Case 2:24-cv-06311-SPG-RAO Document 1 Filed 07/26/24 Page 1 of 58 Page ID #:1
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`STEPHEN T. KAM (Cal. Bar No. 327576)
`Email: kams@sec.gov
`RUTH C. PINKEL (Cal. Bar No. 164470)
`Email: pinkelR@sec.gov
`SARAH S. NILSON (Cal. Bar No. 254574)
`Email: nilsons@sec.gov
`WENDY E. PEARSON (Cal. Bar No. 211099)
`Email: pearsonw@sec.gov
`Attorneys for Plaintiff
`Securities and Exchange Commission
`Katharine Zoladz, Regional Director
`Gary Y. Leung, Associate Regional Director
`Brent Wilner, Associate Regional Director
`Douglas Miller, Regional Trial Counsel
`444 S. Flower Street, Suite 900
`Los Angeles, California 90071
`Telephone: (323) 965-3998
`Facsimile: (213) 443-1904
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`
`SECURITIES AND EXCHANGE
`COMMISSION,
`Plaintiff,
`
` Case No.
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`2:24-cv-06311
`
`COMPLAINT
`
`vs.
`ANDREW LEFT, AND
`CITRON CAPITAL, LLC,
`Defendants,
`
`Plaintiff Securities and Exchange Commission (“SEC”) alleges:
`JURISDICTION AND VENUE
`1. The Court has jurisdiction over this action pursuant to Sections 20(b),
`20(d)(1) and 22(a) of the Securities Act of 1933 (“Securities Act”), 15 U.S.C. §§
`77t(b), 77t(d)(1) & 77v(a), and Sections 21(d)(1), 21(d)(3)(A), 21(e) and 27(a) of
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`COMPLAINT
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`the Securities Exchange Act of 1934 (“Exchange Act”), 15 U.S.C. §§ 78u(d)(1),
`78u(d)(3)(A), 78u(e) & 78aa(a).
`2. Defendants have, directly or indirectly, made use of the means or
`instrumentalities of interstate commerce, of the mails, or of the facilities of a
`national securities exchange in connection with the transactions, acts, practices and
`courses of business alleged in this complaint.
`3. Venue is proper in this district pursuant to Section 22(a) of the Securities
`Act, 15 U.S.C. § 77v(a), and Section 27(a) of the Exchange Act, 15 U.S.C. §
`78aa(a) because certain of the transactions, acts, practices and courses of conduct
`constituting violations of the federal securities laws occurred within this district. In
`addition, venue is proper in this district because Defendant Left resided in this
`district during the relevant period. Further, during the relevant period, defendant
`Citron Capital, LLC had its principal place of business in this district.
`SUMMARY
`4. Defendant Andrew Left (“Left”) is an activist short publisher. Starting
`around 2008, Left published tweets and reports which recommended investment
`ideas to the market through his online platform, Citron Research. These
`publications frequently purported to expose negative information on target
`companies, were often larded with hyped rhetoric, and frequently urged his readers
`to sell their stock in the target companies. At times, these publications also
`presented positive information on target companies and encouraged Left’s readers
`to buy. Left and Citron Research had a substantial following – on twitter alone,
`Citron Research had more than a hundred thousand followers.
`5. This civil enforcement action concerns Left’s misuse of the Citron
`Research platform in connection with reports and tweets he published between
`approximately March 2018 to December 2020 (the “Relevant Period”) relating to 23
`target companies on at least 26 separate occasions which allowed him to generate
`approximately $20 million in illegal trading profits through a scheme to defraud.
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`6. Through these reports and tweets, Left exploited his Citron Research
`platform by taking the following steps. First, Left established long or short
`exposure in the target company through equity shares and/or options. Next, Left
`issued reports and tweets informing his readers or leading them to believe that he
`had long or short exposure in the target company. Left then recommended that his
`readers trade in the same direction as his positions. Finally, in many cases, Left
`gave his readers a purported price target, i.e., a share price at which the stock would
`trade. Following Left’s reports and tweets, the price of these target stocks moved
`on average more than 12%. Unbeknownst to the market, however, Left planned to
`capitalize on those price movements and quickly reverse his own positions in the
`equity shares and options – which he had induced readers to follow – but at prices
`far higher (or lower) than the price targets Left had pushed to his readers and the
`marketplace. In other words, Left bought back the stock almost immediately after
`telling his readers to sell, and Left sold stock almost immediately after telling his
`readers to buy. This fraudulent practice deceived investors and allowed Left to use
`his Citron Research reports and tweets as catalysts from which he could derive
`short-term profits. Left directed this trading in furtherance of the scheme through
`his personal accounts and accounts in the name of his entity, Defendant Citron
`Capital, LLC (“Citron Capital”), generating millions in profits.
