Full text
Exhibit 7
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THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
IN RE ALIBABA GROUP
HOLDING LIMITED
SECURITIES LITIGATION
Civil Action No. 1:15-md-02631 (CM)
EXPERT REPORT OF DAVID I. TABAK, PH.D.
I.
SCOPE OF ANALYSIS AND SUMMARY OF FINDINGS
1. This report concerns Plaintiffs’ motion to certify a proposed class defined as “All
persons and/or entities that purchased or otherwise acquired Alibaba Group Holding
Limited American Depositary Shares (‘ADS’), or purchased call options or sold put
options on Alibaba ADS, during the period September 19, 2014, through January 28,
2015, inclusive (the ‘Class Period’), other than those shares purchased directly in the
September 19, 2014 Initial Public Offering. Excluded from the Class are: (a) persons
who suffered no compensable losses; and (b) Defendants; the present and former officers
and directors of Alibaba at all relevant times; members of their immediate families and
their legal representatives, heirs, successors, or assigns; and any entity in which any of
the Defendants, or any person excluded under this subsection (b), has or had a controlling
interest at any time.”1
1 Quote provided by counsel. In ¶1 of the Consolidated Complaint (“Complaint”), the
proposed class period was defined to include January 29, 2015. Because the disclosure
on January 29, 2015 occurred before the market open, that date is not properly in the
class period, and therefore is not included in my analysis of market efficiency.
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2. Counsel for plaintiffs in this matter has asked me to examine whether Alibaba’s
ADSs and options traded in efficient markets during the Class. I have also been asked to
determine whether there are methodologies that can be used to determine the damages for
ADS purchasers, for purchasers of call options, and for sellers of put options.
3. As discussed below, the markets for Alibaba’s ADSs showed overwhelming
evidence of efficiency in the aftermarket (i.e., all trades following the company’s initial
public offering (“IPO”) on September 19, 2014). In contrast, there is insufficient support
for a finding that the offering price (i.e., the price of $68 per share at which shares were
purchased in the IPO from the company via its underwriters) can be described as having
been set in an efficient market. Based on the efficiency of the price for Alibaba shares in
the aftermarket and on an examination of the relationship between Alibaba call and put
prices to that price, the markets for Alibaba calls and puts were also efficient.
4. Damages for purchasers of Alibaba’s ADSs in the aftermarket, for purchasers of
Alibaba call options, and for sellers of Alibaba put options can be determined through
common methodologies.
II.
QUALIFICATIONS AND REMUNERATION
5. I received Bachelor’s degrees in Physics and in Economics from the
Massachusetts Institute of Technology and a Master’s degree and a Ph.D. in Economics
from Harvard University. I have appeared as an expert in federal district courts; state
trial courts; bankruptcy court; and in arbitration forums, including the National
Association of Securities Dealers, the International Chamber of Commerce International
Court of Arbitration, and the American Arbitration Association. I have published in my
fields of expertise on subjects such as market efficiency, loss causation, statistics, and the
analysis of stock price movements.
6. National Economic Research Associates (“NERA”) was established in 1961 and
now employs approximately 500 people in over twenty offices worldwide. NERA
provides consulting for economic matters to parties for their internal use, to parties in
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litigation, and to governmental and regulatory authorities. I have worked at NERA for
over twenty years and am a managing director in NERA’s securities and finance practice.
My work entails providing analyses for parties in litigation and consulting for parties in
non-litigation settings. I have served as a speaker at events providing CLE credits for
attorneys and at academic conferences on areas related to securities litigation. I have
provided reports and/or testimony for plaintiffs and defendants in numerous securities
class actions.
7. My curriculum vitae, which sets forth in further detail my publications and prior
testimony experience, is attached to this report as Exhibit 1.
8. NERA is being compensated on a non-contingent basis for out-of-pocket costs
and at our usual rates for time. My billing rate is $900 per hour. I have been assisted by
a number of individuals at NERA working at my direction who are billing at their
standard rates.
III. MATERIALS CONSIDERED
9. Materials considered for the purposes of this report are listed in Exhibit 2.
IV. THE THEORY OF MARKET EFFICIENCY
10. In the 1960s, economists Paul Samuelson and Eugene Fama each developed
theories that developed into the modern theory of market efficiency, known as the
“Efficient Market Hypothesis.”2 Professors Samuelson and Fama recognized that if
market participants are rational, a security cannot have an expected change in price.3 For
2 See, for example, the New Palgrave Dictionary of Economics, 2008 edition, entry on
Efficient Markets Hypothesis, available online at
https://rd.springer.com/referenceworkentry/10.1057/978-1-349-95121-5_42-2.
3 While later refinements of the theory examined whether certain types of stock price
movements are possible because of factors such as the risk entailed in trying to profit
(continued)
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example, suppose that the market expected a stock price to be $15 tomorrow. The stock
could not trade at $10 today, because there would be little reason for anyone to sell at $10
today given that there would be buyers more than happy to pay $11 today for a stock that
they could sell at $15 tomorrow. This process would result in an equilibrium where the
price today would be bid up to nearly $15. Similarly, no rational investor would
purchase a stock at $16 today if it was believed that the price would be $15 tomorrow.
Thus, the stock price today would be nearly equal to the price tomorrow, and any changes
in stock prices would be due to unexpected information or randomness, leading to the
theory that stock prices follow a “random walk.” In other words, one cannot predict
future price changes based on historical prices or trading patterns.
11. In particular, there are three forms of the Efficient Market Hypothesis, known as
weak-form efficiency, semi-strong-form efficiency, and strong-form efficiency. Weak-
form efficiency posits that the price of a stock rapidly incorporates all information
contained in prior stock prices. Semi-strong-form efficiency posits that the price of a
stock rapidly incorporates all publicly available information. Strong-form efficiency
posits that the price of a stock rapidly incorporates all public and private information.4
When discussing the Efficient Market Hypothesis with regard to publicly traded
securities such as Alibaba’s, financial economists are generally referring to the semi-
strong form of market efficiency. I will follow the same convention here.
12. One of the implications of the Efficient Market Hypothesis is that the market
begins to incorporate unexpected news quickly into security prices. Therefore, if the
market learns of material new, unexpected positive (negative) information about an
issuer, then the price of the issuer’s common stock (or ADSs) will rise (fall) if the market
from those expected movements, the general outlines of the theory discussed above are
still correct. Throughout the discussion, I abstract away from any such issues.
4 This is a standard taxonomy of Efficient Market Hypothesis theories, discussed, for
example in Eugene Fama, “Efficient Capital Markets: A Review of Theory and Empirical
Work,” Journal of Finance, 1970. (See, for example, p. 388.)
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is efficient. Of course, markets may take time to fully absorb new material information,
but they should not fail to begin the process of reacting to news as soon as it is available.5
13. To determine whether a market is efficient, financial economists and the courts
have developed various tests. These tests can broadly be divided into direct tests of
whether a market violates the conditions of market efficiency (e.g., whether the price of a
security actually responds to material new unexpected information) and indirect tests of
the conditions that one expects would be present in an efficient market (e.g., substantial
analyst coverage, which suggests that market participants are interested in understanding
and responding to news). In the following two sections, I discuss the results of these tests
for Alibaba’s ADSs.
V.
TESTS OF MARKET EFFICIENCY FOR ALIBABA’S ADSS
14. One seminal legal case providing for tests of market efficiency is Cammer v.
Bloom.6 This decision discussed five tests of market efficiency that are commonly
referred to as the “Cammer factors”:
(1) an “average weekly trading of two percent or more of the outstanding
shares would justify a strong presumption that the market for the
security is an efficient one; one percent would justify a substantial
presumption”;
(2) “a significant number of securities analysts followed and reported on a
company's stock during the class period”;
(3) the “stock had numerous market makers. The existence of market
makers and arbitrageurs” would aid in market efficiency;
(4) “the Company was entitled to file an S-3 Registration Statement in
connection with public offerings”; and
5 Under the Efficient Market Hypothesis, a market may initially underestimate or
overestimate the effects of news, as long as the price movements reflect, on average, an
unbiased estimate of the effects of the new information.
6 Cammer v. Bloom, 711 F. Supp. 1264, 1286-87 (D.N.J. 1989).
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(5) “empirical facts showing a cause and effect relationship between
unexpected corporate events or financial releases and an immediate
response in the stock price.”7
15. In addition to these tests, the Third Circuit in DVI Securities Litigation stated that
(6) “the listing of a security on a major exchange such as the NYSE or the NASDAQ
weighs in favor of a finding of market efficiency.”8 Furthermore, three additional factors
that may be relevant, as discussed in Krogman v. Sterritt and other cases are: (7) market
capitalization, (8) bid-ask spread, and (9) float.9
16. Academics and courts have also looked at whether there was autocorrelation (also
known as serial correlation) in the returns of a security, i.e., whether rather than behaving
randomly, a movement in the price of a security was more likely to be followed by
another movement in the same direction (positive autocorrelation) or by a movement in
the opposite direction (negative autocorrelation).10
17. I will discuss each of these tests in more detail as they are presented below, and
then present my conclusions based on the totality of the information obtained by
examining each of these factors. I understand that recently the Second Circuit endorsed a
“holistic” view of the “direct” (Cammer Factor 5, above) and “indirect” (all other factors)
tests of market efficiency.11 Where I deem it relevant or helpful, I divide up the
discussion of a factor into an analysis of the aftermarket (i.e., all trades after the IPO) and
of the IPO price.
7 This factor is typically addressed through the use of a statistical analysis known as an
“event study,” as discussed below.
8 In re DVI Securities Litigation, 639 F.3d 623,634 (3d Cir. 2011) (“DVI II”).
9 Krogman, Inc. v. Sterritt, 202 F.R.D. 467, 478 (N.D. Tex. 2001).
10 See, e.g., In re DVI, Inc. Securities Litigation, 249 F.R.D. 196, 213 (E.D.Pa. 2008)
(“DVI I”). Autocorrelation can also be measured based on the size of the price
movements and not just their direction.
11 In re Petrobras Securities Litigation, 862 F.3d 250 (2d Cir. July 7, 2017).
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(1) Trading Volume
a. Aftermarket
18. The first Cammer factor is the average weekly trading volume as a percent of
shares (or, in this case, ADSs) outstanding. As noted on page 1286 of that decision,
“[t]he reason the existence of an actively traded market, as evidenced by a large weekly
volume of trades, suggests there is an efficient market is because it implies significant
investor interest in the company.” Exhibit 3 shows the weekly volume of trading in
Alibaba’s ADSs as reported by Bloomberg, L.P., a recognized data vendor, and the last
reported number of shares (which have been or could be converted into ADSs)
outstanding for each week. The volume figures are adjusted to remove trades created by
estimated market-maker participation.12 I next calculate the mean and median percentage
of ADSs outstanding traded in each week during the Class Period. The mean is simply
the arithmetic average of the weekly percentages of trading volume for each full week in
the Class Period.13 The median is the midpoint of the weeks if arranged by the
percentage of shares traded relative to shares outstanding, so that half of the weeks have
the same or a larger percentage and half have the same or a smaller percentage.
19. Over the Class Period following the IPO, the average market-maker-adjusted
weekly trading volume is 4.29% percent of shares outstanding (or over 100 million ADS
per week on average), and the median figure is 3.61% percent.14 In just the first day of
12 A market maker sometimes serves as the counterparty to investor orders. For example,
one investor may sell shares to the market maker at $20 and later the market maker sells
those shares to another investor at $21. Both trades would be reported, but there really
was only one transfer of shares between actual investors. Support for this type of
adjustment is found in Unger v. Amedisys Inc., 401 F.3d 316, 324 (5th Cir. 2005).
13 Including any partial week at the beginning or end of the Class Period would have
minimal effects on the results.
14 The average weekly trading volume also exceeded 38% of the float while the median
trading volume exceeded 32% of the float. Shares outstanding exceed ADSs outstanding
and the float because ADSs were not issued for shares that were held by pre-IPO holders
if those holders did not move to sell those shares.
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trading alone, 272 million ADS traded (before the market-maker adjustment), or more
than 11% percent of the shares outstanding following the IPO. As previously noted, the
Cammer court stated that an “average weekly trading of two percent or more of the
outstanding shares would justify a strong presumption that the market for the security is
an efficient one; one percent would justify a substantial presumption…” Thus, the
volume figures for Alibaba support a “strong presumption” in favor of market efficiency
for the ADSs under Cammer.
b. IPO
20. While shares are purchased in the IPO, the price for those purchases is not set by
finding a “market-clearing” price, or one where supply equals demand. Therefore, the
number of shares purchased in the IPO does not provide any indication of the level of
market efficiency.
(2) Analyst Coverage
21. In discussing the relevance of analyst coverage, the Cammer court stated on page
1286 that “[t]he existence of such analysts would imply, for example, the [auditor]
reports [on the issuer] were closely reviewed by investment professionals, who would in
turn make buy/sell recommendations to client investors.” (Closing footnote omitted.)
That is, analysts seek out, review, and disseminate information about a company and
make it easier for market participants to understand and react, or choose not to react, to
that information, thus facilitating the process that leads to market efficiency.
22. While analysts provide coverage that is meant to inform investors about a
company, different analysts provide varying levels of coverage that may have differential
impacts in determining whether that coverage should be considered to be a material
factor in aiding market efficiency. For example, some analysts may provide limited
analysis or merely repeat what a company has said while others may provide informative
analyses of a company’s current and future expected revenues.
23. There are many ways to focus an examination on analysts that are providing at
least some meaningful coverage. One such way is to identify the number of analysts
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included in the Institutional Brokers’ Estimate System (“I/B/E/S”) consensus earnings
estimate for a given company. Exhibit 4a shows the number of analysts included in the
I/B/E/S earnings estimate for the upcoming quarter for Alibaba on a monthly basis from
September 2014 through January 2015.15 As can be seen in the exhibit, there were two
analysts covering Alibaba even before the IPO. That figure rose to 11 in October 2014,
and then to a minimum of 26 in the remainder of the Class Period.
24. The Cammer court found efficiency where the security at issue (the common
stock of Coated Sales, Inc.) was the subject of “[a]t least 15 research reports … from July
1987 through June 1988,” (p. 1283) a 12-month period. Here, by contrast, there were at
least that number during each month in the Class Period. (See Exhibit 4b, listing analyst
reports available form one data vendor.)16 There were seven analyst reports on Alibaba
in September 2014 before the September 19 IPO date as well as one on September 19
before trading began,17 comparing favorably with the 15 reports in the full year of the
Cammer class period. Furthermore, there were over 140 analyst reports on Alibaba over
the Class Period.
25. In addition, before the IPO, Yahoo had a substantial investment in Alibaba, so
much so that there were estimates that the bulk of Yahoo’s value came from its stake in
Alibaba.18 As a result, analysts following Yahoo before the Alibaba IPO frequently
analyzed and reported on Alibaba, even providing Yahoo reports with titles such as
“Alibaba Growth Reaccelerates in 2Q:CY14; Positive for YHOO’s 23% Stake,”19
15 I/B/E/S reports data as of a date near the middle of each month.
16 The issuing firms included prominent investment houses including Bank of America
Merrill Lynch, Barclays, Citi, Deutsche Bank, JP Morgan, Morgan Stanley, and UBS.
17 “Open Sesame! Uncovering Alibaba’s Treasure Trove; Initiating at BUY with $90
PT,” Cantor Fitzgerald, September 19, 2014. (“BABA starts trading today…”)
18 See the following two footnotes for examples.
19 Cantor Fitzgerald, August 27, 2014. (Analyst provides a $39 price target of which $25
is attributed to Alibaba.)
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“BABA: Mobile Take-Rate Key for IPO; Retail Market Structure Highly Favorable,”20
“Yahoo! Inc.: Weaker Results Offset by Alibaba,”21 and “YHOO – In-Line 1Q14 EPS
with Upside from Alibaba & Display.”22 Thus, unlike with many IPOs, where there is
highly limited coverage before the IPO itself, in this case, due to the substantial
dependence of Yahoo’s valuation on Alibaba’s financial performance, there were analyst
reports that effectively covered Alibaba before the IPO through their analysis of Alibaba
as part of their coverage of Yahoo.
(3) Market Makers and Arbitrageurs
a. Aftermarket
26. Alibaba’s ADSs traded on the New York Stock Exchange, which is widely
regarded as one of the most open, developed, and efficient in the world. The New York
Stock Exchange maintains a system where there is a “designated market maker” (similar
20 MKM Partners, August 13, 2014. (“On our valuation assumptions for BABA ($155Bn
IPO price/$190Bn public market value), we assign $29 per share to YHOO in our SOP.
As nearly 80% of this is related to the public market price, we expect YHOO shares will
trade with BABA shares post-IPO.” This report effectively covers both Alibaba and
Yahoo.) Over the Class Period, the correlation between movements in Alibaba’s ADS
price and Yahoo’s stock price was 0.73, where a value of 0.00 would mean no correlation
and a value of 1.00 would mean perfect correlation. This result is highly statistically
significant, with a p-value of less than 0.0000000000001%, or less than one-trillionth of
the value of 5% that is the maximum value for statistical significance at the standard 5%
level. Because even after Yahoo had sold a large portion of its stake in Alibaba, Yahoo’s
stock was still a very good indicator of the value of Alibaba, Yahoo’s stock was
presumably an even stronger indicator of the value of Alibaba before the Alibaba IPO
(i.e., when an even greater fraction of Yahoo’s value came from its holdings of Alibaba
shares).
21 Barclays, July 16, 2014. (“With no growth in core Yahoo!, the company continues to
trade mostly on its ownership in Alibaba[.]”)
22 CRT Capital, April 16, 2014. See also “Yahoo! Inc.: ‘Baba in Overdrive on Route
‘66’…Next Stop, IPO?” Susquehanna Financial Group, April 16, 2014. (“[T]he
valuation is all about a (rapidly growing) Alibaba.”)
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to what was previously known as a “specialist”) that is in charge of ensuring that there is
a well-functioning market. Therefore the question about market makers for securities
that trade on the New York Stock Exchange is that there is always one particular entity
tasked with that role, though there may be others that also act as market makers.
27. Arbitrageurs are investors who attempt to profit from any possible mispricing of a
security. There are two types of arbitrageurs that we can examine: those who take a
“long” (or positive) position in the stock and those that take a “short” (or negative)
position. While there are no data on the identities of arbitrageurs in particular securities
or their holdings of those securities, one would expect many of the arbitrageurs who are
active enough to move the market to be found among the largest market participants. We
can therefore use information about institutional holdings, which are reported quarterly,
as a proxy for arbitrageurs that take a long position. Though not all institutions are
arbitrageurs, many of the major arbitrageurs who take a long position large enough to
affect the price of a stock would be institutional investors, as non-institutional investors
may not have the capital to take a long-term position of the same magnitude.
28. A total of over 600 institutions held 320 million ADSs, or 13.0 percent of the
shares outstanding as of September 30, 2014, the first calendar quarter-end in the Class
Period. This figure did not remain constant, and institutions held 331.5 million ADSs as
of December 31, 2014, the last calendar quarter-end during the Class Period and 444.7
million as of March 31, 2015, the first quarter-end following the Class Period. The
directions of the change in institutional holdings is not important; what is important is
that there was a potential for change, with institutions buying or selling in response to
factors including news about Alibaba and changes in its ADS price. Aggregate quarterly
institutional holdings figures are shown in Exhibit 5.
29. As alluded to above, if an institution held the same number of ADSs throughout
the Class Period, it may not be adding to market efficiency, since it would be providing
neither upward pressure through buy orders nor downward pressure through sell orders.
However, an examination of the data underlying Exhibit 5 shows that most institutions
did change their positions, with numerous examples of a single reporting institution
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changing its holdings up or down by over a million ADSs over the course of a single
quarter. Moreover, during the Class Period, of institutions with a non-zero holding of
ADSs at the end of a quarter, 86.8 percent reported a different holding figure at the end of
the next quarter (i.e., considering September 30, 2014 and January 31, 2014, the two
quarter-ends in the Class Period). These observations show that as a group, institutions
were not passive investors, but changed their positions, a hallmark of arbitrage activity.
Even among the institutions that did not change their positions, there may be some that
actively evaluated news about Alibaba and changes in its ADS price and were
comfortable maintaining their prior position. The fact that on average more than eight
out of ten institutions holding Alibaba ADSs changed their position is evidence that a
substantial number of large investors were following the company.
30. With regard to arbitrageurs who held a short position in Alibaba ADSs, I obtained
data on the aggregate short position, which is reported monthly by FactSet Research
Systems, Inc., and shown in Exhibit 6. The average aggregate short position over the
Class Period was 1.56 percent of Alibaba’s shares outstanding. The monthly short
position over the Class Period as a percentage of shares outstanding more than doubled
from 0.83 percent in September 2014 to 1.86 percent in November, before falling to 1.68
percent in January 2015. These differences are important because they allow us to infer
that those who wanted to create or increase a short position were generally not prevented
from doing so. If, in contrast, the aggregate short position were always approximately
the same, for example always between, say, 1.0 and 1.1 percent, one would have to
consider whether the shares available for shorting were always used or close to used,
thereby preventing investors who wanted to take a short position in response to new
information from doing so.23
23 In order to short an Alibaba ADS, the investor who wants to take the short position
must, through their broker, find an ADS held by another investor to borrow. The investor
going short delivers this ADS to the counterparty (the purchaser) in the short transaction
and is required to later return an ADS to the investor from whom he or she borrowed the
share. When there are not enough ADSs available for borrowing, investors may not be
(continued)
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31. Overall, I find that both institutions and short sellers actively changed their
holdings over the Class Period, an indication of their attention to the price of Alibaba’s
ADSs.24 Institutional holdings varied from 13.0 to 18.0 percent of shares outstanding
from the first quarter-end in the Class Period to the quarter-end following the end of the
Class Period, with 86.8 percent of institutions with a positive holding in one quarter
reporting a different amount of holdings in the next. The maximum aggregate short
position was more than twice the minimum aggregate short position. In addition, the
change in the aggregate short position supports the conclusion that investors were able to,
and did, take and change positions in Alibaba’s ADSs to reflect their views, the core
mechanism by which financial markets are driven to efficiency.
b. IPO
32. Trading in an IPO is different than in the aftermarket. In the aftermarket, almost
any market participant can either buy or sell, allowing them to act as arbitrageurs if they
feel the price is either too low or too high. In an IPO, the company sells shares and
others buy them. Thus, as they can only declare their intention to purchase but not to sell
(or even to actually guarantee that they will make a purchase), arbitrageurs have a more
limited ability to influence the IPO price in a manner that would create an efficient
market. That is, arbitrageurs can act only as potential purchasers in the IPO, but cannot
engage in the typical arbitrage activities of buying a security they think is overpriced and
selling one they think is underpriced.
(4) S-3 Registration Statement
33. Another Cammer factor is the ability of an issuer to register new shares through
an S-3 registration statement form rather than using a Form S-1 or S-2, both of which
able to establish or expand their short positions, and therefore would not be able to
contribute to arbitrage and market efficiency by varying the size of their short positions.
24 Some changes in institutional holdings may be due to other factors, such as a decision
to sell shares for liquidity purposes. Still, the substantial number of changes is evidence
of active monitoring of Alibaba by many institutions.
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require more disclosure than a Form S-3. The SEC allows qualifying companies to
register shares using the less burdensome S-3 based on the assumption that news about
such companies is already publicly available to market participants and therefore does
not need to be included in the registration statement. At the time of the Cammer opinion,
an issuer had to have a float (i.e., shares outstanding that are not held by insiders) with a
market value of at least $150 million to use a Form S-3. That requirement was later
reduced to $75 million. Exhibit 7 shows the market capitalization and float for Alibaba.25
The market value of Alibaba’s float, which averaged over $27 billion during the Class
Period,26 easily exceeded $150 million throughout the Class Period, and in fact exceeded
that level by billions of dollars throughout the Class Period.
34. A second requirement to be able to file a Form S-3 registration statement is that
the issuer be current in its SEC filings over the past twelve months. Alibaba was not
delinquent in its SEC filings during the Class Period but did not have a twelve-month
history as an SEC-reporting company. While Alibaba itself was a foreign company that
would not file an S-3, but would file a F-3 with the same filing requirements, the relevant
economic requirements that one considers in this Cammer factor (i.e., float and timeliness
of SEC filings) still point to Alibaba’s securities trading in an efficient market, though the
lack of a reporting history limits the weight of this factor.
25 Where there was uncertainty about whether certain insider holdings were included in
the ADS figures, I included treated those holdings as part of the ADS total, thereby
producing a conservative (i.e., low) estimate of the float.
26 This exceeded the total market capitalization (and thus the total float) of over 90
percent of publicly traded companies in the United States as of December 31, 2014. (See
2015 Valuation Handbook – Guide to Cost of Capital, Duff & Phelps, Appendix 3,
showing that the largest decile of companies sorted by market capitalization had a
minimum market capitalization of $24.4 billion.)
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(5) Price Response to News
a. Aftermarket
35. Whether a stock price responds to material, new unexpected information is often
considered the most direct and important of the Cammer factors. The Cammer court
noted on page 1291 that “one of the most convincing ways to demonstrate efficiency
would be to illustrate, over time, a cause and effect relationship between company
disclosures and resulting movements in stock price.”
36. Accordingly, I performed statistical analyses, based on tests known as “event
studies,” the standard means of quantifying stock price responses to news, to examine
this factor. An event study is a statistical test that first measures the movement in the
price of a stock or other security immediately following a news event by removing the
influence of general market and/or industry effects. The remaining movement is then
compared to a “control period” of similar market-adjusted price movements to see if it is
unusual (i.e., statistically significant). If so, then one may be able to make the inference
that the news was the cause of the unusual stock price movement.27 In general, we expect
that the price of a stock will increase in response to unexpectedly positive news and fall
in response to unexpectedly negative news.
37. To test the general proposition of whether a stock price responds to news, it is
necessary to examine the stock price responses to two different groups of dates: those
with news and those without news.28 That is, one conducts event studies on the different
27 Event studies or similar analyses are often required in securities fraud litigation. See,
for example, In re Executive Telecard, Ltd. Securities Litigation, 979 F. Supp. 1021,
1027 (S.D.N.Y. 1997). (“The Expert Witness’ failure to conduct a thorough ‘event study’
would be reason enough to exclude his proposed testimony.”) The event studies I
employ here are consistent with my own published work (David Tabak and Frederick
Dunbar, in Litigation Services Handbook, The Role of the Financial Expert (3d ed.
2001).)
28 Ideally, one wants to define news as unexpected material new information. Other news
may be consistent with prior expectations and should not be expected to cause a change
in a stock’s price.
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news and non-news days, and then compares the results of those two analyses. This is
the same idea behind a medical study that has a control group and a treatment group.
Here, the control group (i.e., the group not receiving treatment) consists of the “non-news
days” while the treatment group consists of the “news days.” Establishing two such
groups is necessary because even if the market for a stock were not efficient, there would
generally still be some news days that were randomly associated with stock price
movements. Selecting a few examples of such instances and claiming to have thereby
found an association between news and stock price movements would be clearly
incorrect.29
38. Another relevant consideration in this analysis is to recognize that we typically
cannot use the news and price movement at the end of a class period in an analysis of
market efficiency. This is because most class periods are chosen to end with a news
event corresponding with a large stock price decline. Defining our analysis period to
include such a date would result in an improper bias toward finding an association
between news and stock price movements.30 Thus, I end the analysis before the price
movements associated with the end of the Class Period.31
29 For example, if such a methodology were valid, one could identify several people with
blue eyes who are right-handed and then claim to have “found” an association between
blue eyes and right-handedness. One could also, under the same methodology, identify
several left-handed blue-eyed people and also claim to have “found” an association
between blue eyes and left-handedness. A description of the method of analysis I use
here is found in Paul Ferrillo, Frederick Dunbar, and David Tabak, “The ‘Less Than’
Efficient Capital Markets Hypothesis: Requiring More Proof From Plaintiffs in Fraud-on-
the-Market Cases,” 78 St. John’s L. Rev. 81, 120-21 (2004).
30 One would also want to exclude the first day of a class period if it were chosen because
of news causing a large increase in the stock price. Here, there does not seem to be
evidence that the initial day of the Class Period was chosen because of a stock price
increase, but, rather, it was chosen because of the IPO.
31 Arguably, one could include the January 28, 2015 price movement and exclude only
the January 29, 2015 price movement from the analysis. Had I done so, I would have
added in another news day with a statistically significant price movement to many of the
analyses and thereby obtained results even more in favor of market efficiency.
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39. As noted above, the test of a stock price’s response to news depends on
classifying days into news days and non-news days. If not performed carefully, this
classification may be somewhat subjective. Thus, one generally wishes to use an
objective measure of news, or at least one where any subjective decisions have been
made by others who are not part of the analysis of market efficiency.32 To remove any
possible subjectivity on my part as to which “news days” were selected for examination, I
performed one analysis by defining news days as days with Alibaba earnings
announcements. This is, of course, an overly restrictive definition of “news days,” and
results in comparing (1) a set of particular news days (though in this case, just a single
day) with (2) a mixed set composed of both non-news days and days that would (but for
the restrictive definition) be considered news days. Because the second set of days has a
mix of types of days, this will tend to make it harder for a comparison of (1) and (2) to
show that Alibaba’s ADS price responded to news.33 I performed another analysis with
32 See, for example, In re Countrywide Financial Corporation Securities Litigation, 273
F.R.D. 586, 618 (C.D. Cal. 2009) (“It should be obvious, even to those without a
background in statistics or econometrics, that the events for study should be selected
using criteria that are as objective as possible. Further, those criteria should be
determined before looking at the result to be studied (here, stock returns). Relatedly,
unless the expert uses articulable objective criteria, it is difficult to evaluate the probative
value of expert evidence without evaluating also the expert's own credibility.”)
33 To see this, imagine that Alibaba’s ADS price moved by ten percent on news days and
by zero on non-news days. If we had perfectly identified news days and non-news days,
we would be comparing a set of days with an average price movement of ten percent to
another set of days with an average price movement of zero. Because the second set of
days includes some news days, we may wind up comparing a set of days with an average
stock price movement of ten percent (some of the news days) to some positive figure
such as five percent (if half of the second set consisted of news days). Thus, rather than a
difference of ten percentage points, the difference would be only five percentage points,
making it harder to prove that there is a meaningful difference between the two figures.
One should note that under some circumstances (e.g., if non-earnings news has a very
small impact on prices), then grouping those with non-news days may make the average
price impact of the remaining news stories greater, which could aid in reaching a correct
finding that a stock responds to earnings news.
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broader sets of news days, in which I define news days as days with stories published by
the Dow Jones Newswires. In each case, I limit news stories to those that use “Alibaba”
or the BABA ticker in the headline.34 As there was news on 69 out of 88 days in the
Class Period, I also performed the analysis two more times by looking at a proxy for the
amount of news each day by counting the number of stories in Dow Jones Newswires, a
technique from the field of content analysis.35 I then order the trading days by the
number of news stories from high to low and create two proxies for days with high news
content: (1) the days in the upper half of this ordered list and (2) the days in the top ten
percent of this ordered list.36 Finally, I performed an additional test, starting with the top
ten percent of the news days as just defined. I reviewed the stories that appeared in the
Dow Jones Newswires and removing any that were solely reporting on Alibaba’s ADS
price movements or volume (i.e., instances where the news was responding to the ADS
price rather than the ADS price potentially responding to news), that appeared to be
duplicates of previously reported news, or were deemed to be non-material because they
reported data irrelevant to the value of the Company.37
34 If a news story came out before 4 pm (i.e., before the close of trading on the New York
Stock Exchange), that day was characterized as a news day. If the story occurred after 4
pm but before midnight, then the following trading day was characterized as a news day.
35 Content analysis is based on the premise that the “frequency with which a symbol,
idea, reference or topic occurs in a stream of messages is taken to indicate the importance
of, attention to, or emphasis on that symbol, idea, reference, or topic in the messages.”
(Klaus Krippendorff, Content Analysis: An Introduction to Its Methodology, 2nd edition,
2004, p. 59. Emphases in original.) That is, the more often the news reports on a topic,
the more important it is likely to be. The use of content analysis was endorsed by the
First Circuit in Bricklayers and Trowel Trades v. Credit Suisse LLC, 752 F.3d 82 (1st Cir.
2014).
36 Because there were a number of days with the same number of news stories, the
analyses actually have more than half and more than ten percent of the trading days
classified as news days.
37 News was deemed to be non-material based on a review of the news story. For
example, some stories referred to which shareholders were receiving Alibaba shares or to
the effect of Alibaba on Yahoo. Because these are necessarily subjective determinations,
(continued)
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40. Exhibit 8a compares (A) the percentage of news days within the Class Period that
are associated with statistically significant market-adjusted ADS price movements with
(B) the percentage of statistically significant market-adjusted ADS price movements in
the control group of non-news days for the ADSs. The first row in Exhibit 8a was run
using the definition of news days as days with Alibaba earnings announcements. The
second row was run with news days defined as those days with any reported news
mentioning Alibaba in the headline of articles in Dow Jones Newswires, obtained from
Factiva, a well-recognized data vendor. The third and fourth rows limit the definition of
news days to include half and ten percent of the days (though in practice the number of
days is higher because there is more than one day with the same number of news stories).
Finally, the fifth row was run by reallocating four news days (listed in Exhibit 8c) from
the fourth row as non-news days because they represented solely duplicate or immaterial
news.
41. The market model, i.e., the statistical analysis that I employed as part of my event
study to control for the effect of general market factors on Alibaba’s ADS prices, used
the EMQQ Emerging Markets Internet Index as a proxy for the market as a whole, and is
presented in Exhibit 8b.38 Because the Class Period begins with the IPO, there are no
trading prices for the typical estimation period of one year before the start of the Class
Period. Thus, for the estimation period, I choose to still use data not potentially affected
by the alleged fraud by using the year after the Class Period as the estimation period for
the market model. As set forth in Exhibit 8b, the R-squared, a measure of how well
the results could be different if the review were performed by different experts.
Consequently, this analysis should be considered in combination with the analysis before
the subjective review is undertaken (i.e., the corresponding row in Exhibit 8a).
38 The EMQQ Emerging Market Internet Index returns are adjusted to remove the
Alibaba returns from the index. Results using the unadjusted index yield the same results
for tests of statistical significance as using the adjusted index. This index was
specifically designed to include companies like Alibaba. See “An Emerging Market ETF
to Address the Alibaba Index Problem – Barron’s Blog,” Dow Jones Institutional News,
November 26, 2014.
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movements in the chosen index relate to movements in Alibaba’s ADS prices was 0.48,
similar to the values that I have observed in similar analyses.39
42. As seen in the first row of Exhibit 8a (“Earnings Dates”), in the Class Period,
when I limit the definition of news days to earnings announcements, 9.2 percent of the
non-news days are associated with a statistically significant ADS price movement, while
100 percent of the news days (which, in this case, means one out of one day) are
associated with a statistically significant ADS price movement. The difference between
these two percentages is statistically significant, showing that the market for Alibaba’s
ADSs reacted differently on days with earnings announcements than on days without
earnings announcements, though there was only one earnings announcement in the Class
Period.40 The standard level of statistical significance for tests in financial economics is
the five-percent level, meaning that there is only a five percent chance that a result as
strong as or stronger than the one observed in the data would appear if the market did not
react to news. This means that we consider results to be statistically significant if they
have a false-positive error rate (i.e., a finding of a reaction to news when no such reaction
exists) of five percent or less.
