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Viceroy activates ‘The Honeypot’ – Parker H. Petit & MiMedx caught red-handed

New insights on MiMedx instructions to physicians on how to fraudulently increase compensation.

Following the release of our previous report titled “Viceroy release MiMedx EOB emails”, Viceroy Research has been contacted by physicians corroborating MiMedx’s role in distributing EOB to fraudulently increase Medicare reimbursement. This occurs through the reclassification of AmnioFix products as EpiFix products in order to obtain Medicare reimbursements.

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MiMedx’s recent nonsensical responses to our research have been evasive and does not acknowledge that at its core, the practice construes Medicare fraud. In order to demonstrate this, Viceroy set a Honeypot. MiMedx in their desperation to mislead investors, have taken our bait.

While the issue of reclassifying MiMedx product to exploit federal billing facilities was a major issue, there was another underlying element to the EOB.

Consider the following: in principle, Medicare reimbursements cover 80% of the cost of any treatment used as well as 80% of the Medicare application fee. Typically, this means a reduced payment for the patient, however by utilizing a larger graft than is necessary a physician can be reimbursed more than the cost of treatment.

Per the Rosenberger email, how can MiMedx justify physicians PROFITING from Medicare when system is intended to cover a PORTION of costs?

Viceroy yesterday showed MiMedx has zero credibility regarding their statements. Previously MiMedx had state to investors AvKare wasn’t an intermediary, controlled sales and it was all lies. MiMedx know full well what the implications of Mike Carlton’s deposition under oath means. There is no commentary, statements issued by MiMedx are purely intended to manipulate a situation where blind and naive analysts continue to promote the stock.

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MiMedx continue to consciously mislead investors, defame Viceroy and Marc Cohodes

AvKare just “made it easier” for former Advanced BioHealing agents to stuff federal customers with MiMedx product

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Viceroy present indisputable proof that Parker H. Petit has been misleading investors and defaming Marc Cohodes & Viceroy.

Mike Carlton, VP of Global Sales, was under oath giving a deposition about MiMedx’s relationship with Mid-South Biologics, who are suing MiMedx regarding contractual issues. Parker H. Petit and MiMedx attorneys would have known that during the deposition, Mike Carlton said this:

 

“AvKare didn’t sell the product. They didn’t do anything. They just made it easier to sell.”

Interestingly, when Viceroy and Marc Cohodes echoed this statement, we were met by a barrage of lies and a law suit from MiMedx who want to falsely asset our reports are factually inaccurate.

For the analysts that can find ‘no credible evidence of wrong-doing’, we recommend they review filings for all cases MiMedx are involved in.

Today’s focus is on case is Mid-South Biologics LLC (Pla) Vs. MiMedx Group Inc (Def) – Reference: Case 2:17-cv-02028-JTF-egb   Document 43-3   Filed 12/04/17. The deposition was taken on the 13th Day of October 2017.

Parker H. Petit and Mike Carlton are advised that we have forwarded this information to the SEC. Investors should be aware of the lengths MiMedx will go to mislead and misinform its shareholders

As a recap:

Analysts who can blindly find no credible evidence of wrong-doing should seriously review Viceroy’s reports and MiMedx’s own documentation showing channel-stuffing, fake revenue recognition, ‘free evaluation products’, breaches to anti-kickback statutes and many more violations.

As previously reported, MiMedx is being investigated by Regulators, it would be prudent for the sellside to conduct their own investigation instead of relying on a “binary outcome” in relation to allegations of fraud.

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Viceroy release MiMedx EOB emails

Viceroy has obtained emails instructing physicians how to falsify MiMedx Q-codes to fraudulently increase reimbursement.

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Viceroy have obtained printouts of emails sent from MiMedx employees specifically instructing physicians on how to fraudulently increase Medicare reimbursement.

An EOB document titled “EpiFix – Made Easy” has been sent to Viceroy, which appears to be advice from MiMedx to physicians on how to receive Medicare reimbursements for their product.

One problem: this advice was provided to surgical clients; whose products are ineligible for Medicare reimbursement.

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Steinhoff’s skeletons: off-balance sheet entities inflating earnings, obscuring losses

Viceroy is pleased to release its research report on Steinhoff International Holdings NV.

