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BIO-key (NASDAQ: BKYI) CLO granted 250 shares via ESPP

Filing Impact
(Neutral)
Filing Sentiment
(Neutral)
Form Type
4

Rhea-AI Filing Summary

BIO-key International’s Chief Legal Officer, James David Sullivan, acquired 250 shares of Common Stock as a grant under the company’s 2021 Employee Stock Purchase Plan. The shares were credited at a price of $3.83 per share in a transaction classified as a grant or award.

After this transaction, Sullivan directly holds 9,986 shares of BIO-key common stock. The footnotes note that all share amounts reflect BIO-key’s 1-for-10 reverse stock split that became effective on April 30, 2026.

Positive

  • None.

Negative

  • None.
Insider Sullivan James David
Role Chief Legal Officer
Type Security Shares Price Value
Grant/Award Common Stock 250 $3.83 $957.50
Holdings After Transaction: Common Stock — 9,986 shares (Direct, null)
Footnotes (1)
  1. Represents shares acquired under the BIO-key International, Inc. 2021 Employee Stock Purchase Plan as amended in a transaction that was exempt under both Rule 16b-3(d) and Rule 16b-3(c). All share amounts reflect BIO-key's 1-for-10 reverse stock split, which was effective April 30, 2026.
Shares acquired 250 shares Grant under 2021 Employee Stock Purchase Plan on June 30, 2026
Grant price $3.83 per share Price used for ESPP share acquisition
Total holdings after transaction 9,986 shares Direct common stock ownership after the ESPP grant
Reverse stock split ratio 1-for-10 Reverse split effective April 30, 2026 for all reported share amounts
Employee Stock Purchase Plan financial
"Represents shares acquired under the BIO-key International, Inc. 2021 Employee Stock Purchase Plan as amended"
An employee stock purchase plan is a company program that lets workers buy shares through small payroll deductions, often at a discount to the market price and after a set offering period. Think of it like a workplace savings plan that turns into ownership: it encourages employees to share in the company’s success and can create predictable buying or selling of stock that investors watch because it affects supply, demand and employee incentives.
Rule 16b-3(d) regulatory
"in a transaction that was exempt under both Rule 16b-3(d) and Rule 16b-3(c)"
Rule 16b-3(d) is a narrow SEC safe-harbor that shields company insiders (officers, directors and large shareholders) from liability for short‑swing profits when their buys or sells of company stock are made under a pre-established, written plan or contract that removes the insider’s ability to time trades. For investors, this matters because it permits predictable, automated insider transactions — like scheduled sales for diversification or payroll withholding — without triggering forced disgorgement, so such planned trades are treated differently from opportunistic insider trading.
Rule 16b-3(c) regulatory
"in a transaction that was exempt under both Rule 16b-3(d) and Rule 16b-3(c)"
An SEC rule that lets corporate insiders avoid automatic "short‑swing" profit recovery when they buy or sell their company’s stock under a pre‑approved, written plan that meets specific conditions. For investors, it matters because it clarifies when insider trades are treated as routine, reducing legal uncertainty and helping distinguish trades made for ordinary compensation or pre‑planned reasons from those that might signal opportunistic or timely insider advantage.
reverse stock split financial
"All share amounts reflect BIO-key's 1-for-10 reverse stock split, which was effective April 30, 2026"
A reverse stock split reduces a company's number of outstanding shares while raising the price per share proportionally, so the total value of each investor's holding is unchanged; a 1-for-10 split turns 100 shares worth $1 each into 10 shares worth $10 each. Companies often do this to regain compliance with an exchange's minimum price rule or to attract investors who avoid very low-priced stocks.
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Learn about SEC filing dates
SEC Form 4
FORM 4UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940
OMB APPROVAL
OMB Number:3235-0287
Estimated average burden
hours per response:0.5
Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).
Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.
1. Name and Address of Reporting Person*
Sullivan James David

(Last)(First)(Middle)
C/O BIO-KEY INTERNATIONAL, INC.
101 CRAWFORDS CORNER RD, SUITE 4116

(Street)
HOLMDEL NEW JERSEY 07733

(City)(State)(Zip)

UNITED STATES

(Country)
2. Issuer Name and Ticker or Trading Symbol
BIO KEY INTERNATIONAL INC [ BKYI ]
5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)
Director10% Owner
XOfficer (give title below)XOther (specify below)
Chief Legal OfficerSVP Strategy & Compliance
2a. Foreign Trading Symbol
3. Date of Earliest Transaction (Month/Day/Year)
06/30/2026
6. Individual or Joint/Group Filing (Check Applicable Line)
XForm filed by One Reporting Person
Form filed by More than One Reporting Person
4. If Amendment, Date of Original Filed (Month/Day/Year)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3) 2. Transaction Date (Month/Day/Year)2A. Deemed Execution Date, if any (Month/Day/Year)3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4)
CodeVAmount(A) or (D)Price
Common Stock06/30/2026A(1)250A$3.839,986(2)D
Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned
(e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3) 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (Month/Day/Year)3A. Deemed Execution Date, if any (Month/Day/Year)4. Transaction Code (Instr. 8) 5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 6. Date Exercisable and Expiration Date (Month/Day/Year)7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4) 8. Price of Derivative Security (Instr. 5) 9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4) 10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4)
CodeV(A)(D)Date ExercisableExpiration DateTitleAmount or Number of Shares
Explanation of Responses:
1. Represents shares acquired under the BIO-key International, Inc. 2021 Employee Stock Purchase Plan as amended in a transaction that was exempt under both Rule 16b-3(d) and Rule 16b-3(c).
2. All share amounts reflect BIO-key's 1-for-10 reverse stock split, which was effective April 30, 2026.
/s/ James D Sullivan07/02/2026
** Signature of Reporting PersonDate
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 4: SEC 1474 (03-26)

FAQ

What did BIO KEY INTERNATIONAL INC (BKYI) disclose in this Form 4?

BIO-key reported that Chief Legal Officer James David Sullivan acquired 250 shares of Common Stock. The shares were received as a grant under the 2021 Employee Stock Purchase Plan at $3.83 per share, increasing his direct holdings to 9,986 shares.

How many BIO KEY (BKYI) shares did the CLO acquire and at what price?

James David Sullivan acquired 250 shares of BIO-key Common Stock at $3.83 per share. The acquisition was recorded as a grant or award under the company’s 2021 Employee Stock Purchase Plan, not an open-market purchase, and increased his direct ownership.

What are James David Sullivan’s total BIO KEY (BKYI) holdings after this transaction?

Following the grant, James David Sullivan directly holds 9,986 shares of BIO-key Common Stock. This total already reflects the company’s 1-for-10 reverse stock split that became effective on April 30, 2026, as noted in the Form 4 footnotes.

Was the BIO KEY (BKYI) share acquisition by the CLO an ESPP transaction?

Yes. The 250 shares were acquired under the BIO-key International, Inc. 2021 Employee Stock Purchase Plan. The filing notes the transaction was exempt under Rule 16b-3(d) and Rule 16b-3(c), indicating it was a compensation-related plan acquisition rather than a market trade.

How did BIO KEY’s reverse stock split affect this Form 4 for BKYI?

The Form 4 states that all share amounts reflect BIO-key’s 1-for-10 reverse stock split effective April 30, 2026. This means both the 250-share grant and the 9,986 total holdings are already adjusted to post-split levels in the disclosure.