39 To the extent that a different market model would provide a better explanation of
Alibaba’s ADS price movement, then my analysis has understated the results of this test
of market efficiency. That is, because a better model would result in data with less noise,
the differences in returns on news days and non-news days would likely be sharper and
more easily identifiable through statistical analysis.
40 The test is run by comparing the proportions of the news and non-news days with
statistically significant returns. A test of proportions implicitly assumes equal variances
under the null hypothesis, an update in methodology that I have used in prior cases
relative to that used in a publication I co-authored in 2004 (Paul A. Ferrillo, Frederick C.
Dunbar, and David Tabak, “The less than efficient capital markets hypothesis: Requiring
more proof from plaintiffs in fraud-on-the-market cases,” St. John's L. Rev. 78 (2004):
81.) It is also worth noting that had I included the earnings announcement at the end of
the Class Period, there would have been an even stronger finding of statistical
significance when examining this difference between the price movements on news days
and non-news days.
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43. One can also examine the absolute value of the excess returns. However, because
of the small number of days in the Class Period, this test is unlikely to yield statistically
significant results, even with reasonable differences between the news days. The excess
returns averaged 3.4 in log-points (approximately 3.5% in percentage terms) for earnings
release dates and 1.5 log-points (approximately 1.5%) for other dates. (See Exhibit 8c.)
Even though the average return on news days is more than twice that of non-news days,
the difference is not statistically significant, which, again, is not surprising given that the
relevant test tends to need a large number of data points to recognize material differences.
44. In the second row of Exhibit 8a (“Dow Jones Newswires”), where news days are
broadly defined based on headline and lead paragraph mentions in the Dow Jones
Newswires, we see that in the Class Period, just one, or 5.3 percent of the non-news days
are associated with a statistically significant stock price movement in the ADSs, while
11.6 percent of the news days are associated with a statistically significant price
movement. While the difference in these figures results is not statistically significant at
better than the standard five-percent level, this is due to the small number of non-news
days.41 In fact, as just 5.3 percent of the non-news days is associated with a statistically
significant price movement, that result is exactly what would be expected due to chance
at the five-percent significance level.42 When the definition of news days is restricted to
41 It is worth noting that there is no meaningful benchmark for the percent of news days
that should be associated with a statistically significant return. As the definition of news
days becomes looser (i.e., less likely to be material), then the expected percent of such
days associated with a statistically significant return should fall. In addition, the results
presented are based on the five-percent significance level. The use of a more or less
stringent significance level would result in fewer or more price movements, respectively,
passing the test of statistical significance. Given the variability of both the definition of
news and of statistical significance, there is no reason to expect any particular percentage
of news days to be associated with statistically significant returns.
42 As an analogy, imagine examining whether a coin is biased toward heads and flipping
the coin once. If the coin comes up heads, that is the strongest possible evidence one
could find for a bias toward heads in a single flip. However, that single result would not
reach the level of statistical significance. Thus, while supportive of a finding that some
“effect” exists, the result is not by itself sufficient to reach such a conclusion.
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those days with high numbers of news stories, as discussed above and shown in the third
and fourth rows of Exhibit 8a, the percentage of news days associated with statistically
significant returns increases and the results become statistically significant.
45. Finally, for the fifth row of Exhibit 8a, I reviewed the news stories in the “Dow
Jones Newswires – Top 10%” row and determined that four of the eight news days could
be treated as non-news days because all of the news on those days was either a repetition
of previous news, described price movements, or was not material to the valuation of the
stock. (See Exhibit 8d for the listing of the four days.) While the difference between the
two sets of days becomes starker, the statistical significance of the difference (which was
already well beyond the standard five-percent level) is not materially different from those
in the fourth row of Exhibit 8a due to the small number of news days in this analysis.43
46. The tests of stock price response to news, the Cammer factor that most directly
tests market efficiency, provide strong evidence that Alibaba’s ADS prices responded to
material new information. Alibaba’s ADS prices were much more likely to exhibit a
statistically significant response to news, whether we define news objectively and
narrowly as earnings announcements or objectively and broadly as a majority of the days
with headline and lead-paragraph mentions in stories from various news sources. In
summary, there is overwhelming evidence that Alibaba’s ADS prices responded to new
information during the Class Period.
43 One interesting finding is that on October 29, 2014, when the “quiet period” following
the IPO expired, more than a dozen firms that were involved in the IPO were allowed to
and did initiate coverage of Alibaba. The event study shows that there was not a
statistically significant price movement on this day. This demonstrates that due to
existing analyst and news coverage (including any coverage by these firms of Yahoo
before the Alibaba IPO), the market had already accounted for the net effect of the
information and analysis provided by these analysts, meaning that their coverage was not
necessary to achieve efficiency in the market for Alibaba’s ADSs.
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b. IPO
47. To determine if the IPO price responded to news, one would want information
about how the (projected) IPO price changed over time. Unfortunately, the public data
on this is sporadic and often represents market participants’ predictions about the future
IPO price rather than the actual company and/or underwriter views of the future IPO
price.
48. Had the IPO price been similar to the initial trading prices in the aftermarket after
the IPO, it may have been reasonable to argue that there was evidence that the IPO price
was incorporating the same information as the market. Instead, in this instance, the IPO
was priced at $68, while the opening price for Alibaba’s ADSs on September 19, 2014
was $92.70 and the closing price was $93.89. These substantial differences make it hard
to know whether the IPO price was incorporating all of the same news as the aftermarket
and applying some discount, or whether the IPO price was not incorporating all of the
same news that market participants were impounding in the ADS price. Put simply,
given the large difference between the IPO price and the aftermarket prices, we cannot
use any conclusions about the efficiency of the aftermarket to make reliable inferences
about the efficiency of the IPO price.
(6) Trading on a Major Securities Market
a. Aftermarket
49. The court in DVI II, citing prior case law, stated on page 634, “Securities markets
like the NYSE and the NASDAQ are ‘open and developed,’ … and are therefore ‘well
suited for application of the fraud on the market theory,’…. Accordingly, the listing of a
security on a major exchange such as the NYSE or the NASDAQ weighs in favor of a
finding of market efficiency.” That is, major securities markets, such as the New York
Stock Exchange, have mechanisms in place to ensure conditions such as the rapid
dissemination of price and volume information that allow investors to trade easily and
with reliable information about recent trading. Market participants are then better able to
spot any potential deviations of the stock price from an efficient value and move to
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quickly eliminate any such inefficiencies. Alibaba’s ADSs traded on the New York
Stock Exchange during the Class Period and therefore satisfy this criterion.
b. IPO
50. The IPO price was not set as a result of trading on a major securities market.
While Alibaba’s meeting the listing requirements of the NYSE is a positive factor in
terms of market efficiency, the fact that the IPO price was not set based on actual trading
on that market reduces the weight that this factor would play in terms of providing
evidence in favor of market efficiency.
(7) Market Capitalization
51. A large market capitalization is another factor that courts have found to weigh in
favor of finding an efficient market. As noted previously, Exhibit 7 shows Alibaba’s
market capitalization over the Class Period. Alibaba’s smallest market capitalization
over the Class Period was over $200 billion, while its average market capitalization
exceeded $240 billion.44 This large capitalization means that there would have been
opportunities for investors to make large profits if there were any apparent mispricing,
thus providing an incentive for investors to carefully analyze news and information about
Alibaba.
(8) Bid-Ask Spread
a. Aftermarket
52. A narrow bid-ask spread is a potential indicator of market efficiency because the
spread provides information about the cost of arbitrage, with a narrow spread meaning
that those costs are lower. Market makers typically work to keep a market functioning by
being continuously willing to buy at a certain price (the bid) and to sell at another price
(the ask). Market makers make a profit by keeping the bid price below the ask. For
44 As with the float, this exceeded the market capitalization of over 90 percent of
companies publicly traded in the United States as of December 31, 2014.
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example, if the bid is $20.00, the ask may be $20.50. If a market maker receives one
market order to buy and one to sell, it buys at $20.00 from the seller and sells at $20.50 to
the purchaser. The market maker’s gross profit of $0.50 is reduced by the costs of
maintaining an inventory of securities (in case there are more buyers than sellers) and the
other costs of running a market-making operation. While the market maker earns $0.50
in this transaction, an arbitrageur who thinks that a stock is undervalued would pay $0.50
on their round-trip transaction, hoping that between the purchase and sale times the stock
rises by more than this amount. Thus, the spread between the bid and ask represent the
cost of arbitrage, and thus equals a degree of mispricing that arbitrageurs may not seek to
exploit because doing so will be unprofitable after taking into account the arbitrageur’s
transaction costs.45
53. Exhibit 9 shows the daily bid-ask spread for Alibaba’s ADSs for each trading day
in the Class Period. The bid-ask spread averaged 0.028% of the same-day’s closing price
over the Class Period. This is a low figure, indicating that it would be profitable (in
expectation) for investors to trade in Alibaba ADSs if they felt that they were mispriced
by as little as 0.028%. This low level of the bid-ask spread supports a finding that
arbitrageurs would have an incentive to trade on any perceived mispricing, and therefore
would have an incentive to undertake the activities that lead to a stock trading in an
efficient market. To put this into context, Alibaba’s ADS price fell by 4.4% on January
28, 2015, and by 8.8% on January 29, 2015, both over one hundred times the average
bid-ask spread.46 Thus, the price impact of the corrective disclosures is well in excess of
the bid-ask spread, meaning that the market would have been expected to have reacted
45 In reality, arbitrageurs may be able to trade “between the quotes” and not pay the full
bid-ask spread. However, it is still generally true that the larger the bid-ask spread, the
larger are the expected costs of arbitrage activities.
46 Adjusting for market and industry movements per the event study described above, the
January 28 and January 29 price movements are 4.1% and 7.1%, respectively.
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quickly had it known of the allegedly omitted and/or misrepresented information.47
Another way to put this into context is that Alibaba’s mean bid-ask spread as a
percentage of its stock price was between the 25th and 26th smallest percentile of stocks
traded on the New York Stock Exchange over the Class Period (i.e., approximately three
quarters of those stocks had a larger mean bid-ask spread as a percent of their stock
price).
b. IPO
54. There is no equivalent to the bid-ask spread for the IPO. Rather than investors
being able to purchase at the ask and sell at the bid, in an IPO investors can only purchase
(if they are able to make a purchase at all) at the IPO price. Thus, there is no arbitrage
opportunity directly in the IPO, and this factor cannot be said to support market
efficiency.
(9) Float
a. Aftermarket
55. Courts have considered the size of an issuer’s float (i.e., the shares outstanding
not held by insiders) as another indicator of efficiency for the issuer’s common stock. A
larger float suggests greater liquidity for shares, making it easier to purchase and sell
shares in the market. Exhibit 7 also shows the float, or the ADSs not held by insiders.
47 The news that affected the ADS price on January 28, 2015 (i.e., the posting of the
White Paper) is entirely related to the allegations in this case. That price decline alone
demonstrates the impact of the allegations on Alibaba’s ADS price. Had the market
learned of this information, there would have been an immediate profit opportunity in
excess of trading costs, which would be expected to lead to a rapid price response.
Notably, the Complaint alleges that the “Registration Statement misled investors because
it failed to disclose” various information. (Complaint, ¶102.) The Complaint defines the
Registration Statement to include not only the initial registration statement but
amendments through September 15, 2014, as well as the Prospectus dated September 22,
2014. As the Complaint alleges that relevant information should have been disclosed on
September 15, 2014, as well as on earlier dates, the market would have had ample
opportunity to digest that information before trading began on September 19, 2014.
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Courts have often found that a float representing a large percentage of the shares
outstanding is an indicator of efficiency.48 This would be true because investors are only
able to trade shares that are in the float. Thus, investors’ ability to profit from any
apparent mispricing, and their incentives to examine a company’s stock price and news
about the company, will be related to the number of shares that they can attempt to trade
in order to make potential profits. Over 9% of Alibaba’s shares were in the public float
throughout the Class Period, meaning that market participants were able to trade ADSs
valued at over $27 billion, and thereby incorporate any information they had into the
market price.
b. IPO
56. As all shares were held by insiders prior to the IPO, this factor cannot aid in
showing efficiency for the IPO price.
(10)
Autocorrelation
57. A final test is whether there is autocorrelation in Alibaba’s ADS prices, or
whether there is a predictable statistical pattern of positive and negative changes in the
ADS prices.49 For example, if a price rises on Monday, then if the market were able to
predict that the stock was more likely to move in the same direction (i.e., rise) than move
in the opposite direction on Tuesday, there would be evidence of positive autocorrelation.
Similarly, if the market were able to predict that the market would move in the opposite
direction on Tuesday to its movement on Monday, there would be evidence of negative
autocorrelation. Evidence of autocorrelation would be an indicator counter to market
efficiency and would invite the question of how severe that violation of market efficiency
48 See, for example, Krogman 202 F.R.D. 467, p. 474.
49 Autocorrelation, also known as serial correlation, is discussed as a test of potential
market efficiency in Eugene F. Fama, “Efficient Capital Markets: A Review of Theory
and Empirical Work,” Journal of Finance, 1970. (“More of the literature has, however,
been concerned with tests of serial covariances of returns.” p. 391.)
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would be. In particular, persistent autocorrelation beyond transaction costs would
represent a potential failure of investors to exploit profit opportunities in an ADS,
suggesting that investors may not be properly analyzing the company’s stock price
movements.
58. In Exhibit 10a, I show the measure of first-degree, or one-day, autocorrelation in
the ADSs for the Class Period. When first-degree autocorrelation is present, then the size
and direction of the price movement of a security on one day can be statistically
estimated (though, of course, not precisely, but with some degree of uncertainty) in
advance based on the size and direction of the security’s price movement on the prior
trading day. As can be seen, there is no statistically significant degree of autocorrelation
at the standard 5% significance level over the Class Period.
59. A second way to examine autocorrelation is by means of what is called a “runs
test.”50 To see how such a test works, imagine flipping a coin N times. We would expect
that if the coin were unbiased it would sometimes come up heads and sometimes tails;
sometimes there may be a single head followed by tails, and sometimes there may be a
string of heads in a row. Suppose first that in running this experiment the coin switched
back and forth between heads and tails on every flip. Then the number of runs in the N
flips would also be N, as every single flip would start a new run of heads or tails. This
would be a form of negative autocorrelation because a result in one direction would
indicate that we should expect the next result to be in the other direction. Now suppose
instead that the first N/2 flips were heads and the second N/2 flips were tails. In this
50 See, for example, footnote 15 of Prof. Fama’s 1970 paper. (“For the daily price
changes, the actual number of runs of price changes of the same sign is less than the
expected number for 26 out of 30 stocks. Moreover, of the eight stocks for which the
actual number of runs is more than two standard errors less than the expected number
[i.e., is statistically significant at the five-percent level], five of the same stocks have
positive daily, first order serial correlations in Table 1 that are more than twice their
standard errors [i.e., are statistically significant at the five-percent level]. But in both
cases the statistical ‘significance’ of the results is largely a reflection of the large sample
sizes.”)
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case, we have only two runs, one of heads and one of tails. This would be a form of
positive autocorrelation, because with one exception right in the middle, one could
always predict a flip of the coin by assuming that it would be the same as the last flip.
Probability theory allows us to show that a fair coin would have approximately N/2 runs.
Probability theory also lets us determine how many runs represent a statistically
significant deviation from this expected number of runs.
60. This theory has been applied to stock price movements by examining the number
of runs of increases or decreases in the stock price during some time period.51 If the
number of runs is sufficiently small, there is evidence of positive autocorrelation while if
the number of runs is sufficiently large, there is evidence of negative autocorrelation.
The number of runs needed to result in a statistically significant deviation from the
results of an unpredictable outcome can be determined by the use of probability and
statistical theory.
61. The results of the runs test similarly point very strongly toward a lack of
autocorrelation, which weighs in favor of a finding of efficiency. Again, there is no
statistically significant evidence of autocorrelation over the Class Period. Results are
shown in Exhibit 10b.
62. Thus, using two types of tests of autocorrelation (i.e., runs tests and tests based on
magnitudes of stock price returns), I find no statistically significant degree of
autocorrelation at the standard 5% significance level based on any of the tests. These
tests of autocorrelation thus provide support for a finding that Alibaba’s ADSs traded in
an efficient market.
51 The analysis is actually run comparing the number of runs of returns, or percentage
price changes, above and below the median. Because stock prices tend to have a median
return of around zero, for present purposes one can imagine looking at runs of positive
and negative returns.
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(11)
Summary
63. The above analyses indicate that Alibaba’s ADSs traded in an efficient market
when they traded in the aftermarket. The market for Alibaba’s ADSs shows clear
evidence of efficiency under all five Cammer tests. It also does extremely well on the
Krogman tests. Adding my tests for autocorrelation, I find additional evidence consistent
with market efficiency. Looked at as a whole, the evidence strongly supports findings of
market efficiency for Alibaba’s ADSs during the Class Period.
64. In contrast, the evidence for whether the IPO price was set in an “efficient”
manner is mixed and often contradictory. On the one hand, there were numerous news
stories and analyst reports on Alibaba even before the IPO. On the other, there was no
true market mechanism by which traders could directly influence the IPO price. Most
importantly, the IPO price was substantially below even the first price (i.e., the
September 19, 2014 opening price) in the aftermarket. Thus, in this case, it is difficult to
argue that the IPO price incorporated the same news that the market did, but just in a
different manner. Thus, I conclude that one cannot reliably say that the IPO price is
reflective of the price that would prevail in an efficient market.52
VI. TESTS OF MARKET EFFICIENCY FOR ALIBABA OPTIONS
65. Counsel for Plaintiffs has also asked me to examine the efficiency for the markets
for Alibaba’s options. My understanding is that the proposed class in this action includes
purchasers of publicly traded calls and sellers of publicly traded puts.
66. To begin, I note that options are derivative financial instruments because their
values are derived from stock price plus other inputs. A call option gives the holder the
52 To be clear, had the information that Plaintiffs allege was withheld from the market
been publicly known, it may have affected demand for the IPO shares and thereby been
reflected in the IPO price. However, at this stage, without any discovery on the issue, I
do not believe that we have sufficient evidence to reliably conclude that that would or
would not have been the case.
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right, but not the obligation, to purchase shares at a pre-set price, while a put option gives
the holder the right, but not the obligation, to sell shares at a pre-set price. For example,
consider a call with an exercise price of $30, meaning that if the holder of the call
exercises the option, he or she pays $30 and receives one share of stock. If the stock is
trading at $35, the holder of the call option can make an immediate profit of $5 before
considering transaction costs by paying $30 to exercise the option and then selling the
share received for $35. If the stock is trading at $40, the holder of the call option can
make an immediate profit of $10 before transaction costs through the same mechanism.
Because the value of the call option is related to the immediate profit (and various other
variables that measure how that profit opportunity may change over time), the price of a
call option will tend to rise when the price of the underlying stock goes up and will tend
to fall when the price of the underlying stock goes down.
67. A put option gives the holder the right, but not the obligation, to sell (to put) a
share of stock to the counterparty at a preset price. For example, a put with an exercise
price of $30 allows the person who purchased the put to force the seller of the put to
purchase a share of stock at a price of $30. If the stock trades at $25, the seller of the put
can spend $25 to purchase a share in the open market and then exercise the put and
receive $30 from the purchaser of the put. The seller has thus made an immediate profit
of $5 before transaction costs. If the price of the underlying stock falls to $20, the
immediate profit is then $10 ($30 exercise price less the $20 cost of purchasing a share of
stock) less transaction costs. Thus, the immediate profit on a put rises when the
underlying stock price falls and falls when the underlying stock price rises. Because the
price of a put is related to the immediate profit, the price of a put falls when the
underlying stock price rises. Thus, if the price of a stock is inflated, the price of a put on
the stock will tend to be too low, and parties that sell (or write) puts will receive too little
from those transactions.
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68. There is a relationship, known as put-call parity, that provides bounds on the
relative prices of the stock, puts, and calls for a given company.53 Thus, if the market for
Alibaba’s ADSs is efficient, there is a mechanism to make the markets for its options
efficient as well. In addition, the academic finance literature has long held that
“informed traders choose to trade in leveraged option markets,”54 suggesting that option
markets may be as efficient if not more efficient than markets for stock in the same
company.
69. The Chicago Board Options Exchange listed 2,638 unique Alibaba options over
the Class Period. These options can be grouped into 1,319 pairs of puts and calls with
identical strike prices and maturities. Of the 2,638 options, 81.6 percent had reported
volume on at least one day during the Class Period. The average volume traded during
the Class Period for these options was over 5,419 contracts, where each contract
represents 100 shares of Alibaba ADSs, meaning the equivalent of trading an average of
more than 541,900 Alibaba ADSs per option. The median number of contracts traded per
option was 333, representing over 33,300 Alibaba ADSs traded for the median options
during the Class Period.
53 The put-call parity condition is based on a potential arbitrage opportunity if the relative
prices of the stock and the options are not in alignment. For example, an investor can
buy the stock and simultaneously write (sell) a call and purchase a put with identical
strike prices and maturities. When the options mature, the investor can be sure to either
sell the stock using the put (if the stock price has fallen) or have the call counterparty
purchase the stock. Either way, the investor will wind up with the strike price of the
option and no longer own the stock. Consequently, if the stock price is below the present
value of the strike price, then there is a potential arbitrage opportunity, assuming that the
difference is not eliminated through transaction costs. Consideration of the various
possible arbitrage opportunities results in the full put-call parity conditions.
54 James S. Doran, Andy Fodor and Kevin Krieger, “Option Market Efficiency and
Analyst Recommendations,” Journal of Business Finance & Accounting, June/July 2010,
p. 584. In fact, the authors find “evidence of information incorporation into option
markets prior to equity markets…” (p. 584)
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70. With regard to the testing of market efficiency, I rely on a test of the put-call
parity condition. The reason for not relying on the other tests is that while they may
provide circumstantial evidence about conditions related to market efficiency, the most
important such condition is whether Alibaba’s ADSs traded in an efficient market. If that
is true, then the conditions for properly pricing Alibaba’s options will also be present,
allowing us to proceed to the direct tests of efficiency.55
71. For a dividend-paying stock, the put-call parity conditions are the following:
S – PV(div) – K ≤ C – P ≤ S – PV(K),
where S is the price of the stock, PV means the present value of a future amount, div is
the stream of expected future dividends until the maturity of the option, K is the strike
price, C is the price of a call, and P is the price of a put. (In the formula, the call and put
must both have the same strike price, K, and must also have the same maturity.)
72. In addition to requiring the prices of the stock and the related calls and puts,
analyzing the put-call parity conditions requires the use of an interest rate (for the
present-value formula) and estimates of future dividends. For the interest rate, I use the
Treasury constant maturity rate.56 As Alibaba did not historically pay dividends, I
assume that the dividend yield, or the ratio of annual dividends to stock price, is zero.
55 This is true because option-pricing formulas, such as the Black-Scholes formula,
provide a link between certain stock price information (the price and volatility of the
stock price, in combination with data on interest rates and the maturity of the option) and
prices of options. This distinguishes call and put options from bonds for which that link
is not easily captured by a simple mathematical equation.
56 These data are available from
https://www.federalreserve.gov/datadownload/Choose.aspx?rel=H15. To obtain the
proper rate for each option series, I interpolate based on the rates for the Treasuries with
the closest maturities shorter and longer than the option examined. For example, the rate
for an option with a two-month maturity would be halfway between the Treasury rates on
one-month and three-month bills. For options with maturities less than one month, I used
the Treasury rates for one-month bills.
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73. For the analysis of the put-call parity conditions, on each day in the Class Period,
I examine those option series that had reported bids and asks not equal to zero for both
the call and the put (the “Options Data Sample”). The Option Data Sample includes 76.5
percent of all options. The analysis shows that 4.09 percent of the Options Data Sample
satisfy the put-call parity conditions. Of course, there are transaction costs that may
explain some of this difference. In addition, some of the put and call values may be from
a point earlier in the day than the closing price of the stock, further explaining some of
the deviations from the put-call parity conditions. I deal with these issues below.
74. First, put-call parity is based on arbitrage, or the ability to engage in at least three
trades: one for the call, one for the put, and one for the stock. To capture the costs of
trading, I include a trading cost solely for the stock transaction, conservatively assuming
that there are no transaction costs for the call or put and also assuming that there are no
costs to exit the arbitrage transaction. We also use these analyses not as actual trading
costs, but as measures of the magnitude of the deviation from put-call parity to see the
maximum degree of potential mispricing that would appear to not be fully arbitraged
away in the Alibaba options markets.
75. If we assume transaction costs of one-half of a percent of the stock price, then the
4.09 percent of the Options Data Sample satisfying the put-call parity conditions rises to
81.21 percent; if transaction costs equal one percent of the stock price, then 96.04 percent
of the Options Sample Data satisfy the put-call parity conditions. If the transaction costs
are 1.5 percent of the stock price, then 98.99 percent of the Options Sample Data satisfy
the put-call parity conditions. Even if these transaction costs are higher than large
institutional investors would pay, the results show that nearly all of the violations of put-
call parity are small in magnitude. Put differently, if one believed that material news had
an effect of at least 1.5 percent of the stock price, then investors could rely on option
prices to generally respond to and reflect unexpected material new information about
Alibaba. Trading costs of 2.77 percent of the ADS price would eliminate all put-call
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parity violations in the Options Sample Data.57 See Exhibit 11a for the percent of options
satisfying the put-call parity condition assuming only transaction costs on the stock
transaction (i.e., not accounting for costs of the option transactions or for possible
asynchronous trading). As a check on the results, Exhibit 11b runs the same analysis but
further excluding days with zero reported option volume in either the call or put in an
option pair.
76. It should again be noted that some of the apparent put-call violations may be due
to trading prices for the options that did not correspond in time to the closing price of the
stock. To examine this, I use the high and low price of Alibaba’s ADS each day in the
put-call parity analysis rather than the closing price. In particular, for each option pair, I
ask whether there exists some ADS price between the high and the low price for the day
that results in the put-call parity condition holding for that option pair. Under this
analysis, with even no trading costs, 97.46 percent of the Options Sample Data satisfy the
put-call parity conditions.
77. As initially noted, due to the close connection between options and the stock on
which they are based, if the stock trades in an efficient market, it is highly likely that the
options on that stock will as well. This distinguishes options from other securities, such
as debt, that do not have a formula tying their price to that of the underlying stock.
Beyond this theoretical connection, analysis shows that most of the option data fit the
put-call parity conditions even in the absence of trading costs, and that relatively small
57 Using the market model in the analysis of Alibaba’s ADS price response to news
discussed above, Alibaba’s daily raw and market-adjusted ADS price movements were
both over 10 percent in absolute magnitude from January 27 to January 29, 2015 (i.e,
both the return from January 27 to January 28 and the return from January 28 to 29 were
greater than 10 percent in absolute magnitude). This price movement was also
statistically significant according to the event-study analysis described above. Both the
raw and market-adjusted price movements are well over the 2.77 percent trading cost
figure discussed above. Thus, the news related to these disclosures should be sufficient
to move the prices of Alibaba’s options, meaning that the price impact of that news
would be observed in the markets for Alibaba’s ADSs, calls, and puts.
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trading costs or intraday price differences can explain the small violations of those
conditions. This further supports my conclusion that Alibaba’s puts and calls traded in
efficient markets.
VII. DAMAGES FOR INVESTORS IN ALIBABA’S ADSS AND OPTIONS
CAN BE CALCULATED THROUGH A COMMON METHODOLOGY
78.
While I have not yet been asked to determine the level of inflation in
Alibaba’s ADSs and options, I have been asked to provide an opinion on whether such an
analysis can be performed on a Class-wide basis for each of the securities. As discussed
below, the answer is unambiguously that such a common methodology is not only
possible, but is the only appropriate way to measure damages in a fraud-on-the-market
securities class action. While the particular inflation series would be different for the
three securities (and, in fact, would be negative or represent deflation in the case of the
put options if Plaintiffs’ theory of liability is correct), each analysis would apply for one
security and could be applied to all the Class members with trades in that security.
79.
A fraud-on-the-market securities class action assumes that members of the
class have overpaid (in the most common type of case) because the market price of the
security they purchased was artificially inflated. Thus, the proper form of analysis
depends not on what an individual investor believed, but on the degree, if any, by which
the market price of the security in question was inflated.58 As all investors face the same
market price, the proper analysis of damages will be the same across all investors in any
given security.
80.
The starting point for damages for an investor is determined by the amount of
artificial inflation in a security at the time of their purchase less the inflation in that
58 Certain investors, such as defendants, may be excluded from a class based on their
knowledge or beliefs, as the fraud-on-the-market theory applies to an investor who “buys
or sells stock [or another security] at the price set by the market[.]”Basic Inc. v. Levinson,
485 U.S. 224, 247, 108 S. Ct. 978, 99 L. Ed. 2d 194 (1988).
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security when sold. If an investor holds their purchase past the end of the class period,
then the starting point for damages is the amount of inflation at the time of purchase.
Further adjustments may be necessary if the amount of inflation declines for reasons
other than a corrective disclosure (e.g., if inflation changes due to market or company-
specific reasons unrelated to the allegations). In addition, the 1995 Private Securities
Litigation Reform Act provides a limitation on damages. Notably, all of the above
calculations are performed on a class-wide basis.
81.
For common stock or ADSs, the inflation calculation referenced above is
based on an event study, or, in this matter, the analysis of the change in the market prices
of Alibaba’s ADSs, accounting for changes in market and/or industry effects, on the
date(s) of any corrective disclosure(s) based on the allegations in the case. For example,
the Complaint alleges that news on the evening of January 27, 2015 and before the
market opened on January 29, 2015 disclosed information relate to the allegations in this
matter.59
82.
In addition, to the extent that there is material news unrelated to the
allegations on any corrective disclosure date, the effects of that news must be accounted
for to obtain the amount of the price movement due to the corrective information.60 The
news that affected the ADS price on January 28, 2015 included Alibaba’s
acknowledgement of the July 16 meeting as well as the company’s earnings
announcement. I note that the Amended Memorandum Decision and Order Granting
59 Complaint, ¶¶15 and 17.
60 For example, it is common to look at corrective disclosures that occur simultaneously
with or as part of an earnings announcement to see how much of the earnings miss is
attributable to the corrective disclosure or the effects that the corrective disclosure
reveals. I note that this share can be larger or smaller than the actual earnings surprise
(e.g., a company can miss earnings by ten cents a share due to negative effects of twelve
cents a share due to the corrective disclosure offset by two cents a share of unexpected
positive news unrelated to the allegations). Notably, this is a common procedure and has
a common effect on the inflation in the stock or ADS (and, from there to the options) for
all Class members.
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Defendants’ Motion to Dismiss dated June 27, 2016, p. 14, states that “Plaintiffs make
clear, then that their allegations about the Red Shield Program and Alibaba’s reliance on
counterfeit goods are not independent violations of Section 10(b) and Rule 10b-5. …
Rather, they are part and parcel of a single, unified allegation that the failure to disclose
the fact of the July 16 Meeting and the delivery of administrative guidance by the SAIC
violated the federal securities laws.” At this point, I have not investigated whether any,
some, or all of the earnings news related to changes in Alibaba’s practices regarding
reliance on counterfeit goods, as some of the analysis may depend on discovery and on
forensic accounting analyses.61 Notably, any such discovery would be relevant to all
class members, and any analyses are based on information obtained in discovery would
be relevant to the determination of inflation in a manner that is relevant to all members of
the Class.
83.
For options, the inflation (or deflation) can be calculated with reference to the
inflation in the ADSs. An option-pricing formula, such as the Black-Scholes formula,
provides a relationship between the price of an option, the price of the underlying stock
(or ADS), and a parameter known as the volatility or the implied volatility of the stock or
ADS. In this case, one would use the actual trading prices of the ADSs and options to
back out the “implied” volatility from the formula. Then, the formula could be applied
using the “but-for” ADS price (i.e., the price of the ADS less the artificial inflation
caused by any misrepresentations) and that calculated implied volatility to obtain the but-
for option prices. The difference between the actual and but-for option prices would
represent the inflation or deflation in each option on each day in the Class Period.
84.
While there may be questions about how to calculate inflation, those questions
will affect all members of the Class who purchased a given security in the same manner.
Consequently, the inflation in any security will be determined in a common manner for
61 To be clear, I am not opining that these are necessary, but merely that as I have not yet
been asked to perform a full damages analysis, I am not offering an opinion as to the
exact details of what that analysis would entail.
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all Class members. The resultant figures will then be applied to each Class member’s
transactions in a mechanical fashion to determine the appropriate claim for each member
of the Class.
I reserve the right to modify or extend my opinion in light of any new
information, including submissions by any experts for Defendants, that becomes
available to me.
tJ
David I. Tabak
March 9, 2018
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David I. Tabak
Managing Director
National Economic Research Associates, Inc.
1166 Avenue of the Americas
New York, New York 10036
+1 212 345 3000 Fax +1 212 345 4650
Direct dial: +1 212 345 2176
david.tabak@nera.com
www.nera.com
EXHIBIT 1
DAVID I. TABAK
MANAGING DIRECTOR
Dr. Tabak earned his Ph.D. and M.A. degrees in Economics from Harvard University and his
B.S. in Economics and B.S. in Physics from the Massachusetts Institute of Technology. While at
Harvard, Dr. Tabak participated in teaching courses in micro- and macroeconomics and
American economic policy at the undergraduate and graduate levels and in the creation of an
undergraduate textbook and accompanying software package.
Dr. Tabak has appeared as an expert in state, federal, and bankruptcy court, and before
arbitration panels, including the National Association of Securities Dealers, the American
Arbitration Association, the International Dispute Resolution Centre, and the International
Chamber of Commerce International Court of Arbitration. He has published in his areas of
expertise in forums such as St. John’s Law Review and Shannon Pratt’s Business Valuation
Update, and has published peer-reviewed articles in Litigation Economics Review and the
Journal of Forensic Economics. Dr. Tabak is also the author of book chapters and has served as
a member of BV Q&A Update’s expert author panel and as a referee for peer-reviewed journals.
His publications have covered topics such as commercial disputes, economic analysis of market
efficiency, valuation discounts for lack of marketability, and the application of statistics in
litigation analyses. Dr. Tabak has been an invited presenter at the Securities and Exchange
Commission and has spoken at forums that provide continuing legal education credits or
continuing professional education credits for accountants and valuation professionals.
Dr. Tabak has been retained as an expert to address issues including allegations of valuations,
contract disputes, commercial damages, and disputes between brokers and customers. His non-
litigation work has included developing a risk-scoring model for a reinsurance company,
assisting financial institutions in new product development, analysis of potential insider trading
for a financial institution, and interpretation of statistical analyses of treatment effectiveness for a
program for at-risk youth.
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David I. Tabak
NERA Economic Consulting
2
Education
Harvard University
Ph.D., Economics, 1996
M.A., Economics, 1992
Massachusetts Institute of Technology
B.S., Economics, 1990
B.S., Physics, 1990
Professional Experience
NERA Economic Consulting
2005-
Managing Director (f/k/a Senior Vice President)
Provide written and oral testimony. Conduct and supervise economic analyses,
with a focus on securities litigation and valuation cases.