`7. To carry out this scheme, Left and Citron Research (“Defendants”)
`engaged in several deceptive acts. For example, in order to present Citron Research
`as an independent publication to investors, Defendants posted purported “investor
`letters” to create the false impression that Citron Capital was a successful hedge
`fund with investors, when in fact Citron Capital never had any outside investors and
`Left simply used Citron Capital to trade his own money. They created anonymous
`websites to enhance the recommendations in their tweets and reports so they could
`induce more trading activity in a target company and generate higher profits for
`their scheme. Left also created phony invoices for “consulting services” that he did
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`not provide for the purpose of concealing that he was receiving over $1 million
`from a hedge fund in exchange for Citron Research publishing certain reports and
`tweets. Defendants used price targets to give the impression that the stock would
`drastically move in the direction of their recommendation, and to attract media
`attention that would amplify their recommendations.
`8. Defendants also made several false and misleading statements in
`connection with the scheme. For example, Defendants told the market that they
`would stay long a target stock until the price hit $65, when in fact they immediately
`began selling the stock at $28. They falsely represented to the market that Citron
`Research was an independent research outlet that had never received compensation
`from hedge funds, when in fact they had. They stated that they had long or short
`exposure in target stocks and included purported price targets at which they claimed
`the stock would move, when in fact they planned to immediately trade in direct
`contradiction to those statements. Left bragged to colleagues that some of these
`statements were especially effective at inducing retail investors to trade based on his
`recommendations and said that it was like taking “candy from a baby.”
`9. Through their conduct, and as further detailed in this complaint and
`Appendix A, Defendants violated the antifraud provisions of Section 17(a) of the
`Securities Act, Section 10(b) of the Exchange Act, and Rule 10b-5 thereunder, and
`pursuant to Section 20(a) of the Exchange Act, Left is responsible for Citron
`Capital’s violations of Section 10(b) as a control person of the entity.
`10. As a result of this conduct, the SEC is seeking permanent injunctions
`against Defendants and conduct-based injunctions against Left for their violations
`of the federal securities laws, and to bar Left from acting as an officer or director of
`a public issuer pursuant to Sections 20(e) and 21(d)(2) of the Exchange Act. The
`SEC also seeks an order barring Left from offering or selling penny stocks and from
`acting as or being associated with any investment adviser. The SEC further seeks to
`disgorge their ill-gotten gains, along with prejudgment interest thereon, and to
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`impose civil money penalties against Defendants pursuant to Sections 21(d)(3) of
`the Exchange Act and 20(d) of the Securities Act.
`THE DEFENDANTS
`11. Andrew Left (“Left”), age 54, was a resident of Beverly Hills,
`California during the Relevant Period. He currently resides in in Boca Raton,
`Florida. In 1998, Left was sanctioned by the National Futures Association (a self-
`regulatory organization for the U.S. derivatives industry) for making false and
`misleading statements to customers. In 2016, the Hong Kong Futures and
`Securities Commission barred Left from trading securities in Hong Kong for five
`years.
`12. Citron Capital, LLC (“Citron Capital”) is an investment adviser
`established by Left and Business Associate One in October 2018. Citron Capital
`registered with the SEC as an investment adviser between October 2018 and April
`2019, and thereafter was an exempt reporting adviser registered with the California
`Department of Business Oversight until March 2022. Citron Capital managed an
`investment fund, Citron Capital LP (“Citron Fund”).
`RELATED PERSONS AND ENTITIES
`13. Citron Research (“Citron Research”) (formerly “StockLemon.com”) is
`not a formal entity, but rather Left’s online moniker through which he releases
`tweets and reports purporting to expose frauds or other problematic conduct at
`target companies. Left has been releasing online stock commentary since at least
`2001 and has used the Citron Research moniker since approximately 2008.
