Saturday, January 5, 2013

Ackman's Herbalife thesis: someone from the government will help poor people and billionaire hedge fund managers...


I was just on CNBC talking about Herbalife. Nervous as they come and was propped the wrong way by the sound guy (and hence never looked at Herb Greenberg who interviewed me).

But here is the quick summary.

I agreed with Bill Ackman that Herbalife is mostly about ripping off distributors and people at the end of the chain. The product is more than twice as expensive as competitor shakes. I called Herbalife "scumbags".

But they are highly cash flow positive scumbags and they will use the cash flow to buy back shares. Over the past five years the share count has gone from 140 million to 108 million and will fall further.

They are scumbags then - but they are scumbags working for stock market investors.

That I pointed out was similar to tobacco companies. Tobacco companies kill 5 million people globally per year - 400 thousand of them in the USA. Is anyone stupid enough to think the government would close them? That has been a bad short thesis for decades!

Bill Ackman is shorting a profitable company - and his argument is that they run an illegal pyramid scheme. By implication his argument that the government is going to somehow close them down.

That is a really truly awful short thesis - the short thesis that Government is going to come and help poor people and a billionaire hedge fund manager! Normally neither group is high on the agenda!

---

I said that I had reported many frauds to the SEC. Sometimes the SEC acted. Mostly it did not. When it acted it was often after the stock had gone to zero.

If my thesis was the government was going to help me then I got it wrong!

Bill Ackman has that one wrong!

---

I did not state other important parts of the argument.

(a). Being wrong on crowded shorts is very dangerous indeed. Herbalife is a crowded short - the short is however mostly one person - Bill Ackman - who has a massive position.

(b). The nutrition clubs have some merit. I once shared house with a lesbian Avon lady. She sold a couple of hundred thousand dollars worth of make-up a year. Her shtick was simple. She visited women stuck in outer-suburbia - the land of the 3 hours of daily commute. Their husbands were away from them for 11 hours a day and they were very stuck. She would play with them - putting makeup on them like 14 year old girls put makeup on each other. She would tell them they were beautiful and be supportive. This was multi-level marketing as decentralized support mechanism and it worked.

The nutrition clubs are like that. Fat men turn up and share a shake with other fat men and support each other to lose weight. It is sort of a Hispanic obese person's version of alcoholics anonymous. Mostly Hispanic anyway - as it started in the Hispanic community. Guys turn up and they say something like "My name is Jose and I am fat". It works.

The Manhattan version of support for weight loss is a highly priced gymnasium with a personal trainer to push you to remove the pounds. But it is blindingly arrogant to believe that that is the only valid sort of support group for weight loss.

---

I also did not say what I think Herbalife's strategy should be. They are going to offer a defence. I think it should be bland - simply a statement of profits and maybe the merit of the system.

Anything to allow Herbalife to buy back more stock. Herbalife has a lot of capacity to buy back stock as it is very cash flow positive. The more stock they buy back the better for remaining shareholders.

I might wind up a remaining shareholder. So I hope they buy a huge quantity of stock back - and the easiest way to do that is to do that when the stock is cheap - that is right now.

---

As per usual on this blog I could be wrong. The government might just decide to help a billionaire hedge fund manager out and save Bill Ackman from his oversized position.

That however is something I am willing to bet against.




John

47 comments:

Anonymous said...

excellent point. I liked the way you didn't look at Herb the whole interview.

Anonymous said...

Hilarious appearance and well done.

As for the "back turned away from Greenberg," honestly, I just thought you couldn't take your eyes of the anchorwoman.

Michael R said...

"Bill Ackman is shorting a profitable company - and his argument is that they run an illegal pyramid scheme. By implication his argument that the government is going to somehow close them down.

"That is a really truly awful short thesis - the short thesis that Government is going to come and help poor people and a billionaire hedge fund manager!"

So, basically, what you're saying is that the case against the Herbalife shorts is essentially the same as the case against the WaMu shorts?

Anonymous said...

I'd say billionaire hedge fund managers are pretty high on the government's agenda. Carried interest FTW.

Anonymous said...

I took away 2 pts from his thesis. The first, you covered and I agree completely with you...never rely on the gov for a catalyst. The second tho may have some merit, eventually: that they are running out of warm boddies (why they've had to expand into Ghana). The "pop and drop" has been masked by geographic expansion, but the clock is ticking. I'm with you tho, it's a race to see how much stock they can buy back in the interim, I'd rather be long than short right now.