2001-2005
Vice President
1998-2001
Senior Consultant
1996-1998
Senior Analyst
Harvard University
1991-1996
Teaching Fellow in Economics
Participated in teaching various courses from introductory principles of
economics to graduate macroeconomics. Ran coursewide tutorial program for the
largest class at Harvard for two academic years, with a staff of over fifty part-time
employees.
Worth Publishers
1991, 1993
Research Assistant/Independent Contractor
Worked on data collection, software analysis, and creation of a problem bank for
an educational economics software package.
National Bureau of Economic Research
1991
Research Assistant
Performed data collection and econometric analysis for a project on comparisons
of international growth rates.
Honors and Professional Activities
Member, American Economic Association, 1993-present
Referee, Journal of Forensic Economics, 2005, 2006, 2008, 2009, 2011, 2012, 2015
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David I. Tabak
NERA Economic Consulting
3
Referee, Litigation Economics Review, 2002, 2003, 2004
William M. Mercer Securities Corporation, Registered Representative, Series 7 and 63,
2000 - 2002
Marsh & McLennan Securities Corporation, Registered Representative, Series 7 and 63,
1998 - 2000
Adjunct Member, Committee on International Trade, Association of the Bar of the City of
New York, 1998 – 2001
Harvard University Scholarship, 1990-1992
Derek Bok Teaching Award, 1993, 1994, 1995, and 1996
Allyn Young Teaching Award, 1996
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Expert Reports and Testimony
Expert Report of David I. Tabak, Ph.D. before JAMS Arbitration in John Mariani, Jr. et al. v.
James Mariani et al., February 21, 2018.
Expert Report of David I. Tabak, Ph.D. before the Court of Chancery of the State of Delaware in
A. Schulman, Inc., et al. v. Citadel Plastics Holdings, LLC, et al., February 16, 2018.
Rebuttal Expert Report of David I. Tabak, Ph.D. before the United States District Court for the
Southern District of New York in In re Vale S.A. Securities Litigation, November 17, 2017.
Deposition testimony before the United States District Court for the Southern District of New
York in In re Vale S.A. Securities Litigation, October 26, 2017.
Report of David I. Tabak, PhD in Babscay Pty Ltd v. Slater & Gordon Limited, Federal Court
Proceeding VID 659 / 2017, Australia, October 26, 2017.
Deposition testimony before the Supreme Court of the State of New York, County of
Westchester, in Paraco Gas Corporation v. Ferrellgas, L.P., September 28, 2017.
Rebuttal Expert Report of David I. Tabak, Ph.D. before the Supreme Court of the State of New
York, County of Westchester, in Paraco Gas Corporation v. Ferrellgas, L.P., September 20,
2017.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of New York in In re Vale S.A. Securities Litigation, September 14, 2017.
Expert Report of David I. Tabak, Ph.D. before the Supreme Court of the State of New York,
County of Westchester, in Paraco Gas Corporation v. Ferrellgas, L.P., August 24, 2017.
Supplement to Reply Expert Report of David I. Tabak, Ph.D. before the United States District
Court for the District of Vermont in Louisiana Municipal Police Employees’ Retirement System
et al. v. Green Mountain Coffee Roasters, Inc. et al., August 9, 2017.
Deposition Testimony before the United States District Court for the District of Vermont in
Louisiana Municipal Police Employees’ Retirement System et al. v. Green Mountain Coffee
Roasters, Inc. et al., August 1, 2017.
Reply Expert Report of David I. Tabak, Ph.D. before the United States District Court for the
District of Vermont in Louisiana Municipal Police Employees’ Retirement System et al. v. Green
Mountain Coffee Roasters, Inc. et al., June 15, 2017.
Sur-Reply Expert report of David I. Tabak, Ph.D. before the United States District Court for the
District of New Jersey in Bing Li et al. v. Aeterna Zentaris et al., May 31, 2017.
Reply Expert Report of David I. Tabak, Ph.D. before the United States District Court for the
District of Vermont in Louisiana Municipal Police Employees’ Retirement System et al. v. Green
Mountain Coffee Roasters, Inc. et al., May 26, 2017.
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Expert Report of David I. Tabak, Ph.D. before the United States District Court for the District of
South Carolina in Edna Selan Epstein et al. vs. World Acceptance Corporation et al., May 8,
2017.
Deposition Testimony before the United States District Court for the District of New Jersey in
Bing Li et al. v. Aeterna Zentaris et al., April 21, 2017.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the District of
Vermont in Louisiana Municipal Police Employees’ Retirement System et al. v. Green Mountain
Coffee Roasters, Inc. et al., April 13, 2017.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the District of
New Jersey in Bing Li et al. v. Aeterna Zentaris et al., March 23, 2017.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the District of
South Carolina in Edna Selan Epstein et al. vs. World Acceptance Corporation et al., March 16,
2017.
Supplement to Expert Report of David I. Tabak, Ph.D. before the United States District Court for
the Northern District of California in In re Rocket Fuel, Inc. Securities Litigation, February 21,
2017.
Deposition Testimony before the United States District Court for the Middle District of Florida,
Jackson Division in In re Rayonier Inc. Securities Litigation, February 8, 2017.
Expert Rebuttal Report of David I. Tabak, Ph.D. before the United States District Court for the
Southern District of New York in In re Salix Pharmaceuticals, January 17, 2017.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Middle
District of Florida, Jackson Division in In re Rayonier Inc. Securities Litigation, December 12,
2016.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the District of
Vermont in Louisiana Municipal Police Employees’ Retirement System et al. v. Green Mountain
Coffee Roasters, Inc. et al., December 9, 2016.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Northern
District of California in In re Rocket Fuel, Inc. Securities Litigation, December 8, 2016.
Deposition Testimony before the United States District Court for the Southern District of New
York in In re Salix Pharmaceuticals, November 3, 2016.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of New York in In re Salix Pharmaceuticals, October 7, 2016.
Rebuttal Expert Report of David Tabak, Ph.D. before the United States District Court for the
District of Minnesota in Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude
Medical, Inc. et al., May 6, 2016.
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Deposition Testimony before the United States District Court for the District of Minnesota in
Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude Medical, Inc. et al.,
February 11, 2016.
Deposition Testimony before the United States District Court for the Eastern District of Virginia
in In re Genworth Securities Litigation, February 9, 2016.
Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the Eastern
District of Virginia in In re Genworth Securities Litigation, February 3, 2016.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Western
District of Texas in KB Partners I v. Pain Therapeutics, Inc. et al., January 29, 2016.
Expert Report of David Tabak, Ph.D. before the Securities and Exchange Commission in In the
Matter of Arthur F. Jacob, CPA and Innovative Business Solutions, LLC, January 29, 2016.
Deposition Testimony before the United States District Court for the Eastern District of New
York in In re Symbol Technologies, Inc. Securities Litigation, January 28, 2016.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
Minnesota in Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude Medical,
Inc. et al., December 23, 2015.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Eastern
District of Virginia in In re Symbol Technologies, Inc. Securities Litigation, December 11, 2015.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Eastern
District of Virginia in In re Genworth Securities Litigation, December 2, 2015.
Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the District of
Minnesota in Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude Medical,
Inc. et al., November 16, 2015.
Expert Report of David I. Tabak, Ph.D. in the United States District Court for the Western
District of Texas in KB Partners I v. Pain Therapeutics, Inc. et al., November 12, 2015.
Deposition Testimony before the United States District Court for the District of Minnesota in
Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude Medical, Inc. et al.,
September 2, 2015.
Deposition Testimony before the United States District Court for the Southern District of
California in In re Bridgepoint Securities Litigation, July 20, 2015.
Rebuttal Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of California in In re Bridgepoint Securities Litigation, June 15, 2015.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of California in In re Bridgepoint Securities Litigation, June 1, 2015.
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Expert Report of David I. Tabak, Ph.D. before the Supreme Court of the State of New York,
Nassau County, in John M. Ferolito et al. against AriZona Beverages USA LLC et al., March 30,
2015.
Declaration of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of New York in George Byrun et al. v. Salix Pharmaceuticals et al., 30 January 2015.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
Minnesota in Första AP-Fonden and Danke Invest Management A/S et al. v. St. Jude Medical,
Inc. et al., January 13, 2015.
Expert Report of David Tabak before the Securities and Exchange Commission in the matter of
Airtouch Communications, Inc., Hideyuki Kanakubo, and Jerome Kaiser, CPA, December 16,
2014.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Southern
District of New York in In re Puda Coal Securities et al. Litigation, November 13, 2014.
Deposition Testimony before the United States District Court for the Southern District of Ohio,
Western Division (at Dayton) in Antioch Litigation Trust, W. Timothy Miller, Trustee, against
McDermott Will & Emery LLP, July 2, 2014.
Testimony before the Supreme Court of the State of New York, Nassau County, in John M.
Ferolito et al. against AriZona Beverages USA LLC et al., June 16, 2014.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of Ohio, Western Division (at Dayton) in Antioch Litigation Trust, W. Timothy Miller,
Trustee, against McDermott Will & Emery LLP, June 11, 2014.
Supplemental Expert Report of David I. Tabak, Ph.D. before the Supreme Court of the State of
New York, Nassau County, in John M. Ferolito et al. against AriZona Beverages USA LLC et al.,
June 3, 2014.
Deposition before the Supreme Court of the State of New York, Nassau County, in John M.
Ferolito et al. against AriZona Beverages USA LLC et al., March 31, 2014.
Cross Examination in the Matter of the Companies’ Creditors Arrangement Act and in the Matter
of a Plan of Compromise or arrangement of Nortel Networks Corporation et al. before the
Ontario Superior Court of Justice (Commercial List), March 19, 2014.
Report of David I. Tabak, Ph.D. before the Supreme Court of the State of New York, Nassau
County, in John M. Ferolito et al. against AriZona Beverages USA LLC et al., March 11, 2014.
Report of David I. Tabak in the Matter of the Companies’ Creditors Arrangement Act and in the
Matter of a Plan of Compromise or arrangement of Nortel Networks Corporation et al. before the
Ontario Superior Court of Justice (Commercial List), February 28, 2014.
Deposition Testimony before the United States District Court for the District of New Jersey in In
re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation, November 8, 2013.
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Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the District of
New Jersey in In re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation, September
4, 2013.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
New Jersey in In re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation, July 12,
2013.
Deposition Testimony before the United States District Court for the Southern District of
California in In re Novatel Wireless Securities Litigation, June 27, 2013.
Deposition Testimony before the United States District Court for the Western District of Texas
in KB Partners I v. Pain Therapeutics, Inc. et al., May 10, 2013.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Southern
District of California in In re Novatel Wireless Securities Litigation, April 11, 2013.
Declaration of David I. Tabak, Ph.D. in the United States District Court for the Western District
of Texas in KB Partners I v. Pain Therapeutics, Inc. et al., March 21, 2013.
Reply Declaration of David Tabak, Ph.D. before the United States District Court for the District
of New Jersey in In re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation,
November 8, 2012.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Southern
District of New York in In re Bank of America Corp. Securities, Derivative, and Employee
Retirement Income Security Act (ERISA) Litigation, November 6, 2012.
Deposition Testimony before the United States District Court for the District of New Jersey in In
re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation, July 12, 2012.
Testimony before the United States Bankruptcy Court for the Southern District of New York in
In re: Adelphia Communications Corp. and Adelphia Recovery Trust vs. FPL Group, May 3,
2012.
Written Direct Testimony of David Tabak, Ph.D. before the United States Bankruptcy Court for
the Southern District of New York in In re: Adelphia Communications Corp. and Adelphia
Recovery Trust vs. FPL Group, April 17, 2012.
Declaration of David Tabak, Ph.D. before the United States District Court for the District of New
Jersey in In re Merck & Co, Inc. Securities, Derivative & “ERISA” Litigation, April 10, 2012.
Rebuttal Report before the Supreme Court of Victoria at Melbourne in Pathway Investments Pty
Ltd and Doystoy Pty Ltd vs. National Australia Bank Limited,January 30, 2012.
Expert Report before the Supreme Court of Victoria at Melbourne in Pathway Investments Pty
Ltd and Doystoy Pty Ltd vs. National Australia Bank Limited,December 5, 2011. (Affidavits
testifying to the report executed on December 9, 2011 and December 20, 2011.)
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Deposition Testimony before the United States Bankruptcy Court for the Southern District of
New York in In re: Adelphia Communications Corp. and Adelphia Recovery Trust vs. FPL
Group, August 1, 2011.
Expert Report of David Tabak, Ph.D. before the United States Bankruptcy Court for the
Southern District of New York in In re: Adelphia Communications Corp. and Adelphia Recovery
Trust vs. FPL Group, July 8, 2011.
Deposition Testimony before the United States District Court for the Southern District of
California in In re Novatel Wireless Securities Litigation, February 3, 2011.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Southern
District of California in In re Novatel Wireless Securities Litigation, January 11, 2011.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
New Jersey in Securities and Exchange Commission v. Alfred S. Teo, et al., November 4, 2010.
Declaration of David Tabak, Ph.D. before the United States District Court for the District of
Massachusetts in In re Smith and Wesson Holding Corp. Securities Litigation, October 29, 2010.
Deposition Testimony before the United States District Court for the District of Massachusetts in
In re Smith and Wesson Holding Corp. Securities Litigation, October 7, 2010.
Expert Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the
District of Massachusetts in In re Smith and Wesson Holding Corp. Securities Litigation,
September 16, 2010.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
Massachusetts in In re Smith and Wesson Holding Corp. Securities Litigation, August 30, 2010.
Rebuttal Declaration of David Tabak, Ph.D. before the United States District Court for the
Southern District of California in Maureen Bakke, et al. vs. Novatel Wireless, et al., April 25,
2010.
Declaration of David Tabak, Ph.D. before the United States District Court for the Southern
District of California in Maureen Bakke, et al. vs. Novatel Wireless, et al., March 12, 2010.
Testimony before the International Dispute Resolution Centre in the matter of an arbitration and
in the matter of the Arbitration Acts 1950-1979 between Motorola, Inc. and Ace Bermuda
Insurance, Ltd., November 6, 2009.
Expert Rebuttal Report of David Tabak, Ph.D., before the International Dispute Resolution
Centre in the matter of an arbitration and in the matter of the Arbitration Acts 1950-1979
between Motorola, Inc. and Ace Bermuda Insurance, Ltd., October 19, 2009.
Expert Report of David Tabak, Ph.D., before the United States District Court for the Central
District of California in Donald Johnson v. James D. Aljian, Kirk Kerkorian, and Tracinda
Corporation, September 17, 2009.
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Expert Report of David Tabak, Ph.D., before the International Dispute Resolution Centre in the
matter of an arbitration and in the matter of the Arbitration Acts 1950-1979 between Motorola,
Inc. and Ace Bermuda Insurance, Ltd., September 10, 2009.
Rebuttal Expert Report of David Tabak, Ph.D., before the District Court for the Northern District
of Georgia in In re NetBank Securities Litigation, July 16, 2009.
Declaration of David Tabak before the District Court for the Northern District of Texas in Fluor
Corporation v. Citadel Equity Fund Ltd., July 13, 2009.
Rebuttal Expert Report of David Tabak, Ph.D., before the District Court for the Northern District
of Texas in Fluor Corporation v. Citadel Equity Fund Ltd., June 26, 2009.
Deposition Testimony before the District Court for the Northern District of Georgia in In re
NetBank Securities Litigation, June 16, 2009.
Declaration and Expert Report of David Tabak, Ph.D., before the District Court for the Northern
District of Georgia in In re NetBank Securities Litigation, May 29, 2009.
Deposition Testimony before the District Court for the Northern District of Texas in Fluor
Corporation v. Citadel Equity Fund Ltd., May 6, 2009.
Expert Report of David Tabak, Ph.D., before the District Court for the Northern District of Texas
in Fluor Corporation v. Citadel Equity Fund Ltd., April 15, 2009.
Deposition Testimony before the Supreme Court of the State of New York, County of New
York, in Herbert Feinberg against Jerome S. Boros; Robinson, Silverman, Pearce, Aronsohn &
Berman and Bryan Cave, February 17, 2009.
Declaration of David Tabak, Ph.D., before the United States District Court for the Central
District of California in Donald Johnson v. James D. Aljian, Kirk Kerkorian, and Tracinda
Corporation, January 5, 2009.
Expert Report of David Tabak, Ph.D., before the Supreme Court of the State of New York,
County of New York, in Herbert Feinberg against Jerome S. Boros; Robinson, Silverman,
Pearce, Aronsohn & Berman and Bryan Cave, December 15, 2008.
Declaration of David Tabak, Ph.D., before the District Court for the Northern District of Texas
in Fluor Corporation v. Citadel Equity Fund Ltd., November 7, 2008.
Deposition Testimony before the District Court for the Southern District of New York in In Re
American International Group Inc. Securities Litigation, October 31, 2008.
Declaration of David Tabak, Ph.D., before the District Court for the Southern District of New
York in In Re American International Group Inc. Securities Litigation, September 23, 2008.
Cross-Examination before the Superior Court of Justice, Ontario, in Peter McCann v. CP Ships
Limited, Raymond Miles, Frank Halliwell, and Ian Weber, June 23, 2008.
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Surrebuttal Report of David Tabak before the New York Stock Exchange in Ronald G.
Pettengill, et al. v. Robertson Stephens, Inc. et al., January 11, 2008.
Affidavit of David I. Tabak before the Superior Court of Justice, Ontario, in Peter McCann v. CP
Ships Limited, Raymond Miles, Frank Halliwell, and Ian Weber, December 19, 2007.
Rebuttal Report of David Tabak before the New York Stock Exchange in Ronald G. Pettengill,
et al. v. Robertson Stephens, Inc. et al., December 19, 2007.
Report of David Tabak before the New York Stock Exchange in Ronald G. Pettengill, et al. v.
Robertson Stephens, Inc. et al., December 3, 2007.
Deposition Testimony before the District Court for the Northern District of Georgia in
Carpenters Health & Welfare Fund, et al. vs. The Coca-Cola Company, August 23, 2007.
Deposition Testimony before the District Court of the Fourth Judicial District of the State of
Idaho, in and for the County of Ada in Holmes Lundt et al. v. Fenwick & West, LLP and Robert
A. Freedman, June 13, 2007.
Expert Report of David Tabak before the District Court for the Northern District of Georgia in
Carpenters Health & Welfare Fund, et al. vs. The Coca-Cola Company, May 30, 2007.
Deposition Testimony before the United States District Court for the Southern District of New
York in In re Omnicom Group Inc. Securities Litigation, April 27, 2007.
Expert Report of David Tabak before the District Court of the Fourth Judicial District of the
State of Idaho, in and for the County of Ada in Holmes Lundt et al. v. Fenwick & West, LLP and
Robert A. Freedman, April 4, 2007. (Amended report, June 25, 2007.)
Rebuttal Report of David Tabak before the United States District Court for the Southern District
of New York in In re Omnicom Group Inc. Securities Litigation, January 18, 2007.
Expert Report of David Tabak before the United States District Court for the Southern District of
New York in In re Omnicom Group Inc. Securities Litigation, December 18, 2006.
Deposition Testimony before the United States District Court for the District of Colorado in
Genesis Insurance Company v. Daniel D. Crowley, Arlin M. Adams, National Union Fire
Insurance Company of Pittsburgh PA, November 9, 2006.
Deposition Testimony before the United States District Court for the Eastern District of
Michigan in In re CMS Energy Securities Litigation, October 13, 2006.
Affidavit of David I. Tabak before the United States District Court for the District of Colorado in
In re Rhythms Securities Litigation, October 11, 2006.
Rebuttal Report before the United States District Court for the Eastern District of Michigan in In
re CMS Energy Securities Litigation, October 4, 2006.
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Expert Report before the United States District Court for the District of Colorado in Genesis
Insurance Company v. Daniel D. Crowley, Arlin M. Adams, National Union Fire Insurance
Company of Pittsburgh PA, October 4, 2006.
Deposition Testimony before the United States District Court for the Eastern District of
Michigan in In re CMS Energy Securities Litigation, September 15, 2006.
Expert Report before the United States District Court for the Eastern District of Michigan in In
re CMS Energy Securities Litigation, August 25, 2006.
Deposition Testimony before the United States District Court for the District of Colorado in In re
Rhythms Securities Litigation, July 20, 2006.
Deposition Testimony before the United States District Court for the Southern District of Texas
in In re Enron Corporation Securities Litigation, May 25, 2006.
Affidavit before the United States District Court for the Northern District of Oklahoma in In re
Williams Securities Litigation (WCG Subclass), April 14, 2006.
Deposition Testimony before the United States District Court for the Northern District of
Oklahoma in In re Williams Securities Litigation (WCG Subclass), March 24, 2006.
Rebuttal Expert Report of David Tabak before the United States District Court for the Southern
District of Texas in In re Enron Corporation Securities Litigation, March 17, 2006.
Rebuttal Expert Report of David Tabak before the United States District Court for the Northern
District of Oklahoma in In re Williams Securities Litigation (WCG Subclass), March 9, 2006.
Expert Report of David Tabak before the United States District Court for the District of
Colorado in In re Rhythms Securities Litigation, February 13, 2006.
Expert Report of David Tabak before the United States District Court for the Northern District of
Oklahoma in In re Williams Securities Litigation (WCG Subclass), February 1, 2006.
Rebuttal Report of David Tabak, Ph.D. before the American Arbitration Association in Warren
N. Lieberfarb v. Warner Home Video Inc., November 30, 2005.
Deposition Testimony before the American Arbitration Association in Warren N. Lieberfarb v.
Warner Home Video Inc., November 9, 2005.
Expert Report of David Tabak, Ph.D. before the American Arbitration Association in Warren N.
Lieberfarb v. Warner Home Video Inc., October 3, 2005.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Eastern
District of Pennsylvania in Sean Fitzpatrick v. Michael Queen, Thomas McGreal, Joseph W.
Luter, IV, Michael H. Cole, Smithfield Foods, Inc., Showcase Foods, Inc., and Pennexx Foods,
Inc., March 25, 2005.
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Deposition Testimony before the United States District Court for the Northern District of
Georgia, Atlanta Division in In re CryoLife, Inc. Securities Litigation, February 24, 2005.
Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the Northern
District of Georgia, Atlanta Division in In re CryoLife, Inc. Securities Litigation, February 18,
2005.
Affidavit of David Tabak, Ph.D. and Stephanie Plancich, Ph.D. before the United States District
Court for the Northern District of Illinois, Eastern Division in Doug Sutton and Prescott
Nottingham v. Robert F. Bernard, Robert T. Clarkson, and Bert B. Young, January 11, 2005.
Deposition Testimony before the United States District Court for the Northern District of
Georgia, Atlanta Division in In re CryoLife, Inc. Securities Litigation, January 5, 2005.
Expert Report of David I. Tabak before the United States District Court for the Eastern District
of New York in Phoenician Trading Partners, L.P. v. Blue Water Fund Ltd., et al., January 3,
2005.
Affidavit of David Tabak, Ph.D. before the United States District Court for the Northern District
of Georgia, Atlanta Division in David Jones and Susan Jones v. InfoCure Corporation, et al.,
December 14, 2004.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Northern
District of Georgia, Atlanta Division in In re CryoLife, Inc. Securities Litigation, December 10,
2004.
Deposition Testimony before the United States District Court for the Northern District of
Georgia, Atlanta Division in David Jones and Susan Jones v. InfoCure Corporation, et al.,
October 4, 2004.
Rebuttal Report of David Tabak, Ph.D. before the United States District Court for the Northern
District of Georgia, Atlanta Division in David Jones and Susan Jones v. InfoCure Corporation,
et al., September 22, 2004.
Deposition Testimony before the United States District Court for the Northern District of Illinois,
Eastern Division in Richard C. Snyder, et al. v. Thomas and Betts Corporation, September 9,
2004.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Northern
District of Illinois, Eastern Division in Richard C. Snyder, et al. v. Thomas and Betts
Corporation, August 20, 2004.
Further Additional Statement of David Tabak before the New York Stock Exchange in Robert
Belau et al. v. FleetBoston Financial Corporation et al., July 30, 2004.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Northern
District of Georgia, Atlanta Division in David Jones and Susan Jones v. InfoCure Corporation,
et al., June 30, 2004.
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Testimony before the United States Bankruptcy Court for the District of Delaware in In Re
Coram Healthcare Corp. and Coram, Inc., April 7, 2004.
Deposition Testimony before the United States Bankruptcy Court for the District of Delaware in
In Re Coram Healthcare Corp. and Coram, Inc., April 2, 2004.
Expert Report of David Tabak before the United States Bankruptcy Court for the District of
Delaware in In Re Coram Healthcare Corp. and Coram, Inc., March 31, 2004.
Statement of David Tabak, Ph.D. before the United States District Court for the Southern District
of New York in United States of America v. Morris Weissman, February 10, 2004.
Additional Statement of David Tabak before the New York Stock Exchange in Robert Belau et
al. v. FleetBoston Financial Corporation et al., December 17, 2003.
Expert Report of David Tabak, Ph.D. before the United States District Court for the Southern
District of Ohio Eastern District (at Columbus) in Barry F. Bovee, et al. v. Coopers & Lybrand,
et al., December 16, 2003.
Deposition Testimony before the United States District Court for the District of South Carolina
in In Re Safety-Kleen Stockholders Litigation and in In Re Safety-Kleen Rollins Shareholders
Litigation, October 23, 2003.
Statement of David Tabak before the New York Stock Exchange in Robert Belau et al. v.
FleetBoston Financial Corporation et al., October 1, 2003.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
South Carolina in In Re Safety-Kleen Stockholders Litigation, August 28, 2003.
Expert Report of David Tabak, Ph.D. before the United States District Court for the District of
South Carolina in In Re Safety-Kleen Rollins Shareholders Litigation, August 28, 2003.
Testimony before the NASD in Ralph Rubenstein, JANT Foundation, et al. v. Merrill Lynch,
Pierce, Fenner & Smith, Inc., June 19, 2003.
Affidavit of David Tabak, Ph.D. and Ramzi Zein, Ph.D. in Support of Norwegian Cruise Line’s
Opposition to Proposed Rule before the Federal Maritime Commission, May 30, 2003.
Testimony before the Circuit Court of Maryland for Baltimore City in Carnegie International
Corporation, et al. vs. Grant Thornton, LLP., et al., March 11 and 12, 2003.
Declaration of David I. Tabak in Support of Defendant’s Motion in Opposition to Appointment
of Additional Lead Plaintiffs and Class Certification before the United States District Court for
the District of Columbia in In Re Baan Company Securities Litigation, June 21, 2002.
Affidavit before the United States District Court for the District of Rhode Island in George
Kinney et al. v. Metro Global Media, Inc., et al. May 15, 2002.
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Testimony before the American Arbitration Association in Beth Kaplan v. Rite Aid Corporation;
Rite Aid Corporation v. Beth Kaplan and Bruce Sholk, May 2-3, 2002.
Expert Report of David I. Tabak before the United States District Court for the District of Idaho
in Pippin v. ICF Kaiser International, et. Al, Wood v. Edwards et al., February 11, 2002.
Deposition Testimony before the United States District Court for the District of Columbia in In
Re Baan Company Securities Litigation, February 7, 2002.
Deposition Testimony before the United States District Court for the Eastern District of
Pennsylvania in In Re Equimed Securities, Inc. Litigation, January 17, 2002.
Affidavit before the United States District Court for the District of Columbia in In Re Baan
Company Securities Litigation, January 10, 2002.
Expert Report of David I. Tabak before the United States District Court for the Eastern District
of Pennsylvania in In Re Equimed Inc. Securities Litigation, December 28, 2001.
Expert Report of David I. Tabak before the United States District Court for the Southern District
of New York in Castle Creek Technology Partners LLC against Cellpoint Inc., December 13,
2001.
Deposition Testimony before the United States District Court for the Southern District of New
York in Morgens, Waterfall, Vintiadis & Co., Inc. et al. against Donaldson, Lufkin & Jenrette
Securities Corporation et al., October 11, 2001.
Deposition Testimony before the Circuit Court of Maryland for Baltimore City in Carnegie
International Corporation, et al. vs. Grant Thornton, LLP., et al., September 25, 2001.
Expert Report of David I. Tabak, Ph.D. before the Circuit Court of Maryland for Baltimore City
in Carnegie International Corporation, et al. vs. Grant Thornton, LLP., et al., September 17,
2001.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of New York in Morgens, Waterfall, Vintiadis & Co., Inc. et al. against Donaldson,
Lufkin & Jenrette Securities Corporation et al., September 6, 2001.
Testimony before the United States District Court for the Eastern District of New York in United
States of America against Harry Shuster, July 30, 2001.
Declaration before the United States District Court for the Eastern District of New York in
United States of America against Roy Ageloff, et al., July 23, 2001.
Testimony before the National Association of Securities Dealers in In the Matter of the
Arbitration Between Michael A. Brownlee, M.D. against Marc Keller, Schroder & Co., Inc. and
Sanfrey Securities, Inc., May 29, 2001.
Opinion Letter before the United States District Court for the Eastern District of New York in
United States of America against Roy Ageloff, et al., May 24, 2001.
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Testimony before the United States District Court for the Southern District of New York in
Oscar Gruss & Son, Inc. against Yossie Hollander, May 22, 2001.
Testimony before the Supreme Court of the State of New York, County of New York in Robert
Klein against 5B Technologies Corporation f/k/a Paramount Financial Corporation and
Deltaforce Personnel Services, Inc., May 17, 2001.
Expert Report of David I. Tabak, Ph.D. before the National Association of Securities Dealers in
In the Matter of the Arbitration Between Michael A. Brownlee, M.D. against Marc Keller,
Schroder & Co., Inc. and Sanfrey Securities, Inc., April 25, 2001.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Central
District of California in In Re Imperial Credit Industries, Inc. Securities Litigation, April 5,
2001.
Affidavit before the United States District Court for the Southern District of New York in Oscar
Gruss & Son, Inc. against Yossie Hollander, February 8, 2001.
Deposition Testimony before the Circuit Court of the 15th Judicial Circuit in and for Palm Beach
County, Florida in U.S. Diagnostic, Inc. and Diversified Therapy Corporation vs. Bachner,
Tally, Polevoy & Misher, LLP and Michael Karsch, January 19, 2001.
Expert Report of David I. Tabak before the Circuit Court of the 15th Judicial Circuit in and for
Palm Beach County, Florida in U.S. Diagnostic, Inc. and Diversified Therapy Corporation vs.
Bachner, Tally, Polevoy & Misher, LLP and Michael Karsch, January 11, 2001.
Supplemental Expert Report of David I. Tabak before the State of Minnesota, County of
Hennepin District Court, Fourth Judicial District in Irving P. Knelman v. Investment Advisers,
Inc., September 13, 2000.
Expert Report of David I. Tabak before the United States District Court for the Eastern District
of New York in Martin R. Lautman v. The Loewen Group Inc., et al., September 6, 2000.
Supplemental Affidavit of David I. Tabak before the Circuit Court of Franklin County, Alabama
in James Taff, individually and on behalf of all others similarly situated, vs. CareMark Rx, Inc
and PNC Bank, Kentucky Inc., May 25, 2000.
Affidavit of David I. Tabak and Christoph Muelbert before the Circuit Court of Franklin County,
Alabama in James Taff, individually and on behalf of all others similarly situated, vs. CareMark
Rx, Inc and PNC Bank, Kentucky Inc., May 23, 2000.
Expert Report of David I. Tabak before the State of Minnesota, County of Hennepin District
Court, Fourth Judicial District in Irving P. Knelman v. Investment Advisers, Inc., April 28, 2000.
Testimony before the American Arbitration Association in Roderick Covlin against C.S. Block
New York, LLC, Dr. Sharaif Amanat, Omar Amanat, March 30, 2000.
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Expert Report of David I. Tabak before the National Association of Securities Dealers Office of
Dispute Resolution in Brooks, Houghton & Company, Inc. Private Corporate Advisors, Inc., and
Brooks, Houghton Securities, Inc. against BIG Entertainment, Inc., March 17, 2000.
Declaration of David I. Tabak before the United States District Court for the Southern District of
New York in GST Telecommunications, Inc., GST USA, Inc., and GST Telecom Inc. v. Stephen
Irwin, David Adler, and Olshan Grundman Frome & Rosenzweig LLP, February 21, 2000.
Expert Report of David I. Tabak before the United States District Court for the Southern District
of New York in The Klass Report LLC and Christopher M. Klass against Telemation, Inc.,
December 15, 1999.
Expert Report of David I. Tabak, Ph.D. before the United States District Court for the Southern
District of New York in GST Telecommunications, Inc., GST USA, Inc., and GST Telecom Inc. v.
Stephen Irwin, David Adler, and Olshan Grundman Frome & Rosenzweig LLP, November 26,
1999.
Expert Report of David I. Tabak, Ph.D. before the National Association of Securities Dealers in
A.R. DiGima, Inc. vs. A.G. Edwards & Sons, Inc. and Eugene Damico, November 5, 1999.
Deposition Testimony before the United States District Court for the Southern District of New
York in Oscar Gruss & Son, Inc. against Yossie Hollander, October 22, 1999.
Expert Report of David I. Tabak before the United States District Court for the Southern District
of New York in Oscar Gruss & Son, Inc. against Yossie Hollander, September 16, 1999.
Expert Report of Frederick C. Dunbar and David I. Tabak before the United States District Court
for the Northern District of Alabama, Southern Division in MedPartners, Inc. v. Dun &
Bradstreet, Inc, July 28, 1999.
Testimony before the International Chamber of Commerce International Court of Arbitration in
Hanbo Engineering and Construction Co., Ltd. and Hanbo Corporation v. CE Casecnan Water
and Energy Company, Inc., April 13, 1998.
Expert Witness Statement of David I. Tabak before the International Chamber of Commerce,
International Court of Arbitration in Hanbo Engineering and Construction Co., Ltd. and Hanbo
Corporation v. CE Casecnan Water and Energy Company, Inc., March 13, 1998.
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Publications
“Securities Class Actions Appear to Be Largely ‘Price-Maintenance’ and Omissions Cases,”
NERA Working Paper, April 10, 2017.
“Further Insight into ‘What Should We Expect When Testing for Price Response to News in
Securities Litigation?’,” Oxford Business Law Blog, September 27, 2016.
“Gauging Share-Price Response to News in Securities Litigation,” The CLS Blue Sky Blog,
Columbia Law School’s Blog on Corporations and the Capital Markets, September 8, 2016.
“What Should We Expect When Testing for Price Response to News in Securities Litigation?”
NERA Working Paper, August 11, 2016.
“Should Solvency Tests Give the Same Answer?” NERA Working Paper, July 28, 2015
“Implications for Market Efficiency and Damages Analysis of Plaintiff Interpretations of
Halliburton II’s Statement that ‘market efficiency is a matter of degree,’” Loyola University
Chicago Law Journal, Spring 2015.
“The Solvency Two-Step,” Guest Post on the Weil Bankruptcy Blog. March 2013.
“Do Courts Count Cammer Factors?” NERA Working Paper, republished in the Harvard Law
School Forum on Corporate Governance and Financial Regulation. Also published in modified
form as “Counting Cammer Factors – A Review of Case Law” at Law360.com, August 2012.
“Settlement reasonableness from negotiations to coverage disputes,” Litigation and Dispute
Resolution 2012 Global Reference Guide. A prior version of this was published as a NERA
Working Paper, February 2012.