`14. “Business Associate One” is the person with whom Left formed Citron
`Capital in October 2018. From at least that point forward, Business Associate One
`assisted Left in operating Citron Capital and Citron Research.
`15. Anson Funds Management, LP (“Anson Funds”) is a limited
`partnership organized under the laws of Texas with a principal place of business in
`Dallas, Texas. It has been registered as an investment adviser with the SEC since
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`2012.
`16. Anson Advisors, Inc. (“Anson Advisors”) is a corporation organized
`under the laws of Ontario, with a principal place of business in Toronto, Canada.
`Anson Advisors is registered with the Ontario Securities Commission and has
`reported to the SEC as an exempt reporting adviser since 2013. Anson Advisors
`and Anson Funds (collectively, “Anson”) are co-investment advisers of a number of
`private pooled investment vehicles. Anson was the subject of a cease-and-desist
`and administrative proceeding with the SEC related to its work with Left and other
`short publishers. In the Matter of Anson Advisors Inc. and Anson Funds
`Management LP, Inv. Adv. Act Rel. No. 6622 (June 11, 2024).
`17. Portfolio Manager One was employed by Anson Advisors as a
`Portfolio Manager.
`18. Hedge Fund Two is an investment adviser that manages private funds.
`From January 2019 through January 2021, Citron Capital acted as a sub-adviser for
`Hedge Fund Two.
`19. Third-Party Intermediary is a small research firm that provides
`research to a handful of clients. Third-Party Intermediary at times had separate
`engagements with Left and Anson to provide research services.
`TERMS USED IN THIS COMPLAINT
`20. An investor typically takes a “long” position when he or she anticipates
`that the value of the security will increase. If the price increases, the investor may
`profit by selling shares of the security for more than he or she purchased the
`security. If, on the other hand, the price decreases, the investor may take a loss.
`21. An investor typically takes a “short” position when he or she anticipates
`that the price of the security will decrease. A “short sale” by an investor is the sale
`of a security that the seller does not own or any sale that is consummated by the
`delivery of a security borrowed by, or for the account of, the seller. In order to
`deliver the security to the purchaser, the short seller will borrow the security,
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`typically from a broker-dealer or an institutional investor. The investor can
`subsequently “cover” or “exit” his or her short position by purchasing the security
`and returning it to the lender. If the price decreases, the investor may profit by
`covering (purchasing the security) for less than the short sale price. If, on the other
`hand, the price increases, the investor may take a loss.
`22. The terms “call” and “put” options, as used in this complaint, refer to
`contracts that give their holders the right, but not the obligation, to buy (a call
`option) or sell (a put option) a fixed number of shares of the underlying security at a
`specific price—called the “strike price” or “exercise price”—on or before a
`specified time. Each equity options put and call contract typically represents 100
`shares of the underlying security. The purchaser of a call option typically believes
`that the price of the underlying stock will rise. The purchaser of a put option
`typically believes that the price of the underlying stock will fall.
`23. A “limit order” is an order to buy or sell a security at a specified price or
`better.
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`I.
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`THE ALLEGATIONS
`Defendants’ Fraudulent Scheme to Manipulate the Market
`A. Left Develops Citron Research and Its Reputation as an
`Independent Research Firm
`1.
`Left Creates Citron Research
`24. Defendant Andrew Left began publishing reports recommending
`investment ideas to the market in the early 2000s through StockLemon.com, a
`website he created.
`25. Left rebranded his platform under the name Citron Research in 2008.
`From that point forward, Left used Citron Research as a platform to release reports
`and tweets containing trading recommendations, which often included information
`about target companies, statements that Citron was long or short the stock, the
`projected direction the target companies’ stock price was moving, and encouraged
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`readers to take a short or long position in the companies.
`26. Left established Citron Research as an activist “short” publisher, largely
`releasing negative or disparaging information on target companies.
`27. Left often drafted Citron Research’s short publications in a sensationalist
`exposé style and strongly encouraged readers to sell the stock of the target
`company. These publications would often declare a company a “fraud,” “scam,” or
`“scheme,” and use powerful imagery and language, such as calling a company “the
`Harvey Weinstein of social media,” “uninvestable,” declaring that “investors have
`been warned,” “wait until Senate finds out what Citron has published,” and warning
`that the “SEC should immediately HALT this stock.”
