SEC Form 4 activity reveals a pronounced and consistent sell-side posture, with no open-market purchases recorded across the 45 transactions spanning two companies. The aggregate sell value reached approximately $77.8 million, driven entirely by open-market sales (code S) in NVIDIA (NVDA) and Tenable Holdings (TENB). Notably, the most concentrated selling occurred in July 2025, when Brooke executed 13 NVDA sales between July 9 and July 14, ranging from roughly $139,000 to $4.6 million per transaction, for a combined total near $25 million. That cluster was followed by a single NVDA sale of $2.34 million on December 2, 2025, and a TENB sale of $2.85 million on December 15, 2025, alongside smaller TENB disposals in September 2025. The pattern is unambiguous: every open-market transaction in the dataset is a sale, with zero buy-side conviction (code P) and no acquisitions (code A) that involved cash outlay. The recent trades also include non-discretionary events—option exercises (code M) in TENB, share grants (code A) in both NVDA and TENB, and gifts (code G) in NVDA—but these carry no dollar values and do not alter the sell bias. The largest single-day activity occurred on July 14, 2025, when four NVDA sales totaled roughly $8 million, while the July 10 sales added another $8 million. Across all filings, the sell values are consistently material, with the December 2025 TENB transaction at $2.85 million being the largest single trade outside the July NVDA cluster. This trajectory—persistent selling with no offsetting purchases—suggests a deliberate reduction of equity exposure in both NVDA and TENB over the past year. The absence of any recent buys, combined with the steady cadence of sales through 2025 and into late December, underscores a one-directional flow. While the filings do not indicate whether these sales were pre-arranged under Rule 10b5-1 plans, the data itself is clear: Brooke has been a net seller of substantial value, with the most intense activity concentrated in mid-2025 and a continued, if less frequent, sell pattern thereafter.