“Guesstimating Loss for Sentencing,” published in Law360.com, February 2012. (Originally
published with the title “Estimating Loss For Sentencing Purposes.” Retitled by Law360.com
after initial publication on its website.)
“Economic Analysis of Loss in the United States Sentencing Commission’s Proposed
Methodologies,” NERA Working Paper, February 2012.
“Guideline Companies in Valuation: A Careful View of the Market Approach,” Journal of
Business Valuation, 2011 Volume 1. (A previous version appeared as a NERA working paper
entitled “Guideline Companies in Valuation: The Economist’s View of the Market Approach” in
October 2008.)
“The Matrixx of Materiality and Statistical Significance in Securities Fraud Cases,” (co-authored
with Frederick Lee of Boies, Schiller & Flexner) NERA Working Paper, December 2010.
“Materiality and Statistical Significance Explained” (co-authored with Frederick Lee of Boies,
Schiller & Flexner), published in Law360.com, December 2010.
“Satisfying Fiduciary Duty Under ERISA,” Employment Law Strategist, June 2010.
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“Use and Misuse of Event Studies to Examine Market Efficiency,” NERA Working Paper, April
2010. (A previous version appeared in September 2009, and a condensed version appeared as a
Guest Column, “On the Misuse of Event Studies to Examine Market Efficiency,” in May 2010
on www.securitiesdocket.com.)
“Comment: ‘A Closer Look at Correction for False Discovery Bias When Making Multiple
Comparisons,” Journal of Forensic Economics, December 2009.
Book Review of Business Valuation: In Integrated Theory (Second Edition) in Valuation
Strategies, November/December 2008.
Guest Author/Respondent, BVUpdate, published by Business Valuation Resources, LLC, Special
Report: What Will the Wall Street Meltdown Mean to the BV Profession? (with Raymund
Wong), November 2008.
“Inflation and Damages in a Post-Dura World,” NERA Working Paper, September 2007.
“Multiple Comparisons and the Known or Potential Error Rate,” Journal of Forensic
Economics,” Volume XIX, Number 2, published March 2007.
“Making Assessments About Materiality Less Subjective Through The Use of Content
Analysis,” NERA Working Paper, March 2007.
“Risk Disclosures and Damages Measurement in Securities Fraud Cases,” published in the
Securities Reform Act Litigation Reporter, April 2006. (Previously published as a NERA
Working Paper.)
Guest Author/Respondent, BV Q&A Update, published by Business Valuation Resources, LLC.,
January, March, June, and July 2004; February, May, August, and September 2005.
“Loss Causation and Damages in Shareholder Class Actions: When it Takes Two Steps to
Tango,” in Securities Litigation & Enforcement Institute 2004, published by the Practising Law
Institute. (Previously published as a NERA Working Paper.)
“The ‘Less Than’ Efficient Capital Markets Hypothesis: Requiring More Proof From Plaintiffs in
Fraud-On-The-Market Cases” (with Paul A. Ferrillo and Frederick C. Dunbar), St. John’s Law
Review, Winter 2004. (Previously published as a working paper by NERA and Weil, Gotshal &
Manges, LLP.)
“Determination of the Appropriate Event Window Length in Individual Stock Event Studies”
(with Dmitry Krivin, Robert Patton, and Erica Rose), NERA Working Paper, November 4, 2003.
“Inflation Methodologies in Securities Fraud Cases: Theory and Practice” (with Chudozie
Okongwu), published in Securities Litigation & Enforcement Institute 2003, by the Practising
Law Institute. (Previously published as a NERA Working Paper.)
“Hedging and the Estimation of Marketability Discounts,” in Shannon Pratt’s Business
Valuation Update, published by Business Valuation Resources, LLC, August 2003. (Also
reprinted in BVR’s Guide to Discounts for Lack of Marketability, 2007.)
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“Shareholders’ Suit against Corporation,” in Litigation Support Report Writing: Accounting,
Finance, and Economic Issues, edited by Jack P. Friedman and Roman L. Weil, published by
John Wiley & Sons, Inc., 2003.
“A CAPM-Based Approach to Calculating Illiquidity Discounts,” NERA Working Paper,
November 2002.
“A Proposed Methodology to Measure Damages for Option Traders Alleging Securities Fraud”
(with Svetlana Starykh and Marc Shotland), Litigation Economics Review, Vol. 5, No. 2, Winter
2001 (printed July 2002).
“Intraday Trading Rates in Shareholder Class Actions,” NERA Securities and Finance Insights,
June 2002.
“Materiality and Magnitude: Event Studies in the Courtroom” (with Frederick C. Dunbar),
Litigation Services Handbook: The Role of the Financial Expert, Third Edition, 2001, edited by
Roman L. Weil, Michael J. Wagner and Peter B. Frank, published by John Wiley & Sons, Inc.
(Previous versions appeared in the 2000 Supplement to the Litigation Services Handbook and as
a NERA Working Paper.)
“Are Investors Signalling You About Your Y2K Risk?” (with Vinita M. Juneja and Denise N.
Martin), Y2K Marketwatch, December 1999.
“What Does the Market Think About Your Y2K Exposure?” (with Vinita M. Juneja and Denise
N. Martin), Viewpoint, Issue No. 2, November 1999.
“Economic Analysis and Identification of Class Conflicts in Securities Fraud Litigation,” NERA
Working Paper, June 1998.
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Selected Presentations
Panelist, “Emerging Issues in Securities Class Actions,” Duke Law Center for Judicial Studies,
New York, NY, July 20, 2017.
Panelist, “Keeping Or Closing The Employer Stock Fund: A Dudenhoeffer-Based Process,”
American Bar Association Section of Taxation, Chicago, IL, September 19, 2015.
Presenter, “Multiple Comparisons and the Known or Potential Error Rate,” National Association
of Forensic Economics session at the Eastern Economics Association, New York, NY, 27
February 2015.
Panelist, Annual Institute for Investor Protection Conference at Loyola University Chicago Law
School, 24 October 2014.
Panelist, 2014 Business Law Section Annual Meeting, American Bar Association, Chicago, 11
September 2014.
Moderator, New York University Ross Roundtable, April 7, 2014.
Commentator, Institute for Law and Economic Policy Conference: “Business Litigation and
Regulatory Agency Review in the Era of the Roberts Court,” April 4, 2014.
Panelist, “The Supreme Court’s Decision in Amgen and Other Recent Cases,”
Securitiesdocket.com; July 24, 2013.
Panelist, “Securities Law: Fraud-on-the-Market Theory Demystified,” The Knowledge Congress;
July 23, 2013.
Moderator, New York University Ross Roundtable, April 15, 2013.
Panelist, 1st Annual Securities Litigation & Enforcement Institute; New York City Bar; New
York, NY; December 11, 2012.
Panelist, The Litigation Summit and Exposition; Washington DC; November 12, 2012.
Panelist, The Society of Corporate Secretaries on materiality issues in determining corporate
disclosures, October 18, 2012; New York, NY.
Panelist, Symposium in honor of Nobel Prize Winner Daniel Kahneman at Loyola University,
Chicago, IL; October 5, 2012.
Panelist, Practising Law Institute, “Taking and Defending Expert Depositions”; New York, NY
June 27, 2012.
Discussant, National Association of Forensics Economics; Chicago IL; January 7, 2012.
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Panelist, Advanced eDiscovery Institute (session: Statistics and Sampling for Lawyers: How to
Apply a Well-Accepted Methodology in the World of eDiscovery); Washington DC; November
17, 2011.
Presenter, Securities Regulation Committee of the New York State Bar Association; New York,
New York; July 20, 2011.
Panelist, 2nd Annual Law Firm Marketing U& Business Development Leadership Forum,
sponsored by The American Lawyer (session: Macro Economic Industry-by-Industry Overview –
a power-packed session exploring the sectors that will shape 2011 and beyond); New York, NY;
May 24, 2011.
Presenter in webinar on “Fair Value Measurement Consideration for 2010 and Beyond,” The
Knowledge Congress, July 13, 2010.
Panelist, Forum for Institutional Investors, sponsored by Bernstein Litowitz Berger & Grossman
LLP; New York, NY; October 24, 2008.
Presenter, Office of Litigation Support, Securities and Exchange Commission; Washington, DC;
May 20, 2008.
Presenter, IQPC Subprime Litigation Conference; New York, New York; February 27, 2008.
Presenter, IQPC Securities Litigation Conference; New York, New York; May 18, 2007.
Presenter, “Everything You Were Afraid To Know About Experts,” Fordham University;
January 19, 2006.
Presenter, Eugene P. and Delia S. Murphy Conference on Corporate Law, Fordham University;
November 4, 2005.
Panel Member, Directors & Officers Under Fire: Protecting Your Interests in this Hostile
Environment, a Directors Roundtable seminar; Washington, D.C.; June 8, 2004.
Guest Lecturer, Fordham University; New York, New York; March 8, 2004.
Panel Member, Business Valuation Resources audio conference on discounts for lack of
marketability; May 14, 2003.
Presenter, Third Annual Law and Business Conference, Vanderbilt University Law School,
(“Inflation Methodologies in Securities Fraud Cases: Theory and Practice”); March 28, 2003.
Guest Lecturer, Middlebury College; Middlebury, Vermont; January 28, 2003.
Panel Member, Second Annual Grant & Eisenhofer Institutional Investor Conference; New
York, New York; December 9, 2002.
Guest Speaker, Deutsche Bank institutional investor conference call; November 22, 2002.
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Panel Member, Key Issues Facing Board Members: The Coming Tide in Securities Class
Actions, a Directors Roundtable seminar; Chicago, Illinois; February 22, 2001.
Panel Member, Securities Litigation: Risk Management and Avoidance, Emerging Challenges
for CXOs, a seminar sponsored by Jones, Day, Reavis and Pogue and PriceWaterhouseCoopers;
Reston, Virginia; September 20, 2000.
“When the Litigation Comes In and the Money Goes Out: What Determines Settlement Values?”
presented at Balancing Disclosure and Litigation Risks for Public Companies (or Soon-to-Be
Public Companies), a seminar sponsored by Alston & Bird and RR Donnelley Financial;
Raleigh, North Carolina; November 10, 1999.
February 2018
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Exhibit 2
Alibaba Group Holding Limited
Materials Considered
Page 1 of 16
Academic Literature
David Tabak and Frederick Dunbar, Chapter 19 of Litigation Services Handbook, The Role of the
Financial Expert, (3d ed. 2001).
Eugene Fama, “Efficient Capital Markets: A Review of Theory and Empirical Work,” Journal of
Finance, 1970.
James S. Doran, Andy Fodor and Kevin Krieger, “Option Market Efficiency and Analyst
Recommendations,” Journal of Business Finance & Accounting, June/July 2010, p. 584.
Klaus Krippendorff, Content Analysis: An Introduction to Its Methodology, 2nd edition, 2004, p.
59.
Paul Ferrillo, Frederick Dunbar, and David Tabak, “The ‘Less Than’ Efficient Capital Markets
Hypothesis: Requiring More Proof From Plaintiffs in Fraud-on-the-Market Cases,” 78 St. John’s
L. Rev. 81, 120-21 (2004).
Analyst Reports
“Alibaba Growth Reaccelerates in 2Q:CY14; Positive for YHOO’s 23% Stake,” Cantor
Fitzgerald, August 27, 2014.
“BABA: Mobile Take-Rate Key for IPO; Retail Market Structure Highly Favorable,” MKM
Partners, August 13, 2014.
“Open Sesame! Uncovering Alibaba’s Treasure Trove; Initiating at BUY with $90 PT,” Cantor
Fitzgerald, September 19, 2014.
“Yahoo! Inc.: ‘Baba in Overdrive on Route ‘66’…Next Stop, IPO?” Susquehanna Financial
Group, April 16, 2014.
“Yahoo! Inc.: Weaker Results Offset by Alibaba,” Barclays, July 16, 2014.
“YHOO – In-Line 1Q14 EPS with Upside from Alibaba & Display,” CRT Capital, April 16,
2014.
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Exhibit 2
Alibaba Group Holding Limited
Materials Considered
Page 2 of 16
Case Law
Basic Inc. v. Levinson, 485 U.S. 224, 247, 108 S. Ct. 978, 99 L. Ed. 2d 194 (1988).
Bricklayers and Trowel Trades v. Credit Suisse LLC, 752 F.3d 82 (1st Cir. 2014).
Cammer v. Bloom, 711 F. Supp. 1264, 1286-87 (D.N.J. 1989).
In re Countrywide Financial Corporation Securities Litigation, 273 F.R.D. 586, 618 (C.D. Cal.
2009).
In re DVI Securities Litigation, 249 F.R.D. 196, 213 (E.D.Pa. 2008) (“DVI I”).
In re DVI Securities Litigation, 639 F.3d 623,634 (3d Cir. 2011) (“DVI II”).
In re Executive Telecard, Ltd. Securities Litigation, 979 F. Supp. 1021, 1027 (S.D.N.Y. 1997).
In re Petrobras Securities Litigation, 862 F.3d 250 (2d Cir. July 7, 2017).
Krogman, Inc. v. Sterritt, 202 F.R.D. 467, 474, 478 (N.D. Tex. 2001).
Unger v. Amedisys Inc., 401 F.3d 316, 324 (5th Cir. 2005).
Data
Alibaba Group Holding Limited analyst coverage obtained from Capital IQ and Thomson
Reuters.
Alibaba Group Holding Limited ADS daily closing price, low price, high price, and trading
volume data obtained from Bloomberg L.P.
Alibaba Group Holding Limited earnings consensus estimate data, earnings report dates, and
number of analyst estimates obtained from Institutional Brokers’ Estimate System (I/B/E/S) via
FactSet Research Systems Inc.
Alibaba Group Holding Limited ADS options data obtained from iVolatility.
Alibaba Group Holding Limited quarterly institutional and insider holdings for ADSs obtained
from FactSet Research Systems Inc.
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Exhibit 2
Alibaba Group Holding Limited
Materials Considered
Page 3 of 16
(Data continued)
Alibaba Group Holding Limited ADS shares outstanding and ADSs outstanding data obtained
from Bloomberg L.P.
Alibaba Group Holding Limited ADS short interest data obtained from Bloomberg L.P.
Alibaba Group Holding Limited ADS 424B4, 6-K, and 20-F forms filed with the SEC.
Daily bid, ask, and closing price data for all NYSE constituents during the Class Period obtained
from FactSet Research Systems, Inc.
EMQQ Emerging Markets Internet Index data obtained from Bloomberg L.P.
Market maker participation rate data obtained from the NYSE website.
Treasury rates obtained from the Board of Governors of the Federal Reserve System, available at
https://www.federalreserve.gov/datadownload/Choose.aspx?rel=H15.
News Articles
“An Emerging Market ETF to Address the Alibaba Index Problem – Barron’s Blog,” Dow Jones
Institutional News, November 26, 2014.
See pages 5 - 17 for a list of news stories obtained from the Factiva Dow Jones used in Exhibits
8a, 8c, and 8d.
Pleadings in This Matter
Consolidated Complaint, dated July 1, 2015.
Other Materials
New Palgrave Dictionary of Economics, 2008 edition, entry on Efficient Markets Hypothesis,
available online at:
https://rd.springer.com/referenceworkentry/10.1057/978-1-349-95121-5_42-2.
2015 Valuation Handbook – Guide to Cost of Capital, Duff & Phelps, Appendix 3.
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Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
9/18/2014
5:12:00 PM
9/19/2014
Alibaba IPO Priced at $68 a Share, Top of Range, Source Says
Dow Jones Institutional News
9/18/2014
5:14:00 PM
9/19/2014
At Offering Price, Alibaba IPO Raises $21.8 Billion, Valued At $168 Billion
Dow Jones Newswires Chinese (English)
9/18/2014
5:14:00 PM
9/19/2014
Alibaba IPO Priced at $68 a Share, Top of Range, Source Says
Dow Jones Newswires Chinese (English)
9/18/2014
5:17:00 PM
9/19/2014
Alibaba to Open on NYSE Friday Under Symbol 'BABA'
Dow Jones Newswires Chinese (English)
9/18/2014
5:23:00 PM
9/19/2014
Alibaba IPO Priced At $68 a Share, Top of Range, Source Says
Dow Jones Newswires Chinese (English)
9/18/2014
5:30:00 PM
9/19/2014
Alibaba IPO Priced at $68 a Share
Dow Jones Institutional News
9/18/2014
5:33:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share -- Update
Dow Jones Institutional News
9/18/2014
5:45:00 PM
9/19/2014
Alibaba IPO Priced at $68 a Share
Dow Jones Institutional News
9/18/2014
5:51:00 PM
9/19/2014
Yahoo Trading Picks Up As Alibaba Prices IPO -- Market Talk
Dow Jones Institutional News
9/18/2014
5:51:00 PM
9/19/2014
Yahoo Trading Picks Up As Alibaba Prices IPO -- Market Talk
Dow Jones Institutional News
9/18/2014
6:04:00 PM
9/19/2014
Alibaba Inside Sellers Could Be Secret Weapon -- Market Talk
Dow Jones Institutional News
9/18/2014
6:04:00 PM
9/19/2014
Press Release: Alibaba Group Announces Pricing of Initial Public Offering
Dow Jones Institutional News
9/18/2014
6:04:00 PM
9/19/2014
Alibaba Inside Sellers Could Be Secret Weapon -- Market Talk
Dow Jones Institutional News
9/18/2014
6:23:00 PM
9/19/2014
Alibaba Value Still Cheaper Than Some Rivals -- Market Talk
Dow Jones Institutional News
9/18/2014
6:23:00 PM
9/19/2014
Alibaba Value Still Cheaper Than Some Rivals -- Market Talk
Dow Jones Institutional News
9/18/2014
7:03:00 PM
9/19/2014
Alibaba's IPO: We Know the Price! Now How Does It Stack Up
Dow Jones Institutional News
9/18/2014
7:35:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share - Update
Dow Jones Newswires Chinese (English)
9/18/2014
7:36:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share - Update -2-
Dow Jones Newswires Chinese (English)
9/18/2014
7:37:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share - Update -3-
Dow Jones Newswires Chinese (English)
9/18/2014
7:38:00 PM
9/19/2014
Alibaba Value Still Cheaper Than Some Rivals -- Market Talk
Dow Jones Newswires Chinese (English)
9/18/2014
7:40:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share -- Update 2
Dow Jones Institutional News
9/18/2014
7:42:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share - Update -5-
Dow Jones Newswires Chinese (English)
9/18/2014
8:35:00 PM
9/19/2014
Alibaba's IPO: We Know the Price! Now How Does It Stack Up
Dow Jones Newswires Chinese (English)
9/18/2014
8:35:00 PM
9/19/2014
Alibaba IPO Big Pay Day For Some Employees -3-
Dow Jones Newswires Chinese (English)
9/18/2014
8:35:00 PM
9/19/2014
Alibaba IPO Big Pay Day For Some Employees -2-
Dow Jones Newswires Chinese (English)
9/18/2014
8:35:00 PM
9/19/2014
Alibaba IPO Big Pay Day For Some Employees
Dow Jones Newswires Chinese (English)
9/18/2014
8:37:00 PM
9/19/2014
Alibaba's IPO: We Know the Price! Now How Does It Stack Up -3-
Dow Jones Newswires Chinese (English)
9/18/2014
8:37:00 PM
9/19/2014
Alibaba's IPO: We Know the Price! Now How Does It Stack Up -2-
Dow Jones Newswires Chinese (English)
9/18/2014
9:43:00 PM
9/19/2014
Alibaba's IPO Priced at $68 a Share - Update
Dow Jones Newswires Chinese (English)
9/18/2014
9:46:00 PM
9/19/2014
Alibaba Mania Isn't Built to Last
Dow Jones Newswires Chinese (English)
9/18/2014
9:52:00 PM
9/19/2014
Alibaba Mania Isn't Built to Last -2-
Dow Jones Newswires Chinese (English)
9/18/2014
10:34:00 PM
9/19/2014
Tencent 2-Week High; Alibaba Effect
Dow Jones Newswires Chinese (English)
9/18/2014
10:34:00 PM
9/19/2014
MARKET TALK: Tencent 2-Week High; Alibaba Effect
Dow Jones Newswires Chinese (English)
9/18/2014
11:15:00 PM
9/19/2014
Alibaba Float Reaps $1B Windfall for Employees -- Market Talk
Dow Jones Institutional News
9/18/2014
11:34:00 PM
9/19/2014
MARKET TALK: Tencent 2-Week High; Alibaba Effect
Dow Jones Newswires Chinese (English)
9/19/2014
12:22:00 AM
9/19/2014
Alibaba Will Have a Fight on Its Hands Outside Asia -- Market Talk
Dow Jones Institutional News
9/19/2014
12:37:00 AM
9/19/2014
Alibaba Will Have a Fight on Its Hands Outside Asia -- Market Talk
Dow Jones Newswires Chinese (English)
9/19/2014
12:38:00 AM
9/19/2014
Alibaba Debuts Friday: Here's What You Need to Know
Dow Jones Institutional News
9/19/2014
1:37:00 AM
9/19/2014
Alibaba Will Have a Fight on Its Hands Outside Asia -- Market Talk
Dow Jones Newswires Chinese (English)
9/19/2014
1:51:00 AM
9/19/2014
Alibaba IPO to Give Yahoo Windfall
Dow Jones Institutional News
9/19/2014
2:45:00 AM
9/19/2014
Alibaba IPO to Give Yahoo Windfall -2-
Dow Jones Newswires Chinese (English)
9/19/2014
2:45:00 AM
9/19/2014
Alibaba IPO to Give Yahoo Windfall
Dow Jones Newswires Chinese (English)
9/19/2014
2:46:00 AM
9/19/2014
Alibaba IPO to Give Yahoo Windfall -3-
Dow Jones Newswires Chinese (English)
9/19/2014
3:04:00 AM
9/19/2014
Thriving Tmall Key to Alibaba's Growth: Morningstar -- Market Talk
Dow Jones Institutional News
9/19/2014
3:08:00 AM
9/19/2014
Alibaba IPO Will Power Its Global Expansion, Says Gartner -- Market Talk
Dow Jones Institutional News
9/19/2014
3:27:00 AM
9/19/2014
Alibaba IPO Will Power Its Global Expansion, Says Gartner -- Market Talk
Dow Jones Newswires Chinese (English)
9/19/2014
4:03:00 AM
9/19/2014
Alibaba's IPO Priced at $68 a Share
Dow Jones Newswires Korean (English)
9/19/2014
4:27:00 AM
9/19/2014
Alibaba IPO Will Power Its Global Expansion, Says Gartner -- Market Talk
Dow Jones Newswires Chinese (English)
9/19/2014
5:07:00 AM
9/19/2014
Alibaba's Political Risk
Dow Jones Newswires Korean (English)
9/19/2014
5:13:00 AM
9/19/2014
SoftBank's Alibaba Alchemy: How to Turn $20 Million Into $50 Billion
Dow Jones Institutional News
9/19/2014
5:30:00 AM
9/19/2014
Asia Week Review: Alibaba's Partners Haven't Got The Ali Bump -- Barron's Blog
Dow Jones Institutional News
9/19/2014
5:41:00 AM
9/19/2014
Legal Structure, Allocations on Mind of Asia Investors Ahead of Alibaba Debut
Dow Jones Institutional News
9/19/2014
5:47:00 AM
9/19/2014
Alibaba Debuts Friday: Here's What You Need to Know
Dow Jones Institutional News
9/19/2014
7:06:00 AM
9/19/2014
Alibaba IPO Generates Sense of Missed Opportunity for Many in China
Dow Jones Institutional News
9/19/2014
8:18:00 AM
9/19/2014
Cantor: Alibaba Worth It If Growth Maintained -- Market Talk
Dow Jones Institutional News
9/19/2014
8:35:00 AM
9/19/2014
ICE's Handling of Alibaba IPO to Be Watched -- Market Talk
Dow Jones Institutional News
9/19/2014
8:35:00 AM
9/19/2014
ICE's Handling of Alibaba IPO to Be Watched -- Market Talk
Dow Jones Institutional News
9/19/2014
9:03:00 AM
9/19/2014
Alibaba Started at Buy by Cantor Fitzgerald >BABA
Dow Jones Newswires Chinese (English)
9/19/2014
9:03:00 AM
9/19/2014
Alibaba Started at Buy by Cantor Fitzgerald >BABA
Dow Jones Institutional News
9/19/2014
9:24:00 AM
9/19/2014
Alibaba Shares Make New York Trading Debut
Dow Jones Institutional News
9/19/2014
9:29:00 AM
9/19/2014
BABA Shares Spread Awfully Thin Among 1,700 Entities, Says CNBC -- Barron's Blog
Dow Jones Institutional News
9/19/2014
9:35:00 AM
9/19/2014
The Daily Startup: Alibaba's Big Day
Dow Jones Institutional News
9/19/2014
9:44:00 AM
9/19/2014
Majority Of Alibaba Shares Placed With U.S. Investors -- Sources
Dow Jones Institutional News
9/19/2014
9:44:00 AM
9/19/2014
Alibaba Gave Around 50% Of IPO Stock To 25 Investment Firms -- Sources
Dow Jones Institutional News
9/19/2014
9:46:00 AM
9/19/2014
Alibaba Had Over 1,700 Orders For Stock; Only About Half Got Shares -- Sources
Dow Jones Newswires Chinese (English)
9/19/2014
9:47:00 AM
9/19/2014
Alibaba Gave Around 50% Of IPO Stock To 25 Investment Firms -- Sources
Dow Jones Newswires Chinese (English)
9/19/2014
9:47:00 AM
9/19/2014
Majority Of Alibaba Shares Placed With U.S. Investors -- Sources
Dow Jones Newswires Chinese (English)
9/19/2014
9:59:00 AM
9/19/2014
Details of Alibaba IPO Trickle Out
Dow Jones Institutional News
9/19/2014
10:01:00 AM
9/19/2014
Payday Nears for Alibaba Bankers -- But It's Not as Much as You May Think
Dow Jones Institutional News
9/19/2014
10:06:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
10:06:00 AM
9/19/2014
Alibaba Group Holding (BABA) Halt:
Dow Jones Institutional News
9/19/2014
10:08:00 AM
9/19/2014
Alibaba IPO Indicated Opening Range $80-$83
Dow Jones Institutional News
9/19/2014
10:09:00 AM
9/19/2014
Alibaba IPO Indicated Opening Range $80-$83
Dow Jones Newswires Chinese (English)
9/19/2014
10:19:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
10:21:00 AM
9/19/2014
Details of Alibaba IPO Trickle Out
Dow Jones Newswires Chinese (English)
9/19/2014
10:22:00 AM
9/19/2014
Details of Alibaba IPO Trickle Out -3-
Dow Jones Newswires Chinese (English)
9/19/2014
10:22:00 AM
9/19/2014
Details of Alibaba IPO Trickle Out -2-
Dow Jones Newswires Chinese (English)
9/19/2014
10:24:00 AM
9/19/2014
Alibaba IPO Shares Now Indicated $82-$85
Dow Jones Newswires Chinese (English)
9/19/2014
10:29:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
10:32:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Range $84-$87
Dow Jones Newswires Chinese (English)
9/19/2014
10:43:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
Page 4 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 66 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 67 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
9/19/2014
10:44:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $86-$88
Dow Jones Newswires Chinese (English)
9/19/2014
10:51:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
10:52:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts
Dow Jones Institutional News
9/19/2014
10:58:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
11:00:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $88-$90
Dow Jones Newswires Chinese (English)
9/19/2014
11:04:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
11:05:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $89-$91
Dow Jones Newswires Chinese (English)
9/19/2014
11:09:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts
Dow Jones Institutional News
9/19/2014
11:13:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
11:14:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $90-$91
Dow Jones Newswires Chinese (English)
9/19/2014
11:16:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts
Dow Jones Newswires Chinese (English)
9/19/2014
11:21:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
11:21:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts -2-
Dow Jones Newswires Chinese (English)
9/19/2014
11:23:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $91-$92
Dow Jones Newswires Chinese (English)
9/19/2014
11:26:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts -3-
Dow Jones Newswires Chinese (English)
9/19/2014
11:27:00 AM
9/19/2014
Alibaba Group Holding (BABA) Ind: 80.00-83.00 Last 0.00
Dow Jones Institutional News
9/19/2014
11:28:00 AM
9/19/2014
Alibaba IPO Shares New Indicated Opening Range $92-$93
Dow Jones Newswires Chinese (English)
9/19/2014
11:38:00 AM
9/19/2014
Watch the Alibaba Effect on 5 Stocks in 5 Charts
Dow Jones Institutional News
9/19/2014
11:47:00 AM
9/19/2014
Alibaba Shares Seen Heading for Big Gains Once Trading Starts -4-
Dow Jones Newswires Chinese (English)
9/19/2014
11:53:00 AM
9/19/2014
Alibaba Group Holding Begins Trading at $92.70
Dow Jones Institutional News
9/19/2014
11:53:00 AM
9/19/2014
Alibaba Group Holding (BABA) Resumed Trading
Dow Jones Institutional News
9/19/2014
11:54:00 AM
9/19/2014
Alibaba Group Holding Begins Trading at $92.70
Dow Jones Newswires Chinese (English)
9/19/2014
11:54:00 AM
9/19/2014
Alibaba Group Holding (BABA) Resumed Trading
Dow Jones Newswires Chinese (English)
9/19/2014
11:55:00 AM
9/19/2014
Alibaba Shares Trade Higher In Market Debut
Dow Jones Institutional News
9/19/2014
12:00:00 PM
9/19/2014
Alibaba Shares Trade Higher In Market Debut
Dow Jones Newswires Chinese (English)
9/19/2014
12:06:00 PM
9/19/2014
Alibaba IPO Sparks Celebrations in Company's Hometown
Dow Jones Institutional News
9/19/2014
12:08:00 PM
9/19/2014
Alibaba Shares Soar as Trading Begins
Dow Jones Institutional News
9/19/2014
12:10:00 PM
9/19/2014
Alibaba Shares Trade Higher In Market Debut--Update
Dow Jones Institutional News
9/19/2014
12:15:00 PM
9/19/2014
Alibaba Shares Trade Higher In Market Debut -2-
Dow Jones Newswires Chinese (English)
9/19/2014
12:16:00 PM
9/19/2014
Three Reasons to Avoid Alibaba, One Reason Not to Worry, and a Bonus Red Flag
Dow Jones Institutional News
9/19/2014
12:23:00 PM
9/19/2014
Alibaba's Financial Health Profile Lines Up Well Against Other Tech Companies
Dow Jones Institutional News
9/19/2014
12:27:00 PM
9/19/2014
Alibaba Shares Trade Higher In Market Debut--Update
Dow Jones Newswires Chinese (English)
9/19/2014
12:40:00 PM
9/19/2014
Alibaba Shares Trade Higher In Market Debut--2nd Update
Dow Jones Institutional News
9/19/2014
12:41:00 PM
9/19/2014
Yahoo Falls as Alibaba Opens for Trade -- Market Talk
Dow Jones Institutional News
9/19/2014
12:41:00 PM
9/19/2014
Yahoo Falls as Alibaba Opens for Trade -- Market Talk
Dow Jones Institutional News
9/19/2014
12:55:00 PM
9/19/2014
Alibaba's Financial Health Profile Lines Up Well Against Other Tech Companies
Dow Jones Newswires Chinese (English)
9/19/2014
1:28:00 PM
9/19/2014
Alibaba Spurs Growth In Late-Stage Investments Into Chinese Startups
Dow Jones Institutional News
9/19/2014
1:38:00 PM
9/19/2014
Celebrating Alibaba's Debut In Hangzhou: 'It's Going to Break $100!'
Dow Jones Institutional News
9/19/2014
1:40:00 PM
9/19/2014
Press Release: Alibaba Group Celebrates Initial Public Offering and First Day of Trading onDow Jones Institutional News
9/19/2014
1:54:00 PM
9/19/2014
In Silicon Valley, Awe and Dread for Alibaba
Dow Jones Institutional News
9/19/2014
1:56:00 PM
9/19/2014
In Silicon Valley, Awe and Dread for Alibaba
Dow Jones Institutional News
9/19/2014
1:57:00 PM
9/19/2014
In Silicon Valley, Awe, Dread and Hope for Alibaba
Dow Jones Institutional News
9/19/2014
2:07:00 PM
9/19/2014
Alibaba: Now Comes the Hard Part--Heard on the Street
Dow Jones Institutional News
9/19/2014
2:31:00 PM
9/19/2014
Alibaba IPO Leaves Investors Wanting More
Dow Jones Institutional News
9/19/2014
2:41:00 PM
9/19/2014
Alibaba IPO Leaves Investors Wanting More--Update
Dow Jones Institutional News
9/19/2014
3:04:00 PM
9/19/2014
Alibaba Has Been Busy in the Startup Space -- Market Talk
Dow Jones Institutional News
9/19/2014
3:04:00 PM
9/19/2014
Alibaba Has Been Busy in the Startup Space -- Market Talk
Dow Jones Institutional News
9/19/2014
3:15:00 PM
9/19/2014
Pilot Delays His Flight for Alibaba Debut, Nabs Shares at $94
Dow Jones Institutional News
9/19/2014
3:17:00 PM
9/19/2014
Celebrating Alibaba's Debut In Hangzhou: 'It's Going to Break $100!&
Dow Jones Newswires Chinese (English)
9/19/2014
3:17:00 PM
9/19/2014
Celebrating Alibaba's Debut In Hangzhou: 'It's Going to Break $100!&
Dow Jones Newswires Chinese (English)
9/19/2014
3:18:00 PM
9/19/2014
Celebrating Alibaba's Debut In Hangzhou: 'It's Going to Break $100!&
Dow Jones Newswires Chinese (English)
9/19/2014
3:21:00 PM
9/19/2014
Alibaba IPO to Give Yahoo Windfall
Dow Jones Institutional News
9/19/2014
3:37:00 PM
9/19/2014
Yahoo's Alibaba Cash Still Growing -- Market Talk
Dow Jones Institutional News
9/19/2014
3:37:00 PM
9/19/2014
Yahoo's Alibaba Cash Still Growing -- Market Talk
Dow Jones Institutional News
9/19/2014
3:48:00 PM
9/19/2014
In Silicon Valley, Awe, Dread and Hope for Alibaba
Dow Jones Newswires Chinese (English)
9/19/2014
3:50:00 PM
9/19/2014
In Silicon Valley, Awe, Dread and Hope for Alibaba -2-
Dow Jones Newswires Chinese (English)
9/19/2014
4:06:00 PM
9/22/2014
Alibaba Favored Mutual Funds In Allotments: CNBC -- Barron's Blog
Dow Jones Institutional News
9/19/2014
4:18:00 PM
9/22/2014
Crystal Ball: Send Us Your Prediction for Alibaba's Stock Price
Dow Jones Institutional News
9/19/2014
5:07:00 PM
9/22/2014
Alibaba IPO to Give Yahoo Windfall
Dow Jones Institutional News
9/19/2014
5:24:00 PM
9/22/2014
Alibaba Shares Rise Nearly $26 a Share in First Day--4th Update
Dow Jones Institutional News
9/19/2014
5:33:00 PM
9/22/2014
Podcast: Alibaba's Red-Letter Day
Dow Jones Institutional News
9/19/2014
5:35:00 PM
9/22/2014
Alibaba's IPO, By the Numbers
Dow Jones Institutional News
9/19/2014
5:38:00 PM
9/22/2014
Alibaba IPO to Give Yahoo Windfall
Dow Jones Institutional News
9/19/2014
5:50:00 PM
9/22/2014
Yahoo's Core Business Value Cut in Half to $6.8 Billion After Alibaba IPO
Dow Jones Institutional News
9/19/2014
5:54:00 PM
9/22/2014
Alibaba's IPO, By the Numbers
Dow Jones Institutional News
9/19/2014
5:57:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More -- 2nd Update
Dow Jones Institutional News
9/19/2014
6:04:00 PM
9/22/2014
Alibaba Shares Rise Nearly $26 a Share in First Day
Dow Jones Newswires Chinese (English)
9/19/2014
6:05:00 PM
9/22/2014
Alibaba Shares Rise Nearly $26 a Share in First Day -2-
Dow Jones Newswires Chinese (English)
9/19/2014
6:37:00 PM
9/22/2014
Goldman's Go-To Alibaba Guy Works Out the Kinks
Dow Jones Institutional News
9/19/2014
7:09:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More -2-
Dow Jones Newswires Chinese (English)
9/19/2014
7:09:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More
Dow Jones Newswires Chinese (English)
9/19/2014
7:10:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More -3-
Dow Jones Newswires Chinese (English)
9/19/2014
7:14:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More -5-
Dow Jones Newswires Chinese (English)
9/19/2014
7:14:00 PM
9/22/2014
Alibaba IPO Leaves Investors Wanting More -4-
Dow Jones Newswires Chinese (English)
9/19/2014
8:15:00 PM
9/22/2014
Alibaba Debut Makes A Splash
Dow Jones Institutional News
9/20/2014
12:04:00 AM
9/22/2014
Asian Trader: Why Alibaba Isn't In Your Fund -- Barron's
Dow Jones Institutional News
9/20/2014
12:09:00 AM
9/22/2014
A Return Visit To Earlier Stories: Best Way To Play Alibaba: Buy Yahoo! -- Barron's
Dow Jones Institutional News
9/20/2014
3:50:00 AM
9/22/2014
Alibaba Makes Big Splash With IPO
Dow Jones Institutional News
9/20/2014
3:54:00 AM
9/22/2014
China Watches From the Bleachers As Alibaba Goes Public
Dow Jones Institutional News
9/21/2014
3:12:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins?
