Professional Investment Advisor and finance professional. U.S. based M.D. with over 18 years of clinical experience. M.B.A. with finance and financial markets specialization from New York University Stern School of Business. Expert in picking healthcare-related investments, especially biotechnology and pharmaceuticals (focus on small, emerging companies). Investments are selected based on detailed due diligence, including proprietary DCF valuation models. Value investor with long-term horizon. Founder, managing principal of Vasuda Capital Management, healthcare focused investment management firm, vasudacapitalmanagement.com. Registered Investment Advisor in Massachusetts. The firm also operates a private pooled investment partnership, Vasuda Life Sciences Fund. Also started and continue to sponsor Vasuda Global Orphan/ Rare disease biotechnology index, the first global equity index covering rare/orphan disease sector. Index quotes are available on bloomberg/reuters terminals.
A veteran of the pharma industry. Specializing in the analysis of small pharma companies with a focus on the pipeline and opportunities for licensing or major deals with large pharma. Financial analysis including burn rate, venture capital funding, and cash flow.
The enormous advancement in the biological sciences that is taking place has begun to change the traditional way of practicing medicine. Far-reaching biological products are being approved and news about breakthroughs are occupying the media headlines. However, selecting the biotechnology firms for investment requires not only an understanding of the company's finances, but also deep knowledge of the company's potential and the potential and scientific validity of it's products and technologies.
Our Mission is evaluating biotechnology companies, their products, their technologies, scientists, managements, as well as their finances. Our goal is to impart our readers with the knowledge and insight so that they may have a heightened understanding and appreciation for the biotechnology industry.
The Prohost Letter has been in circulation since 1992. Our readers are comprised of venture capital, fund managers, investors, medical professionals and individuals with one common interest, biotechnology.
Prohost Letter is posted in the members areas on the www.prohostbiotech.com. around 40 times a year. Articles are posted several times a week for subscribers in TODAY'S HIGHLIGHTS section and in News & Comments sector for all website visitors
I added stock and bond analysis to my IT consulting business at the request of a small cap investment specialist in 2002. For my own account I invest mainly in technology and biotechnology stocks, but occasionally I invest in industrial, retail and other stocks. My technology and investment web site is openicon.com. I still enjoy IT consulting and always have some sort of R&D project going on.
Biomed Group is an independent research group, with a goal of providing investors with real-time information and exclusive specialised research on biotechnology stocks, so that they can make informed investment decisions.
Tom Konrad, PhD., CFA is a financial analyst, freelance writer, and portfolio manager specializing in renewable energy and energy efficiency. He is currently looking for a money management firm to sponsor what he believes would be the first dividend income oriented green mutual fund, based on a strategy he has been managing since December 2013.
. He is Editor at AltEnergyStocks.com.
Tom lives in New York's lower Hudson River Valley. He volunteers for the environmental nonprofit community, runs, and is a woodworker. He's currently using those woodworking skills to renovate (and upgrade the energy performance) of the 1930 farmhouse he lives in with his wife.
He can be reached at tom at tom konrad dot com.
Sharon di Stefano has spent 20 years as an analyst, beginning her career at Smith Barney, Harris Upham & Co. specializing in medical devices, pharmaceuticals, healthcare information technology, and biopharmacology. Ms. di Stefano had also served as Senior Venture Officer for the Edison Innovation Fund, implemented through the New Jersey Economic Development Authority that provided funding for early-stage life sciences companies. Industry experience includes laboratory research for Johns Hopkins Hospital and the Department of Defense.
Ms. di Stefano received a Masters of Science degree, in Business, from Johns Hopkins University in 1986, and a Bachelor of Arts from the University of Delaware in 1984 with a minor in biology.
The Life Sciences Report features leading investment coverage of the life sciences sector, including biotechnology, pharmaceuticals, tools & diagnostics, and medical devices. A Streetwise Reports publication. www.TheLifeSciencesReport.com
Donald Kay Riker, Ph.D. is President & Founder, On Point Advisors, LLC [www.onpointadvisors.com], a consumer healthcare consultancy he founded in 2007 and Editor-in-Chief, OTC Product News [www.otcproductnews.com]. Dr. Riker was a fellow at New York’s prestigious Rockefeller University, earned his Ph.D. in Neurobiology at Cornell University and won a three-year NIH Research Fellowship in neuropharmacology and neurochemistry in the laboratory of Nobel Prize winner in medicine Paul Greengard and Robert Roth at Yale University School of Medicine. During this tenure he worked on neurotransmitter systems in neurological disease. After one year at the West Haven VA Hospital he joined the clinical development group at Richardson-Vicks, an over-the-counter healthcare company later acquired by Procter & Gamble, while remaining a Research Affiliate in Medicine & Psychiatry at Yale. During this time he helped design and implement the first prescription drug monitoring program for the National Football League.