Wexboy said...

John, great appearance!

I'll admit I initially thought you were entranced by yr fellow country-woman - the delightful Mandy:

http://www.investbabes.com/amanda-drury/

I entirely agree with your government comments - at the very least, government bodies move slowly - far too slowly for a crowded short. As regards 'saving' lower-income people, I tweeted:

'Obama saving low income people frm $HLF?! Shut it down & those v people wd think their dreams of riches were snatched away!'

Anonymous said...

No need to feel bad about it. At least it wasn't as contrived as that thing Morningstar hosted the previous day on CNBC.

Carl HT said...

I agree with your point about the government not wanting to help out a billionaire, albeit, isn't that why all his profits go to charity, so it takes the emphasis of Ackman/Pershing's pocket out of the equation?

The FTC just finished up on the Google antitrust case, perhaps that frees up a few employees?

Alex Campbell said...

A lot of the commentary on Herbalife has come down to: "Ackman's short thesis depends on the government stepping in and that seems unlikely"

But Herbalife operates in 85 countries around the world. They only need one regulator in one country to take an interest and get the ball rolling.

So maybe the FTC will sit on its laurels but regulators in Australia or Brazil or Singapore or the U.K. start an investigation.

That would add some real cred to Ackman's allegations. If Herbalife is found to be an illegal pyramid scheme in one country then surely other regulators would have to start wondering whether it is an illegal pyramid scheme in their jurisdiction.

A Belgium court has already ruled it to be an illegal pyramid scheme and that didn't seem to stir much interest elsewhere, but that was pre Ackman's grand announcement.

michael webster said...

This is probably the most interesting story since Minkow made shorting the MLM's a blood sport.

Bill isn't appealing to the FTC, his point is directed at the MLM distributors.

They flee, he wins.

Simon Forrest aka sinoforestanalyst said...

There appears to be a much safer way to benefit from the outcome of this "hedge fund porn" movie, rather than betting either way on HLF...

Anonymous said...

why would the FTC acting against hlf be so improbable? They meet their definition of pyramid scheme definitively. You point to tobacco as an apples to apples comparison but the fact is is that tobacco is not illegal and there have been substantial fines against the industry numerous times.

The herbalife issue is coming to the forefront now because even if the ftc doesn't get involved, the pyramid will implode on itself Just look at the last 15 countries herbalife has entered. Lebanon had the highest GDP per capita at $10,000. They have also entered aruba which doesn't even have a GDP per capita measurement. They also entered Ghana which doesn.t even have food...

I firmly believe that this company will be broken up sooner than later.

And the fact that they have cash flow is exactly the reason they'll break up. They are extracting cash flow from the poor and those who bought into their false hope; It's so sad. The fact is is that 88% of the commission profits go to 1% of the distributors. If they don't continuously replace the churn at the bottom levels of the pyramid, they are toast.

You are wrong about HLF and Ackman is correct in my opinion.

David Tan said...

John, loved your 2 min on CNBC. You were checking out your fellow Aussie!
1) You're making up the story on Jose's weight-loss support group, right? My friend owns a nutrition club that is located in the lobby of an office building in the financial center of Kuala Lumpur. Mostly ladies come in before work, on their "coffee" breaks, & at lunch. They either have a Herbalife shake in the shop, or bring their shakes back to their office. My friend will also weight them & measure them every week or so, to track their weight loss. You are absolutely right that the support is part of the appeal of MLM marketing. Herbalife gets results, and people are consuming the product. Ackman is wrong.
2) "Anonymous" is only repeating what was on Ackman's slide about Ghana. McDonalds & Coca-Cola are in Ghana. You could argue that if people in Ghana spend their limited money on Herbalife protein shakes instead of McD's & Coke, they would be healthier. Ackman's logic is flawed again.

shakti said...

Ackman & team are aware of HLF's buyback programme since they refer to it during the Sohn conference. Seems unlikely that they'd overlook the potential for the management team to see off short-sellers by aggressively buying back shares ?

I think we have yet to see all the cards in this particular game.

Triple M blog- Motorsports, Menswear, and Money said...

This reminds me of the quote, "The market can remain irrational longer than you can remain solvent." Both sides of this trade have rational arguments. $HLF will eventually run out of suckers to sell their product to, and then run out of cash to support the stock. Question is will they pump and dump before that? And will Ackman stay short all the while?

cig said...