`28. At times, Left also used Citron Research’s platform to recommend
`“long” investment ideas by presenting positive, favorable descriptions of a target
`company and its stock’s value. On the long side he also used powerful imagery and
`language, such as “S&P Stock of the Year,” “biz is on fire” and “Citron Research is
`Bullish on the Most Shorted Stock in the World.”
`29. Left disseminated his views through written reports posted on the Citron
`Research website, CitronResearch.com. The reports were also published to
`subscribers through an email blast, and typically linked to a tweet from Citron’s
`twitter feed, @CitronResearch. Left also frequently appeared on media broadcasts
`such as CNBC where he would discuss the recommendations he had published
`through Citron Research.
`30. Left sometimes expressed his views on stocks by posting tweets stating
`or leading readers to believe that he had “long” or “short” exposure in a target
`company without posting an accompanying report.
`2.
`Left Creates Citron Capital and Holds It Out as a
`Successful Hedge Fund with Outside Investors
`31. In late 2018, Left and Business Associate One created Citron Capital.
`32. Left touted Citron Capital as a successful hedge fund with double and
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`triple-digit returns through purported “investor letters” that he posted publicly.
`33. In these purported investor letters, Left created the false impression that
`Citron Capital had outside investors. For example, certain investor letters
`represented that Citron Capital managed a “pooled investment vehicle” and
`referenced the “Fund’s offering memorandum.” In addition, in a July 17, 2019
`investor letter, Left wrote “the managers of Citron would like to reassure our
`investors” when discussing Citron Capital’s trading strategy.
`34. Left also gave the appearance of having a successful hedge fund to the
`media to enhance his public image. In February 2019, when communicating with a
`CNBC producer, Left said the “Citron fund is up close to 40%. SEC Registered.”
`He also sent a year-end investor letter to CNBC with the subject line “First year of
`Citron Capital in the books.”
`35. However, Citron Capital never had any outside investors. In reality, Left
`only used Citron Capital as a vehicle to trade his own money.
`3.
`Left Controls Both Citron Research and Citron
`Capital
`36. Left controlled both Citron Research and Citron Capital and at times
`blurred the lines between the two entities. For example, Left noted in the Citron
`Research reports that they “have been prepared by either Citron Research or Citron
`Capital.” Left also at times defined “Citron” as both Citron Research and Citron
`Capital, or represented that “Citron” held a position, referring to the position held in
`the Citron Capital account.
`37. Left controlled the day-to-day business operations and policies of Citron
`Research. Left had ultimate responsibility for Citron Research’s business, crafting
`the narratives and drafting Citron Research’s publications. At all relevant times,
`Left controlled the content and dissemination of these publications. Left was also a
`frequent guest on financial news media programs as the person behind Citron
`Research and advocated Citron Research’s investment views. Left had ultimate
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`responsibility for the tweets published by Citron Research through its twitter feed,
`@CitronResearch.
`38. Left had the authority to control the business operations and policies of
`Citron Capital with assistance from Business Associate One. As a principal of
`Citron Capital, Left solely directed all trading and investment decisions of Citron
`Capital and owned all of Citron Capital’s funds. Left and Business Associate One
`extensively participated in the day-to-day business of Citron Capital. Left was the
`sole public voice on behalf of Citron Capital and made media appearances and
`drafted and disseminated purported investor letters.
`4.
`Left Promotes Himself and Citron Research to the
`Public as a Trustworthy, Independent Publisher
`39. Left promoted Citron Research to the public on its twitter header as
`“representing the other side of Wallstreet,” and “[t]he Other Side of Research.”
`The Citron Research website also stated that Left had been “quoted in every major
`US financial publication, including Forbes, Fortune, Wall Street Journal, Barron’s,
`CNBC, Investors’ Business Daily, and Business Week.”
`40. Left presented Citron Research as publishing independent research and
`held himself out as a “private investor” who led “a team of investigators.” In July
`2011, Left told the Financial Times that “the role I play in the market is I try to tell
`the other side of the story, when everybody blindly cheerleads, there's always
`another side of the story ...” In addition, in the “About Citron Research” section of
`the Citron Research website Left represented that “The goal of this website is and
`has always been to provide truthful information in an entertaining format to the
`investing public.”
`41. Left also portrayed himself to the media as an independent publisher. In
`September 2018, Left told a CNBC representative “I do not trade based on TV
`appearances.”
