Replies to post #609183 on NorthWest Biotherapeutics Inc (NWBO)

[CrashOverride]

Adam Feuerstein exhibit 2, a bunch of SEC filings (probably the risk sections), and broker quotations?

This is their defense for thousands of documented illegal spoofing incidents?

LOL!

Thanks for that Kenny Boy and Dirty Doug!

By the way, idiots, these are litigated at trial not in pretrial motions!

Thanks for showing us your shoddy defense, though.

Play poker, much?

[meirluc]

Thank you Pgsd for that MTD information.

[muee88]

I’m sure Hoffmann will post it tomorrow with some analysis. I have the document open myself, but it’s late and all the lines are blurring together. Also, I specialize in patents, so reading this type of lawsuit is mind numbing for me haha

[muee88]

This is what is said about AF's Exhibit 2:

NWBO is a clinical-stage biotechnology company that has never received approval for a
single drug. ¶ 2.4 Although the Amended Complaint alleges that NWBO has experienced a “string of encouraging news about its lead product,” in reality NWBO has suffered several crises,
including that NWBO’s lead drug “perform[ed] worse than a placebo” and other reported criticism
of its drug development efforts; regulatory concerns about changing “endpoints” for its clinical
trials; and an SEC enforcement action related to long-standing material weaknesses regarding its
internal controls over financial reporting. NWBO’s shares currently trade at around $0.57, and
have not traded over $1.00 for months, aside from a momentary spike around the time NWBO
filed its initial Complaint. Defendants are SEC-registered broker-dealers and, in that capacity,
regularly trade on behalf of clients. ¶¶ 38, 287. Most of the Defendants also function as market
makers, providing liquidity by publicly displaying proprietary quotations to buy and sell OTC
equity securities.

E.g., Ex. 2, Adam Feuerstein, It took years, but the failure of Northwest Bio’s brain cancer vaccine is now in the open, STAT NEWS (May 10, 2022), https://www.statnews.com/2022/05/10/it-took-years-but-the-failure-andfutilityof-northwest-bios-brain-cancer-vaccine-is-now-in-the-open/. The Court may take judicial notice of each of the publicly-available documents cited in this memorandum. See Blue Tree Hotels Inv. (Can.), Ltd. v. Starwood Hotels & Resorts Worldwide, Inc., 369 F.3d 212, 217 (2d Cir. 2004) (court “may also look to public records . . . in deciding a motion to dismiss”); In re Citigroup, Inc., 2011 WL 744745, at *3, 9 (S.D.N.Y. Mar. 1, 2011) (taking judicial notice of SEC Order, disclosure statements, and website and prospectus excerpts), aff’d sub nom. Finn v. Barney, 471 F. App’x 30 (2d Cir. 2012); see also Plumbers & Steamfitters Loc. 773 Pension Fund v. Can. Imperial Bank of Comm., 694 F. Supp. 2d 287, 297 n.2 (S.D.N.Y. 2010) (considering “supplemental documents” to “inform the competing inference analysis required by Tellabs”).