Dow Jones Institutional News
9/21/2014
3:32:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks
Dow Jones Institutional News
Page 5 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 67 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 68 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
9/21/2014
4:15:00 PM
9/22/2014
Alibaba Bankers Exercise 'Green Shoe' Option -- Sources
Dow Jones Institutional News
9/21/2014
6:16:00 PM
9/22/2014
Strong Alibaba IPO Demand Seen as Positive Sign for Stocks -- Market Talk
Dow Jones Institutional News
9/21/2014
6:16:00 PM
9/22/2014
Strong Alibaba IPO Demand Seen as Positive Sign for Stocks -- Market Talk
Dow Jones Institutional News
9/21/2014
7:26:00 PM
9/22/2014
Alibaba Bankers Exercise 'Green Shoe' Option -- Sources
Dow Jones Newswires Chinese (English)
9/21/2014
7:52:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins? -2-
Dow Jones Newswires Chinese (English)
9/21/2014
7:52:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins?
Dow Jones Newswires Chinese (English)
9/21/2014
7:53:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins? -4-
Dow Jones Newswires Chinese (English)
9/21/2014
7:53:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins? -3-
Dow Jones Newswires Chinese (English)
9/21/2014
7:54:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins? -5-
Dow Jones Newswires Chinese (English)
9/21/2014
8:25:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks
Dow Jones Newswires Chinese (English)
9/21/2014
8:25:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks -2-
Dow Jones Newswires Chinese (English)
9/21/2014
8:26:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks -3-
Dow Jones Newswires Chinese (English)
9/21/2014
8:27:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks -4-
Dow Jones Newswires Chinese (English)
9/21/2014
8:34:00 PM
9/22/2014
Alibaba's IPO, By the Numbers
Dow Jones Newswires Chinese (English)
9/21/2014
8:35:00 PM
9/22/2014
Alibaba's IPO, By the Numbers -3-
Dow Jones Newswires Chinese (English)
9/21/2014
8:35:00 PM
9/22/2014
Alibaba's IPO, By the Numbers -2-
Dow Jones Newswires Chinese (English)
9/21/2014
9:13:00 PM
9/22/2014
Yahoo's Core Business Value Cut in Half to $6.8 Billion After Alibaba IPO
Dow Jones Newswires Chinese (English)
9/21/2014
9:14:00 PM
9/22/2014
Yahoo's Core Business Value Cut in Half to $6.8 Billion After Alibaba IPO -2-
Dow Jones Newswires Chinese (English)
9/21/2014
10:11:00 PM
9/22/2014
Three Reasons to Avoid Alibaba, One Reason Not to Worry, and a Bonus Red Flag -2-
Dow Jones Newswires Chinese (English)
9/21/2014
10:11:00 PM
9/22/2014
Three Reasons to Avoid Alibaba, One Reason Not to Worry, and a Bonus Red Flag
Dow Jones Newswires Chinese (English)
9/21/2014
10:14:00 PM
9/22/2014
Alibaba Spurs Growth In Late-Stage Investments Into Chinese Startups -2-
Dow Jones Newswires Chinese (English)
9/21/2014
10:14:00 PM
9/22/2014
Alibaba Spurs Growth In Late-Stage Investments Into Chinese Startups
Dow Jones Newswires Chinese (English)
9/21/2014
10:15:00 PM
9/22/2014
Alibaba Spurs Growth In Late-Stage Investments Into Chinese Startups -3-
Dow Jones Newswires Chinese (English)
9/21/2014
10:35:00 PM
9/22/2014
Three Reasons to Avoid Alibaba, One Reason Not to Worry, and a Bonus Red Flag
Dow Jones Newswires Chinese (English)
9/21/2014
10:36:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks
Dow Jones Newswires Chinese (English)
9/21/2014
10:37:00 PM
9/22/2014
Alibaba IPO Signals Strength in U.S. Stocks
Dow Jones Newswires Chinese (English)
9/21/2014
10:58:00 PM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins?
Dow Jones Newswires Chinese (English)
9/21/2014
11:43:00 PM
9/22/2014
MARKET TALK: Tencent Dn 1.9%; Alibaba Spotlight Fading
Dow Jones Newswires Chinese (English)
9/21/2014
11:43:00 PM
9/22/2014
Tencent Dn 1.9%; Alibaba Spotlight Fading
Dow Jones Newswires Chinese (English)
9/21/2014
11:46:00 PM
9/22/2014
Heard on the Street -- Alibaba Proxy Drain -- Market Talk
Dow Jones Institutional News
9/22/2014
12:43:00 AM
9/22/2014
MARKET TALK: Tencent Dn 1.9%; Alibaba Spotlight Fading
Dow Jones Newswires Chinese (English)
9/22/2014
1:14:00 AM
9/22/2014
Not Everyone in Asia Is Sore About Their Alibaba Allocations -- Market Talk
Dow Jones Institutional News
9/22/2014
1:38:00 AM
9/22/2014
Not Everyone in Asia Is Sore About Their Alibaba Allocations -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
2:38:00 AM
9/22/2014
Not Everyone in Asia Is Sore About Their Alibaba Allocations -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
3:08:00 AM
9/22/2014
Can Alibaba Keep Growing Without Sacrificing High Profit Margins?
Dow Jones Newswires Korean (English)
9/22/2014
5:14:00 AM
9/22/2014
Jefferies: Alibaba Drives Softbank, But It's Just One Of The Gems -- Barron's Blog
Dow Jones Institutional News
9/22/2014
5:17:00 AM
9/22/2014
Common Misconceptions about Alibaba
Dow Jones Institutional News
9/22/2014
5:51:00 AM
9/22/2014
Asian Investors Come Up Short In Alibaba IPO
Dow Jones Institutional News
9/22/2014
6:06:00 AM
9/22/2014
Plenty More Upside for Alibaba, Says Principal -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
7:06:00 AM
9/22/2014
Plenty More Upside for Alibaba, Says Principal -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
7:30:00 AM
9/22/2014
Press Release: Alibaba Group Announces Exercise of Underwriters' Option to Purchase AddDow Jones Institutional News
9/22/2014
7:32:00 AM
9/22/2014
Alibaba Group Announces Exercise Of Underwriters' Option To Purchase Additional ADSs Dow Jones Newswires Chinese (English)
9/22/2014
7:34:00 AM
9/22/2014
Alibaba Group: Underwriters Haver Exercised Option To Purchase Added 48 Million ADSsDow Jones Newswires Chinese (English)
9/22/2014
7:35:00 AM
9/22/2014
Alibaba Pictures: Independent Audit Available by November
Dow Jones Institutional News
9/22/2014
7:39:00 AM
9/22/2014
Alibaba Pictures: Independent Audit Available by November
Dow Jones Newswires Chinese (English)
9/22/2014
8:17:00 AM
9/22/2014
Alibaba Worth $2.45B More Than at Friday's Close -- Market Talk
Dow Jones Institutional News
9/22/2014
8:17:00 AM
9/22/2014
Alibaba Worth $2.45B More Than at Friday's Close -- Market Talk
Dow Jones Institutional News
9/22/2014
8:22:00 AM
9/22/2014
Asian Investors Come Up Short In Alibaba IPO -2-
Dow Jones Newswires Chinese (English)
9/22/2014
8:22:00 AM
9/22/2014
Asian Investors Come Up Short In Alibaba IPO
Dow Jones Newswires Chinese (English)
9/22/2014
8:23:00 AM
9/22/2014
Asian Investors Come Up Short In Alibaba IPO -3-
Dow Jones Newswires Chinese (English)
9/22/2014
8:36:00 AM
9/22/2014
Alibaba Worth $2.45B More Than at Friday's Close -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
8:41:00 AM
9/22/2014
Alibaba Worth $2.45B More Than at Friday's Close -- Market Talk
Dow Jones Newswires Chinese (English)
9/22/2014
9:06:00 AM
9/22/2014
Alibaba Pictures: Results of Independent Audit Ready by Nov
Dow Jones Newswires Chinese (English)
9/22/2014
10:19:00 AM
9/22/2014
Bernstein Downgrades Yahoo After Alibaba IPO -- Market Talk
Dow Jones Institutional News
9/22/2014
10:19:00 AM
9/22/2014
Bernstein Downgrades Yahoo After Alibaba IPO -- Market Talk
Dow Jones Institutional News
9/22/2014
11:51:00 AM
9/22/2014
What Happens to Yahoo's Stock Now that Alibaba Is Public?
Dow Jones Institutional News
9/22/2014
1:54:00 PM
9/22/2014
$100 Too Rich for Alibaba? How About $125? -- Market Talk
Dow Jones Institutional News
9/22/2014
1:54:00 PM
9/22/2014
$100 Too Rich for Alibaba? How About $125? -- Market Talk
Dow Jones Institutional News
9/22/2014
3:03:00 PM
9/22/2014
Green Shoe Boosts Banker Fees on Alibaba IPO
Dow Jones Institutional News
9/22/2014
7:40:00 PM
9/23/2014
How Startups View Alibaba As An Active Investor
Dow Jones Institutional News
9/22/2014
9:51:00 PM
9/23/2014
Alibaba Deal Pummels Yahoo Stock
Dow Jones Institutional News
9/23/2014
12:33:00 AM
9/23/2014
How Startups View Alibaba As An Active Investor -2-
Dow Jones Newswires Chinese (English)
9/23/2014
12:33:00 AM
9/23/2014
How Startups View Alibaba As An Active Investor
Dow Jones Newswires Chinese (English)
9/23/2014
12:35:00 AM
9/23/2014
How Startups View Alibaba As An Active Investor -4-
Dow Jones Newswires Chinese (English)
9/23/2014
12:35:00 AM
9/23/2014
How Startups View Alibaba As An Active Investor -3-
Dow Jones Newswires Chinese (English)
9/23/2014
1:11:00 AM
9/23/2014
Oh Alibaba, When Will We See Your Like Again? -- Market Talk
Dow Jones Institutional News
9/23/2014
1:13:00 AM
9/23/2014
Alibaba the Investor: How Its Startups View the Company
Dow Jones Institutional News
9/23/2014
1:43:00 AM
9/23/2014
Oh Alibaba, When Will We See Your Like Again? -- Market Talk
Dow Jones Newswires Chinese (English)
9/23/2014
2:12:00 AM
9/23/2014
What Happens to Yahoo's Stock Now that Alibaba Is Public?
Dow Jones Newswires Chinese (English)
9/23/2014
2:17:00 AM
9/23/2014
What Happens to Yahoo's Stock Now that Alibaba Is Public? -2-
Dow Jones Newswires Chinese (English)
9/23/2014
2:43:00 AM
9/23/2014
Oh Alibaba, When Will We See Your Like Again? -- Market Talk
Dow Jones Newswires Chinese (English)
9/23/2014
3:33:00 AM
9/23/2014
What Indians Are Selling on Alibaba -2-
Dow Jones Newswires Chinese (English)
9/23/2014
3:33:00 AM
9/23/2014
What Indians Are Selling on Alibaba
Dow Jones Newswires Chinese (English)
9/23/2014
3:34:00 AM
9/23/2014
What Indians Are Selling on Alibaba -3-
Dow Jones Newswires Chinese (English)
9/23/2014
4:11:00 AM
9/23/2014
Alibaba's Jack Ma Is Richest Person in China, Survey Shows
Dow Jones Institutional News
9/23/2014
4:47:00 AM
9/23/2014
Asia Roundup: China Techs Fall After Alibaba IPO -- Barron's Blog
Dow Jones Institutional News
9/23/2014
5:29:00 AM
9/23/2014
Alibaba's Jack Ma Is Richest Person in China, Survey Shows
Dow Jones Newswires Chinese (English)
9/23/2014
7:02:00 AM
9/23/2014
SoftBank's Alibaba Alchemy: How to Turn $20 Million Into $50 Billion
Dow Jones Newswires Korean (English)
9/23/2014
8:00:00 AM
9/23/2014
Press Release: Alibaba Joins FIDO Alliance Board of Directors
Dow Jones Institutional News
9/23/2014
8:08:00 AM
9/23/2014
The Expensive Search for India's Alibaba -- Heard on the Street
Dow Jones Institutional News
9/23/2014
8:30:00 AM
9/23/2014
How Alibaba Makes Money from Ads
Dow Jones Institutional News
Page 6 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 68 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 69 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
9/23/2014
9:03:00 AM
9/23/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows--Update
Dow Jones Institutional News
9/23/2014
9:59:00 AM
9/23/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows--Update -2-
Dow Jones Newswires Chinese (English)
9/23/2014
9:59:00 AM
9/23/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows--Update
Dow Jones Newswires Chinese (English)
9/23/2014
10:00:00 AM
9/23/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows--Update -4-
Dow Jones Newswires Chinese (English)
9/23/2014
10:00:00 AM
9/23/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows--Update -3-
Dow Jones Newswires Chinese (English)
9/23/2014
8:02:00 PM
9/24/2014
Alibaba Not Worth Pursuing Above $83? Q3 Growth Robust -- Barron's Blog
Dow Jones Institutional News
9/23/2014
8:18:00 PM
9/24/2014
Expensive Search For Next Alibaba Among Indian Tech Stocks -- Heard On The Street
Dow Jones Institutional News
9/23/2014
9:00:00 PM
9/24/2014
How Alibaba Makes Money from Ads -2-
Dow Jones Newswires Chinese (English)
9/23/2014
9:00:00 PM
9/24/2014
How Alibaba Makes Money from Ads
Dow Jones Newswires Chinese (English)
9/23/2014
9:01:00 PM
9/24/2014
How Alibaba Makes Money from Ads -3-
Dow Jones Newswires Chinese (English)
9/23/2014
11:12:00 PM
9/24/2014
Nikkei Down 0.3%; SoftBank, Yahoo Japan Weak Post Alibaba IPO -- Market Talk
Dow Jones Institutional News
9/24/2014
12:37:00 AM
9/24/2014
SoftBank, Yahoo Japan Continue Fall After Alibaba Listing in NY -- Market Talk
Dow Jones Institutional News
9/24/2014
12:42:00 AM
9/24/2014
Why Buy Softbank Now That Alibaba Is Public? -- Barron's Blog
Dow Jones Institutional News
9/24/2014
5:06:00 AM
9/24/2014
Alibaba's Jack Ma Is China's Richest Person, Survey Shows
Dow Jones Newswires Korean (English)
9/24/2014
6:02:00 AM
9/24/2014
Common Misconceptions About Alibaba
Dow Jones Newswires Korean (English)
9/24/2014
11:25:00 AM
9/24/2014
Press Release: Citi Appointed Depositary Bank for Alibaba Group Holding Limited's Spons Dow Jones Institutional News
9/24/2014
11:37:00 AM
9/24/2014
Citi Appointed Depositary Bank For Alibaba Group Holding Limited's Sponsored ADR Pro Dow Jones Newswires Chinese (English)
9/25/2014
9:46:00 AM
9/25/2014
Alibaba Could Become a Victim of its Success
Dow Jones Institutional News
9/25/2014
12:45:00 PM
9/25/2014
Yahoo Loses Some Analysts Backing After Alibaba IPO -- Market Talk
Dow Jones Institutional News
9/25/2014
12:45:00 PM
9/25/2014
Yahoo Loses Some Analysts Backing After Alibaba IPO -- Market Talk
Dow Jones Institutional News
9/25/2014
3:27:00 PM
9/25/2014
Third Stock Downgrade Hits Yahoo Since Alibaba IPO
Dow Jones Institutional News
9/26/2014
1:15:00 AM
9/26/2014
Alibaba Gains First Index Inclusion -- Market Talk
Dow Jones Institutional News
9/26/2014
1:15:00 AM
9/26/2014
Alibaba Gains First Index Inclusion -- Market Talk
Dow Jones Institutional News
9/26/2014
4:00:00 AM
9/26/2014
Alibaba Could Become a Victim of its Success
Dow Jones Newswires Korean (English)
9/26/2014
7:12:00 AM
9/26/2014
China's Yuan Hits New Half-Year High, This Time Due to Alibaba
Dow Jones Institutional News
9/26/2014
8:39:00 AM
9/26/2014
China's Yuan Hits New Half-Year High, This Time Due to Alibaba
Dow Jones Newswires Chinese (English)
9/26/2014
11:36:00 AM
9/26/2014
Alibaba Options Could Trade Like Facebook's -- Market Talk
Dow Jones Institutional News
9/26/2014
11:36:00 AM
9/26/2014
Alibaba Options Could Trade Like Facebook's -- Market Talk
Dow Jones Institutional News
9/26/2014
1:53:00 PM
9/26/2014
Alibaba Gives Bigger Share of IPO Incentive Fees to Credit Suisse, Morgan Stanley -- Sour Dow Jones Institutional News
9/26/2014
2:01:00 PM
9/26/2014
Alibaba Gives Bigger Share of IPO Incentive Fees to Credit Suisse, Morgan Stanley -- Sour Dow Jones Newswires Chinese (English)
9/26/2014
2:42:00 PM
9/26/2014
Alibaba Gives Bigger Incentive Fees to Credit Suisse, Morgan Stanley -- Update
Dow Jones Institutional News
9/27/2014
12:05:00 AM
9/29/2014
The Striking Price: Alibaba Options Look Attractive -- Barron's
Dow Jones Institutional News
9/28/2014
2:17:00 AM
9/29/2014
SoftBank's Masayoshi Son Wants Dream Home for Alibaba Riches
Dow Jones Institutional News
9/28/2014
8:38:00 PM
9/29/2014
Alibaba Group Buys 15% Stake In Beijing Shiji Information Technology -- Filing
Dow Jones Institutional News
9/28/2014
8:39:00 PM
9/29/2014
Alibaba Group Buys 15% Stake In Beijing Shiji Information Technology -- Filing
Dow Jones Newswires Chinese (English)
9/28/2014
8:52:00 PM
9/29/2014
Alibaba Buys 15% Stake In Beijing Shiji Information Technology For About $457 Million Dow Jones Newswires Chinese (English)
9/28/2014
9:31:00 PM
9/29/2014
Alibaba Buys Stake in Chinese Hotel-Tech Company - Update
Dow Jones Institutional News
9/28/2014
10:46:00 PM
9/29/2014
Alibaba Acquisition Spree Picks up Pace -- Market Talk
Dow Jones Institutional News
9/28/2014
11:01:00 PM
9/29/2014
Alibaba Buys Stake in Chinese Hotel-Tech Company -- 2nd Update
Dow Jones Institutional News
9/28/2014
11:04:00 PM
9/29/2014
Alibaba Acquisition Spree Picks up Pace -- Market Talk
Dow Jones Newswires Chinese (English)
9/28/2014
11:35:00 PM
9/29/2014
Beijing Shiji Info Tech Limits up on Alibaba Investment -- Market Talk
Dow Jones Institutional News
9/28/2014
11:56:00 PM
9/29/2014
Beijing Shiji Info Tech Limits up on Alibaba Investment -- Market Talk
Dow Jones Newswires Chinese (English)
9/29/2014
12:04:00 AM
9/29/2014
Alibaba Acquisition Spree Picks up Pace -- Market Talk
Dow Jones Newswires Chinese (English)
9/29/2014
12:56:00 AM
9/29/2014
Beijing Shiji Info Tech Limits up on Alibaba Investment -- Market Talk
Dow Jones Newswires Chinese (English)
9/29/2014
1:56:00 AM
9/29/2014
Alibaba Affiliate Wins Approval to Start Private Bank
Dow Jones Institutional News
9/29/2014
5:13:00 AM
9/29/2014
Alibaba Buys Stake in Chinese Hotel-Tech Company
Dow Jones Newswires Korean (English)
9/29/2014
6:04:00 AM
9/29/2014
SoftBank Loses Some Luster After Alibaba IPO
Dow Jones Institutional News
9/29/2014
8:02:00 AM
9/29/2014
Alibaba Group Started at Positive by Susquehanna >BABA
Dow Jones Institutional News
9/29/2014
8:04:00 AM
9/29/2014
Alibaba Group Started at Positive by Susquehanna >BABA
Dow Jones Newswires Chinese (English)
9/29/2014
10:56:00 AM
9/29/2014
Alibaba Helps Fuel Surge in U.S. IPOs
Dow Jones Institutional News
9/29/2014
12:44:00 PM
9/29/2014
Short Sellers in 'No Rush' to Bet Against Alibaba
Dow Jones Institutional News
9/29/2014
1:00:00 PM
9/29/2014
Short Sellers in 'No Rush' to Bet Against Alibaba
Dow Jones Institutional News
9/29/2014
3:30:00 PM
9/29/2014
Short Sellers in 'No Rush' to Bet Against Alibaba
Dow Jones Institutional News
9/29/2014
9:48:00 PM
9/30/2014
Short Sellers in 'No Rush' to Bet Against Alibaba
Dow Jones Newswires Chinese (English)
9/29/2014
9:49:00 PM
9/30/2014
Short Sellers in 'No Rush' to Bet Against Alibaba -2-
Dow Jones Newswires Chinese (English)
9/29/2014
10:39:00 PM
9/30/2014
Press Release: Alibaba Group Announces Strategic Investment in Shiji Information TechnolDow Jones Institutional News
9/29/2014
10:40:00 PM
9/30/2014
Alibaba Group Announces Strategic Investment In Shiji Information Technology
Dow Jones Newswires Chinese (English)
9/29/2014
10:41:00 PM
9/30/2014
Alibaba to Get 15% Stake in Beijing Shiji Information Technology
Dow Jones Newswires Chinese (English)
9/29/2014
10:41:00 PM
9/30/2014
Alibaba: Taobao to Invest RMB2.81 Billion in Beijing Shiji Information Technology Co
Dow Jones Newswires Chinese (English)
9/29/2014
10:43:00 PM
9/30/2014
Alibaba Will Have One Seat on Board of Shiji Information Technology
Dow Jones Newswires Chinese (English)
9/29/2014
10:44:00 PM
9/30/2014
Alibaba: Investment Aimed at Bolstering Online Travel Market Service Capabilities
Dow Jones Newswires Chinese (English)
9/29/2014
10:48:00 PM
9/30/2014
Short Sellers in 'No Rush' to Bet Against Alibaba
Dow Jones Newswires Chinese (English)
9/29/2014
10:49:00 PM
9/30/2014
Short Sellers in 'No Rush' to Bet Against Alibaba -2-
Dow Jones Newswires Chinese (English)
9/29/2014
11:17:00 PM
9/30/2014
Option Traders Bullish on Alibaba
Dow Jones Institutional News
9/30/2014
1:04:00 AM
9/30/2014
Next Battleground for Alibaba, Tencent: Financial Services
Dow Jones Institutional News
9/30/2014
3:28:00 AM
9/30/2014
Next Battleground for Alibaba, Tencent: Financial Services
Dow Jones Newswires Chinese (English)
9/30/2014
3:29:00 AM
9/30/2014
Next Battleground for Alibaba, Tencent: Financial Services -3-
Dow Jones Newswires Chinese (English)
9/30/2014
3:29:00 AM
9/30/2014
Next Battleground for Alibaba, Tencent: Financial Services -2-
Dow Jones Newswires Chinese (English)
10/1/2014
12:25:00 PM
10/1/2014
Mixed Alibaba Options Activity as Shares Decline -- Market Talk
Dow Jones Institutional News
10/1/2014
1:24:00 PM
10/1/2014
Wayfair IPO Marks First Test For E-Commerce Offering In Alibaba's Wake
Dow Jones Institutional News
10/2/2014
4:15:00 PM
10/3/2014
Press Release: KraneShares CSI China Internet ETF (Nasdaq Ticker: KWEB) will own AlibDow Jones Institutional News
10/5/2014
1:09:00 PM
10/6/2014
Alibaba IPO's Short-Lived Halo Effect -- Heard on the Street
Dow Jones Institutional News
10/6/2014
1:26:00 AM
10/6/2014
Alibaba IPO's Short-Lived Halo Effect -- Heard on the Street
Dow Jones Newswires Chinese (English)
10/7/2014
4:33:00 AM
10/7/2014
Heard on the Street: Flipkart's Alibaba Worship -- Market Talk
Dow Jones Institutional News
10/9/2014
3:30:00 PM
10/9/2014
Alibaba Seems So Long Ago: IPOs Hit Rough Patch
Dow Jones Institutional News
10/9/2014
6:27:00 PM
10/10/2014
Alibaba Invests in Control-Tech Company Peel Technologies -- Market Talk
Dow Jones Institutional News
10/9/2014
6:27:00 PM
10/10/2014
Alibaba Invests in Control-Tech Company Peel Technologies -- Market Talk
Dow Jones Institutional News
10/10/2014
3:52:00 PM
10/10/2014
After Going Big, Early Alibaba Backer GGV Capital Goes Small for Totspot
Dow Jones Institutional News
10/13/2014
2:52:00 AM
10/13/2014
Artificially Inflated Smartphone Sales Lead to Questions for Alibaba
Dow Jones Institutional News
10/13/2014
3:47:00 AM
10/13/2014
Artificially Inflated Smartphone Sales Lead to Questions for Alibaba
Dow Jones Newswires Chinese (English)
10/13/2014
3:49:00 AM
10/13/2014
Artificially Inflated Smartphone Sales Lead to Questions for Alibaba -2-
Dow Jones Newswires Chinese (English)
Page 7 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 69 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 70 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
10/14/2014
3:32:00 AM
10/14/2014
Philips, Alibaba Launch Smart Air Purifier in China
Dow Jones Institutional News
10/14/2014
3:47:00 AM
10/14/2014
Philips, Alibaba Launch Smart Air Purifier in China
Dow Jones Institutional News
10/14/2014
4:00:00 AM
10/14/2014
Philips, Alibaba Launch Smart Air Purifier in China
Dow Jones Newswires Chinese (English)
10/14/2014
4:05:00 AM
10/14/2014
Press Release: Costco Makes China Market Debut Through Alibaba Group's Tmall Global PDow Jones Institutional News
10/14/2014
4:07:00 AM
10/14/2014
Costco Makes China Market Debut Through Alibaba Group's Tmall Global Platform
Dow Jones Newswires Chinese (English)
10/14/2014
6:36:00 AM
10/14/2014
Costco Makes First Foray into China Via Alibaba
Dow Jones Institutional News
10/14/2014
7:00:00 AM
10/14/2014
Costco Makes First Foray into China Via Alibaba
Dow Jones Newswires Chinese (English)
10/14/2014
12:13:00 PM
10/14/2014
Alibaba Started at Buy by UBS >BABA
Dow Jones Institutional News
10/15/2014
10:55:00 PM
10/16/2014
Alibaba Financial Affiliate: Alipay Mobile App Has 190 Million Active Users
Dow Jones Institutional News
10/15/2014
10:57:00 PM
10/16/2014
Alibaba Financial Affiliate: Alipay Mobile App Has 190 Million Active Users
Dow Jones Newswires Chinese (English)
10/16/2014
3:35:00 AM
10/16/2014
Alibaba Financial Services Affiliate CEO: No current Plans to Do IPO
Dow Jones Institutional News
10/16/2014
3:39:00 AM
10/16/2014
Alibaba Financial Services Affiliate CEO: No Timetable For Any IPO
Dow Jones Newswires Chinese (English)
10/16/2014
3:39:00 AM
10/16/2014
Alibaba Financial Services Affiliate CEO: No current Plans to Do IPO
Dow Jones Newswires Chinese (English)
10/16/2014
4:16:00 AM
10/16/2014
Alibaba's Alipay Turns to Faces, Fingerprints for Security
Dow Jones Institutional News
10/16/2014
7:19:00 AM
10/16/2014
Alibaba's Alipay Turns to Faces, Fingerprints for Security
Dow Jones Newswires Chinese (English)
10/16/2014
7:20:00 AM
10/16/2014
Alibaba's Alipay Turns to Faces, Fingerprints for Security -3-
Dow Jones Newswires Chinese (English)
10/16/2014
7:20:00 AM
10/16/2014
Alibaba's Alipay Turns to Faces, Fingerprints for Security -2-
Dow Jones Newswires Chinese (English)
10/16/2014
11:48:00 AM
10/16/2014
Will Yahoo Use Alibaba Bounty to Play Catch-Up? -- Market Talk
Dow Jones Institutional News
10/16/2014
11:48:00 AM
10/16/2014
Will Yahoo Use Alibaba Bounty to Play Catch-Up? -- Market Talk
Dow Jones Institutional News
10/16/2014
8:00:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China
Dow Jones Institutional News
10/16/2014
10:11:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China
Dow Jones Newswires Chinese (English)
10/16/2014
10:12:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China -2-
Dow Jones Newswires Chinese (English)
10/16/2014
10:14:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China -3-
Dow Jones Newswires Chinese (English)
10/16/2014
10:16:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China -5-
Dow Jones Newswires Chinese (English)
10/16/2014
10:16:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China -4-
Dow Jones Newswires Chinese (English)
10/16/2014
10:18:00 PM
10/17/2014
Alibaba Partners With Quixey, Aims for "Deep Mobile Search" in China
Dow Jones Newswires Chinese (English)
10/16/2014
11:38:00 PM
10/17/2014
Alibaba Promotes Cloud Computing at Hangzhou Conference -- Market Talk
Dow Jones Institutional News
10/17/2014
12:08:00 AM
10/17/2014
Alibaba Promotes Cloud Computing at Hangzhou Conference -- Market Talk
Dow Jones Newswires Chinese (English)
10/17/2014
5:11:00 AM
10/17/2014
Alibaba Technology Head Touts Promise of Cloud Business -- Market Talk
Dow Jones Institutional News
10/17/2014
5:47:00 AM
10/17/2014
Alibaba Technology Head Touts Promise of Cloud Business -- Market Talk
Dow Jones Newswires Chinese (English)
10/17/2014
7:55:00 AM
10/17/2014
Alibaba Heads Into the Cloud
Dow Jones Institutional News
10/17/2014
10:19:00 AM
10/17/2014
Alibaba Heads Into the Cloud
Dow Jones Newswires Chinese (English)
10/17/2014
10:20:00 AM
10/17/2014
Alibaba Heads Into the Cloud -2-
Dow Jones Newswires Chinese (English)
10/17/2014
10:21:00 AM
10/17/2014
Alibaba Heads Into the Cloud -3-
Dow Jones Newswires Chinese (English)
10/17/2014
11:44:00 AM
10/17/2014
SEC Had Above-Average Number of Comments on Alibaba IPO -- Market Talk
Dow Jones Institutional News
10/17/2014
11:44:00 AM
10/17/2014
SEC Had Above-Average Number of Comments on Alibaba IPO -- Market Talk
Dow Jones Institutional News
10/17/2014
6:02:00 PM
10/20/2014
Five Comments About Structure That The SEC Had For Alibaba
Dow Jones Institutional News
10/19/2014
11:05:00 PM
10/20/2014
Why Alibaba Chairman Jack Ma Invested in Hundsun
Dow Jones Institutional News
10/20/2014
12:52:00 AM
10/20/2014
Why Alibaba Chairman Jack Ma Invested in Hundsun
Dow Jones Newswires Chinese (English)
10/20/2014
12:53:00 AM
10/20/2014
Why Alibaba Chairman Jack Ma Invested in Hundsun -2-
Dow Jones Newswires Chinese (English)
10/20/2014
3:33:00 AM
10/20/2014
Five Questions SEC Posed to Alibaba -4-
Dow Jones Newswires Chinese (English)
10/20/2014
3:33:00 AM
10/20/2014
Five Questions SEC Posed to Alibaba -3-
Dow Jones Newswires Chinese (English)
10/20/2014
3:33:00 AM
10/20/2014
Five Questions SEC Posed to Alibaba -2-
Dow Jones Newswires Chinese (English)
10/20/2014
3:33:00 AM
10/20/2014
Five Questions SEC Posed to Alibaba
Dow Jones Newswires Chinese (English)
10/20/2014
11:09:00 AM
10/20/2014
Why Alibaba's Jack Ma Invested in Hundsun
Dow Jones Top Global Market Stories
10/20/2014
11:23:00 AM
10/20/2014
Why Alibaba's Jack Ma Invested in Hundsun
Dow Jones Top North American Equities Stories
10/21/2014
8:13:00 AM
10/21/2014
Press Release: Alibaba Group Will Announce September Quarter 2014 Results on NovembeDow Jones Institutional News
10/21/2014
8:14:00 AM
10/21/2014
Alibaba Group Will Announce Sept Qtr 2014 Results On Nov 4, 2014
Dow Jones Newswires Chinese (English)
10/21/2014
9:01:00 AM
10/21/2014
Press Release: Alibaba.com and Bigcommerce Streamline Sourcing to Selling for Online BuDow Jones Institutional News
10/21/2014
4:43:00 PM
10/22/2014
Yahoo's Alibaba IPO Riches: $6.3 Billion
Dow Jones Institutional News
10/21/2014
4:57:00 PM
10/22/2014
Yahoo Details Alibaba Payout -- Market Talk
Dow Jones Institutional News
10/21/2014
4:57:00 PM
10/22/2014
Yahoo Details Alibaba Payout -- Market Talk
Dow Jones Institutional News
10/22/2014
10:56:00 PM
10/23/2014
Alibaba Going Hollywood? -- Barron's Blog
Dow Jones Institutional News
10/23/2014
7:35:00 AM
10/23/2014
Yahoo Set to Deliver an Alibaba Tax Shield -- Barron's
Dow Jones Institutional News
10/23/2014
7:50:00 AM
10/23/2014
Yahoo Set to Deliver an Alibaba Tax Shield -- Barron's
Dow Jones Institutional News
10/23/2014
8:58:00 AM
10/23/2014
Alibaba Started at Overweight by Barclays >BABA
Dow Jones Institutional News
10/23/2014
8:59:00 AM
10/23/2014
Alibaba Started at Overweight by Barclays >BABA
Dow Jones Newswires Chinese (English)
10/23/2014
3:07:00 PM
10/23/2014
Alibaba Poised to Set Fresh Closing High For First Time Since Debut
Dow Jones Institutional News
10/23/2014
6:27:00 PM
10/24/2014
Barclays Analysts Initiate Alibaba at Buy, Target $107 -- Market Talk
Dow Jones Institutional News
10/24/2014
9:27:00 AM
10/24/2014
Alibaba Started at Outperform by BMO >BABA
Dow Jones Newswires Chinese (English)
10/24/2014
9:27:00 AM
10/24/2014
Alibaba Started at Outperform by BMO >BABA
Dow Jones Institutional News
10/27/2014
12:25:00 AM
10/27/2014
Alibaba: Jefferies, BMO Start At Buy, But Valuations Vary -- Barron's Blog
Dow Jones Institutional News
10/27/2014
9:00:00 AM
10/27/2014
China Venture Fundraising Plummets in 3Q Amid Alibaba Euphoria
Dow Jones Institutional News
10/27/2014
9:25:00 AM
10/27/2014
Alibaba Started at Buy by Jefferies >BABA
Dow Jones Institutional News
10/27/2014
9:26:00 AM
10/27/2014
Alibaba Started at Buy by Jefferies >BABA
Dow Jones Newswires Chinese (English)
10/27/2014
7:56:00 PM
10/28/2014
Alibaba: Option Volume Up, Profit-Taking At $102 -- Barron's Blog
Dow Jones Institutional News
10/27/2014
9:34:00 PM
10/28/2014
China Venture Fundraising Plummets in 3Q Amid Alibaba Euphoria
Dow Jones Newswires Chinese (English)
10/27/2014
9:34:00 PM
10/28/2014
China Venture Fundraising Plummets in 3Q Amid Alibaba Euphoria -2-
Dow Jones Newswires Chinese (English)
10/27/2014
9:36:00 PM
10/28/2014
China Venture Fundraising Plummets in 3Q Amid Alibaba Euphoria -3-
Dow Jones Newswires Chinese (English)
10/27/2014
9:43:00 PM
10/28/2014
China Venture Fundraising Plummets in 3Q Amid Alibaba Euphoria
Dow Jones Newswires Chinese (English)
10/27/2014
10:55:00 PM
10/28/2014
Press Release: Alibaba Group Announces New "Alitrip" Brand and Domain Name, Shares SDow Jones Institutional News
10/27/2014
10:57:00 PM
10/28/2014
Alibaba Exec Chairman Ma: To Invest More in U.S.