`42.
`In August 2019, Left continued to promote Citron Research as an
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`independent research firm, telling his readers that “in 18 years of publishing, we have
`never been compensated by a third party to publish research.”
`B.
`Left’s Trading Recommendations Published Through Citron
`Research Move the Market
`1.
`Left Brags that the Tweets and Reports He Publishes
`Through Citron Research Are Capable of Moving the
`Market
`43. During the Relevant Period, Citron Research had more than one hundred
`thousand followers on twitter. Citron Research’s tweets were also picked up by the
`media and quickly disseminated to a much wider audience.
`44. Many of the recommendations published on Citron Research were “short
`recommendations,” where Left induced investors to sell their shares in the target
`company. The publications making the short recommendation often represented to
`the market that Citron also had short exposure or was “short” in the target stock.
`45.
`Investors often sold their stock in response to Left and Citron Research’s
`short recommendations. This typically led to a decline in the stock price.
`46. Citron Research also published positive “long recommendations” on
`certain target companies, where Left induced investors to buy the stock by promoting
`the companies. The publications making the long recommendation often represented
`that Citron had a long position or was “long” in the target stock.
`47.
`Investors often bought stock in response to Left and Citron Research’s
`long recommendations, which typically led to an increase in the stock price.
`48. Due to the large number of followers Citron Research had on twitter and
`the attention that its tweets and reports garnered from the media, Left knew, or was
`reckless and negligent for not knowing, that investors often bought or sold stock in
`response to Left and Citron Research’s recommendations, and thus his stock
`recommendations in the tweets or reports impacted the market.
`49. For example, in or around March 2018, Left bragged to colleagues that
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`he was confident he could “destroy” or “kill” companies by publishing a tweet or
`report, and told a colleague in August 2018 that he had a “hot voice” that he planned
`to “take a vantage [sic] of.”
`50. Left knew that he could make money off his tweets because of his
`readers and the impact he had on their trading behavior, telling a colleague, “I save
`tweets for easy money.” Similarly, in May 2018, Left repeated a quote from a
`Business Insider article: that he could “send a stock tumbling with a single tweet.”
`2.
`Left Uses Target Prices to Amplify the Trading
`Recommendations He Publishes on Citron Research
`51. Left frequently included a target price in the Citron Research reports and
`tweets that he published, leading his readers to believe that this was the price at
`which he thought the stock would trade.
`52. The target prices were typically far above (for long publications) or far
`below (for short publications) the stock’s current trading price, giving the market
`the impression that the stock prices of the target companies would drastically
`increase or decrease in the direction of the Citron Research recommendation.
`53. The Citron Research tweets contained little to no analysis of how the
`price target had been determined.
`54. While the reports sometimes contained purported analysis of the price
`targets, Left at times drastically revised the target prices in the days or hours prior to
`posting the report.
`55. Left included these price targets for the purpose of encouraging the
`media to pick up, and thereby amplify, his trading recommendations.
`56. When paired with the inflammatory language in the Citron Research
`publications, the target prices captured the immediate attention of the press, which
`led to further dissemination of the reports and tweets.
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`C. Left’s Misuse of the Citron Research Platform For His
`Personal Profit
`57. At times, Left exploited the Citron Research platform by stating or
`leading readers to believe that he had long or short exposure in the target stocks,
`inducing his readers to trade in the same direction as his stated positions, and
`providing purported price targets for the target stocks.
`58.
`In reality and unbeknownst to investors, Left planned to quickly abandon
`his stated long or short exposure in order to capitalize on the stock price moves
`following the release of these reports and tweets, and planned to do so at far different
`prices than the price targets he was projecting to the market.
`59. Through these actions, Left bought stock almost immediately after
`telling his readers to sell, and sold stock almost immediately after telling his readers
`to buy.
`60. This fraudulent practice deceived investors. It allowed Left to use the
`Citron Research reports and tweets to lead investors to believe they were truthful,
`independent stock recommendations, when in fact they contained false statements or
`misleading half-truths intended to create a catalyst to move the target company’s
`stock price so that Left and Citron Capital could profit.
`1.
`Left’s Trading Strategy
`61. Left told Business Associate One that his strategy was built around
`publishing recommendations on Citron Research for the purpose of causing price
`moves in target companies from which he could quickly profit.
