Contrarian Corpus
short seller letter follow up
2013-12-19 · 9 pages

NQ Mobile, Inc. NQ

NQ Mobile's independent-committee fraud probe is structurally compromised; Muddy Waters offers to fund Plante & Moran to audit the auditors and protect investors from another China-fraud whitewash.

N 4 Narrative
V 2 Visual
C 2 Craft
Source URL unavailable

Thesis

Muddy Waters, having previously alleged NQ Mobile is a fraud, writes to NQ's independent committee offering to pay for Plante & Moran PLLC to oversee and evaluate the committee's own fraud investigation, which is being run by Deloitte FAS under Shearman & Sterling. Carson Block argues the committee has cloaked the probe in attorney-client privilege with no good-faith justification, and cites eight prior China-issuer cases — Sino-Forest, China Agritech, ChinaCast, China Integrated Energy, China Medical Technologies, Duoyuan Global Water, Sino Clean Energy, and Silvercorp — where committee exonerations were followed by 75% to near-total investor losses, delistings, bankruptcies, and SEC/OSC fraud charges. The offer demands Plante & Moran get unrestricted access to all working papers, primary sources, and advisor interviews, with the evaluation published to investors. The deadline is January 7, 2014.

SCQA

Situation

NQ Mobile's independent committee, advised by Deloitte FAS and Shearman & Sterling, is investigating Muddy Waters' fraud allegations and has pledged transparency to shareholders.

Complication

The investigation is shrouded in attorney-client privilege and follows a pattern: in eight prior China-issuer cases including Sino-Forest, committee exonerations preceded total collapses, regulatory action, and bondholder losses.

Resolution

Accept Muddy Waters' offer to fund Plante & Moran PLLC, with full access to working papers and primary sources, to independently evaluate whether the committee's investigation is credible, and publish the result.

Reward

Investors gain genuine transparency into a critical investigation; a favorable Plante & Moran evaluation would lend the committee real credibility instead of the discredited self-clearance pattern of prior China issuers.

The three reasons

  1. 1

    Eight prior China-issuer independent committee exonerations were followed by 75-99% investor losses

  2. 2

    Shearman & Sterling previously cleared China Integrated Energy, which then collapsed

  3. 3

    Attorney-client privilege has no legitimate purpose if directors are not complicit

Primary demands

  • Independent committee should accept Muddy Waters' offer to fund Plante & Moran to evaluate the integrity of the fraud investigation
  • Committee must waive attorney-client privilege over the investigation to ensure transparency
  • Plante & Moran must receive unimpeded access to all working papers, primary sources, and direct communication with Deloitte FAS and Shearman & Sterling
  • Final evaluation report should be published to NQ shareholders

KPIs cited

Sino-Forest investigation cost
~$50 million spent before bankruptcy and OSC fraud charges
China Agritech post-exoneration equity loss
~95% loss since December 2011 IC announcement
ChinaCast Education post-exoneration equity loss
99.5% loss since December 2011 FTI announcement
ChinaCast cash balance verified by FTI
US$132.1 million across 29 PRC institutions, 98.5% of reported
China Integrated Energy loss since fraud allegations
>80% (only 8% post-announcement as already below net cash)
China Medical Technologies share price
Fell from >$20 at announcement to ~zero in liquidation
Duoyuan Global Water post-halt loss
~95% from $3.88 halt price
Sino Clean Energy post-exoneration loss
~93% since March 2012 announcement, Nasdaq de-listed Aug 2012
Silvercorp post-exoneration loss
>75% since October 2011 KPMG announcement

Pattern membership

Where this document fits across the library's 12 rhetorical / structural patterns.

Precedents cited

  • Sino-Forest (Muddy Waters short, OSC fraud charges, bankruptcy)
  • China Agritech (~95% equity loss post-exoneration)
  • ChinaCast Education (FTI cash verification, then 99.5% loss)
  • China Integrated Energy (also advised by Shearman & Sterling)
  • China Medical Technologies (Nasdaq de-listing, liquidation)
  • Duoyuan Global Water (Muddy Waters short, ~95% loss)
  • Sino Clean Energy (Nasdaq de-listing, ~93% loss)
  • Silvercorp (KPMG Forensic clearance; alleged bribery of Chinese police)

Notable slides (4)

Notes

Open letter addressed directly to NQ Mobile's four independent directors, signed by Carson Block. Not a stand-alone short thesis on NQ — it presupposes Muddy Waters' prior fraud reports on NQ and instead attacks the credibility of the company's defensive independent-committee investigation. Strong rhetorical device: lengthy precedent catalogue (8 China-issuer cases, each with Bloomberg price chart showing post-exoneration collapse). Uses verbatim management/committee statements from Sino-Forest, ChinaCast, China Integrated Energy, China Medical Technologies as 'famous last words' contrast. Shearman & Sterling specifically named as having previously advised China Integrated Energy. Document contains 5 small Bloomberg stock-chart screenshots (pp. 4-7); otherwise plain Times-style letter formatting with Muddy Waters logo on p.1.