Will the longs have staying power? It's one thing to make a quick buck by being long between $30 and $50, but that only takes us back to Ackman's entry point. He's only screwed if it goes way up from there and lasts and his short is not broken by technicalities. Would you stay long at $100 for several years?

As for fat people supporting each other, there are surely other players on this market where you don't have to ruin yourself in the process. The bulk of Herbalife distributors don't make it and probably start eating too much again as soon as they realise all their meagre savings are gone.

Anonymous said...

Good points, but I disagree that Ackman's thesis is solely that the FTC is compelled to get intervene. A number of scenarios could significantly cripple this company as a result of this exposure:

1) Significant class-action litigation among the literally MILLIONS of failed distributors who were misrepresented to. Any settlement and/or judgement would likely result in a huge one-time charge but more importantly material changes to the recruiting model.

2) A combination of a declining natural recruiting population (others have touched on) with more exposure of this company's practices could crimp growth. Even you acknowledge that this is a pyramid scheme. If downlines can't recruit in significant numbers then they will stop "paying-to-play", setting off a chain reaction of cancelled annual purchases. (In my opinion this is actually Ackman's thesis).

3) In a more prolonged scenario, Herbalife will be forced to cut their prices to distributors as dumping by the upline sales channel is undercutting their downline markets. Indeed, why would a consumptive-distributor even bother signing up with the company when the can source the product cheaper online

4) In light of the above, no instituational holder in their right mind can be truely long this stock. I expect significant selling into strength for the next several months.

You make a good trading case for this stock, but parallels to the tobbacco industry are wrong. End-consumers actually buy the cigarettes and as a result sales numbers for this industry are credible. Herbalife, no so much.

Finally, a stock buyback may be the worst thing a true long can hope for. While this would no doubt support the stock over the short term, it would continue to affect the balance sheet (already 500 million owed to shrink share count as you mention). Servicing this debt would then affect free cash flow, which I believe will already be under assult for all the reasons I postulate above.

Good luck on your trade.

Anonymous said...

In other words: while they might be scumbags, they are _your_ scumbags? I thought you didn't like that thesis so much with Chinese property developers, why is it different here?

BusSchDean said...

Ackman has three constituents for his presentation:

1) Government - FTC/SEC/state prosecutors, who have been mostly very poor watchdogs regarding this industry, actually pussy cats. I know because I have worked with them on these cases.

2) Current Distributors - Many leave each year and this may accelerate the exodus.

3) Former Distributors - of which there are many thousands. They are a docile group, believing that their failure to make the top 2-5% is on them, when in fact failure is systemic.

Xofruitcake said...

"Will the longs have staying power? It's one thing to make a quick buck by being long between $30 and $50, but that only takes us back to Ackman's entry point. He's only screwed if it goes way up from there and lasts and his short is not broken by technicalities. Would you stay long at $100 for several years?"

I think a more interesting question is whether short has staying power. HLF distribute about 102m dividend in 9 months. So Ackman's 10% short mean about 13m a year in dividend along. And then there is the negative rebate for getting the borrow. It will keep hitting the short's pocket.

-----------------------
Finally, a stock buyback may be the worst thing a true long can hope for. While this would no doubt support the stock over the short term, it would continue to affect the balance sheet (already 500 million owed to shrink share count as you mention). Servicing this debt would then affect free cash flow, which I believe will already be under assult for all the reasons I postulate above.

The 500m term loan will mature in Mar 9, 2016 with a libro+1.5% to Libro+2.5% or base rate + 0.5% to 1.5%. Interest expense were 5m in 3Q12. The 9 months cash flow - cap ex is about 340m.. I am not sure why there is any problem in servicing the next 500m loan if managemnt choose to go that route.

Anonymous said...

A lot of people thought WRLD (a very unethical payday lender) would get killed by new regulations. Yet the stock just keeps going higher and higher.

Kid Ing said...

John,

With all due respect, as you are a wise investor, I think you misunderstand the play and incorrectly assume that historical results will guarantee future results.

His play is not to provoke FTC or SEC action. Although that is good for the short as it will create distractions for management and feed into his negative feedback loop.

