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12/02/22 7:49 PM

#542661 RE: pqr #542363

Hi pqr,

here is the section I found most interesting with regards to an injunction. I bolded the section which indicates the harm to the plaintiff v. the 'insignificant' harm to the defendant.

Would this request not be enforceable/unrealistic, and if so, what are the attorneys at Cohen Milstein Sellers & Toll PLLC, really looking for?

Thanks again for your insights!

277. Plaintiff seeks to permanently enjoin Defendants from engaging in spoofing
conduct that affects NWBO’s share price. Defendants’ actions identified herein have caused,continue to cause, and will cause future permanent and irreparable harm to Plaintiff.

278. Such harm is not merely pecuniary. Defendants’ conduct has significantly impaired
the ability of the Company to raise funds from the public markets, and thus could impact the ability of the Company to get these life-saving cancer treatments quickly to market, robbing people of their lives and health.

279. The balance of the equities favors an injunction to prevent Defendants from
continuing to spoof NWBO stock. The harm to Plaintiff and GBM patients is significant. Through its clinical trials, DCVax-L has shown unprecedented improvements over existing standard of care in long-term survival curve tails for both newly diagnosed and recurrent GBM patients. In contrast, the potential harm to Defendants of injunction is insignificant; Defendants would merely be required to halt their illegal activity. Thus, the public interest, and public health, is best served by enjoining Defendants’ spoofing behavior

.

Best of luck to Patients, NWBO, and Longs!
Bullish
Bullish