At P&G Dr. Riker worked to support over-the-counter analgesic and respiratory products rising to the rank of Associate Director & Research Fellow while managing the conduct of over 125 clinical trials of OTC products & conditions, Rx actives, and clinical model development. For a decade (1982-1992) he was a key player in the academic/industry consortium investigating the understanding of the common cold. In 1994 he co-authored a landmark study in the New England Journal of Medicine on sinus involvement in common colds since quoted in over 350 investigations. Dr. Riker drafted the first proactive technical recommendations that resulted in the acquisition/OTC switch of both Rx naproxen [1985, Aleve] and omeprazole [1996, Prilosec] making similar evaluations of non-sedating antihistamines as potential OTC’s [1990’s]. During his tenure at the world’s most disciplined consumer products company Don worked closely with business development, marketing, finance, regulatory affairs, and consumer insight. He supported brands such as Nyquil, Dayquil, Vicks 44, Sinex, Aleve, Chloroseptic, PeptoBismol, and Prilosec.
In 2001 Dr. Riker was recruited by Chattem, Inc, a leading acquirer of health and beauty care products, to rebuild and lead R&D as its first Vice President of R&D & CSO. Over his five years at Chattem Don installed a first-rate product development and regulatory group launching 6-8 products per year across diverse trade categories, including topical analgesic patches and crèmes [Icy Hot, Capsaizin, Aspercreme], skin care [Gold Bond], lip care [Herpecin], dandruff shampoo [Selsun], sunscreens [Bullfrog], supplements [Dexatrim, Garlique, CardioAssist, New Phase], and menstrual products [Pamprin]. While keeping R&D spending at 1% of sales Chattem’s stock price rose 6-fold during his tenure, a period accounting for 78% of the stock’s appreciation from the company’s inception to the present . Dr. Riker managed product development, QA/QC, analytical services, global regulatory/safety, and consumer affairs.
Few people in consumer healthcare share his experience as both a clinical scientist and a business leader. Dr. Riker is a member of the Society of Neuroscience, Regulatory Affairs Professionals Society, Licensing Executives Society, American Academy of Allergy, Asthma & Clinical Immunology, American Society of Pharmacology and Experimental Therapeutics, American Society of Clinical Pharmacology & Therapeutics, Infectious Disease Society of America, Drug Information Association, and Sigma Xi. Dr. Riker served for five years on the Scientific Affairs Committee of the Consumer Healthcare Product Association the scientific advisory arm of the trade association.
Leonard is an editor of BioTuesdays.com. Before joining the blog, Leonard amassed 36 years of experience as a financial journalist, editor and manager with The Wall Street Journal and Dow Jones News Service, and The Globe and Mail’s Report on Business, where he pioneered the development and launch of the newspaper’s Money & Markets section in the early 1990s. Most recently, he was Canada’s leading biotechnology and healthcare writer, as well as the author of a highly popular stock market blog on globeandmail.com.
Stephen Simpson, CFA, is a freelance financial writer and investor.
PLEASE NOTE: As I means of honoring my late wife and grieving her loss, I do not intend to resume writing until mid-July.
I have worked for both sell-side and buy-side firms (equities and fixed income), with the largest percentage of my working time spent in med-tech. At this point I am now effectively in a "working retirement".
I write because I find that the process helps me take better notes, be more disciplined about modeling, and come up with a more coherent investment view for my portfolio management needs. If I'm writing about a stock, it's generally because I'm interested in it as an investment prospect or I think there's an interesting story to tell.
I don't share my models, so please don't ask.
More of my writings can be found at my blog Kratisto Investing (kratistoinvesting.blogspot.com), or Twitter (@Kratisto_Invest).