His play is to bring the whole ponzi scheme to light. He's attempting to disrupt the business from the inside. He'll cause chaos in the current sales channel when sales people realize that they're getting screwed and being sold lies. He'll cause chaos in the current customer base (who are mostly comprised of sales people anyway) by making them question whether they're getting a good deal. He'll destroy the brand value and make the product into a joke for future customers and salespeople (again, the customers). He's purposely disintegrating the very thing -- dreams -- that has made this company a success.

That's why he unveiled this short so publicly. That's why he created a free and quite beautiful website. He's going to use the media. And he's not going to let the story go away. Both he and the media know that it's good news business to tap into the righteous indignation the public feels over ponzi schemes.

You can't stop the laws of gravity. The short will cause chaos within the organization. I don't think it shows next quarter. But perhaps the following, slowly, the results will show decline. And then the shares will collapse.

And "Anonymous" on January 6, 2013 1:28 AM's said very well, Herbalife is not tobacco, no one is addicted, they're just unwitting members of a ponzi scheme.

All that being said, you've probably made 40% by speculating on the spread between people's initial reaction (immediate collapse) and reality (no impact on next quarter's results). Great work, no question.

But if I decide to sell you shares by shorting on Monday, just know that my time horizon isn't one quarter, it's two years.

Kid

Investor said...

The below is a good point. However Ackman has to do much more than putting a google ad to educate potential distributors. Also, FTC action is limited to US. Also, for recruiting to stop, Ackman has to send his team to each country to educate those potential recruits about their odds of failure. The domino effect in other countries is not plausible ...it may take years and even decades for that happen.

IMO going short on this is dangerous. Going long is less risky..but still you could lose




"2) A combination of a declining natural recruiting population (others have touched on) with more exposure of this company's practices could crimp growth. Even you acknowledge that this is a pyramid scheme. If downlines can't recruit in significant numbers then they will stop "paying-to-play", setting off a chain reaction of cancelled annual purchases. (In my opinion this is actually Ackman's thesis).

Anonymous said...

I work in an MLM company on another continent and I have three comments
1) it is just a deep misconception to think that all the millions of distributors in MLM "is in for the dream". (I can understand that a spectator takes such a view though). 90-95% are happy consumers, like any FMCG. And perhaps 10% tries every year to go for bigger sales volumes and most fail, like entrepreneurs fail daily in any industry.
1) HLF has pumped and dumped some markets but have recovered and overcome previous sales peaks. Not all markets have developed like Japan. Fact is, as a competitor, HLF is very sucessful at the moment gaining momentum after some slow years and creates challenges for us.
2) the whole idea that some PR attack in the US is going to affect the recruiting and unravel the whole business is incredibly naive. 99% of future distributors In the US will never have heard of this debacle. Among the current ones, they are all aware of what they are doing, they are not duped into something. If anything, they probably hate wall street and the rich elite even more after this and become more loyal to HLF

Anonymous said...

I'd bet Greenberg was a HLF short. He seemed like he was wrapped tighter than a snare drum. Then again it doesn't make much sense to short a profitable company whos stock just went from $25 to $37.
How high can this stock go?

Mary Kaplan said...

I've always wondered about Herbalife. I remember that huge building they had on the 405 in LA. Is that still the Herbalife building? Totally agree that Government takes forever to do anything. Doubt it will be involved with Herbalife anytime soon.

Robert Elias said...

Could you please give us more info on the lesbian Avon lady...... Please

Woland said...

Is it not possible that one of hlf's deep pocketed
competitors in the product category might choose to adopt the same MLM strategy in expanding their own
distribution? They certainly have an opportunity to
expand their own profits by doing so, even while
offering a less skewed commission distribution to
their reps. (this strategy would be called competition)

Investor said...

The big question is these final distributors (who become distributors just to get discount - i guess the company considers them as retail - Ackman these people are also buying because of bus opportunity)- will they buy the Herbalife product if

1. They understand their super-slim chances of making money in this business


2. Without the business opportunity, will they pay 2 times the money for Herbalife than its nearest competition product .

My biggest question about Ackman's thesis: How he plans to educate and dissuade people from getting into Herbalife bus opportunity. Just google ad won't do. Nor would a 350 page presentation. Keep in mind 80% of HLF is Non-USA. This is where I am not convinced.

marius said...