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Steinhoff (SNH) has long been under scrutiny for seemingly inexplicable factors including:

  • A long string of acquisitions of stagting or deteriorating businesses whose performance seems to miraculously improve post-acquisition, even if only on paper.
  • Cash flow trends that do not correspond to EBITDA.
  • Investigations into senior executives for tax-evasion, document forgery and fraud.
  • Rampant and dilutive equity raising.

Viceroy’s investigation into Steinhoff has revealed several concerning activities surrounding a number of at least two off-balance sheet, undisclosed related party entities:

  • Campion Capital
  • Southern View Finance

While the existence of some of these entities has been reported by the media, their activities have not. Viceroy’s analysis suggests Steinhoff uses these off-balance sheet vehicles to artificially inflate earnings:

  • Steinhoff has issued expensive loans to and booked interest revenue against Campion subsidiaries for the purchase of loss-making Steinhoff subsidiaries. These revenues will never translate to cash.
  • Steinhoff has moved two loss-making and predatory consumer loan providers to off-balance sheet entities: JD Consumer Finance and Capfin.
  • Steinhoff negotiated the re-purchase of the only profitable portions of JD and Capfin (loan administration and debt collection facilities) while allowing losses to be incurred at off-balance sheet, related party entities under Campion Capital.

Given these loss-making entities, such as Southern View Finance UK, are being round tripped back to Steinhoff, Viceroy believe it is possible that Steinhoff are ‘repaying’ Campion’s outlays through acquisition premiums (i.e. losses are being capitalized through round-trip transactions with related parties).

Viceroy believes that, based on the contents of this report, Steinhoff should consolidate Campion Capital and its subsidiaries given that Steinhoff bears full economic liability for these entities through loan arrangements and exert total control through overlapping management.

Viceroy believes the facts presented in this report will bring Steinhoff’s behavior to the attention of regulatory authorities.

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MiMedx now under investigation by DOJ enforcement & VA

Viceroy has received responses to two Freedom of Information Act (FOIA) requests lodged after the publication of our initial report, one from the Department of Veterans Affairs and the other to the Department of Justice.

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Both agencies withheld all requested documents under 5 U.S. Code § 552 5(b)(7)(A), which provides an exemption for agencies to make available public documents as it could “reasonably be expected to interfere with enforcement proceedings.”

Viceroy now believe MiMedx is under formal investigation by the DOJ, the DVA and the SEC.

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MiMedx caught red-handed circumventing VA regulations

Viceroy’s latest report reveals emails between the VA and MiMedx show MiMedx employees were instructed to circumvent VA policy regarding consignment agreements.

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Viceroy obtained a series of emails between MiMedx employees and VA personnel. These emails are focused on the arrangement of consignment inventory, contrary to VA hospital regulations at the time. The issue comes to a head when a VA supervisor decides to hold MiMedx responsible for repeatedly sending product that was not ordered. The VA have been made aware of these and other emails with a report of concern.

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MiMedx vendors soliciting up-coding of Medicare incentives.

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MiMedx emails to former employees in clear violation of federal law: settlements contingent on retracting statements to regulatory bodies.

Viceroy has obtained from a physician an email sent from MiMedx employees to physicians to fraudulently exploit the reimbursement system to financially benefit both the physician and MiMedx. This is done through manipulation of Q-codes which denote the form of treatment in which a product was used. The aim is for all treatments using MiMedx products to be coded as “wound care” in order to fraudulently maximize reimbursement. This type of Medicare fraud is referred to as ‘up-coding’.

In addition to this Viceroy present recent court filings and emails showing that MiMedx engaged in illegal settlement terms in its legal actions against former employees. MiMedx has sent legal material to former employees requesting that they do not contact regulatory authorities and has stipulated in its settlement agreements that former employees retract their statements to any regulatory body. This is a violation of the United States Code of Federal Regulations.

As a reminder of MiMedx selective statements to its investors, it’s by no coincidence that MiMedx are now blatantly cloaking their conduct in public courts relating to former employee proceedings on confidentiality grounds.

Viceroy continue to be contacted by physicians, former employees, former and current VA employees all speaking on a similar theme when explaining MiMedx conduct. We thank these brave individuals for fighting back against the unnecessary, aggressive, and retaliatory actions of MiMedx.

Viceroy were informed by various physicians that they had reported their concerns to the Office of Inspector General U.S. Department of Health & Human Services .

We are also led to believe that MiMedx’s statement of assisting the Department of Veterans Affairs with its on-going investigation is incomplete, if not deceptive, via omission. Viceroy believe investors should have been told of these investigations and what information was requested by VA investigators.