Dow Jones Institutional News
10/27/2014
10:59:00 PM
10/28/2014
Alibaba Group Announces New "Alitrip" Brand And Domain Name, Shares Strategy To En Dow Jones Newswires Chinese (English)
10/27/2014
11:00:00 PM
10/28/2014
Alibaba Group Says Its Online Travel Business, Taobao Travel Will Become Independent BDow Jones Newswires Chinese (English)
10/27/2014
11:03:00 PM
10/28/2014
Alibaba Exec Chairman Ma: To Invest More in U.S.
Dow Jones Newswires Chinese (English)
10/27/2014
11:04:00 PM
10/28/2014
Alibaba Exec Chairman Ma: Alipay Financial Payment Service Has 300M Active Users
Dow Jones Newswires Chinese (English)
10/27/2014
11:12:00 PM
10/28/2014
Alibaba Exec Chairman Ma: Interested in Cooperation With Apple on Financial Payment
Dow Jones Newswires Chinese (English)
10/27/2014
11:18:00 PM
10/28/2014
Alibaba Exec Chairman Ma: China Will Be Biggest Movie Market in the World
Dow Jones Newswires Chinese (English)
10/27/2014
11:19:00 PM
10/28/2014
Alibaba's Ma: To Put More Resources in Education
Dow Jones Newswires Chinese (English)
10/27/2014
11:20:00 PM
10/28/2014
Alibaba Ma: Looking for Partners in the Movie Business
Dow Jones Newswires Chinese (English)
10/27/2014
11:20:00 PM
10/28/2014
Alibaba Ma: Lots of Opportunities in China Education
Dow Jones Newswires Chinese (English)
Page 8 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 70 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 71 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
10/27/2014
11:20:00 PM
10/28/2014
Alibaba's Jack Ma Demurs on eBay Acquisition Query -- Market Talk
Dow Jones Institutional News
10/27/2014
11:22:00 PM
10/28/2014
Alibaba Exec Chairman Ma: See Great Opportunities in E-Commerce in U.S.
Dow Jones Newswires Chinese (English)
10/27/2014
11:36:00 PM
10/28/2014
Alibaba Interested in Apple Payment Partnership: Jack Ma -- Market Talk
Dow Jones Institutional News
10/27/2014
11:42:00 PM
10/28/2014
Alibaba's Jack Ma Demurs on eBay Acquisition Query -- Market Talk
Dow Jones Newswires Chinese (English)
10/27/2014
11:50:00 PM
10/28/2014
Alibaba Interested in Apple Payment Partnership: Jack Ma -- Market Talk
Dow Jones Newswires Chinese (English)
10/27/2014
11:58:00 PM
10/28/2014
Apple CEO Cook Says Would Love to Partner With Alibaba, Possibly on Apple Pay
Dow Jones Newswires Chinese (English)
10/28/2014
12:22:00 AM
10/28/2014
Apple Would Love to Partner With Alibaba on Mobile Payment -- Market Talk
Dow Jones Institutional News
10/28/2014
12:33:00 AM
10/28/2014
Alibaba Hunting for U.S. Investments, Says Jack Ma -- Market Talk
Dow Jones Institutional News
10/28/2014
12:45:00 AM
10/28/2014
Apple Would Love to Partner With Alibaba on Mobile Payment -- Market Talk
Dow Jones Newswires Chinese (English)
10/28/2014
12:45:00 AM
10/28/2014
Alibaba Shows Interest In Apple Payments
Dow Jones Institutional News
10/28/2014
12:46:00 AM
10/28/2014
Alibaba Interested in Payment Partnership With Apple
Dow Jones Institutional News
10/28/2014
1:08:00 AM
10/28/2014
Alibaba Hunting for U.S. Investments, Says Jack Ma -- Market Talk
Dow Jones Newswires Chinese (English)
10/28/2014
1:18:00 AM
10/28/2014
Alibaba-Apple Payment Alliance Would Face Hurdles
Dow Jones Top Global Market Stories
10/28/2014
1:21:00 AM
10/28/2014
Alibaba Shows Interest In Apple Payments -2-
Dow Jones Newswires Chinese (English)
10/28/2014
1:21:00 AM
10/28/2014
Alibaba Shows Interest In Apple Payments
Dow Jones Newswires Chinese (English)
10/28/2014
1:35:00 AM
10/28/2014
Alibaba Shows Interest In Apple Payments -3-
Dow Jones Newswires Chinese (English)
10/28/2014
2:04:00 AM
10/28/2014
Alibaba Interested in Payment Partnership With Apple -- Update
Dow Jones Institutional News
10/28/2014
2:42:00 AM
10/28/2014
Alibaba's Jack Ma Says Hong Kong Protests Not Just Political
Dow Jones Institutional News
10/28/2014
2:51:00 AM
10/28/2014
Alibaba Interested in Payment Partnership With Apple -- Update
Dow Jones Newswires Chinese (English)
10/28/2014
5:03:00 AM
10/28/2014
Alibaba Eyes Payments Tie-Up With Apple
Dow Jones Newswires Korean (English)
10/28/2014
6:39:00 AM
10/28/2014
Alibaba-Apple Payment Alliance Would Face Hurdles
Dow Jones Top North American Equities Stories
10/28/2014
10:41:00 AM
10/28/2014
Alibaba-Apple Payment Alliance Would Face Hurdles
Dow Jones Institutional News
10/28/2014
11:11:00 AM
10/28/2014
Why RBC Quit Its Lucrative Role on Giant Alibaba IPO
Dow Jones Institutional News
10/28/2014
11:49:00 AM
10/28/2014
Yahoo at 14-Year High as Alibaba Tops $100 -- Market Talk
Dow Jones Institutional News
10/28/2014
11:49:00 AM
10/28/2014
Yahoo at 14-Year High as Alibaba Tops $100 -- Market Talk
Dow Jones Institutional News
10/28/2014
3:06:00 PM
10/28/2014
Alibaba's Market Value Tops Wal-Mart's -- Market Talk
Dow Jones Institutional News
10/28/2014
3:06:00 PM
10/28/2014
Alibaba's Market Value Tops Wal-Mart's -- Market Talk
Dow Jones Institutional News
10/28/2014
6:38:00 PM
10/29/2014
Slip-Up Cost RBC Role in Alibaba IPO
Dow Jones Institutional News
10/28/2014
8:44:00 PM
10/29/2014
Alibaba-Apple Payment Alliance Would Face Hurdles
Dow Jones Newswires Chinese (English)
10/28/2014
8:45:00 PM
10/29/2014
Alibaba-Apple Payment Alliance Would Face Hurdles -3-
Dow Jones Newswires Chinese (English)
10/28/2014
8:45:00 PM
10/29/2014
Alibaba-Apple Payment Alliance Would Face Hurdles -2-
Dow Jones Newswires Chinese (English)
10/28/2014
8:52:00 PM
10/29/2014
Alibaba-Apple Payment Alliance Would Face Hurdles
Dow Jones Newswires Chinese (English)
10/29/2014
12:57:00 AM
10/29/2014
Alibaba vs Amazon: 3rd Party Hosting Wins, Deutsche Says $112 -- Barron's Blog
Dow Jones Institutional News
10/29/2014
1:48:00 AM
10/29/2014
Alibaba: Do I Hear $120? Yes, Nomura Just Said That -- Barron's Blog
Dow Jones Institutional News
10/29/2014
3:39:00 AM
10/29/2014
Xiaomi's US$1 Billion Loan Draws 29 Banks, More Than Alibaba's $8B Loan Last Year
Dow Jones Institutional News
10/29/2014
3:41:00 AM
10/29/2014
Xiaomi's US$1 Billion Loan Draws 29 Banks, More Than Alibaba's $8B Loan Last Year
Dow Jones Newswires Chinese (English)
10/29/2014
4:50:00 AM
10/29/2014
Alibaba: $125? Yes, Really, Says Pacific Crest -- Barron's Blog
Dow Jones Institutional News
10/29/2014
6:23:00 AM
10/29/2014
Alibaba Group Holding Started at Buy by Citigroup
Dow Jones Institutional News
10/29/2014
6:27:00 AM
10/29/2014
Alibaba Group Holding Started at Buy by Citigroup
Dow Jones Newswires Chinese (English)
10/29/2014
7:08:00 AM
10/29/2014
Alibaba vs Amazon: 3rd Party Hosting Wins
Dow Jones Top North American Equities Stories
10/29/2014
7:47:00 AM
10/29/2014
Goldman, Alibaba's IPO "Stabilization Agent", Says Hold -- Barron's Blog
Dow Jones Institutional News
10/29/2014
8:28:00 AM
10/29/2014
Alibaba Started at Outperform by Pacific Crest >BABA
Dow Jones Institutional News
10/29/2014
8:28:00 AM
10/29/2014
Alibaba Started at Outperform by Pacific Crest >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:31:00 AM
10/29/2014
Alibaba Started at Overweight by JPMorgan >BABA
Dow Jones Institutional News
10/29/2014
8:31:00 AM
10/29/2014
Alibaba Started at Buy by Morgan Stanley >BABA
Dow Jones Institutional News
10/29/2014
8:31:00 AM
10/29/2014
Alibaba Started at Buy by Deutsche Bank >BABA
Dow Jones Institutional News
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Buy by Citigroup >BABA
Dow Jones Institutional News
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Outperform by Credit Suisse >BABA
Dow Jones Institutional News
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Outperform by Credit Suisse >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Overweight by JPMorgan >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Buy by Morgan Stanley >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:32:00 AM
10/29/2014
Alibaba Started at Buy by Deutsche Bank >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:33:00 AM
10/29/2014
Alibaba Started at Buy by Citigroup >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:47:00 AM
10/29/2014
Alibaba Started at Neutral by Goldman Sachs >BABA
Dow Jones Institutional News
10/29/2014
8:47:00 AM
10/29/2014
Alibaba Started at Neutral by Goldman Sachs >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:51:00 AM
10/29/2014
Alibaba Started at Buy by Evercore Partners >BABA
Dow Jones Institutional News
10/29/2014
8:52:00 AM
10/29/2014
Alibaba Started at Buy by Evercore Partners >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:52:00 AM
10/29/2014
Alibaba Started at Buy by Topeka Capital Markets >BABA
Dow Jones Institutional News
10/29/2014
8:53:00 AM
10/29/2014
Alibaba Started at Buy by Topeka Capital Markets >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
8:57:00 AM
10/29/2014
Alibaba Underwriters Join Its Other Cheerleaders -- Market Talk
Dow Jones Institutional News
10/29/2014
8:57:00 AM
10/29/2014
Alibaba Underwriters Join Its Other Cheerleaders -- Market Talk
Dow Jones Institutional News
10/29/2014
8:59:00 AM
10/29/2014
Alibaba Started at Buy by Stifel Nicolaus >BABA
Dow Jones Institutional News
10/29/2014
9:01:00 AM
10/29/2014
Alibaba Started at Buy by Stifel Nicolaus >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
9:15:00 AM
10/29/2014
Alibaba Started at Outperform by Raymond James >BABA
Dow Jones Institutional News
10/29/2014
9:16:00 AM
10/29/2014
Goldman Only Goes Neutral on Alibaba -- Market Talk
Dow Jones Institutional News
10/29/2014
9:16:00 AM
10/29/2014
Alibaba Underwriters Join Its Other Cheerleaders -- Market Talk
Dow Jones Newswires Chinese (English)
10/29/2014
9:16:00 AM
10/29/2014
Alibaba Started at Outperform by Raymond James >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
9:32:00 AM
10/29/2014
Alibaba Started at Buy by SunTrust Robinson Humphrey >BABA
Dow Jones Institutional News
10/29/2014
9:33:00 AM
10/29/2014
Alibaba Started at Buy by SunTrust Robinson Humphrey >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
9:34:00 AM
10/29/2014
Alibaba Started at Outperform by RBC >BABA
Dow Jones Institutional News
10/29/2014
9:35:00 AM
10/29/2014
Alibaba Started at Outperform by RBC >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
10:57:00 AM
10/29/2014
Alibaba Finds More Friends on Wall Street
Dow Jones Institutional News
10/29/2014
3:34:00 PM
10/29/2014
Alibaba vs Amazon: 3rd Party Hosting Wins
Dow Jones Top Global Market Stories
10/29/2014
4:47:00 PM
10/30/2014
Alibaba Started at Outperform by Wells Fargo >BABA
Dow Jones Institutional News
10/29/2014
4:50:00 PM
10/30/2014
Alibaba Started at Outperform by Wells Fargo >BABA
Dow Jones Newswires Chinese (English)
10/29/2014
5:38:00 PM
10/30/2014
Alibaba's Jack Ma Romances Hollywood
Dow Jones Institutional News
10/29/2014
7:47:00 PM
10/30/2014
Alibaba Retreats On Wall Street's Choral Fantasy -- Barron's Blog
Dow Jones Institutional News
10/29/2014
8:37:00 PM
10/30/2014
Alibaba's Jack Ma Romances Hollywood
Dow Jones Newswires Chinese (English)
10/29/2014
8:38:00 PM
10/30/2014
Alibaba's Jack Ma Romances Hollywood -2-
Dow Jones Newswires Chinese (English)
10/29/2014
9:18:00 PM
10/30/2014
Alibaba's Underwriters Are Bullish on the Stock -2-
Dow Jones Newswires Chinese (English)
10/29/2014
9:18:00 PM
10/30/2014
Alibaba's Underwriters Are Bullish on the Stock
Dow Jones Newswires Chinese (English)
Page 9 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 71 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 72 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
10/29/2014
9:19:00 PM
10/30/2014
Alibaba's Underwriters Are Bullish on the Stock -3-
Dow Jones Newswires Chinese (English)
10/29/2014
10:51:00 PM
10/30/2014
Nomura Rates Alibaba a Buy With 20%-Plus Upside -- Market Talk
Dow Jones Institutional News
10/29/2014
10:59:00 PM
10/30/2014
Nomura Rates Alibaba a Buy With 20%-Plus Upside -- Market Talk
Dow Jones Newswires Chinese (English)
10/29/2014
11:00:00 PM
10/30/2014
Press Release: Youku Tudou and Alibaba Group Collaborate to Innovate Online Video MarkDow Jones Institutional News
10/29/2014
11:04:00 PM
10/30/2014
Youku Tudou, Alibaba to Collaborate on Online Video Marketing
Dow Jones Newswires Chinese (English)
10/30/2014
2:04:00 AM
10/30/2014
No Surprise, Alibaba Bookrunners Are Bullish on Alibaba -- Market Talk
Dow Jones Institutional News
10/30/2014
2:33:00 AM
10/30/2014
No Surprise, Alibaba Bookrunners Are Bullish on Alibaba -- Market Talk
Dow Jones Newswires Chinese (English)
10/30/2014
6:03:00 AM
10/30/2014
After Alibaba, Xiaomi Lures 29 Banks for Loan
Dow Jones Newswires Korean (English)
10/30/2014
7:32:00 AM
10/30/2014
Alibaba Set for 30% Annual Growth -- Barron's
Dow Jones Institutional News
10/30/2014
10:54:00 AM
10/30/2014
Alibaba's Jack Ma Romances Hollywood
Dow Jones Top North American Equities Stories
10/30/2014
11:29:00 AM
10/30/2014
Alibaba's Jack Ma Romances Hollywood
Dow Jones Top Global Market Stories
10/31/2014
7:05:00 AM
10/31/2014
Alibaba Set for 30% Annual Growth -- Barron's
Dow Jones Institutional News
11/1/2014
12:06:00 AM
11/3/2014
Why Alibaba Will Flatten Its Rival --Barron's
Dow Jones Institutional News
11/2/2014
7:02:00 AM
11/3/2014
Investors Eagerly Await Alibaba's Results
Dow Jones Institutional News
11/2/2014
5:30:00 PM
11/3/2014
Alibaba Profit, Revenue Seen Rising 45% in First Results After IPO -- Earnings Preview
Dow Jones Institutional News
11/2/2014
6:49:00 PM
11/3/2014
Alibaba Profit, Revenue Seen Rising 45% in First Results After IPO -- Earnings Preview
Dow Jones Institutional News
11/2/2014
8:30:00 PM
11/3/2014
How Alibaba Plans To Help U.S. Exporters -- WSJ.D Live Report
Dow Jones Institutional News
11/2/2014
9:08:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results
Dow Jones Newswires Chinese (English)
11/2/2014
9:09:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results -4-
Dow Jones Newswires Chinese (English)
11/2/2014
9:09:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results -3-
Dow Jones Newswires Chinese (English)
11/2/2014
9:09:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results -2-
Dow Jones Newswires Chinese (English)
11/2/2014
9:16:00 PM
11/3/2014
Alibaba Profit, Revenue Seen Rising 45% in First Results After IPO -2-
Dow Jones Newswires Chinese (English)
11/2/2014
9:16:00 PM
11/3/2014
Alibaba Profit, Revenue Seen Rising 45% in First Results After IPO
Dow Jones Newswires Chinese (English)
11/3/2014
12:01:00 AM
11/3/2014
How Alibaba Plans To Help U.S. Exporters -- WSJ.D Live Report
Dow Jones Newswires Chinese (English)
11/3/2014
12:02:00 AM
11/3/2014
How Alibaba Plans To Help U.S. Exporters -- WSJ.D Live Report -3-
Dow Jones Newswires Chinese (English)
11/3/2014
12:02:00 AM
11/3/2014
How Alibaba Plans To Help U.S. Exporters -- WSJ.D Live Report -2-
Dow Jones Newswires Chinese (English)
11/3/2014
12:03:00 AM
11/3/2014
How Alibaba Plans To Help U.S. Exporters -- WSJ.D Live Report -4-
Dow Jones Newswires Chinese (English)
11/3/2014
1:06:00 AM
11/3/2014
Investors Eagerly Await Alibaba's Results -4-
Dow Jones Newswires Chinese (English)
11/3/2014
5:34:00 AM
11/3/2014
How Alibaba Plans to Help U.S. Exporters
Dow Jones Newswires Korean (English)
11/3/2014
12:49:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results
Dow Jones Top North American Equities Stories
11/3/2014
12:52:00 PM
11/3/2014
Don't First Look at Alibaba's EPS, Revenue -- Market Talk
Dow Jones Institutional News
11/3/2014
12:52:00 PM
11/3/2014
Don't First Look at Alibaba's EPS, Revenue -- Market Talk
Dow Jones Institutional News
11/3/2014
1:49:00 PM
11/3/2014
Investors Eagerly Await Alibaba's Results
Dow Jones Top Global Market Stories
11/3/2014
3:07:00 PM
11/3/2014
Wedbush: 30% Growth for Alibaba -- Barron's Blog
Dow Jones Institutional News
11/3/2014
4:18:00 PM
11/4/2014
Options Market Expecting Good News from Alibaba
Dow Jones Institutional News
11/3/2014
9:17:00 PM
11/4/2014
Deutsche: Alibaba Hosts 3rd Parties -- And Merchants Like It -- Barron's Blog
Dow Jones Institutional News
11/4/2014
2:46:00 AM
11/4/2014
Alibaba Revenue Seen Rising 45% in First Results After IPO
Dow Jones Newswires Chinese (English)
11/4/2014
2:48:00 AM
11/4/2014
Alibaba Revenue Seen Rising 45% in First Results After IPO -2-
Dow Jones Newswires Chinese (English)
11/4/2014
2:51:00 AM
11/4/2014
Alibaba Revenue Seen Rising 45% in First Results After IPO -2-
Dow Jones Newswires Chinese (English)
11/4/2014
7:00:00 AM
11/4/2014
Press Release: Alibaba Group Announces September Quarter 2014 Results
Dow Jones Institutional News
11/4/2014
7:03:00 AM
11/4/2014
Alibaba Group Holding 2Q Rev $2.74B >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:03:00 AM
11/4/2014
Alibaba Group Holding 2Q Mobile Rev $606M>BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:03:00 AM
11/4/2014
Alibaba Group Holding 2Q Net $494M >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:03:00 AM
11/4/2014
Alibaba Group Holding 2Q EPS 20c >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group: 217M Monthly Active Users On Mobile Commerce Apps In September
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group: Annual Active Buyers Increased 52% >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group Holding 2Q Gross Merchandise Volume Up 49%>BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group Holding: Annual Active Buyers Increase 52% Year-on-Year
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group: Significant 3Q Growth Across Key Operating Metrics >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:04:00 AM
11/4/2014
Alibaba Group Holding 2Q Adj EPS 45c >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:05:00 AM
11/4/2014
Alibaba Group Holding 2Q Adj EBITDA $1.38B>BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:05:00 AM
11/4/2014
Alibaba Group Holding 2Q Income From Ops $708M>BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:06:00 AM
11/4/2014
Alibaba 3Q China Retail Marketplaces Gross Merchandise Volume Rose 49% >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:06:00 AM
11/4/2014
Alibaba Group: $95B In Mobile GMV For 12 Months Ended September
Dow Jones Newswires Chinese (English)
11/4/2014
7:07:00 AM
11/4/2014
Strong Initial Results From Alibaba -- Market Talk
Dow Jones Institutional News
11/4/2014
7:07:00 AM
11/4/2014
Strong Initial Results From Alibaba -- Market Talk
Dow Jones Institutional News
11/4/2014
7:08:00 AM
11/4/2014
Alibaba Group 3Q Non-GAAP Ebitda $1.38B >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:09:00 AM
11/4/2014
Alibaba Group 3Q Net Cash Provided By Operating Activities $955M >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:09:00 AM
11/4/2014
Alibaba Group 3Q Free Cash Flow $1.46B >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:09:00 AM
11/4/2014
Alibaba Group 3Q Mobile Revenue $606M >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:09:00 AM
11/4/2014
Alibaba Group 3Q Capital Spending $553M >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:09:00 AM
11/4/2014
Alibaba 3Q-End Cash, Equivalents, Short-Term Investments $17.9B
Dow Jones Newswires Chinese (English)
11/4/2014
7:12:00 AM
11/4/2014
Alibaba Revenue Rises 54%
Dow Jones Institutional News
11/4/2014
7:18:00 AM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps
Dow Jones Top North American Equities Stories
11/4/2014
7:19:00 AM
11/4/2014
Alibaba Group: Net Declined As Share-Based Compensation More Than Tripled Due to GraDow Jones Institutional News
11/4/2014
7:20:00 AM
11/4/2014
Alibaba Profit Falls, Revenue Jumps
Dow Jones Institutional News
11/4/2014
7:23:00 AM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps
Dow Jones Top News & Commentary
11/4/2014
7:24:00 AM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps
Dow Jones Top Global Market Stories
11/4/2014
7:25:00 AM
11/4/2014
Alibaba Revenue Rises 54%--Update
Dow Jones Institutional News
11/4/2014
7:26:00 AM
11/4/2014
Alibaba Group Holding 2Q Rev $2.74B >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:27:00 AM
11/4/2014
Alibaba 3Q China Retail Marketplaces Gross Merchandise Volume Rose 49% >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:28:00 AM
11/4/2014
Alibaba Group 3Q Free Cash Flow $1.46B >BABA
Dow Jones Newswires Chinese (English)
11/4/2014
7:28:00 AM
11/4/2014
Strong Initial Results From Alibaba -- Market Talk
Dow Jones Newswires Chinese (English)
11/4/2014
7:32:00 AM
11/4/2014
Alibaba: Q3 Beat, No Growth Slowdown, Mobile Gained; Margin Weaker -- Barron's Blog Dow Jones Institutional News
11/4/2014
7:35:00 AM
11/4/2014
Alibaba Profit Falls, Revenue Jumps
Dow Jones Institutional News
11/4/2014
7:37:00 AM
11/4/2014
Alibaba Revenue Rises 54%
Dow Jones Newswires Chinese (English)
11/4/2014
7:40:00 AM
11/4/2014
Alibaba: Mobile GMV Accounts For 35.8% of Total GMV
Dow Jones Institutional News
11/4/2014
7:41:00 AM
11/4/2014
Alibaba: Mobile GMV Accounts For 35.8% of Total GMV
Dow Jones Newswires Chinese (English)
11/4/2014
7:54:00 AM
11/4/2014
Alibaba Reports 54% Rise In Revenue--2nd Update
Dow Jones Institutional News
11/4/2014
7:56:00 AM
11/4/2014
Alibaba Revenue Rises 54% -2-
Dow Jones Newswires Chinese (English)
11/4/2014
8:12:00 AM
11/4/2014
Alibaba's Mobile Monetization Rate Rises -- Market Talk
Dow Jones Institutional News
Page 10 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 72 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 73 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
11/4/2014
8:12:00 AM
11/4/2014
Alibaba's Mobile Monetization Rate Rises -- Market Talk
Dow Jones Institutional News
11/4/2014
8:21:00 AM
11/4/2014
Alibaba Revenue Rises 54%
Dow Jones Newswires Chinese (English)
11/4/2014
8:25:00 AM
11/4/2014
Alibaba's Mobile Monetization Rate Rises -- Market Talk
Dow Jones Newswires Chinese (English)
11/4/2014
8:27:00 AM
11/4/2014
Alibaba Q3: Mobile Monetization Rate Jumped; No Guidance -- Barron's Blog
Dow Jones Institutional News
11/4/2014
8:28:00 AM
11/4/2014
Alibaba Reports 54% Rise In Revenue--3rd Update
Dow Jones Institutional News
11/4/2014
8:44:00 AM
11/4/2014
Alibaba M&A Strategy Focused on Long Term -- Market Talk
Dow Jones Institutional News
11/4/2014
8:44:00 AM
11/4/2014
Alibaba M&A Strategy Focused on Long Term -- Market Talk
Dow Jones Institutional News
11/4/2014
9:16:00 AM
11/4/2014
Alibaba M&A Strategy Focused on Long Term -- Market Talk
Dow Jones Newswires Chinese (English)
11/4/2014
9:19:00 AM
11/4/2014
Alibaba Reports 54% Rise In Revenue-- Update -2-
Dow Jones Newswires Chinese (English)
11/4/2014
9:19:00 AM
11/4/2014
Alibaba Reports 54% Rise In Revenue-- Update
Dow Jones Newswires Chinese (English)
11/4/2014
9:21:00 AM
11/4/2014
Alibaba Reports 54% Rise In Revenue-- Update -3-
Dow Jones Newswires Chinese (English)
11/4/2014
9:31:00 AM
11/4/2014
No 'Wow Factor' From Alibaba's Report -- Market Talk
Dow Jones Institutional News
11/4/2014
9:31:00 AM
11/4/2014
No 'Wow Factor' From Alibaba's Report -- Market Talk
Dow Jones Institutional News
11/4/2014
10:17:00 AM
11/4/2014
China's Online Firm Alibaba Sees Revenue Soar
Dow Jones Institutional News
11/4/2014
10:51:00 AM
11/4/2014
Alibaba's Big Earnings Gap -- Heard on the Street
Dow Jones Institutional News
11/4/2014
11:28:00 AM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps -- 4th Update
Dow Jones Institutional News
11/4/2014
11:38:00 AM
11/4/2014
Alibaba's Rise Looks Like Boon for Fidelity, T. Rowe Price -- Barron's Blog
Dow Jones Institutional News
11/4/2014
11:43:00 AM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps -- 4th Update
Dow Jones Institutional News
11/4/2014
12:02:00 PM
11/4/2014
Cantor Raises Alibaba Price Target to $110 -- Market Talk
Dow Jones Institutional News
11/4/2014
12:02:00 PM
11/4/2014
Cantor Raises Alibaba Price Target to $110 -- Market Talk
Dow Jones Institutional News
11/4/2014
1:04:00 PM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps--5th Update
Dow Jones Institutional News
11/4/2014
1:19:00 PM
11/4/2014
Alibaba's Profit Falls, Revenue Jumps--5th Update
Dow Jones Institutional News
11/4/2014
3:05:00 PM
11/4/2014
Susquehanna Another Alibaba Target Hiker -- Market Talk
Dow Jones Institutional News
11/4/2014
3:05:00 PM
11/4/2014
Susquehanna Another Alibaba Target Hiker -- Market Talk
Dow Jones Institutional News
11/4/2014
3:25:00 PM
11/4/2014
Alibaba's Analysts Say Buy!
Dow Jones Institutional News
11/4/2014
3:54:00 PM
11/4/2014
5 Things to Read Today: Midterm Elections 2014, Alibaba's Profit Falls and More
Dow Jones Institutional News
11/4/2014
7:45:00 PM
11/5/2014
Alibaba's Analysts Say Buy! -3-
Dow Jones Newswires Chinese (English)
11/4/2014
7:45:00 PM
11/5/2014
Alibaba's Analysts Say Buy! -2-
Dow Jones Newswires Chinese (English)
11/4/2014
7:45:00 PM
11/5/2014
Alibaba's Analysts Say Buy!
Dow Jones Newswires Chinese (English)
11/4/2014
7:46:00 PM
11/5/2014
Alibaba's Analysts Say Buy! -5-
Dow Jones Newswires Chinese (English)
11/4/2014
7:46:00 PM
11/5/2014
Alibaba's Analysts Say Buy! -4-
Dow Jones Newswires Chinese (English)
11/4/2014
7:51:00 PM
11/5/2014
Alibaba's Analysts Say Buy!
Dow Jones Newswires Chinese (English)
11/4/2014
7:52:00 PM
11/5/2014
Alibaba's Wide Divide On Earnings -- Heard On The Street
Dow Jones Institutional News
11/4/2014
8:29:00 PM
11/5/2014
Alibaba's Big Earnings Gap
Dow Jones Top Global Market Stories
11/4/2014
9:49:00 PM
11/5/2014
Alibaba's Big Earnings Gap -- Heard on the Street -2-
Dow Jones Newswires Chinese (English)
11/4/2014
9:49:00 PM
11/5/2014
Alibaba's Big Earnings Gap -- Heard on the Street
Dow Jones Newswires Chinese (English)
11/4/2014
9:50:00 PM
11/5/2014
Alibaba Revenue Lifted by User, Mobile Growth
Dow Jones Institutional News
11/4/2014
9:50:00 PM
11/5/2014
Alibaba's Big Earnings Gap -- Heard on the Street -3-
Dow Jones Newswires Chinese (English)
11/4/2014
10:19:00 PM
11/5/2014
Don't Be Fooled by the Profit Drop, Alibaba Results Are Good -- Market Talk
Dow Jones Institutional News
11/4/2014
10:44:00 PM
11/5/2014
Don't Be Fooled by the Profit Drop, Alibaba Results Are Good -- Market Talk
Dow Jones Newswires Chinese (English)
11/5/2014
12:40:00 AM
11/5/2014
Softbank Slumps On Sprint, But How About Alibaba Bump? -- Barron's Blog
Dow Jones Institutional News
11/5/2014
3:45:00 AM
11/5/2014
Alibaba: Post Q3, Wall Street Tweaks Up TP To $112 -- Barron's Blog
Dow Jones Institutional News
11/5/2014
6:34:00 AM
11/5/2014
Alibaba's Big Earnings Gap
Dow Jones Top North American Equities Stories
11/7/2014
6:30:00 AM
11/7/2014
Press Release: Alibaba Group Will Host Sixth Annual 11.11 Shopping Festival
Dow Jones Institutional News
11/9/2014
6:01:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba
Dow Jones Institutional News
11/9/2014
10:26:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba -2-
Dow Jones Newswires Chinese (English)
11/9/2014
10:26:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba
Dow Jones Newswires Chinese (English)
11/9/2014
10:27:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba -3-
Dow Jones Newswires Chinese (English)
11/9/2014
10:28:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba -6-
Dow Jones Newswires Chinese (English)
11/9/2014
10:28:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba -5-
Dow Jones Newswires Chinese (English)
11/9/2014
10:28:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba -4-
Dow Jones Newswires Chinese (English)
11/9/2014
11:37:00 PM
11/10/2014
Quiet Before Storm At Alibaba Delivery Firm
Dow Jones Institutional News
11/9/2014
11:44:00 PM
11/10/2014
Quiet Before Storm At Alibaba Delivery Firm
Dow Jones Top Global Market Stories
11/9/2014
11:52:00 PM
11/10/2014
Alibaba Buffs a Key Business Metric
Dow Jones Institutional News
11/10/2014
2:13:00 AM
11/10/2014
Quiet Before Storm At Alibaba Delivery Firm
Dow Jones Newswires Chinese (English)
11/10/2014
2:14:00 AM
11/10/2014
Quiet Before Storm At Alibaba Delivery Firm -2-
Dow Jones Newswires Chinese (English)
11/10/2014
3:43:00 AM
11/10/2014
Should Alibaba's Singles' Day Volume Be 25% Smaller?