The founding members of Chimera Research Group have over 50 years of combined experience in the biotech and pharmaceutical sector. Their experience includes work at Investment Banks, Hedge Funds, Pharmaceutical Companies, top-tier Universities, and the U.S. Food and Drug Administration (FDA). Their published work includes freelance and editorial contributions both print and on-line, clinical and medical research, books and tutorials, as well as contributions to on-line social media. Through these and other activities they were able to collaborate and connect amongst themselves to establish this cadre of like-minded biotech/pharma trading and investing aficionados.
The Team includes:
Chief Scientific Analyst - Jason Chew
Chief Research Analyst - Patrick Crutcher
Chief Medical Analyst - Dr. Tro Kalayjian
CEO & Trading Analyst - Tony Pelz
Research Analyst - Dr. Andrew Goodwin
Research Analyst - Dr. Juan Pedro Rodríguez Serrate
Technical Analyst - Joe Gantoss
Research Analyst - Dr. Steven Murphy
PropThink is an intelligence service that delivers long and short trading ideas to investors in the healthcare and life sciences sectors. Our Editorial Team is comprised of individuals with a strong background in science, medicine and the business of successfully commercializing therapeutics, medical devices, diagnostics and healthcare services. Our ultimate objective is to leverage the knowledge, experience, and relationships of our contributors to introduce our subscribers to profitable long and short investment opportunities in the healthcare sector.
Successfully trading, and investing in emerging growth healthcare companies is a difficult task. Over 90% of drugs never make it out of the clinic. Huge capital requirements along the way result in highly dilutive equity financings often done on the backs of retail investors. At PropThink, we believe that due diligence is the key to success in this industry. We leverage a combined 50 years of experience in science, medicine, legal, regulatory affairs, finance, and operational industry experience to analyze companies at a highly technical level. This detailed analysis and due diligence process defines our editorial strategy and provides our subscribers a high level of confidence in our research. Our focus is on identifying and analyzing technically-complicated companies and equities that are grossly over or under-valued.
Visit PropThink.com to see all of our coverage and research, and subscribe to our free newsletter to receive reports, articles, and trading alerts.
Follow @SmithOnStocks on Twitter for more updates (http://twitter.com/#SmithOnStocks
Please read this section carefully for some important disclosures.
Who Am I?
My name is Larry Smith. My career was spent on Wall Street as a biotechnology and pharmaceuticals analyst and also as Director of Research at Smith Barney and Hambrecht and Quist. On my website, SmithOnStocks, which can be addressed from this Seeking Alpha site, I publish articles on biotechnology and pharmaceutical companies. I attempt to be objective and present a balanced view of negatives and positives. Readers should not rely on Seeking Alpha for my latest views and articles on Seeking Alpha should be viewed as informational only. The reports section of my website reflects my most current view on a stock.
How Do I Get Paid?
My only source of revenues from my articles is from subscription revenues from my website. I do not receive any compensation from companies or investor relations firms to write articles. I do not receive any direct or indirect compensation from hedge funds, other investment managers or any entity to write articles. I consider direct compensation to be cash compensation that is directly or indirectly tied to my writing articles.
I also do not receive compensation in the form of content. I believe that it is not uncommon for some writers to receive content from hedge funds, other investment managers or any entity that are critical components of the articles that they write. I consider this as non-cash compensation. I do not receive advertising revenues from my website so there is no incentive to be sensational in order to create page hits. I only get paid if my subscribers believe that my articles are of value to them and they then decide to subscribe to my services.
You Should View Articles Published on Seeking Alpha as Informational Only
I want to make clear to readers that not all of the reports that I publish on my website are also published on Seeking Alpha. Also, I will sometimes make reports available on my website a significant period of time before publishing the same or a condensed version on Seeking Alpha. All of the articles that are published on Seeking Alpha and my website at the same time have consistent views and opinions. However, at a later data, it may be the case that my viewpoint and opinion may change and these changes in viewpoint and opinion may only be published in articles on my website.
For this reason, readers may want to check the reports section on my website for my current opinion on a stock and should not rely on the latest Seeking Alpha article as my viewpoint or opinion may have changed. The content on my website is intended only for subscribers, but non-subscribers can view the headlines in the reports section which in most cases but not all will announce a change in viewpoint or opinion. However, I emphasize that I undertake no obligation to update my articles on Seeking Alpha and the latest article on Seeking Alpha may not reflect my latest thinking. This is why I want to re-emphasize that any article published on Seeking Alpha should be viewed as information only.