The more MiMedx management continue to lie to its investors through press releases and responses to short seller articles, the more disillusioned and harassed former employees send Viceroy evidence countering their claims.

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MiMedx Halloween Special – Viceroy evidence more PODs and channel stuffing of deceased doctors.

Part 14 – Halloween Special

Viceroy have discovered legal proceedings against MiMedx vendor RedMed for their alleged role in a kickback scheme and False Claims act violations. In addition to this Redmed’s principal Jeff Hannes is also involved with several other Physician Owned/related Distributors (PODs).

Viceroy will also highlight MiMedx sales to another POD whose physician is no longer alive and the LLC deregistered.

Viceroy will release details of further PODs shortly.

Happy Halloween.

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“The same thing happened at Matria”

Pete Petit would like us to examine his track record of running public companies. We find that Pete and his close-knit board & management has a tendency to run them into the ground.

Part 13 – The same thing happened at Matria
This report concerns MiMedx directors Parker “Pete” H Petit, Debbie Dean and Joseph “Joe” G Bleser and their previous positions at other Petit companies; Healthdyne Inc., Healthdyne Information Enterprises (HIE), Healthdyne Maternity Management (HMM) and Matria Healthcare.
The events detailed in this report resulted in a catastrophic collapse of Matria’s share price due to earnings downgrades and revision of future performance.

 

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MiMedx: Palmer-geddon

MiMedx employee Ricky Palmer worked as distributor for MiMedx customer, selling to the Department of Veterans Affairs and the Department of the Army.

This report concerns MiMedx employee Ricky Palmer and his position at a MiMedx distributor Southwest Medical Systems Inc while simultaneously being employed at MiMedx.

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Viceroy also addresses major discrepancies in MiMedx’s latest “commentary” piece. Specifically, MiMedx claim its “sales agents” do not “distribute” MiMedx supplies:

Short CommentaryThis statement directly contradicts FDA records suggesting many agents in MiMedx’s 2016 sales report both store and distribute inventory.

 

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MiMedx 2016 Ortho Sales Reports: Read ‘em & weep

Viceroy releases MiMedx sales records that directly contradict company statements. MiMedx, which department will Viceroy expose next?

Part 11 MiMedx Ortho Sales Report

MiMedx has increasingly come under pressure from both analysts and short sellers over the past month. The market is waking up to find MiMedx’s closet of skeletons quickly spilling open. Dubious hiring practices, physician owned distributors, employee owned distributors and poor corporate governance are all coming into focus. The spectre of action by the United States Department of Justice, Office of the inspector General of Veteran’s Affairs and the Securities and Exchanges Commission now hangs over the company.

Viceroy has obtained documents from former MiMedx employees detailing sales targets and historical figures broken down by distributor. The information directly contradicts statements made by MiMedx. Viceroy believes that MiMedx has systematically and deliberately misled investors and stakeholders and has forwarded this information to the relevant authorities.

 

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MiMedx: Up Schmidt Creek

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This report is concerned with the creation of Physician Owned/Related Distributors (henceforth PODs). The potential for fraud is well documented as evidenced by the release of the special fraud alert by the Office of the Inspector General of the Department of Health and Human Services:

https://oig.hhs.gov/fraud/docs/alertsandbulletins/2013/pod_special_fraud_alert.pdf

We previously highlighted the activities Donovan Schmidt, MiMedx Market Development Manager available here:

https://viceroyresearch.org/2017/10/03/mimedxs-selective-non-compete-litigation-questionable-disclosures/   

We now evidence MiMedx employee Donovan Schmidt’s active involvement in the premediated formation of a physician owned/related distributor (POD) with a prominent Atlanta physician.

“There is a MiMedx employee his name is Donovan Schmidt, he is an employee and also a distributor and also worked for Orthofix.” – Former MiMedx Employee

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More physician owned distributors – MiMedx may not wish to address its investors but it will have to answer the regulators

Viceroy is releasing more on illegal physician owned distributors (PODs) operating in the wound care space within the state of Texas. Our spreadsheet will follow shortly to expose multi state PODS and conflicts.

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Given the large proportion of income derived from Texas sales, investors should be concerned, especially as the numerous, undeniable, illegal PODs we illustrated on our report dated October 13, 2017 have not been addressed by management.

