[144] Sea Limited American SEC Filing

Q: What securities does the Form 144 for Sea Limited (SE) propose to sell?

The notice proposes the sale of 85,500 ADS (American Depositary Shares).

Q: Who is the broker named for the proposed SE ADS sale?

The broker listed is J.P. Morgan Securities LLC located in New York.

Q: How were the ADS being sold acquired?

The ADS were acquired on 08/08/2024 by exercise of share options under the issuer's ESOP , with payment characterized as compensation for services.

Q: Does the filing show any recent sales of SE ADS by related parties?

Yes, the filing lists numerous ADS sales by Devon Court Limited on many dates from June through September 2025.

Q: What is the aggregate market value reported for the proposed sale?

The aggregate market value reported for the proposed 85,500 ADS is $16,473,285 .

Filing Impact

(Low)

Filing Sentiment

(Neutral)

Form Type

144

Rhea-AI Filing Summary

Sea Limited (SE) notice proposes the sale of 85,500 American Depositary Shares (ADS) through J.P. Morgan Securities. The filing identifies an approximate sale date of 09/10/2025 and reports an aggregate market value for the planned sale of $16,473,285 against 543,584,213 ADS outstanding, showing the offering represents a small fraction of total shares.

The securities were acquired on 08/08/2024 by exercise of share options under the issuer's employee stock option plan and the stated nature of payment is compensation for services. The filing also lists numerous ADS dispositions by Devon Court Limited on many dates between June and September 2025, indicating ongoing secondary-market sales by an affiliated holder.

Positive

Planned sale disclosed publicly via Form 144, meeting Rule 144 transparency requirements
Securities acquired via ESOP exercise, showing alignment with employee compensation programs
Broker engagement by J.P. Morgan Securities indicates an organized execution channel for the sale

Negative

Multiple recent dispositions by Devon Court Limited between June and September 2025 signal ongoing secondary-market selling
Planned sale adds supply to market which could exert modest downward pressure if demand is limited

Insights

TL;DR: Executive/insider-originated ADS sale scheduled via broker; acquisition from ESOP, and multiple recent secondary sales were reported.

The notice documents a proposed disposition of 85,500 ADS through J.P. Morgan Securities with an indicated aggregate market value of $16,473,285. The shares were acquired by exercise of company stock options under the issuer's ESOP on 08/08/2024 and were characterized as compensation for services, which is typical for option exercises by insiders or service providers. The filing also catalogs frequent, small-block sales by Devon Court Limited across many dates from June through September 2025, showing active liquidity and secondary-market harvesting by that holder. Overall, the disclosure is routine for Rule 144 transactions and does not, on its face, indicate a material change to capital structure.

TL;DR: Governance disclosure is complete for Rule 144 mechanics; shows exercised options and subsequent scheduled sales, with required representations made.

The form identifies the nature of the acquisition as an ESOP option exercise and the filer represents no undisclosed material adverse information, consistent with Form 144 attestations. Engagement of a major broker (J.P. Morgan Securities) indicates a standard execution path for an insider sale. The detailed listing of recent sales by Devon Court Limited provides transparency on past dispositions that may be aggregated under Rule 144 aggregation rules. From a governance perspective, the filing satisfies public-disclosure requirements for intended insider sales.

09/10/2025 - 04:26 PM

144: Filer Information

Filer CIK

Filer CCC

Is this a LIVE or TEST Filing?

LIVE TEST

Submission Contact Information

Name

Phone

E-Mail Address

144: Issuer Information

Name of Issuer

SEC File Number

Address of Issuer

Phone

Name of Person for Whose Account the Securities are To Be Sold

See the definition of "person" in paragraph (a) of Rule 144. Information is to be given not only as to the person for whose account the securities are to be sold but also as to all other persons included in that definition. In addition, information shall be given as to sales by all persons whose sales are required by paragraph (e) of Rule 144 to be aggregated with sales for the account of the person filing this notice.

Relationship to Issuer

144: Securities Information

Title of the Class of Securities To Be Sold

Name and Address of the Broker

Number of Shares or Other Units To Be Sold

Aggregate Market Value

Number of Shares or Other Units Outstanding

Approximate Date of Sale

Name the Securities Exchange

ADS

J.P. Morgan Securities LLC
390 Madison Avenue - 6th Floor
New York NY 10017

85500

16473285

543584213

09/10/2025

NYSE

Furnish the following information with respect to the acquisition of the securities to be sold and with respect to the payment of all or any part of the purchase price or other consideration therefor:

144: Securities To Be Sold

Title of the Class

Date you Acquired

Nature of Acquisition Transaction

Name of Person from Whom Acquired

Is this a Gift?

Date Donor Acquired

Amount of Securities Acquired

Date of Payment

Nature of Payment *

ADS

08/08/2024

Exercise of share options under Issuers ESOP

Issuer

85500

08/08/2024

Compensation for services provided

* If the securities were purchased and full payment therefor was not made in cash at the time of purchase, explain in the table or in a note thereto the nature of the consideration given. If the consideration consisted of any note or other obligation, or if payment was made in installments describe the arrangement and state when the note or other obligation was discharged in full or the last installment paid.

Furnish the following information as to all securities of the issuer sold during the past 3 months by the person for whose account the securities are to be sold.

144: Securities Sold During The Past 3 Months

Name and Address of Seller

Title of Securities Sold

Date of Sale

Amount of Securities Sold

Gross Proceeds