What SmithOn Stocks is All About
SmithOnStocks is not registered as a securities broker-dealer or as an investment adviser with the U.S. Securities and Exchange Commission or with any state securities regulatory authority. SOS relies solely on publicly disclosed and available information. While SOS makes all reasonable efforts to confirm the accuracy of its statements and opinions, all comments should be considered only as opinion and should not be considered to be absolute fact. Investors should carefully read the Terms & Conditions and Disclosures sections of my website. Investors should carefully perform their own due diligence, seek other points of view and consult with their broker or financial advisor.
Investing in equities includes considerable risk, and investors should be prepared for the possibility of capital loss. This is particularly the case with biotechnology stocks in which hard to predict clinical and commercial outcomes can often disappoint investors and lead to unusually large declines in price. Potential investors in biotechnology stocks must often be prepared to risk the loss of substantially all of their investment. These stocks are only suitable for investors willing and able to accept unusually high financial risk. Users of my information acknowledge that SOS and its owner are not liable to any person or entity for the accuracy, thoroughness, reliability, or timeliness of the information provided. Users further acknowledge that SOS is also not responsible for any direct or indirect losses that may arise from the use of information provided to any person or entity.
Employees of SmithOnStocks or SOS do buy and sell healthcare stocks, some of which may be the subject of written articles appearing on Seeking Alpha. In the event that employees have a stock investment in a company, that ownership is fully disclosed in notes on Seeking Alpha. On any new recommendation, I have a 48 hour waiting period before initiating a position in a stock. I trade in line with my recommendations.
In 1999 I made an ethical breach that resulted in a suspension from being a registered representative in the securities industry for a period of time. I believe that this measure was harsh beyond any reasonable measure and totally unwarranted. I have gone to great lengths in this report to give my side of the story and I hope that you will read the in-depth account that I have provided. This took place over 16 years ago and has long since ended. There has been no restriction from the NYSE for many years on my working as a registered representative if I choose to go through the required registration procedures.
Still, this NYSE action is like a Scarlett letter that I carry. I would urge you to read the full account of the events that led to this NYSE action and if you do so I believe you will agree that this in no way reflects on my integrity and the way I have always conducted myself, then and now. I strongly believe that the action taken was excessive and I think that if you read my full account you will agree.
People make mistakes. Bill Clinton lied under oath, was impeached and disbarred as a lawyer in Arkansas in connection with the Monica Lewinsky affair. However, society has judged him on the body of work that he has done. Suspensions in the security industry can result from serious infractions in which investors are defrauded or swindled. In the events that led to my suspension no investors lost money and as I explain in this report investors who followed my advice made significant amounts of money. Before you rush to any conclusions, let me tell you my story.
I Am Proud in How I Have Conducted My Career
Before I go into the details of this ethical breach, I want to emphasize that I have had a distinguished career on Wall Street. My record from 1971 when I started on Wall Street until 1999 was unblemished. I came to New York from Indiana with no business connections and no money but through hard work I became a highly regarded Wall Street analyst and was selected to the Institutional Investor All Star team in pharmaceuticals for ten years in a row. Based on my record as being the top or one of the top analysts at Smith Barney, I was selected to be head of research from 1981 until 1989. I also served on the Board of Directors at Smith Barney.
Based on my strong reputation, Hambrecht and Quist approached me in 1989 to head their life sciences research effort and to run the annual H&Q (now JP Morgan) healthcare conference. I was a Managing Director and on the operating committee at H&Q. I left H&Q in the late 1990s because I disliked the bureaucracy that was such an integral part of being head of research. I had made enough money to be financially secure and I wanted to get back into doing what I loved, biotechnology research. I joined Tucker Anthony in 1997 as a biotechnology analyst.
Explaining the Events That Led to the NYSE Issue
Tucker Anthony had a sister firm called Sutro and a decision was made early in 1998 to move health care research from Tucker to Sutro. Tucker was an east coast based firm and Sutro was based in Los Angeles. Sutro leased a New York office to which I moved. It was here that an unfortunate train of events was set in motion that led to the NYSE action that put a stain on what I consider an outstanding career.