MiMedx’s blanket denial of Viceroy’s report and aversion to conducting an investigation suggest that management are either fully aware of these illegal distributors, or have been negligent in their duties…

MiMedx is not operating in an industry where these abuses are commonplace, and yet within the single state of Texas, we have connected MiMedx with:

  • Numerous illegal PODs;
  • Numerous related party distributors; and
  • Forest Park Medical Center, a $40m fraud uncovered by the DOJ and FBI.

Malfeasance by Physician Owned Distributors and kickbacks are an abuse of the healthcare system. The abuse not only costs patients and insurers, but ultimately undermines the integrity of physicians where products are prescribed to enrich suppliers (namely MiMedx) and enable Physician’s to obtain a kickback in reward.

This report further details connections between MiMedx and its network of physician owned distributors. This network of distributorships owned by employees and physicians allows MiMedx to engaged in large scale channel stuffing activities. The benefit to the physicians and employees comes at a cost to insurers and the medical facilities who ultimately pay the costs.

Lou Roselli made the headlines once more last week as an incriminating email surfaced where Lou admits MiMedx cannot reconcile inventory to federal customers. In the tissues business, this is strictly against the law.

Given the substantive evidence presented in our reports, we call on the board of MiMedx launch an immediate external investigation into the conduct of Senior Personnel, and subsequently resign.

The structure of these distributors leaves open great opportunities to exploit the US healthcare system. As a reminder to our readers, the Office of the Inspector General of the Department of Health and Human Services issued a special fraud warning stating that such ventures “should be closely scrutinized under the fraud and abuse laws.”

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Bankruptcy & DOJ/FBI indictments of Physician Owned Medical Center inconvenienced MiMedx CPM channel stuffing program

This report focuses on commercial relationships with currently indicted individuals for fraud with direct trading links with MiMedx and a Physician Owned Distributors in Texas with more to come.

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In this report, we detail exactly what MiMedx management withheld about its relationship with CPM Medical & unquestionably evidence physician owned distributors that have sold & are selling MiMedx products, with full references & FDA evidence. MiMedx’s channel stuffing distributor, CPM Medical, defaulted on its credit terms due to a DOJ/FBI crackdown on a key client, Forest Park Medical Center – a convicted $40M fraudulent kickback scheme.

Viceroy also present indisputable FDA evidence that MiMedx was specifically trading with physician’s spouses – via physician owned/related distributors registered to store MiMedx products ONLY.

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More whistleblowers come forward with details of MiMedx sales scheme

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Viceroy has previously published on MiMedx detailing its dubious hiring practices, connections to related party employee owned distributors, improper government filings and undisclosed SEC investigation. Since publication many former MiMedx employees that are not in legal conflict with MiMedx have reached out to Viceroy to provide information and corroboration of our investigations.

Information Viceroy has received from a further Whistleblower expands and gives details into the channel stuffing practices at MiMedx, including the structure of the employee and physician owned distributors and mechanisms of sales enticements.

 

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Ex-employees blow the lid on MiMedx sales scheme

Prior to Viceroy’s publications, we filed a significant data bundle of evidence to the SEC Whistleblower program. We always believe where appropriate in notifying regulators first. We under some may not wish to disclose or communicate with Viceroy, however can contact the SEC directly: https://www.sec.gov/whistleblower.

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Viceroy has previously published on MiMedx detailing its dubious hiring practices, connections to related party employee owned distributors, improper government filings and undisclosed SEC investigation.

Many former MiMedx employees that are not in legal conflict with MiMedx have reached out to Viceroy to provide information and corroboration of our investigations.

In this report, we detail:

  • Allegations corroborated by whistleblowers that MiMedx engage in a scheme with its distributors, in which larger and / or a number of small products are labeled as cheaper products. This scheme would draw attention away from MiMedx financial accounts as there are no ‘direct’ cash kickbacks to distributors, but distributors can unsuspiciously make large margins on marked up products.
  • Further apparent MiMedx related party entities controlled Donovan Schmidt, all of which appear to deal with medical products – we have a lot more to come on this.
  • MiMedx former subsidiary and current distributor Stability Biologics’ history as a with Osiris Therapeutics, a former NASDAQ listed competitor who is under investigation by the US Attorney’s Office for a criminal offence which, Viceroy believe this investigation is likely related to channel stuffing practices and revenue recognition.

Allegations as they stand are so substantial that Viceroy are now engaging in dialogue with the Department of Justice.

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How are MiMedx making their numbers?

