BuyCo is purchasing SellCo, and paying in shares. BuyCo has a share price of $40, with 15 million shares outstanding. SellCo has a share price of $12, with 10 million shares outstanding. If the merger will create synergies with an NPV of $39 million dollars, and SellCo will not sell unless they get 0.2 of the synergies, how many shares in the merged form should BuyCo offer SellCo's equity holders in payment?