Dow Jones Institutional News
11/10/2014
5:14:00 AM
11/10/2014
Alibaba: Singles Day, What To Expect This Year? -- Barron's Blog
Dow Jones Institutional News
11/10/2014
5:51:00 AM
11/10/2014
Should Alibaba's Singles' Day Volume Be 25% Smaller?
Dow Jones Newswires Chinese (English)
11/10/2014
5:56:00 AM
11/10/2014
Should Alibaba's Singles' Day Volume Be 25% Smaller? -2-
Dow Jones Newswires Chinese (English)
11/10/2014
6:34:00 AM
11/10/2014
Quiet Before Storm At Alibaba Delivery Firm
Dow Jones Top North American Equities Stories
11/10/2014
6:34:00 AM
11/10/2014
Crucial Business Day Looms for Alibaba
Dow Jones Top North American Equities Stories
11/10/2014
1:32:00 PM
11/10/2014
Press Release: Alibaba Group Generated US$2 Billion in GMV in First Hour of 11.11 Shop Dow Jones Institutional News
11/10/2014
1:34:00 PM
11/10/2014
Alibaba Group Generated $2 Billion In GMV In First Hour Of Nov. 11 Shopping Festival
Dow Jones Newswires Chinese (English)
11/10/2014
3:14:00 PM
11/10/2014
Crucial Business Day Looms for Alibaba
Dow Jones Top Global Market Stories
11/10/2014
11:10:00 PM
11/11/2014
How to Invest in Alibaba As Shares Keep Rising -- Barron's Asia
Dow Jones Institutional News
11/11/2014
12:15:00 AM
11/11/2014
Alibaba: Further Mobile Gains On Singles' Day; 86% Market Share -- Barron's Blog
Dow Jones Institutional News
11/11/2014
12:35:00 AM
11/11/2014
Alibaba: Singles Day Transaction Volume Tops 2013 Record of RMB36.2 Billion
Dow Jones Institutional News
11/11/2014
12:37:00 AM
11/11/2014
Alibaba: Singles Day Transaction Volume Tops 2013 Record of RMB36.2 Billion
Dow Jones Newswires Chinese (English)
11/11/2014
1:12:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record
Dow Jones Institutional News
11/11/2014
1:24:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record
Dow Jones Top Global Market Stories
11/11/2014
1:51:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record
Dow Jones Newswires Chinese (English)
11/11/2014
1:52:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record -2-
Dow Jones Newswires Chinese (English)
11/11/2014
1:55:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record -2-
Dow Jones Newswires Chinese (English)
11/11/2014
3:12:00 AM
11/11/2014
Alibaba Exec: Would Be Good for Alibaba Financial Affiliate to Become Public Company Dow Jones Institutional News
11/11/2014
3:16:00 AM
11/11/2014
Alibaba Exec: Would Be Good for Alibaba Financial Affiliate to Become Public Company Dow Jones Newswires Chinese (English)
11/11/2014
3:17:00 AM
11/11/2014
Alibaba Exec: IPO Possible in Future, Focus now Is on Other Things
Dow Jones Newswires Chinese (English)
11/11/2014
3:17:00 AM
11/11/2014
Alibaba Exec: IPO Possible in Future, Focus now Is on Other Things
Dow Jones Newswires Chinese (English)
11/11/2014
4:19:00 AM
11/11/2014
Alibaba Exec: Talks With Apple Focusing on Payments in China Market
Dow Jones Newswires Chinese (English)
11/11/2014
4:20:00 AM
11/11/2014
Alibaba Exec: Alipay Providing Back-End Services For Apple Pay a Possible Scenario
Dow Jones Newswires Chinese (English)
11/11/2014
4:20:00 AM
11/11/2014
Alibaba Exec: Alibaba Financial Affiliate in Talks With Apple About Possible Payment C
Dow Jones Newswires Chinese (English)
Page 11 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 73 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 74 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
11/11/2014
4:23:00 AM
11/11/2014
Alibaba Exec: Seeking Alliances in Many Areas Including Entertainment
Dow Jones Newswires Chinese (English)
11/11/2014
4:24:00 AM
11/11/2014
Alibaba Exec: Discussing Possible Alliances With Many Messaging Apps Including Line
Dow Jones Newswires Chinese (English)
11/11/2014
4:24:00 AM
11/11/2014
Alibaba Exec: No Specific Limit to Budget For Acquisitions
Dow Jones Newswires Chinese (English)
11/11/2014
4:25:00 AM
11/11/2014
Alibaba Exec: Room For Growth Given Low E-Commerce Penetration in China
Dow Jones Newswires Chinese (English)
11/11/2014
4:44:00 AM
11/11/2014
Alibaba Exec: No Timeframe for Possible IPO of Financial Affiliate
Dow Jones Newswires Chinese (English)
11/11/2014
5:56:00 AM
11/11/2014
Alibaba, Apple Talks on Payments Tie-Up Focused on China -- Update
Dow Jones Institutional News
11/11/2014
6:14:00 AM
11/11/2014
Alibaba, Apple Talks on Payments Tie-Up Focused on China
Dow Jones Top Global Market Stories
11/11/2014
6:24:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record
Dow Jones Top North American Equities Stories
11/11/2014
6:24:00 AM
11/11/2014
Alibaba, Apple Talks on Payments Tie-Up Focused on China
Dow Jones Top North American Equities Stories
11/11/2014
7:30:00 AM
11/11/2014
Alibaba, Apple Talks on Payments Tie-Up Focused on China -- Update
Dow Jones Newswires Chinese (English)
11/11/2014
7:30:00 AM
11/11/2014
Alibaba, Apple Talks on Payments Tie-Up Focused on China -- Update
Dow Jones Newswires Chinese (English)
11/11/2014
8:33:00 AM
11/11/2014
Press Release: Alibaba Group Generated US$8 Billion in GMV with a Few Hours Left of 11Dow Jones Institutional News
11/11/2014
8:35:00 AM
11/11/2014
Alibaba Group Generated US$8 B In GMV With A Few Hours Left Of 11.11 Shopping FestDow Jones Newswires Chinese (English)
11/11/2014
8:41:00 AM
11/11/2014
Alibaba Puts Thanksgiving Weekend in Perspective -- Market Talk
Dow Jones Institutional News
11/11/2014
8:41:00 AM
11/11/2014
Alibaba Puts Thanksgiving Weekend in Perspective -- Market Talk
Dow Jones Institutional News
11/11/2014
9:01:00 AM
11/11/2014
Alibaba Puts Thanksgiving Weekend in Perspective -- Market Talk
Dow Jones Newswires Chinese (English)
11/11/2014
10:17:00 AM
11/11/2014
Alibaba's Jack Ma: We Will Take Alipay Public -CNBC
Dow Jones Institutional News
11/11/2014
10:24:00 AM
11/11/2014
Alibaba's Jack Ma: We Will Take Alipay Public -CNBC
Dow Jones Newswires Chinese (English)
11/11/2014
10:59:00 AM
11/11/2014
Alibaba's Jack Ma: We Will Take Alipay Public -CNBC
Dow Jones Top Global Market Stories
11/11/2014
11:00:00 AM
11/11/2014
Alibaba's Ma: We Will Take Alipay Public
Dow Jones Institutional News
11/11/2014
11:02:00 AM
11/11/2014
Alibaba's Jack Ma: We Will Take Alipay Public -CNBC
Dow Jones Newswires Chinese (English)
11/11/2014
11:04:00 AM
11/11/2014
Alibaba's Jack Ma: We Will Take Alipay Public -CNBC
Dow Jones Top North American Equities Stories
11/11/2014
11:15:00 AM
11/11/2014
Alibaba's Ma: We Will Take Alipay Public
Dow Jones Institutional News
11/11/2014
11:16:00 AM
11/11/2014
Alibaba: Singles Day Shopping Event Transaction Volume Totals $9.3B
Dow Jones Institutional News
11/11/2014
11:19:00 AM
11/11/2014
Alibaba: Singles Day Shopping Event Transaction Volume Totals $9.3B
Dow Jones Newswires Chinese (English)
11/11/2014
11:22:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record -- Update
Dow Jones Institutional News
11/11/2014
11:22:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record
Dow Jones Top News & Commentary
11/11/2014
11:32:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record -- 2nd Update
Dow Jones Institutional News
11/11/2014
11:43:00 AM
11/11/2014
Alibaba Makes the Most of Singles Day, and Plans to IPO Alipay
Dow Jones Institutional News
11/11/2014
11:45:00 AM
11/11/2014
Alibaba Breaks Singles' Day Record -- Update
Dow Jones Newswires Chinese (English)
11/11/2014
1:49:00 PM
11/11/2014
Press Release: Alibaba Group Generated US$9.3 Billion in GMV on 11.11 Shopping Festiv Dow Jones Institutional News
11/11/2014
7:59:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update
Dow Jones Newswires Chinese (English)
11/11/2014
8:00:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update -2-
Dow Jones Newswires Chinese (English)
11/11/2014
8:00:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update -3-
Dow Jones Newswires Chinese (English)
11/11/2014
8:01:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update -4-
Dow Jones Newswires Chinese (English)
11/11/2014
8:02:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update -5-
Dow Jones Newswires Chinese (English)
11/11/2014
8:04:00 PM
11/12/2014
Alibaba Breaks Singles' Day Record -- Update
Dow Jones Newswires Chinese (English)
11/12/2014
3:06:00 AM
11/12/2014
Alibaba Establishes Singles' Day Record
Dow Jones Newswires Korean (English)
11/12/2014
10:03:00 AM
11/12/2014
Alibaba Now Bigger Than P&G, GE and Wells Fargo
Dow Jones Institutional News
11/12/2014
6:50:00 PM
11/13/2014
Alibaba Now Bigger Than P&G, GE and Wells Fargo
Dow Jones Newswires Chinese (English)
11/13/2014
8:39:00 AM
11/13/2014
Press Release: Alibaba Group Announces Proposed Offering of Senior Unsecured Notes
Dow Jones Institutional News
11/13/2014
8:40:00 AM
11/13/2014
Alibaba Group Announces Proposed Offering Of Senior Unsecured Notes
Dow Jones Newswires Chinese (English)
11/13/2014
8:41:00 AM
11/13/2014
Alibaba Says Principal Amount, Interest Rates, Maturity Dates and Other Terms Haven't BeDow Jones Newswires Chinese (English)
11/13/2014
8:43:00 AM
11/13/2014
Alibaba to Use Net Proceeds Primarily to Refinance Existing Credit Facilities>BABA
Dow Jones Newswires Chinese (English)
11/13/2014
8:52:00 AM
11/13/2014
Press Release: Fitch Assigns First-Time 'A+' Rating to Alibaba, Proposed Notes
Dow Jones Institutional News
11/13/2014
8:59:00 AM
11/13/2014
S&P Rates Alibaba Group 'A+' With Stbl Otlk; Notes Rated 'A+'
Dow Jones Institutional News
11/13/2014
9:03:00 AM
11/13/2014
Moody's Assigns First-time A1 Ratings To Alibaba; Outlook Stable
Dow Jones Institutional News
11/13/2014
9:27:00 AM
11/13/2014
Alibaba Group: To Offer Unsecured Notes in U.S.
Dow Jones Institutional News
11/13/2014
10:02:00 AM
11/13/2014
Alibaba to Tap Bond Market for Up to $8 Billion
Dow Jones Top News & Commentary
11/13/2014
10:02:00 AM
11/13/2014
Alibaba to Offer Unsecured Notes to Refinance Some of its Debt
Dow Jones Institutional News
11/13/2014
10:21:00 AM
11/13/2014
Alibaba to Offer Unsecured Notes to Refinance Some of its Debt
Dow Jones Newswires Chinese (English)
11/13/2014
1:35:00 PM
11/13/2014
Alibaba Looking to Raise as Much as $8 Billion in Bond Offering -- Source
Dow Jones Institutional News
11/13/2014
1:36:00 PM
11/13/2014
Alibaba Looking to Raise as Much as $8 Billion in Bond Offering -- Source
Dow Jones Institutional News
11/13/2014
1:38:00 PM
11/13/2014
Alibaba Looking to Raise as Much as $8 Billion in Bond Offering -- Source
Dow Jones Newswires Chinese (English)
11/13/2014
1:39:00 PM
11/13/2014
Alibaba Holding Roadshow Next Week, Bond Sale to Follow -- Investors
Dow Jones Newswires Chinese (English)
11/13/2014
2:12:00 PM
11/13/2014
Alibaba Looks to Raise as Much as $8 Billion in Bond Offering
Dow Jones Institutional News
11/13/2014
2:19:00 PM
11/13/2014
Alibaba Plans $8 Billion Bond Sale
Dow Jones Top North American Equities Stories
11/13/2014
2:19:00 PM
11/13/2014
Alibaba Plans $8 Billion Bond Sale
Dow Jones Top Global Market Stories
11/13/2014
2:23:00 PM
11/13/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update
Dow Jones Institutional News
11/13/2014
2:23:00 PM
11/13/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update
Dow Jones Institutional News
11/13/2014
2:33:00 PM
11/13/2014
Alibaba Looks to Raise as Much as $8 Billion in Bond Offering
Dow Jones Newswires Chinese (English)
11/13/2014
3:34:00 PM
11/13/2014
While Alibaba Gets High Grade, Twitter in Junk -- Market Talk
Dow Jones Institutional News
11/13/2014
3:34:00 PM
11/13/2014
While Alibaba Gets High Grade, Twitter in Junk -- Market Talk
Dow Jones Institutional News
11/13/2014
6:56:00 PM
11/14/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update -2-
Dow Jones Newswires Chinese (English)
11/13/2014
6:56:00 PM
11/14/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update
Dow Jones Newswires Chinese (English)
11/13/2014
6:57:00 PM
11/14/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update -3-
Dow Jones Newswires Chinese (English)
11/13/2014
6:58:00 PM
11/14/2014
Alibaba to Tap Bond Market for Up to $8 Billion--Update -4-
Dow Jones Newswires Chinese (English)
11/13/2014
7:11:00 PM
11/14/2014
Alibaba Plans $8 Billion Bond Sale
Dow Jones Institutional News
11/13/2014
8:13:00 PM
11/14/2014
Sina Q3 Beat On Alibaba Stake Sale, Q4 Outlook Miss -- Barron's Blog
Dow Jones Institutional News
11/14/2014
8:01:00 AM
11/14/2014
Fitch's 'Inside Credit': U.S .Banking Outlook, Bond Market Liquidity & Alibaba's Rating
Dow Jones Institutional News
11/14/2014
4:13:00 PM
11/17/2014
Third Point Reports Alibaba Group Holding Ltd. Stake Worth $639 Million As of Sept. 30 -Dow Jones Institutional News
11/14/2014
4:36:00 PM
11/17/2014
Paulson & Co. Alibaba Stake Valued at $169 Million at Quarter's End -- Filing
Dow Jones Institutional News
11/14/2014
4:44:00 PM
11/17/2014
Soros Takes Stakes in Yahoo, Alibaba
Dow Jones Top News & Commentary
11/14/2014
4:44:00 PM
11/17/2014
Soros Takes Stakes in Yahoo, Alibaba
Dow Jones Institutional News
11/14/2014
4:54:00 PM
11/17/2014
Third Point Discloses Size of Alibaba Stake -- Market Talk
Dow Jones Institutional News
11/14/2014
4:54:00 PM
11/17/2014
Third Point Discloses Size of Alibaba Stake -- Market Talk
Dow Jones Institutional News
11/14/2014
5:04:00 PM
11/17/2014
Loeb's Third Point Took Big Stake in Alibaba During Third Quarter
Dow Jones Institutional News
11/14/2014
5:04:00 PM
11/17/2014
Loeb's Third Point Took Big Stake in Alibaba During Third Quarter
Dow Jones Top News & Commentary
11/14/2014
5:09:00 PM
11/17/2014
Soros Takes Stakes in Yahoo, Alibaba
Dow Jones Top North American Equities Stories
11/14/2014
5:19:00 PM
11/17/2014
Soros Takes Stakes in Yahoo, Alibaba
Dow Jones Top North American Financial Services
11/14/2014
5:19:00 PM
11/17/2014
Soros Takes Stakes in Yahoo, Alibaba
Dow Jones Top Global Market Stories
Page 12 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 74 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 75 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
11/14/2014
5:29:00 PM
11/17/2014
Loeb's Third Point Took Big Stake in Alibaba During Third Quarter
Dow Jones Top North American Financial Services
11/14/2014
5:29:00 PM
11/17/2014
Loeb's Third Point Took Big Stake in Alibaba During Third Quarter
Dow Jones Top North American Equities Stories
11/14/2014
5:34:00 PM
11/17/2014
Loeb's Third Point Took Big Stake in Alibaba During Third Quarter
Dow Jones Top Global Market Stories
11/14/2014
7:05:00 PM
11/17/2014
Alibaba Has Big-Name Fans
Dow Jones Institutional News
11/17/2014
1:43:00 AM
11/17/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans
Dow Jones Institutional News
11/17/2014
8:55:00 PM
11/18/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans -2-
Dow Jones Newswires Chinese (English)
11/17/2014
8:55:00 PM
11/18/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans
Dow Jones Newswires Chinese (English)
11/17/2014
8:56:00 PM
11/18/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans -4-
Dow Jones Newswires Chinese (English)
11/17/2014
8:56:00 PM
11/18/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans -3-
Dow Jones Newswires Chinese (English)
11/18/2014
5:02:00 AM
11/18/2014
Q&A: Alibaba Senior Executive On Apple, M&A and U.S. Plans
Dow Jones Newswires Korean (English)
11/18/2014
11:30:00 AM
11/18/2014
Press Release: Federal-Mogul Motorparts Alibaba Tmall Flagship Store Goes 'Live'
Dow Jones Institutional News
11/18/2014
1:24:00 PM
11/18/2014
Alibaba: Record Singles Day; HSBC's TP $148, "Facebook The Best Comp" -- Barron's BloDow Jones Institutional News
11/18/2014
1:24:00 PM
11/18/2014
UPDATE Alibaba: Record Singles Day; HSBC's TP $148 -- Barron's Blog
Dow Jones Institutional News
11/19/2014
12:31:00 AM
11/19/2014
SoftBank Slips 1.2% After Alibaba Falls 3.0% in New York -- Market Talk
Dow Jones Institutional News
11/19/2014
4:34:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Institutional News
11/19/2014
4:34:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Top News & Commentary
11/19/2014
4:49:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Top Global Market Stories
11/19/2014
4:49:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Institutional News
11/19/2014
6:31:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Newswires Chinese (English)
11/19/2014
6:34:00 AM
11/19/2014
Alibaba and Tencent Make Movie Push
Dow Jones Top North American Equities Stories
11/20/2014
9:24:00 AM
11/20/2014
A.M. Roundup: Alibaba Selling First Bond; Caesars Proposes a REIT -- Barron's Blog
Dow Jones Institutional News
11/20/2014
10:01:00 AM
11/20/2014
Alibaba Could Upsize Debut Bond Deal To About $10B -- Investor
Dow Jones Institutional News
11/20/2014
10:03:00 AM
11/20/2014
Alibaba Could Upsize Debut Bond Deal To About $10B -- Investor
Dow Jones Newswires Chinese (English)
11/20/2014
10:05:00 AM
11/20/2014
Alibaba Final Pricing On Bond Expected Later Today
Dow Jones Newswires Chinese (English)
11/20/2014
10:05:00 AM
11/20/2014
Alibaba Received More Than $55B In Orders For Bond Sale -- Sources
Dow Jones Newswires Chinese (English)
11/20/2014
10:15:00 AM
11/20/2014
High Demand for Alibaba's Bond Debut -- Barron's Blog
Dow Jones Institutional News
11/20/2014
10:19:00 AM
11/20/2014
Alibaba Launches $8 Billion Bond Sale
Dow Jones Top North American Equities Stories
11/20/2014
10:24:00 AM
11/20/2014
Alibaba Launches $8 Billion Bond Sale
Dow Jones Top Global Market Stories
11/20/2014
10:33:00 AM
11/20/2014
Demand Brisk for Alibaba's Debut Bond Sale -- Market Talk
Dow Jones Institutional News
11/20/2014
10:33:00 AM
11/20/2014
Demand Brisk for Alibaba's Debut Bond Sale -- Market Talk
Dow Jones Institutional News
11/20/2014
10:33:00 AM
11/20/2014
Demand Brisk for Alibaba's Debut Bond Sale -- Market Talk
Dow Jones Institutional News
11/20/2014
10:39:00 AM
11/20/2014
Alibaba Could Increase Size of Debut Bond Deal to About $10 Billion
Dow Jones Newswires Chinese (English)
11/20/2014
11:02:00 AM
11/20/2014
Alibaba Lowers Yields on Debut Bonds -- Market Talk
Dow Jones Institutional News
11/20/2014
11:02:00 AM
11/20/2014
Alibaba Lowers Yields on Debut Bonds -- Market Talk
Dow Jones Institutional News
11/20/2014
11:02:00 AM
11/20/2014
Alibaba Lowers Yields on Debut Bonds -- Market Talk
Dow Jones Institutional News
11/20/2014
1:05:00 PM
11/20/2014
Alibaba Launches $8 Billion Bond Sale -- 2nd Update
Dow Jones Institutional News
11/20/2014
2:18:00 PM
11/20/2014
Alibaba Launches First Bond Sale -- Barron's Blog
Dow Jones Institutional News
11/20/2014
4:38:00 PM
11/21/2014
How Alibaba's New Bond Deal Stacks Up
Dow Jones Institutional News
11/20/2014
4:43:00 PM
11/21/2014
Why Do So Many Want Alibaba Bonds? -- Barron's Blog
Dow Jones Institutional News
11/20/2014
7:00:00 PM
11/21/2014
How Alibaba's New Bond Deal Stacks Up
Dow Jones Newswires Chinese (English)
11/20/2014
10:08:00 PM
11/21/2014
Alibaba Becomes Wall Street's Favorite Customer
Dow Jones Newswires Chinese (English)
11/20/2014
11:03:00 PM
11/21/2014
Press Release: Alibaba Group Announces Pricing of Offering of US$8.0 Billion of Senior UDow Jones Institutional News
11/20/2014
11:06:00 PM
11/21/2014
Alibaba Group Announces Pricing Of Offering Of US$8.0 Billion Of Senior Unsecured NotDow Jones Newswires Chinese (English)
11/21/2014
9:08:00 AM
11/21/2014
A.M. Roundup: Big Fees from Alibaba; China's rate Cut; Gross Gets $500M from Soros -- BDow Jones Institutional News
11/21/2014
1:13:00 PM
11/21/2014
WSJ: Big Bank Fees from Alibaba Bond Sale -- Barron's Blog
Dow Jones Institutional News
11/21/2014
3:44:00 PM
11/21/2014
Alibaba Becomes Wall Street's Favorite Customer
Dow Jones Top North American Equities Stories
11/21/2014
6:40:00 PM
11/24/2014
Alibaba, After Record IPO, Bags Debt-Market Trophies Too -- Market Talk
Dow Jones Institutional News
11/21/2014
6:40:00 PM
11/24/2014
Alibaba, After Record IPO, Bags Debt-Market Trophies Too -- Market Talk
Dow Jones Institutional News
11/23/2014
8:04:00 PM
11/24/2014
Alibaba Becomes Wall Street's Favorite Customer
Dow Jones Top Global Market Stories
11/23/2014
8:18:00 PM
11/24/2014
Alibaba, After Record IPO, Bags Debt-Market Trophies Too -- Market Talk
Dow Jones Newswires Chinese (English)
11/23/2014
8:44:00 PM
11/24/2014
Alibaba, After Record IPO, Bags Debt-Market Trophies Too -- Market Talk
Dow Jones Newswires Chinese (English)
11/24/2014
8:39:00 PM
11/25/2014
China Xinjiang Uygur Autonomous Region Reached Cooperation with Alibaba
Dow Jones Newswires Chinese (English)
11/25/2014
9:31:00 AM
11/25/2014
Press Release: Critical Alerts For Alibaba, Ulta Salon Cosmetics & Fragrance Inc., Marriott Dow Jones Institutional News
11/26/2014
6:31:00 AM
11/26/2014
Alibaba Looks to Invest More in India
Dow Jones Institutional News
11/26/2014
7:47:00 AM
11/26/2014
Alibaba Looks to Invest More in India
Dow Jones Newswires Chinese (English)
11/26/2014
4:36:00 PM
11/28/2014
An Emerging Market ETF to Address the Alibaba Index Problem -- Barron's Blog
Dow Jones Institutional News
11/27/2014
3:24:00 AM
11/28/2014
Alibaba Launches Internet TVs In China With Haier
Dow Jones Institutional News
11/27/2014
4:32:00 AM
11/28/2014
Alibaba Launches Internet TVs In China With Haier
Dow Jones Newswires Chinese (English)
12/1/2014
1:49:00 AM
12/1/2014
Fitch Assigns Alibaba's USD Notes Final 'A+' Ratings
Dow Jones Institutional News
12/1/2014
1:50:00 AM
12/1/2014
Fitch Assigns Alibaba's USD Notes Final 'A+' Ratings
Dow Jones Newswires Chinese (English)
12/5/2014
3:59:00 AM
12/5/2014
L'Occitane Launches Online Store on Alibaba's Tmall Site
Dow Jones Institutional News
12/5/2014
8:54:00 AM
12/5/2014
L'Occitane Launches Online Store on Alibaba's Tmall Site
Dow Jones Newswires Chinese (English)
12/7/2014
8:00:00 PM
12/8/2014
Alibaba: Alipay Processing More Transactions Through Mobile Devices
Dow Jones Institutional News
12/7/2014
9:42:00 PM
12/8/2014
Alibaba: Alipay Processing More Transactions Through Mobile Devices
Dow Jones Newswires Chinese (English)
12/9/2014
11:35:00 PM
12/10/2014
Alibaba Pictures: 1H14 Net Profit to Fall by Up to HK$390 Million
Dow Jones Institutional News
12/9/2014
11:37:00 PM
12/10/2014
Alibaba Pictures: 1H14 Net Profit to Fall by Up to HK$390 Million
Dow Jones Newswires Chinese (English)
12/9/2014
11:45:00 PM
12/10/2014
Alibaba Pictures to Make Up to HK$323 Million in Provisions for Film Operations in 1H ReDow Jones Newswires Chinese (English)
12/9/2014
11:46:00 PM
12/10/2014
Alibaba Pictures to Hire Independent Consultant to Advise on Internal Control
Dow Jones Newswires Chinese (English)
12/9/2014
11:47:00 PM
12/10/2014
Alibaba Pictures to Seek Trading Resumption After Releasing 1H Results on Dec. 19
Dow Jones Newswires Chinese (English)
12/9/2014
11:47:00 PM
12/10/2014
Alibaba Pictures to Set Up Internal Audit Team to Strengthen Internal Control
Dow Jones Newswires Chinese (English)
12/9/2014
11:48:00 PM
12/10/2014
Alibaba Pictures to Hire Independent Consultant to Advise on Internal Control
Dow Jones Newswires Chinese (English)
12/10/2014
12:07:00 AM
12/10/2014
Independent Probe Finds Misstated Reports on Taxes, Convertible Bonds at Alibaba PictureDow Jones Newswires Chinese (English)
12/10/2014
12:24:00 AM
12/10/2014
Alibaba Pictures Expects First-Half Net Profit to Fall
Dow Jones Top Global Market Stories
12/10/2014
12:30:00 AM
12/10/2014
Alibaba Pictures Expects First-Half Net Profit to Fall
Dow Jones Institutional News
12/10/2014
12:45:00 AM
12/10/2014
Alibaba Pictures Expects First-Half Net Profit to Fall
Dow Jones Institutional News
12/10/2014
1:16:00 AM
12/10/2014
Alibaba Pictures Expects First-Half Net Profit to Fall on Accounting Irregularities
Dow Jones Newswires Chinese (English)
12/10/2014
1:24:00 AM
12/10/2014
Israeli Researchers Find Security Flaws on Alibaba's International Marketplace
Dow Jones Institutional News
12/10/2014
3:47:00 AM
12/10/2014
Israeli Researchers Find Security Flaws on Alibaba's International Marketplace
Dow Jones Newswires Chinese (English)
12/10/2014
6:02:00 AM
12/10/2014
Alibaba Movie Unit Misstated Taxes, Auditor Analysis Finds -- Update
Dow Jones Institutional News
12/11/2014
8:55:00 AM
12/11/2014
Founder Accused Ahead Of Alibaba Backed Momo's IPO: Theft, Graft, Indency?! -- BarronDow Jones Institutional News
12/15/2014
12:27:00 AM
12/15/2014
Alibaba's Taxi App Soars, Goldman Sees Great Promise In O2O -- Barron's Blog
Dow Jones Institutional News
Page 13 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 75 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 76 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
12/15/2014
3:24:00 AM
12/15/2014
China Dongxiang: 2014 Profit to Rise on Alibaba Investment
Dow Jones Newswires Chinese (English)
12/15/2014
3:50:00 AM
12/15/2014
China Dongxiang: 2014 Profit to Rise on Alibaba Investment
Dow Jones Newswires Chinese (English)
12/15/2014
6:39:00 PM
12/16/2014
Jintian Pharmaceutical: Joins Electronic Platform Operated by Alibaba Health Information TDow Jones Institutional News
12/15/2014
6:40:00 PM
12/16/2014
Jintian Pharmaceutical: Joins Electronic Platform Operated by Alibaba Health Information TDow Jones Newswires Chinese (English)
12/15/2014
7:12:00 PM
12/16/2014
Jintian Pharmaceutical to Supply Medicine Through Alibaba Health
Dow Jones Newswires Chinese (English)
12/15/2014
7:30:00 PM
12/16/2014
China Dongxiang: Higher Profits Related to Investment in Alibaba Group Holding
Dow Jones Newswires Chinese (English)
12/15/2014
8:01:00 PM
12/16/2014
China Dongxiang: 2014 Profit to Surge on Alibaba Investment
Dow Jones Newswires Chinese (English)
12/15/2014
8:30:00 PM
12/16/2014
China Dongxiang Profit Nearly Quadruples on Alibaba Investment -- Market Talk
Dow Jones Institutional News
12/15/2014
9:42:00 PM
12/16/2014
Bullish on China? Put Your Chips on Alibaba -- Barron's Asia
Dow Jones Institutional News
12/16/2014
10:59:00 AM
12/16/2014
Alibaba Was the Most-Searched IPO of 2014
Dow Jones Institutional News
12/17/2014
7:53:00 PM
12/18/2014
Alibaba: Alipay Wallet Can Compete With UnionPay, Says Deutsche -- Barron's Blog
Dow Jones Institutional News
12/17/2014
10:51:00 PM
12/18/2014
Uber Partners With Baidu, But Alibaba, Tencent Hard To Beat -- Barron's Blog
Dow Jones Institutional News
12/18/2014
4:35:00 AM
12/18/2014
Alibaba's Jack Ma and Dalian Wanda's Wang Jianlin in Battle to Top China's Rich List -- ThDow Jones Institutional News
12/18/2014
5:02:00 AM
12/18/2014
Alibaba's Jack Ma and Dalian Wanda's Wang Jianlin in Battle to Top China&apos
Dow Jones Newswires Chinese (English)
12/21/2014
10:22:00 PM
12/22/2014
Alibaba Pictures Narrows Gain; Auditors No Qualified Opinion
Dow Jones Newswires Chinese (English)
12/21/2014
10:22:00 PM
12/22/2014
MARKET TALK: Alibaba Pictures Narrows Gain; Auditors No Qualified Opinion
Dow Jones Newswires Chinese (English)
12/21/2014
11:22:00 PM
12/22/2014
MARKET TALK: Alibaba Pictures Narrows Gain; Auditors No Qualified Opinion
Dow Jones Newswires Chinese (English)
12/22/2014
7:03:00 AM
12/22/2014
Alibaba's Jack Ma and Dalian Wanda's Wang Jianlin in Battle to Top China&
Dow Jones Newswires Korean (English)
12/22/2014
1:02:00 PM
12/22/2014
A Year of IPO Records... From A (Alibaba) to J (Juno Therapeutics)
Dow Jones Institutional News
12/22/2014
1:50:00 PM
12/22/2014
Alibaba's Tmall Global Site Stumbles
Dow Jones Institutional News
12/22/2014
1:50:00 PM
12/22/2014
Alibaba's Tmall Global Site Stumbles
Dow Jones Top News & Commentary
12/22/2014
2:05:00 PM
12/22/2014
Alibaba's Tmall Global Site Stumbles
Dow Jones Institutional News
12/22/2014
6:41:00 PM
12/23/2014
Alibaba Enters Russell Global Indexes; When Will It Enter MSCI? -- Barron's Blog
Dow Jones Institutional News
12/22/2014
7:17:00 PM
12/23/2014
Foreign Brands Struggle To Enter China Via Alibaba: WSJ -- Barron's Blog
Dow Jones Institutional News
12/22/2014
8:21:00 PM
12/23/2014
Alibaba's Tmall Global Site Stumbles
Dow Jones Newswires Chinese (English)
12/22/2014
9:54:00 PM
12/23/2014
Alibaba's Shopping Site No Gold Mine for Foreign Brands
Dow Jones Institutional News
12/26/2014
3:00:00 AM
12/26/2014
A Year of IPO Records... From A (Alibaba) to J (Juno Therapeutics)
Dow Jones Newswires Korean (English)
1/7/2015
10:12:00 PM
1/8/2015
China Internet: Alibaba, Tencent, Baidu To Continue Buying Spree, R&D -- Barron's Blog Dow Jones Institutional News
1/8/2015
9:48:00 AM
1/8/2015
Starboard Warns Yahoo on Acquisitions and Alibaba Stake -- Market Talk
Dow Jones Institutional News
1/8/2015
9:48:00 AM
1/8/2015
Starboard Warns Yahoo on Acquisitions and Alibaba Stake -- Market Talk
Dow Jones Institutional News
1/8/2015
9:52:00 AM
1/8/2015
Starboard Reiterates Demand for AOL Merger, Alibaba Spin-off
Dow Jones Institutional News
1/9/2015
2:20:00 AM
1/9/2015
Alibaba Founder Jack Ma Apologizes for Criticizing Rival JD.com
Dow Jones Institutional News
1/10/2015
3:44:00 AM
1/12/2015
Alibaba, Affiliate Zhejiang Ant to Invest $575 Million in India's One97 Communications -- Dow Jones Institutional News
1/11/2015
6:50:00 PM
1/12/2015
Alibaba to Invest About $575 Million in Indian Online-Shopping Service, Paytm
Dow Jones Newswires Chinese (English)
1/11/2015
9:50:00 PM
1/12/2015
Alibaba At $130? Daiwa Thinks So -- Barron's Blog
Dow Jones Institutional News
1/11/2015
10:13:00 PM
1/12/2015
Daiwa Says Alibaba Is Its Top China E-Commerce Pick -- Market Talk
Dow Jones Institutional News
1/11/2015
10:31:00 PM
1/12/2015
Daiwa Says Alibaba Is Its Top China E-Commerce Pick -- Market Talk
Dow Jones Newswires Chinese (English)
1/11/2015
10:54:00 PM
1/12/2015
India: SunEdison To Invest In Solar, Alibaba In E-Payment -- Barron's Blog
Dow Jones Institutional News
1/11/2015
11:31:00 PM
1/12/2015
Daiwa Says Alibaba Is Its Top China E-Commerce Pick -- Market Talk
Dow Jones Newswires Chinese (English)
1/12/2015
4:25:00 AM
1/12/2015
Alibaba Pays to Play in India -- Heard on the Street
Dow Jones Institutional News
1/12/2015
7:19:00 AM
1/12/2015
Will Alibaba Appear in More ETFs? -- Market Talk
Dow Jones Institutional News
1/12/2015
12:20:00 PM
1/12/2015
FTSE Mulls Index Changes to Allow Alibaba Inclusion -- Barron's Blog
Dow Jones Institutional News
1/12/2015
2:54:00 PM
1/12/2015
Alibaba Pays to Play in India
Dow Jones Top Global Market Stories
1/12/2015
6:18:00 PM
1/13/2015
Alibaba Pays to Play in India -- Heard on the Street
Dow Jones Newswires Chinese (English)
1/12/2015
7:51:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Settles Legal Dispute With Oracle
Dow Jones Institutional News
1/12/2015
7:52:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Settles Legal Dispute With Oracle
Dow Jones Newswires Chinese (English)
1/12/2015
7:53:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Oracle Will Refund Company US$11 Million Dow Jones Newswires Chinese (English)
1/12/2015
7:54:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Expects a Pretax Loss of HK$34.1 Million on Dow Jones Newswires Chinese (English)
1/12/2015
7:58:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Settles Legal Dispute With Oracle
Dow Jones Newswires Chinese (English)
1/12/2015
7:59:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Expects a Pretax Loss of HK$34.1 Million on Dow Jones Newswires Chinese (English)
1/12/2015
7:59:00 PM
1/13/2015
Alibaba Health Information Technology Ltd: Oracle Will Refund Company US$11 Million Dow Jones Newswires Chinese (English)
1/12/2015
8:52:00 PM
1/13/2015
Alibaba Health Information Technology Settles Legal Dispute With Oracle
Dow Jones Institutional News
1/12/2015
9:27:00 PM
1/13/2015
Alibaba Health Information Technology Settles Legal Dispute With Oracle
Dow Jones Newswires Chinese (English)
1/13/2015
3:47:00 AM
1/13/2015
Alibaba to Block Sales of Some Children's Products in U.S. -- Consumer Safety Group Rep Dow Jones Institutional News
1/13/2015
3:50:00 AM
1/13/2015
Alibaba to Block Sales of Some Children's Products in U.S. -- Consumer Safety Gro
Dow Jones Newswires Chinese (English)
1/13/2015
3:52:00 AM
1/13/2015
Alibaba Block Follows Pact With U.S. Consumer Safety Group
Dow Jones Newswires Chinese (English)
1/13/2015
3:52:00 AM
1/13/2015
Alibaba Block Applies to Products That Were Deemed Unsafe in U.S.