“I don’t know how they’re hitting their numbers: that’s what’s blowing me away. What is going on? How are they supposedly hitting these numbers? I want to know.” – Former MiMedx Employee

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Viceroy continues piecing together further damning evidence of MiMedx’s dwindling relationship with the Department of Veteran Affairs.

As a recap, we have established flawed and dubious hiring practices for MiMedx, connections to related party employee owned distributors, improper government filings, photographic evidence of channel stuffing and an undisclosed SEC investigation.

MiMedx refuse to acknowledge the facts. In what appears to be a blatant disregard for the SEC rules and the need for 8-K filing, MiMedx recently filed an 8-K for relating to a “Amendment to Credit Agreement”, ignoring the elephant in the room: the SEC subpoena. According to MiMedx actions, an amendment to credit agreement” is significantly more important than the need to file an 8-K relating to an SEC subpoena. Viceroy believe that this is to avoid people tracking the issues of MiMedx and/or owning up to the seriousness of an on-going investigation.

This is in addition to MiMedx misleading its investors about the publication of an alleged independent report that was concealed from its own investors. As highlighted by Aurelius Value, MiMedx went one step further and prohibited its disclosure even when the SEC made enquiries. Investors would be prudent to check the SEC filings from April 18, 2017

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MiMedx’s selective non-compete litigation & questionable disclosures

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While Viceroy pieces together further damning evidence of MiMedx’s dwindling relationship with the Department of Veteran Affairs, investors should question the discretionary nature of MiMedx’s aggressive litigation. Namely against employees which have breached their non-compete with MiMedx. Viceroy has previously published on MiMedx detailing its dubious hiring practices, connections to related party employee owned distributors, improper government filings and undisclosed SEC investigation.

Many former MiMedx employees that are not in legal conflict with MiMedx have reached out to Viceroy to provide information and corroboration of our investigations. All whistleblowers are extremely fearful of physical and legal retribution from MiMedx. They have provided images, statements, corroborating phone data/records and further information about the company’s channel stuffing practices, executive impropriety and lack of disclosure.

Contrary to their statements, we believe MiMedx intentionally turns a blind eye to certain employees setting up their own distributorships especially where it is likely to benefit MiMedx revenue schemes. This has been confirmed by former employees who told Viceroy:

“…some people are allowed to break a rule [that] others are not. And there’s so much stuff that goes on behind the scenes with the executive team that no one knows who makes the rules…” – Former MiMedx Employee.

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MiMedx’s Channel-Stuffing: Hard Evidence

Viceroy has previously published on MiMedx detailing its dubious hiring practices, connections to related party employee owned distributors, improper government filings and undisclosed SEC investigation.

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Following publication of our first report, MiMedx held an investor conference call on September 21st where management knowingly made false statements to their investors and the general public. MiMedx published a rebuttal to Viceroy’s second report, which is posted to the front page of the MiMedx website, linked to a Box account, and not on company letterhead.

We believe this represents a misaligned focus between the organization’s strategy in crisis control and Pete Petit’s systematic attempts to clear his name and slander Viceroy’s investigations.

Many former MiMedx employees that are not in legal conflict with MiMedx have reached out to Viceroy to provide information and corroboration of our investigations. All whistleblowers are extremely fearful of physical and legal retribution from MiMedx. They have provided us with images, statements and further information about the company’s channel stuffing practices, executive impropriety and lack of disclosure.

 

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MiMedx (MDXG:NASDAQ) Part 2 – The same old story; Mimedx’s response is typical of companies trying to cover their tracks and is unacceptable.

MiMedx cherry-picked a handful of bulls for the September 21 call last week, restricting access for their own investors and others with an interest in the events that transpired on the week ending September 22, 2017. During the call, analysts asked pertinent questions that remain substantially unanswered. To assist investors, we’ve compiled a list of items that were conveniently ignored, avoided or even blatantly misrepresented.

