I think Deerfield has been doing this for a long long time (they just have never been caught, so, probably figured... let's just keep doing it).
Hopefully, this is a wake up call for firms that do this - although, the penalties should be much higher as they clearly knew a financing was coming (especially in the ARRY financing where they shorted 1.4 million ahead of the offering in the quiet period). Probably did the same thing with the Exelixis financing in 2012 as well.
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