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Re: DewDiligence post# 18292

Friday, 05/20/2011 7:05:59 PM

Friday, May 20, 2011 7:05:59 PM

Post# of 24568
Here's the link to a Dawson James research report on Depomed by Stephen Dunn on Jul 10, 2007

http://www.dawsonjames.com/portal/DEPO_Termination_7_10_07.pdf

here's the disclosure at the bottom of the report...

DAWSON JAMES SECURITIES, INC., Member SIPC, FINRA, (the "Firm") does not make a market in these securities. The Firm may perform or seek to perform investment banking services for these companies in the future. Analysts receive no direct compensation in connection with the firm's investment banking business. All Dawson James employees, including the analyst(s) responsible for preparing this research report, may be eligible to receive non-product or service specific monetary bonus compensation that is based upon various factors, including total revenues of Dawson James and its affiliates as well as a portion of the proceeds from a broad pool of investment vehicles consisting of components of the compensation generated by investment banking activities, including but not limited to shares of stock and/or warrants, which may or may not include the securities referenced in this report. The Firm, its officers,directors, analysts or employees may effect transactions in and have long or short positions in the securities (or options or warrants with respect thereto) mentioned herein. Although the statements of fact in this report have been obtained from and are based upon recognized statistical services, issuer reports or communications, or other sources that the Firm believes to be reliable, we cannot guarantee their accuracy. All opinions and estimates included in this report constitute the analyst’s judgment as of the date of this report and are subject to change without notice. The Firm may effect transactions as principal or agent in the securities mentioned herein. The securities discussed or recommended in this report may be unsuitable for investors depending on their specific investment objectives and financial position. This report is offered for informational purposes only, and does not constitute an offer or solicitation to buy or sell any securities discussed herein in any jurisdiction where such would be prohibited. Additional information is available upon request.

Here's a link to all their discontinued research... http://www.dawsonjames.com/portal2.html

The key section is...

All Dawson James employees, including the analyst(s) responsible for preparing this research report, may be eligible to receive non-product or service specific monetary bonus compensation


In other words the analyst may be eligible for "non-product specific" (NOT shares or warrants) or "service specific monetary bonus" (NOT based on favorable recommendations or investment banking transactions)

that is based upon various factors, including total revenues of Dawson James and its affiliates as well as a portion of the proceeds from a broad pool of investment vehicles consisting of components of the compensation generated by investment banking activities, including but not limited to shares of stock and/or warrants, which may or may not include the securities referenced in this report.

The firm Dawson James is sometimes compensated for investment banking services with shares of stock and/or warrants and the proceeds from that compensation are put into a broad pool of investment vehicles from which the analyst is compensated.

Like I said, it is against FINRA rules for an analyst to be compensated for favorable research or specific investment banking services and it's ridiculous to suggest that a brokerage firm would disclose that they are breaking FINRA rules....

http://goo.gl/d8M5N

There are strict rules on the how a research analyst and the investment banking arm of a brokerage firm can interact... these rules have been in place since 2002...

Limitations on Relationships and Communications. Under the new rules, research analysts cannot be supervised or controlled by their firm?s investment banking department. Furthermore, investment banking personnel are prohibited from discussing or reviewing pending research reports with research analysts prior to distribution unless the firm?s legal/compliance department monitors their written and oral communications. Any review of a research report by investment banking personnel must be limited to verification of factual accuracy or to review the report for any potential conflict of interest. Analysts will not be allowed to share drafts of their research reports with subject companies, other than to check facts for accuracy after the approval of the legal/compliance department. Subject companies may not be provided with the research summary, rating or price target
sections of the research report.


http://goo.gl/arLmE

Again, I have found no complaints or regulatory action against Stephen Dunn. There has been nothing reported to FINRA on Stephen Dunn...

http://brokercheck.finra.org/Individual/IndividualSummary.aspx?SearchGroup=Individual&FirmKey=-1&BrokerKey=4649426&IndvlBCCtgry=1&IndvlIACtgry=1

If you know of any illegal activity please disclose it or retract your libelous allegation.

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