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frrol

10/07/16 5:58 PM

#160960 RE: Snowy_Owl #160957

You didn't provide the complete quote, which is far more satisfying:

The pseudonym used by the anonymous short seller in this case is “Mako Research,” not “the Pump Stopper.” Defendants do not know why Plaintiff would attribute the posting at issue to a different anonymous short seller unless the Rosen Law Firm (a) knows that Mako Research and the Pump Stopper are one and the same, (b) has briefed this sanctions issue before and “cut and pasted” the text from another pleading (as it did with respect to the initial and amended complaints here), or (c) was simply careless in its treatment of the facts. In any event, Defendants will substitute the correct author when it quotes to Plaintiff’s Opposition.

I would have preferred this was not footnoted but rather given more prominent place in the reply. Nevertheless, well argued. In fact the whole reply is excellent. Hope the judge is receptive.