When I moved from Tucker to Sutro, I maintained my brokerage accounts at Tucker. I conducted normal trading in this account for some months. Then the research administrative research manager for Sutro contacted me and said that for regulatory purposes I would have to move my account from Tucker to Sutro. After some time spent in looking for a broker to handle my account at Sutro I became frustrated. At that time, I had over $5 million in my brokerage accounts. While I was sophisticated in health care investing which made up 10% of my portfolio, I needed help with other parts of the portfolio. I could find no retail broker at Sutro that I wanted to trust my portfolio to. I asked and received approval to look for a broker outside of Sutro and contacted Schwab about finding an investment advisor there to manage my account.
While this was in process, the research administrative manager at Sutro called again and said that Sutro was probably planning to shut down the New York office and I would have to move to Los Angeles or leave the firm. Moving to Los Angeles was not an option for me as my roots were deep in New York. I informed her that given this choice I would soon be leaving Sutro rather then moving to Los Angeles and began to think about what to do. I came to the preliminary conclusion that I would start a consulting firm dealing in biotechnology. I also concluded that I would have to carefully manage my investment portfolio.
It was here that I made a major mistake that I have regretted ever since. Frustrated that my money was tied up in Tucker and I was unable to trade in my account and unable to find a broker that I trusted, I decided to open an account at Schwab without a broker managing it. I indicated on the account transfer form that I was self-employed based on the assumption that I was going to be leaving Sutro imminently. This was my Bill Clinton moment and turned out to be a major mistake.
I continued to work at Sutro while I was waiting for the New York office to be closed which I thought would be in a matter of days or weeks and during this time, I began to execute trades in my account at Schwab. However, after some weeks the research administrative manager at Sutro called and informed me that based on the response they had gotten from clients and the work that I was doing that the firm had reversed itself and now wanted to keep the office in New York and they were also willing to hire two assistants to aid me. There was also the promise of a significant bonus in the upcoming review that based on my work could amount to several hundreds of thousands of dollars.
Not surprisingly, I decided to stay on at Sutro instead of leaving and starting my own firm. I then looked for and finally found a Sutro broker that I could trust to help manage my portfolio. The brokerage accounts at Schwab were opened in February of 1999 and transferred to Sutro in April 1999. When I moved my accounts to Sutro the compliance department at Sutro saw that there was this hiatus when I had an unauthorized account at another firm. This was reported to NYSE.
NYSE Reviewed My Case and Took No Action for Three Years
Management at Sutro looked very closely at what had occurred and decided that while it was certainly not something they could condone, it was a minor infraction and they thought that given my stellar and unblemished record that NYSE would not take any meaningful action other than a wrist slap. Sutro decided to be pre-emptive in administering the wrist slap and fined me and suspended me for one month. They thought that this would satisfy NYSE based on their interpretation of what had occurred. They wanted me to continue with the firm, paid the sizable bonus I was due and committed to picki up all legal fees.
I then had a deposition with a lawyer from NYSE in early 2000. During a one day interview, he went over all of the details of the accounts that were held at Schwab and all of the trades that occurred in detail. He also looked at all of the reports that I had issued as an analyst during this time to compare to the trading in my account to the issuance of research reports. I then heard nothing more from the NYSE for three years.
Sutro concluded as did I that this issue was behind us. Three years later in mid-2003, I heard from NYSE to my shock that they were re-opening the case. Why after three years was the case being re-opened? In talking to the lawyers at NYSE, I came to understand that this was the result of Elliott Spitzer’s attack on Wall Street research. Remember the famous case of Henry Blodgett who recommended stocks of investment banking clients to clients that he thought were actually sales.
NYSE enforcement was under pressure because this unethical practice had been brought to light by Spitzer and they had missed it. They were under pressure to show how tough they could be as enforcers. They reviewed their records and came up with my case which they decided to reopen it in order to show that they were aggressive enforcers.
They went over the same information that had been gathered in early 2000, but came up with an entirely different interpretation. They said that I effected stock transactions shortly before issuance of research reports which I had prepared and this was a violation of Exchange Rule 472.40(2) (iii). They also said that I failed to disclose that I held securities in stocks recommended in a research report. They said that I opened accounts at a member firm that concealed fact of my employment at another member firm; violated Exchange Rule 407(b). They recommended a censure and two and one-half year suspension.
Two Stock Trades at Question
The information on opening an account at another firm is something that I just discussed at length. This was not in dispute. However, NYSE focused on two stock trades that I made and explained the suspension largely on the basis of these two trades. I believe that they were clearly wrong in their conclusions. Let me discuss those trades in detail.