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Over the last week, MiMedx has:

  • Dismissed “Deceptive Short Seller Reports”, including Viceroy’s, which presented evidence in the form of a withheld FOIA request suggesting that MiMedx was the subject of an undisclosed SEC enforcement investigation.
  • Announced that MiMedx are complying with an SEC subpoena, thus subject to an SEC investigation.
  • Failed to formally announce to the market that they are a subject of an SEC investigation. Viceroy requested management confirm whether it will fulfill their regulatory requirements by filing an 8-K in relation to an ongoing SEC investigation within the four days of becoming aware of it. If they have not filed an 8-K within 4 days of becoming aware of an SEC investigation, they are in breach of withholding material information from the investing public.
  • Been announced as the subject of an investigation by two securities litigation firms: Block & Leviton and Bragar Eagel & Squire, P.C. Both firms announced it had commenced investigations into a class action on behalf of MiMedx shareholders on September 22 and 25, 2017 respectively for not disclosing they were under SEC investigation, amongst other things.
  • Backdated government FAR & DFARS certification records as far as 2013 which were previously filled out by an employee, Don Ayers – who no longer worked at MiMedx at the time of certification – with Kimberley Durgan – who only commenced employment with MiMedx in 2014.
  • Backdated FAR & DFARs certifications remained signed with the authority of VP Brent Miller, whose LinkedIn status as of May 2017 is ‘Officially Retired’, and thus had no authority within MiMedx at the time of the amendments.
  • Announced it had come to a settlement of a confidential lawsuit with terminated employee Hal Purdy, a move we believe serves only to distract from the issues raised in our report which as yet go unacknowledged and undiscussed by the company. With ‘sealed’ documentation.
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MiMedx’s (NASDAQ:MDXG) employment of kickback & bribery scheme inducers makes it uninvestable.

Viceroy Research uncovered substantial previously-unreported data evidencing an incestuous hiring policy from a kickback & bribery scheme, a possible SEC enforcement investigation, and indications of channel stuffing.

  • Sean McCormack – MiMedx’s “New Market Initiatives Director” – was an instrumental figure in Advanced BioHealing’s kickback and bribery inducement scheme, which resulted in the largest settlement of a False Claims Act breach to date: $350m settlement, and a $600m+ write-down by Shire. At least 54 Advanced BioHealing alumnus have been identified by Viceroy within MiMedx’s sales force including at least 15 in senior employment positions.
  • A FOIA request was withheld by the Securities and Exchange Commission (SEC) suggesting MiMedx is the target of an undisclosed SEC enforcement investigation.
  • Former employees-turned whistleblowers accused MiMedx of aggressive channel-stuffing practices and improper revenue recognition policies. Their statement named many ex-Advanced BioHealing employees. Despite the fact these allegations having been withdrawn, Viceroy’s analysis found evidence supporting these claims in MiMedx’s financial accounts – there’s no smoke without fire.
  • MiMedx’s SAM compliance certification was filled out by Don Ayers, who was no longer employed by MiMedx at the time the forms were signed.

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Mitsubishi Tanabe is making a huge mistake: Why we believe that Neuroderm (NASDAQ:NDRM) is a lemon.

Neuroderm PDF Report Download

We believe that Mitsubishi Tanabe and its board need to immediately put a hold on the Neuroderm acquisition. We don’t know what representations have been made to Mitsubishi Tanabe by Neuroderm or others pushing this acquisition, but our research findings demonstrate the following:

  • Neuroderm has misrepresented the SIZE of the market, the RELEVANCE of their clinical study, and the EFFECTIVENESS of their ND0612 pump-delivered drug.
  • AbbVie’s Duopa/Duodopa pump is already ESTABLISHED in the market, has a SUBSTANTIALLY LOWER adverse effect rate, conducted its trials on an APPROPRIATE subject pool, and did not rely on SUPPLEMENTARY oral levodopa or entacapone, to boost its clinical trial results, unlike Neuroderm.
  • Neuroderm claims the size of ND0612’s target market across the USA and EU is ~350,000 patients. AbbVie’s superior pump has targeted the SAME market, only capturing ~3,500 patients.
  • The ND0612 drug is marketed towards ADVANCED stage Parkinson’s sufferers, however the efficacy study for the drug was conducted on EARLY stage Parkinson’s sufferers, which require substantially lower doses of the active drug component in order to be effective. We believe the FDA will closely review the stage 3 trials to ensure ND0612 is tested on an APPROPRIATE and RELEVANT subject pool.
  • Neuroderm’s ND0612 delivery pump is made up of GENERIC COMPONENTS and presents ZERO R&D proprietary value.
  • ND0612 is now only being tested for bioequivalence, not efficacy. While this may lead to a speedier FDA approved drug, Mitsubishi Tanabe is meant to be buying Neuroderm for its TECHNOLOGY. We see this concession as further evidence of Neuroderm’s weak R&D value, which Mitsubishi Tanabe thought it was buying with this acquisition.