I know several people in MLM programs (including Avon, but not Herbalife). The one thing they all have in common is that they are True Believers. No amount of reasoning or evidence can dissuade them from the righteousness of their scheme. I don't anticipate HLF distributors leaving in droves, and can see the managers placating their downlines by dismissing the Ackman as an evil short-seller (amazing that our society considers keeping crooks on their toes to be "evil"), and that Wall Street just "doesn't get HLF". And of course don't forget the old class war argument that Ackman and his ilk want to keep Jose down.

Looking at Jan 2014 option prices, you can get a $25 put for $4.20, and a $50 call for $3.25 . The prices for Jan 2015 are $7/$4. Could be a play there, regardless of the outcome as the stock is worth either $0 or $70.

"Cassandra" said...

Slightly off topic but with has anyone noticed that Yakult (QCode=2267) seems ripe trading north of 40x FY1 EPS with sub 3% sales growth and sub 7% LT forecast EPS growth on the back of MLM-like touted growth derived from the proliferation of "Yakult Ladies" across China. Short interest has always been high in this name, and short-joy has been slim as they keep getting puked whether due to Danone fantasies, or Yakult-lady dreams. Nonetheless, it should be not be ignored in the same sentence as HLF or AVP.

-C

cig said...

if you think of it the short term longs are reinforcing Ackman's case: the ideal price path for him is that the price stays flat at his entry point, so as to make buybacks more expensive and less effective, until they run out of money/punters, and then it can fall to zero.

Mike said...

Some ignorant comments on what is usually a smart comment blog.

Michael R:
"So, basically, what you're saying is that the case against the Herbalife shorts is essentially the same as the case against the WaMu shorts?"

WAMU was insolvent and went out of business/got taken over. What possible connection does this have to a profitable firm?! Serious question - I'd love to know what connection you think exists?

cig:

"He's only screwed if it goes way up from there and lasts and his short is not broken by technicalities"

I don't think you know how being short works. It aint free. Being short costs money - you can't just sit there merrily short until you get bored. You can be very right on a short thesis and lose because your timing is off.

The anonymous comment is very right that the target market for this money making scheme could not care less about Ackman and are very likely to believe in it more even if they did know. It is a well proven psychological fact that humans tend to STRENGTHEN their beliefs when proved wrong.

Personally I think this is a bad place for money short or long. At least Ackman has the $$$ to cause some pain. If the author is looking for some "pop" profit he should take it and go play somewhere safer.

Anonymous said...

Herbalife should announce a special one time dividend just like Texas Roadhouse TXRH did.

Short investors must pay the true owner of the stock (The person they borrowed the stock from)for any dividends that the stock pays out.

This would be a way to punish the short positions by making them come up with cash to cover the dividend.

Anonymous said...

I think it's naive to think that the millions of HLF distributors will one day wake up and say "we've been had!". In fact, history shows that the people who had been had the most, are the ones who come back the most - see various religious end-of-days-sell-all-you-have cults. MLMs are very good at setting up emotional investment (in fact, it's one of their main drivers and I'd say their real business plan, whether they know it or not).

So it's betting against human nature, and that tends to work only if someone else saves the day - which in this case almost certainly means regulator (govt).

cig said...

@Mike, I am assuming he's not shorting with his retail brokerage account in the usual conditions you and I would get, but that he has made a long term deal with someone to get fixed or otherwise predictable costs to cope with the odd short squeeze, and thus not be exposed to short term borrow cost volatility. I mean he's not an idiot who doesn't know about the mechanics of shorting...

Anonymous said...

Simple question, but one that bears asking:

If you were a Madoff investor in 2005 and somebody gave you a detailed breakdown of the scheme before it went nuclear, would you stay long based on the track-record of your previous gains?

No Mean Sum said...

I find it interesting that in some sense your appearance on CNBC and other media is helping Ackman by drawing more attention to the firm.

Of course you also aid the long side by pitching your thesis. But i have to wonder whether it there is any net benefit to being public about your position in the matter.

Respectfully,

No Mean Sum

George Bailey said...

There is, in fact, little new in Mr. Ackman's published analysis of 'Herbalife.'