The first trade was in Stericycle, a medical waste disposal company. I had been following the company for some time with a neutral rating. In my reports, I noted that the Company wanted to buy the medical waste disposal business of Waste Management and if they were successful, I would immediately go to a strong buy.
This acquisition was announced on April 14, 2009 after the close at 4 PM EST. Because it was 1 PM in Los Angeles I held a conference call with Sutro’s traders and the salesforce and told them I was going to a strong buy on the stock. It was the practice of Sutro to initiate new ideas with a conference call in this manner. The traders and sales force would then go out to the clients with the idea. After this, the analyst would follow-up by publishing a note on First Call (an electronic distribution network) and this was done on April 15 This was then followed up by a written research report on April 16. On April 16, I bought 2500 shares of the stock at a price of $12. This was accepted practice at Sutro for research analysts buying stocks that they recommended. There was no requirement to wait for a period of time to buy the stock. The analyst was allowed to buy the stock at the same time as other Sutro employees and clients
The NYSE judged my conduct on standards that were different from those that were accepted practices at Sutro. By today’s standards, the Sutro practices seem very loose but they were common at the time. This is why Sutro did not view this trade as a breach of conduct and kept me as an analyst. The NYSE also said that I did not disclose that I owned Stericycle in my written report. However, none of the analysts at Sutro were required at the time to do so. This was also standard operating procedure.
Stericycle was a major success for investors. Adjusting for stock splits the stock traded at about $3.00 when I first recommended it. Fifteen years later, the stock is trading at about $119. This was one of my best recommendations ever. I held the Stericycle stock for many years and only sold it recently.
The NYSE did not accept that my actions were in line with the practices of Sutro even though I produced a letter to that effect from the research administrative officer. I also argued that a $30,000 investment in a portfolio that amounted to $5 million at the time was de minimus. I argued that the stock was bought and maintained as a long term investment. I argued that it was an excellent money making idea for investors. The NYSE dismissed all of these arguments and maintained that I traded ahead of my recommendation.
The second trade that the NYSE emphasized was a trade in Schering Plough. On April 18, the stock had traded down by 5%. I had an accumulate rating on the stock essentially telling investors to buy the stock for the long term, but connoting less emphasis than a buy. In the morning call to traders and salesmen, I alerted them to the price weakness, but told them there was no change in the fundamental outlook and there was no change in my price target. I was not intending to issue a report, but the research administrative manager told me that the price drop in Schering Plough based on my price target indicated 25% upside that was the accepted criteria for a buy recommendation. Hence, I needed to put out a report in which I upgraded my opinion from accumulate to buy.
I bought the stock on April 20 at the same time as the written report was issued. I previously owned 500 shares and this increased my position to 1000 shares for a total investment of about $35,000 which again was within a $5 million portfolio. The NYSE again accused me of the same things as in the Stericycle situation. They said that I traded ahead of my recommendation and did not disclose that I owned the stock. My responses were the same as for Stericycle and were once again rejected.
Was The NYSE Action Justified?
I think that the NYSE action was out of all proportion to what actually transpired. I think the enforcement officers applied new standards in overturning the prior decision to take no action on this case that had been in effect for three years. They were under pressure to make a big splash in the Elliot Spitzer era to show how tough they were. My recommendations were solid recommendations and indeed the Stericycle recommendation was outstanding.
I fully recognize that my decision to open the brokerage account at Schwab prior to resigning from Sutro was an ethical breach on my part even if I was planning to resign from Sutro. When I decided to stay with Sutro, I transferred my accounts immediately. I strongly and absolutely maintain that my trading in Schering-Plough and Stericycle was in accordance with policies in place at Sutro at the time. By today’s standards these seem loose, but this was common industry practice at the time.
The NYSE review was conducted by a mediator and it was he that determined the punishment. He had spent his entire career as an enforcement officer for the NYSE. He was also friends with the NYSE lawyers on my case and sent out to lunch with them during the hearing. He was the judge, jury and executioner of my fate. As I look back, I question his objectivity and motives. In writing his opinion, he did not acknowledge documents from Sutro that showed that my stock trading disclosures were in-line with their internal procedures. I had no opportunity to review or correct his opinion in the opinion he wrote. In a country in which, guilt or innocence is established by one’s peers, mine was determined by a hanging judge with no experience in the securities business and an apparent pre-determined view on my actions.