`62. For example, in or around 2018, Left explained to Business Associate
`One that “creating a catalyst is the best way to make money.”
`63. Left instructed Business Associate One to “Trade on day of article or
`day before and max $50k in options, get out immediately on catalyst.” Left also
`instructed Business Associate One to “STOP GAMBLING, run a fund . . . ONLY
`PLAY CATALYST.”
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`COMPLAINT
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`Case 2:24-cv-06311-SPG-RAO Document 1 Filed 07/26/24 Page 14 of 58 Page ID #:14
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`64. Left’s strategy focused specifically on taking advantage of unsuspecting
`investors who followed Citron Research’s recommendations, yet who did not know
`of Left and Citron Capital’s plan to quickly sell or purchase contrary to Citron
`Research’s recommendations, and at a price far different than the price targets
`Citron Research provided.
`65. Left told others that one of his strategies involved targeting retail
`investors, because these investors were likely less informed and therefore more
`likely to follow his recommendations, stating that “these retail holders are nervous.
`we will hit them” and “Now that I know who owns [the target stock]. candy from a
`baby.”
`66. In addition, Left used Citron Capital investor letters containing
`information about Citron Capital’s intended trading – which he posted publicly or
`sent to the media for broad distribution – as catalysts around which Defendants
`could trade and profit.
`67. Left’s catalyst strategy was built around inducing his readers to follow
`the trading recommendations on Citron Research.
`68. To that end, at times Left represented to his readers or led them to
`believe that he was trading consistent with the recommendations in the publications
`he issued through Citron Research.
`69. In some short recommendations, Left represented to his readers or led
`them to believe that he had short exposure in the target stocks. He provided price
`targets well below the stock’s current trading price to give the impression that the
`price of the stock was set to drastically decline.
`70. In some long recommendations, he represented to his readers or led them
`to believe that he had long exposure in the target stocks. He provided price targets
`well above the stock’s current trading price to give the impression that the price of
`the stock was set to drastically increase.
`71. At times, Left represented to his readers or led them to believe that he
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`COMPLAINT
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`Case 2:24-cv-06311-SPG-RAO Document 1 Filed 07/26/24 Page 15 of 58 Page ID #:15
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`intended to purchase or sell target stocks only when that stock reached a specific
`price.
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`2.
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`Left Deceives the Market by Quickly Trading
`Inconsistent With His Statements
`72. Unbeknownst to his readers, with respect to the stocks identified in
`Appendix A, Left immediately traded inconsistently with the recommendations that
`he posted to Citron Research.
`73. Left generated profits by trading in both his personal accounts and
`Citron Capital’s account around his recommendations. Prior to issuing short
`recommendations, Left had established short exposure in his personal account and
`in the account of Citron Capital in the target company’s securities. He typically did
`this through a combination of stock and options positions; for stock, short selling
`the stock, and for options, buying puts or, less often, selling calls.
`74. After establishing short exposure, Left then released a short report and/or
`negative tweet about the issuer through the Citron Research platform.
`75. Left knew, or was reckless and negligent for not knowing, that the
`information in the publication typically triggered others to sell the stock, leading to
`a decline in the stock price, and a corresponding price move in the options. For
`example, a decrease in the stock price would cause the price of corresponding put
`options to increase, and the price of corresponding call options to decrease.
`76. Shortly after recommending to the market that it sell a target company’s
`stock, Left then quickly bought back the stock or call options at the depressed price
`to close the short position, or sold his put options for a higher price, yielding
`significant profits.
`77. Left engaged in a similar practice for long recommendations he
`published on Citron Research. Left would buy stock (or buy calls or sell puts) in
`advance of issuing long recommendations. After establishing long exposure, he
`then issued the long recommendation through Citron Research that the stock price
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`COMPLAINT
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`Case 2:24-cv-06311-SPG-RAO Document 1 Filed 07/26/24 Page 16 of 58 Page ID #:16
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`was likely to increase and recommended that his readers buy the stock.
`78. Left knew, or was reckless and negligent for not knowing, that the
`information in the publication typically triggered others to buy the stock, leading to
`an increase in the stock price, and a corresponding price move in the options.
`79. Shortly after inducing his readers to buy the stock, Left then sold his
`stock or call options, or bought back his put options, upon the increase in stock
`price following his publicati