What is new, is that persons, such as the author of this Blog, have suddenly begun commenting on 'Herbalife,' because Bill Ackman has bet US$1.2 billions that 'Herbalife' is a fraud.

http://mlmtheamericandreammadenightmare.blogspot.fr/2012/12/the-bosses-of-herbalife-have.html

http://mlmtheamericandreammadenightmare.blogspot.fr/2013/01/how-does-herbalifemlm-bluff-function.html

http://mlmtheamericandreammadenightmare.blogspot.fr/2013/01/herbalife-has-exhibited-universal.html

http://mlmtheamericandreammadenightmare.blogspot.fr/2012/08/effectively-valueless-nu-skin-shares.html

Anonymous said...

Much more familiar indeed ponzi schemes
he was wrong about Merkin and he is wrong about hlf At a panel meeting discussing Bernie Madoff in January 2009, Ackman defended his long time friend J. Ezra Merkin stating, "Has Ezra committed a crime? I don’t think so,” "I think [Merkin] is an honest person, an intelligent person, an interesting person, a smart investor."[12][13][14] On April 6, 2009, Merkin was charged with civil fraud by the State of New York, for "secretly steering $2.4 billion in client money into Bernard Madoff's Ponzi fraud without their permission."[15] A settlement was reached on June 2012 requiring Merkin to pay $405 million to victims including the Metropolitan Council on Jewish Poverty.[16]

Unknown said...

Tobacco analogy is incorrect. Government HAS forced Tobacco to tell the truth about it's product, and consumers must decide. Herbalife is misleading it's customers. Assuming it is not shut down, it will still take a hit if it can't mislead anymore. There is also a big difference between buying an addictive product for a few bucks a pack and investing your life savings in a bogus business deal. Teens get hooked on a lifelong addiction to tobacco because they think it's cool. There is no "cool" in Herbalife.

Michelle said...

Couldn't agree more. I've said similar things about Herbalife for years, yet there are still so many gullible consumers that buy their products thinking they are 'high quality'.

Scumbags indeed, as is anyone who knowingly rips off a consumer.

Anonymous said...

Never ever take a hedge fund managers word at face value, they will never disclose their true intentions as it is self defeating... if they are talking the stock down i would likely believe they are purchasing and shaking out weak hands and jawboning the market..... nothing in the market is as it seems!

Mike said...

cig said...
@Mike, I am assuming he's not shorting with his retail brokerage account in the usual conditions you and I would get, but that he has made a long term deal with someone to get fixed or otherwise predictable costs to cope with the odd short squeeze, and thus not be exposed to short term borrow cost volatility. I mean he's not an idiot who doesn't know about the mechanics of shorting..."

Nice try Cig! Your original comment clearly implied a cost free short position.
A stock with a multi-billion dollar market cap going up over 150% is not something you think would be covered in a "fixed or otherwise predictable costs" deal?!
Idiot indeed...

Anonymous said...

I am one of the world authorities on Network Marketing and I want to help you guys understand this situation.

The fact is that I know, the whole Direct Sales industry knows, that Ackman is partially right. He has highlighted something the regulators don't have the balls or brains to attack.

Herbalife recruits on the pitch that 'anyone' can succeed in this business.' You can get rich, with rich being a major six-figure income.

The truth is that less than 0.1% of Herbalife's people make enough profit to justify the investment of time and money.

If Ackman JUST focused on this, Herbalife would not know where to turn and the regulators would hammer them AND the rest of the industry, just as they did with the franchising industry in the 1970s.

It would cripple Herbalife's profit and take the shares down last $20. Maybe $10.

People would then be shorting Nu-Skin, USANA, Mannatech, etc.

There is billions to be made shorting these companies.


Ackman's pitch is very credible and he has a $1billion behind it. His problems

Jess Toons said...

Thanks for sharing this article, its been really interesting reading about it. I'm doing this research project on herbalife Denver co and I am really excited about what I've been learning and to see what else I can learn about it. Thanks for sharing!

Stephanie said...

http://au.businessinsider.com/new-york-times-ad-bashes-ackman-2013-1

A man from Cincinnati took out an ad in the New York Times telling hedge fund titan Bill Ackman to “get a life.”


https://pbs.twimg.com/media/BBZlGjICMAEPWhU.jpg

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The content contained in this blog represents the opinions of Mr. Hempton. Mr. Hempton may hold either long or short positions in securities of various companies discussed in the blog based upon Mr. Hempton's recommendations. The commentary in this blog in no way constitutes a solicitation of business or investment advice. In fact, it should not be relied upon in making investment decisions, ever. It is intended solely for the entertainment of the reader, and the author.  In particular this blog is not directed for investment purposes at US Persons.