I have to change my theory slightly now. After doing a little more research I believe that Richardson is potentially trading with Canaccord (at least to buy on the open market). Canadian insider has him listed as purchasing 49900 at $4.00 on Dec 20th.
http://www.canadianinsider.com/coRep...

Just by shear coincidence I posted level 2's with Time&Sales attached and within there it shows broker 033 (Canaccord) purchasing 49900 at $4.00 on Dec 20th (bottom right hand corner).
http://www.agoracom.com/ir/Kodiak/me...

Either this is the biggest coincidence ever or Richardson is using Canaccord for at least one of his brokers. I still think he's using National Bank as well but he's obviously the market maker in this scenario (not that anyone couldn't figure that out haha).

I like conspiracy theories and stuff like that so I'm kind of enjoying peicing this all together.

Cheers.
Gamblor.