NorthWest Biotherapeutics Inc (NWBO)

[pqr]

Some thoughts on Complaint.
Para 9 Plaintiff NWBO identifies trading days on which spoofing occurred, meaning, this data has been obtained and analyzed.
Para 10 Co is claiming damage from selling 49 MM shares at artificially-deflated prices, meaning, Co's counsel can estimate the direct damage amount
Parties/Emotional play to jury. David with a cancer cure vs multi-billionaire Wall St Insider Goliaths cheating David for lucre.
Paras 41 et seq, Lawsuit was not filed until after JAMA-Onco specifically to include allegations with respect to alleged manipulation on publication and thereafter.
Para 52 references "trading records" allegedly showing spoofing, see comment on para 9 above, following Paras describe what happened
Para 59 includes chart showing numbers of "episodes," associated Baiting Orders and Executing Purchases, with % SP decline. NOTE: this is not evidence of causation i don't believe even with expert testimony. Causation will be the battle ground (in addition to procedural issues and specifically scope of discovery by all parties).
Paras 59-236 include Plaintiff's counsel's opinion of the most significant examples of spoofing and are the core of NWBO's causation argument.

TO BE CONTINUED