Dow Jones Newswires Chinese (English)
1/13/2015
3:57:00 AM
1/13/2015
Alibaba Block Follows Pact With U.S. Consumer Safety Group
Dow Jones Newswires Chinese (English)
1/13/2015
5:12:00 AM
1/13/2015
US Safety Commission to Hold Alibaba's 'Feet to the Fire' -- Market Talk
Dow Jones Institutional News
1/13/2015
5:34:00 AM
1/13/2015
US Safety Commission to Hold Alibaba's 'Feet to the Fire' -- Market Talk
Dow Jones Newswires Chinese (English)
1/13/2015
6:51:00 AM
1/13/2015
Alibaba To Block Sales of Unsafe Children's Products in U.S.
Dow Jones Newswires Chinese (English)
1/13/2015
11:49:00 AM
1/13/2015
Online Commerce Co Alibaba Group And CPSC Working Together On Consumer Safety
Dow Jones Institutional News
1/13/2015
11:50:00 AM
1/13/2015
Online Commerce Co Alibaba Group And CPSC Working Together On Consumer Safety
Dow Jones Newswires Chinese (English)
1/13/2015
11:53:00 AM
1/13/2015
Alibaba Enages in Voluntary Collabaration With U.S. Consumer Product Safety CommissioDow Jones Newswires Chinese (English)
1/13/2015
11:54:00 AM
1/13/2015
Alibaba to Cooperate With CPSC in Making Illegal or Recalled Products in U.S. UnavailablDow Jones Newswires Chinese (English)
1/13/2015
11:59:00 AM
1/13/2015
Press Release: Online Commerce Company Alibaba Group and CPSC Working Together OnDow Jones Institutional News
1/13/2015
10:00:00 PM
1/14/2015
Mainlanders Buying Baiyunshan on Tie-Up With Alibaba's Ma -- Market Talk
Dow Jones Institutional News
1/13/2015
10:33:00 PM
1/14/2015
Mainlanders Buying Baiyunshan on Tie-Up With Alibaba's Ma -- Market Talk
Dow Jones Newswires Chinese (English)
1/13/2015
11:01:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm AdChina
Dow Jones Institutional News
1/13/2015
11:02:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm AdChina
Dow Jones Newswires Chinese (English)
1/13/2015
11:15:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm
Dow Jones Institutional News
1/13/2015
11:22:00 PM
1/14/2015
Alibaba Partners With Maker of Generic Viagra and Herbal Tea -- Market Talk
Dow Jones Institutional News
1/13/2015
11:24:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm
Dow Jones Top Global Market Stories
1/13/2015
11:30:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm
Dow Jones Institutional News
1/13/2015
11:33:00 PM
1/14/2015
Mainlanders Buying Baiyunshan on Tie-Up With Alibaba's Ma -- Market Talk
Dow Jones Newswires Chinese (English)
1/13/2015
11:41:00 PM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm
Dow Jones Newswires Chinese (English)
1/14/2015
1:48:00 AM
1/14/2015
Kuaidi Group Investors Include Softbank, Alibaba, Tiger Global - Sources
Dow Jones Newswires Chinese (English)
1/14/2015
2:46:00 AM
1/14/2015
Alibaba-Backed Ride-Hailing App Kuaidi Raising Over $500M -- Market Talk
Dow Jones Institutional News
1/14/2015
6:39:00 AM
1/14/2015
Alibaba Buys Controlling Stake in Chinese Internet Marketing Firm
Dow Jones Top North American Equities Stories
1/14/2015
8:30:00 PM
1/15/2015
Press Release: KuaiDi Dache, China's Leading Mobile Taxi Booking App, Secures US$600 Dow Jones Institutional News
1/14/2015
8:39:00 PM
1/15/2015
Kuaidi Investors in Latest Round Include Alibaba, Tiger Global
Dow Jones Newswires Chinese (English)
Page 14 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 76 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 77 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
1/15/2015
4:09:00 AM
1/15/2015
Press Release: Alibaba Group Will Announce December Quarter 2014 Results on January 2 Dow Jones Institutional News
1/15/2015
8:23:00 PM
1/16/2015
Guangzhou Baiyunshan Pharmaceutical Clarifies Strategic Partnership With Alibaba HealthDow Jones Institutional News
1/15/2015
8:25:00 PM
1/16/2015
Guangzhou Baiyunshan Pharmaceutical Clarifies Strategic Partnership With Alibaba HealthDow Jones Newswires Chinese (English)
1/15/2015
8:33:00 PM
1/16/2015
Guangzhou Baiyunshan Pharmaceutical Clarifies Strategic Partnership With Alibaba HealthDow Jones Institutional News
1/15/2015
9:08:00 PM
1/16/2015
Guangzhou Baiyunshan Pharmaceutical Clarifies Strategic Partnership With Alibaba HealthDow Jones Newswires Chinese (English)
1/16/2015
6:39:00 AM
1/16/2015
MSCI Move Would Affect Chinese Internet Sector Including Alibaba
Dow Jones Newswires Chinese (English)
1/16/2015
10:49:00 AM
1/16/2015
MSCI Green-Lights Alibaba Inclusion Proviso -- Barron's Blog
Dow Jones Institutional News
1/18/2015
9:00:00 PM
1/20/2015
Finally, MSCI Includes Alibaba, Baidu In China Index; A-Shares Next? -- Barron's Blog
Dow Jones Institutional News
1/19/2015
3:17:00 AM
1/20/2015
MSCI Shakeup Could Drive $75B to Likes of Alibaba, Baidu -- Market Talk
Dow Jones Institutional News
1/19/2015
3:42:00 AM
1/20/2015
MSCI Shakeup Could Drive $75B to Likes of Alibaba, Baidu -- Market Talk
Dow Jones Newswires Chinese (English)
1/19/2015
4:42:00 AM
1/20/2015
MSCI Shakeup Could Drive $75B to Likes of Alibaba, Baidu -- Market Talk
Dow Jones Newswires Chinese (English)
1/19/2015
4:46:00 AM
1/20/2015
Alibaba-Backed Group Discount Site Meituan.com Raises $700 Million
Dow Jones Institutional News
1/19/2015
4:48:00 AM
1/20/2015
Alibaba-Backed Group Discount Site Meituan.com Raises $700 Million
Dow Jones Newswires Chinese (English)
1/19/2015
11:27:00 PM
1/20/2015
Finally, MSCI Includes Alibaba, Baidu In China Index; A-Shares Next? -- Barron's B
Dow Jones Newswires Korean (English)
1/20/2015
2:00:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead
Dow Jones Institutional News
1/20/2015
2:01:00 AM
1/20/2015
Alibaba's Visualead Investment Under $10M - Source
Dow Jones Newswires Chinese (English)
1/20/2015
2:01:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead
Dow Jones Newswires Chinese (English)
1/20/2015
2:03:00 AM
1/20/2015
Visualead to Partner With Alibaba in Enabling Merchants to Generate QR Codes
Dow Jones Newswires Chinese (English)
1/20/2015
2:17:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead
Dow Jones Newswires Chinese (English)
1/20/2015
3:10:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead -- Update
Dow Jones Institutional News
1/20/2015
4:33:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead -- Update
Dow Jones Newswires Chinese (English)
1/20/2015
5:59:00 AM
1/20/2015
Alibaba Stake Puts Focus on China Investment Into Israeli Tech -- Market Talk
Dow Jones Institutional News
1/20/2015
9:44:00 AM
1/20/2015
A Primer on Visualead, the Israeli Start-up Alibaba Just Invested in
Dow Jones Institutional News
1/20/2015
11:52:00 AM
1/20/2015
Alibaba Invests in Israeli Startup Visualead -- 2nd Update
Dow Jones Institutional News
1/21/2015
2:33:00 AM
1/21/2015
Alibaba: Q4 Margin Likely Weak, IPO Lock-Up Expires In March -- Barron's Blog
Dow Jones Institutional News
1/21/2015
3:30:00 AM
1/21/2015
Alibaba: Q4 Margin Likely Weak, IPO Lock-Up Expires In March -- Barron's Blog
Dow Jones Newswires Chinese (English)
1/21/2015
10:40:00 PM
1/22/2015
New China Investment Rules Help Alibaba, but May Hurt Tencent -- Market Talk
Dow Jones Institutional News
1/21/2015
10:40:00 PM
1/22/2015
New China Investment Rules Help Alibaba, but May Hurt Tencent -- Market Talk
Dow Jones Institutional News
1/22/2015
12:10:00 AM
1/22/2015
New China Investment Rules Help Alibaba, but May Hurt Tencent -- Market Talk
Dow Jones Newswires Chinese (English)
1/22/2015
12:41:00 AM
1/22/2015
Alibaba: Q4 Margin Likely Weak, IPO Lock-Up Expires In March -- Barron's Blog
Dow Jones Newswires Korean (English)
1/22/2015
1:10:00 AM
1/22/2015
New China Investment Rules Help Alibaba, but May Hurt Tencent -- Market Talk
Dow Jones Newswires Chinese (English)
1/22/2015
6:52:00 PM
1/23/2015
Tencent, Baidu And Alibaba Offer Limited Near-Term Upside: Nomura -- Barron's Blog
Dow Jones Institutional News
1/25/2015
10:56:00 PM
1/26/2015
Alibaba Q4 Preview: Watch For Mobile Mix And Rates, International Expansion -- Barron'sDow Jones Institutional News
1/26/2015
6:25:00 PM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Institutional News
1/26/2015
6:40:00 PM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Institutional News
1/26/2015
7:07:00 PM
1/27/2015
Alibaba Pictures Group: Expect to Swing to 2014 Loss of up to HK$600 Mln
Dow Jones Institutional News
1/26/2015
7:12:00 PM
1/27/2015
Alibaba Pictures Group: Expect to Swing to 2014 Loss of up to HK$600 Mln
Dow Jones Newswires Chinese (English)
1/26/2015
7:13:00 PM
1/27/2015
Alibaba Pictures Group: Expected Loss Partly Due to Significant Drop in Revenue
Dow Jones Newswires Chinese (English)
1/26/2015
7:53:00 PM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Newswires Chinese (English)
1/26/2015
8:24:00 PM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Top Global Market Stories
1/26/2015
8:33:00 PM
1/27/2015
How to Trade Yahoo! As Big Alibaba News Nears -- Barron's Asia
Dow Jones Institutional News
1/26/2015
9:45:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys 9.18% Stake in Alibaba Pictures --Stock Exchange
Dow Jones Institutional News
1/26/2015
9:47:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys 9.18% Stake in Alibaba Pictures --Stock Exchange
Dow Jones Newswires Chinese (English)
1/26/2015
9:48:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures for Around HK$3.09 Bln--StoDow Jones Newswires Chinese (English)
1/26/2015
9:50:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures for Around HK$3.09 Bln--StoDow Jones Newswires Chinese (English)
1/26/2015
9:51:00 PM
1/27/2015
Zhao Wei Buys 1.93 Bln Shares of Alibaba Pictures at Average Price of HK$1.60 Each --St Dow Jones Newswires Chinese (English)
1/26/2015
10:03:00 PM
1/27/2015
Shares of Alibaba Pictures Jump as Much as 12% in Early Morning Session
Dow Jones Newswires Chinese (English)
1/26/2015
10:29:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures
Dow Jones Top Global Market Stories
1/26/2015
10:30:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures
Dow Jones Institutional News
1/26/2015
10:36:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys $399 Mln Stake in Alibaba Pictures -Stock Exchange
Dow Jones Newswires Chinese (English)
1/26/2015
10:44:00 PM
1/27/2015
Alibaba Pictures Jumps on Movie Star's Investment -- Market Talk
Dow Jones Institutional News
1/26/2015
10:45:00 PM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures
Dow Jones Institutional News
1/27/2015
2:12:00 AM
1/27/2015
Alibaba Pictures Warns of Loss, Actress Buys Stake
Dow Jones Institutional News
1/27/2015
5:53:00 AM
1/27/2015
Alibaba Pictures Warns of Loss, Actress Buys Stake -- Update
Dow Jones Institutional News
1/27/2015
6:24:00 AM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Top North American Equities Stories
1/27/2015
6:49:00 AM
1/27/2015
Chinese Movie Star Zhao Wei Buys Stake in Alibaba Pictures
Dow Jones Top North American Equities Stories
1/27/2015
9:14:00 AM
1/27/2015
Yahoo Holders Await Plan for Alibaba Assets
Dow Jones Top Energy Stories
1/27/2015
4:06:00 PM
1/28/2015
Press Release: Yahoo Announces Plan for Tax-Free Spin-Off of Remaining Stake in Alibab Dow Jones Institutional News
1/27/2015
4:09:00 PM
1/28/2015
Yahoo to Spin Off Remaining Holdings in Alibaba Into Newly Formed Independent InvestmDow Jones Newswires Chinese (English)
1/27/2015
4:10:00 PM
1/28/2015
Yahoo: SpinCo Will Own Yahoo's Remaining 384M Shares of Alibaba, Valued at $40 BillioDow Jones Newswires Chinese (English)
1/27/2015
4:14:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Institutional News
1/27/2015
4:20:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Top News & Commentary
1/27/2015
4:22:00 PM
1/28/2015
Yahoo Spins Off Alibaba Stake -- Market Talk
Dow Jones Institutional News
1/27/2015
4:22:00 PM
1/28/2015
Yahoo Spins Off Alibaba Stake -- Market Talk
Dow Jones Institutional News
1/27/2015
4:24:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Top North American Equities Stories
1/27/2015
4:24:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Top Global Market Stories
1/27/2015
4:29:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Institutional News
1/27/2015
4:30:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake -- Update
Dow Jones Institutional News
1/27/2015
4:43:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake
Dow Jones Newswires Chinese (English)
1/27/2015
4:44:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake -- 2nd Update
Dow Jones Institutional News
1/27/2015
4:45:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake -- Update
Dow Jones Institutional News
1/27/2015
4:59:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake -- 2nd Update
Dow Jones Institutional News
1/27/2015
5:00:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 3rd Update
Dow Jones Institutional News
1/27/2015
5:15:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 3rd Update
Dow Jones Institutional News
1/27/2015
5:23:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/27/2015
5:37:00 PM
1/28/2015
Yahoo's Spin of Alibaba Likely First Step of Two-Step Deal -- Market Talk
Dow Jones Institutional News
1/27/2015
5:37:00 PM
1/28/2015
Yahoo's Spin of Alibaba Likely First Step of Two-Step Deal -- Market Talk
Dow Jones Institutional News
1/27/2015
5:38:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/27/2015
5:39:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/27/2015
5:45:00 PM
1/28/2015
Yahoo to Spin Off Alibaba Stake -- 2nd Update
Dow Jones Newswires Chinese (English)
1/27/2015
5:47:00 PM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin -- Heard on the Street
Dow Jones Institutional News
Page 15 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 77 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 78 of
102
Exhibit 2
Alibaba Group Holding Limited
Materials Considered
List of Stories from Factiva Dow Jones used in Exhibits 8a, 8c, and 8d
Date
Time
Effective Date
Title
News Source
(1)
(2)
(3)
(4)
(5)
1/27/2015
5:54:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/27/2015
5:57:00 PM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin -- Heard on the Street
Dow Jones Institutional News
1/27/2015
6:59:00 PM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top Energy Stories
1/27/2015
7:27:00 PM
1/28/2015
Yahoo's Spin of Alibaba Likely First Step of Two-Step Deal -- Market Talk
Dow Jones Newswires Chinese (English)
1/27/2015
7:29:00 PM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top Global Market Stories
1/27/2015
7:46:00 PM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin -- Heard On The Street
Dow Jones Institutional News
1/27/2015
8:10:00 PM
1/28/2015
Will Yahoo's Spin of Its Alibaba Stake Satisfy Starboard?
Dow Jones Institutional News
1/27/2015
8:24:00 PM
1/28/2015
Will Yahoo's Spin of Its Alibaba Stake Satisfy Starboard?
Dow Jones Top Global Market Stories
1/27/2015
8:25:00 PM
1/28/2015
Will Yahoo's Spin of Its Alibaba Stake Satisfy Starboard?
Dow Jones Institutional News
1/27/2015
11:00:00 PM
1/28/2015
Will Softbank Copy Yahoo's Alibaba Spinoff? -- Market Talk
Dow Jones Institutional News
1/27/2015
11:32:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/27/2015
11:35:00 PM
1/28/2015
Will Softbank Copy Yahoo's Alibaba Spinoff? -- Market Talk
Dow Jones Newswires Chinese (English)
1/27/2015
11:47:00 PM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake -- 4th Update
Dow Jones Institutional News
1/28/2015
12:10:00 AM
1/28/2015
Alibaba Affiliate Ant Financial Unveils China's First Credit-Scoring System Using Online DDow Jones Newswires Chinese (English)
1/28/2015
12:43:00 AM
1/28/2015
Chinese Agency Criticizes Alibaba For Lax Internal Controls
Dow Jones Institutional News
1/28/2015
12:45:00 AM
1/28/2015
Chinese Agency Criticizes Alibaba For Lax Internal Controls
Dow Jones Newswires Chinese (English)
1/28/2015
12:46:00 AM
1/28/2015
China's SAIC Criticizes Alibaba For Offering Fake Goods on Online Marketplaces
Dow Jones Newswires Chinese (English)
1/28/2015
1:06:00 AM
1/28/2015
China's SAIC Criticizes Alibaba For Controls on Merchants' Goods--Update
Dow Jones Institutional News
1/28/2015
1:24:00 AM
1/28/2015
China's SAIC Criticizes Alibaba For Controls on Merchants' Goods
Dow Jones Newswires Chinese (English)
1/28/2015
1:26:00 AM
1/28/2015
China's SAIC Criticizes Alibaba For Controls on Merchants' Goods-- 2nd Update
Dow Jones Institutional News
1/28/2015
2:01:00 AM
1/28/2015
Beijing Slap at Alibaba Not to Be Ignored -- Market Talk
Dow Jones Institutional News
1/28/2015
2:01:00 AM
1/28/2015
Beijing Slap at Alibaba Not to Be Ignored -- Market Talk
Dow Jones Institutional News
1/28/2015
2:28:00 AM
1/28/2015
Beijing Slap at Alibaba Not to Be Ignored -- Market Talk
Dow Jones Newswires Chinese (English)
1/28/2015
2:28:00 AM
1/28/2015
Beijing Slap at Alibaba Not to Be Ignored -- Market Talk
Dow Jones Newswires Korean (English)
1/28/2015
2:53:00 AM
1/28/2015
Alibaba Plans to Complain to SAIC About Officials' Methods -- Weibo Statement
Dow Jones Institutional News
1/28/2015
2:57:00 AM
1/28/2015
Alibaba Plans to Complain to SAIC About Officials' Methods -- Weibo Statement
Dow Jones Newswires Chinese (English)
1/28/2015
2:58:00 AM
1/28/2015
Alibaba 'Willing to Accept Responsibility' For Fighting Fakes -- Statement
Dow Jones Newswires Chinese (English)
1/28/2015
2:58:00 AM
1/28/2015
China's SAIC Criticizes Alibaba For Controls on Merchants' Goods-- Update
Dow Jones Newswires Chinese (English)
1/28/2015
2:59:00 AM
1/28/2015
Alibaba's Taobao Platform 'Victim Not Beneficiary' of Fakes -- Statement
Dow Jones Newswires Chinese (English)
1/28/2015
3:00:00 AM
1/28/2015
Alibaba's Taobao Worked to Stop Fakes 'But Still Not Good Enough' -- Statement
Dow Jones Newswires Chinese (English)
1/28/2015
3:28:00 AM
1/28/2015
Beijing Slap at Alibaba Not to Be Ignored -- Market Talk
Dow Jones Newswires Chinese (English)
1/28/2015
3:54:00 AM
1/28/2015
China Calls Alibaba Pompous, Accusing It Of Lax Oversight -- Barron's Blog
Dow Jones Institutional News
1/28/2015
4:07:00 AM
1/28/2015
China's SAIC Criticizes Alibaba Over Fake Goods -- 4th Update
Dow Jones Institutional News
1/28/2015
4:10:00 AM
1/28/2015
Alibaba Set To Report Strong Revenue Growth For Fiscal 3Q Though Margins Likely Sque Dow Jones Institutional News
1/28/2015
4:15:00 AM
1/28/2015
Alibaba Earnings: What to Watch
Dow Jones Institutional News
1/28/2015
4:16:00 AM
1/28/2015
Alibaba Sells Shoddy Goods Says China Watchdog
Dow Jones Institutional News
1/28/2015
4:45:00 AM
1/28/2015
China's SAIC Criticizes Alibaba Over Fake Goods -- 5th Update
Dow Jones Institutional News
1/28/2015
5:04:00 AM
1/28/2015
China's Agency Criticizes Alibaba Over Fake Goods
Dow Jones Top Global Market Stories
1/28/2015
6:03:00 AM
1/28/2015
Yahoo to Spin Off Remaining Alibaba Stake
Dow Jones Newswires Korean (English)
1/28/2015
6:24:00 AM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top Global Market Stories
1/28/2015
6:34:00 AM
1/28/2015
China's Agency Criticizes Alibaba Over Fake Goods
Dow Jones Top North American Equities Stories
1/28/2015
6:35:00 AM
1/28/2015
Will Yahoo's Spin of Its Alibaba Stake Satisfy Starboard?
Dow Jones Top Energy Stories
1/28/2015
6:35:00 AM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top Energy Stories
1/28/2015
8:04:00 AM
1/28/2015
A Closer Look At China's Alibaba Allegations
Dow Jones Institutional News
1/28/2015
8:13:00 AM
1/28/2015
China's SAIC Criticizes Alibaba Over Fake Goods -- 4th Update
Dow Jones Newswires Chinese (English)
1/28/2015
8:57:00 AM
1/28/2015
Alibaba Earnings: What to Watch
Dow Jones Newswires Chinese (English)
1/28/2015
9:03:00 AM
1/28/2015
CMO Today: Yahoo's Alibaba Spinoff Plan
Dow Jones Institutional News
1/28/2015
9:54:00 AM
1/28/2015
China's SAIC Criticizes Alibaba Over Fake Goods -- 6th Update
Dow Jones Institutional News
1/28/2015
10:19:00 AM
1/28/2015
Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top North American Equities Stories
1/28/2015
10:42:00 AM
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Should Alibaba Buy the 15% Stake Yahoo Is Spinning Off?
Dow Jones Institutional News
1/28/2015
12:14:00 PM
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Dow Jones Top North American Equities Stories
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Yahoo Lifts Veil With Alibaba Spin
Dow Jones Top North American Equities Stories
Page 16 of 16
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 78 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 79 of
102
Exhibit 3
Alibaba Group Holding Limited
Weekly Trading Volume as a Percent of Shares Outstanding for ADSs
September 19, 2014 to January 28, 20151
First Trading
Weekly
Shares
Percent of Shares
Week
Date of Week
Volume2
Outstanding3
Traded Weekly
(1)
(2)
(3)
(4)
(5)
(3) / (4)
1
9/19/2014
257,741,704
2,465,006,000
10.46 %
2
9/22/2014
175,088,912
2,465,006,000
7.10
3
9/29/2014
107,601,754
2,465,006,000
4.37
4
10/6/2014
65,456,439
2,465,006,000
2.66
5
10/13/2014
75,438,428
2,465,006,000
3.06
6
10/20/2014
100,428,259
2,465,006,000
4.07
7
10/27/2014
115,949,845
2,465,006,000
4.70
8
11/3/2014
230,878,971
2,465,006,000
9.37
9
11/10/2014
278,976,331
2,465,006,000
11.32
10
11/17/2014
166,060,345
2,465,006,000
6.74
11
11/24/2014
60,967,256
2,465,006,000
2.47
12
12/1/2014
92,330,062
2,465,006,000
3.75
13
12/8/2014
88,783,371
2,465,006,000
3.60
14
12/15/2014
89,172,633
2,465,006,000
3.62
15
12/22/2014
42,621,904
2,465,006,000
1.73
16
12/29/2014
39,042,618
2,465,006,000
1.58
17
1/5/2015
64,996,722
2,465,006,000
2.64
18
1/12/2015
65,390,690
2,465,006,000
2.65
19
1/20/2015
46,266,476
2,465,006,000
1.88
20
1/26/2015
65,183,038
2,465,006,000
2.64
Average Weekly Trading Volume as a Percent of Shares Outstanding4
4.29 %
Median Weekly Trading Volume as a Percent of Shares Outstanding4
3.61 %
Notes and Sources:
Data obtained from Bloomberg L.P.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September
19, 2014 to January 29, 2015. However, since the final disclosure occurs before the market
opened on January 29, 2015, January 28, 2015 is taken to be the end of the class period.
2 Daily trading volume is adjusted for the NYSE designated market maker rate, which is
updated monthly. Weekly trading volume is the arithmetic mean of each week's adjusted
daily trading volume.
3 Shares outstanding figures are as of the most recent reported date. Shares outstanding
figures are used in place of ADSs outstanding figures as any shares sold by pre-IPO
shareholders subsequently become ADSs.
Page 1 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 79 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 80 of
102
Exhibit 3
Alibaba Group Holding Limited
Weekly Trading Volume as a Percent of Shares Outstanding for ADSs
September 19, 2014 to January 28, 20151
4 Calculated using weeks 2 through 19 as week 1 includes only 1 day of the class period and
week 20 includes only 3 days of the class period. Assuming that each trading day in weeks 1
and 19 corresponds to one-fifth of a week, the average weekly trading volume as a percent
of shares outstanding over the class period (20 weeks) is 4.81%. The median weekly trading
volume as a percent of shares outstanding over the entire class period is 3.61%.
Page 2 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 80 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 81 of
102
Exhibit 4a
Alibaba Group Holding Limited
Analysts Contributing to
Quarterly I/B/E/S1 Consensus Earnings Estimates
September 2014 to January 2015
Number of Analysts
Submitting Quarterly
Earnings
Earnings Estimates to
Fiscal Quarter End
Estimate Date
Announcement Date
I/B/E/S2
(1)
(2)
(3)
(4)
09/2014
9/18/2014
11/04/2014
2
09/2014
10/16/2014
11/04/2014
11
12/2014
11/20/2014
01/29/2015
28
12/2014
12/18/2014
01/29/2015
27
12/2014
1/15/2015
01/29/2015
26
Average Number of Analyst Estimates3
23.0
Median Number of Analyst Estimates3
26.5
Notes and Sources:
Earnings dates and number of analyst estimates obtained from I/B/E/S Consensus EPS Surprise
History via FactSet Research Systems, Inc.
1 Institutional Brokers' Estimate System.
2 Number of analyst estimates covering Alibaba ADSs.
3 Calculated using estimates data within the class period (observations October 16, 2014 to
to January 15, 2015).
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 81 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 82 of
102
Exhibit 4b
Alibaba Group Holding Limited
Analyst Reports Covering Alibaba
As Reported by Thomson Reuters
September 2014 to January 2015
Date
Contributor
Analyst
Title
(1)
(2)
(3)
(4)
9/8/2014
JG Capital
Guo, Henry
Alibaba – IPO Pricing $60-66/sh; Our PT is $100
9/8/2014
Susquehanna Financial Group LLLP
Nowak, Brian
21 IPO Roadshow Questions
9/8/2014
Susquehanna Financial Group LLLP
Nowak, Brian
Open Sesame! IPO Preview
9/9/2014
MKM Partners
Strugger, James
It's Not Too Late For Alibaba Exposure
9/11/2014
Wedbush Securities Inc.
Luria, Gil
Initiating with an OUTPERFORM Rating and $80 Price Target; Bigger, Faster Growing and More Profitable, Not Just on a Chinese Scale
9/12/2014
Susquehanna Financial Group LLLP
Nowak, Brian
Alibaba Pre-IPO Conference Call Transcript
9/15/2014
JG Capital
Guo, Henry
BABA – Taking a Closer Look at Alibaba’s Alipay and SMFS
9/16/2014
GUOSEN SECURITIES
Wang, Xueheng
阿里巴巴研究(BABA.US) - 王者归来
9/16/2014
New Street Research LLP
Boodry, Kirk
New Street: Alibaba Group (unrated, TP: $77) - New pricing range still attractive
9/17/2014
CRT Capital
Doshi, Neil
CRT: BABA - BABA-Bing! Initiating with a Buy & $95 PT
9/19/2014
Cantor Fitzgerald
Squali, Youssef
Raising PT to $43 on Alibaba's IPO Valuation; It's All About Tax Efficiency Now
9/19/2014
Cantor Fitzgerald
Squali, Youssef
Open Sesame! Uncovering Alibaba's Treasure Trove; Initiating at BUY with $90 PT
9/21/2014
Oppenheimer & Co., Inc.
Helfstein, Jason
Increasing Price Target on BABA Public Valuation & Roll-forward to '16
9/22/2014
MKM Partners
Sanderson, Rob
Powerhouse in Best Secular Growth Market for eCommerce; Initiate with Buy and $125 PT
9/22/2014
Morningstar, Inc.
Hottovy, R.J.
Morningstar | A powerful network effect in a rapidly growing industry makes wide moat-rated Alibaba a rare find.
9/22/2014
JG Capital
Guo, Henry
BABA – Initiating Coverage of Alibaba with an Overweight and PT of $110
9/23/2014
T.H. Capital Research
Hou, Tian
T. H. Data Flash – Alibaba Group – August 2014: Tmall Shows Strong Growth in August; Mobile Apps Get Boost from Mobile Taobao
9/29/2014
JG Capital
Guo, Henry
BABA – Makes Strategic Investment in Beijing Shiji, One of China’s Top Hotel IT Providers
9/29/2014
Susquehanna Financial Group LLLP
Nowak, Brian
Open Sesame! Initiate with Positive Rating
9/29/2014
MKM Partners
Sanderson, Rob
Volume 1 of Proprietary Study on Chinese eCommerce; Believe the Hype
9/29/2014
Wedbush Securities Inc.
Luria, Gil
With Successful IPO Complete and Ahead of Options Trading, Shares Ready to be Vetted by the Market; Maintain OP and Raising PT to $105 from $80
10/2/2014
Mirabaud Securities
Han, Candy
Mirabaud Securities - Peripheral Vision 2nd October 2014
10/8/2014
Macquarie Research
Ramler, Nathan
SoftBank (Outperform) - Launching coverage on Alibaba
10/8/2014
Macquarie Research
Shao, Jiong
Alibaba Group Holding (Initiating coverage with Neutral) - Doors wide open
10/9/2014
JG Capital
Guo, Henry
BABA – Alibaba Juhuasuan Transitions to Flash Sales Model; Maintain OW; PT $110
10/10/2014
Susquehanna Financial Group LLLP
Nowak, Brian
Where Do We Go From Here?
10/14/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "A global eCommerce ..." (Chinese Version)
10/14/2014
UBS Equities
Leung, Stephen
Softbank "Alibaba initiation, increase SOTP valuation" (Buy) Leung
10/14/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "A global eCommerce leader emerges [EXTRACT]"
10/14/2014
UBS Equities
Sheridan, Eric
Yahoo "The Path Forward After Alibaba" (Buy) Sheridan
10/14/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "A global eCommerce leader emerges" (Buy) Werkun
10/15/2014
CM Research
Mewawalla, Cyrus
Alibaba - What's it worth?
10/16/2014
Brean Capital, LLC
Gaugler, Michael
Initiating Coverage of BABA with Buy Rating and TP of $110
10/17/2014
JG Capital
Guo, Henry
BABA – Alibaba’s Ant Financial Creates Upside Potential in Our View
10/22/2014
Barclays
Yap, Alicia
Alibaba Group Holding Ltd.: Breaching new frontiers; initiate at OW
10/24/2014
BMO Capital Markets
Williams, Edward
BABA--Unlocking the Treasure Trove of E-Commerce; Initiating With Outperform(comment)
10/27/2014
Jefferies
Meng, Cynthia
Alibaba: BABA: BUY: The Powerful E-Commerce Ecosystem Connecting Half of China; Initiate at Buy
10/29/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : AliEveryday
10/29/2014
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
The Alibaba Report Teach-In
10/29/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: Correction: Virtual Economy Titan; Initiate at OW…
10/29/2014
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : US$112 price target, initiate with OW; a unique ecosystem, with growth and upside in store
10/29/2014
EVERCORE ISI
Sena, Ken
Got it Made in China
10/29/2014
Nomura
Wang, Chao
Alibaba Group Holding (BABA US, Buy) - Much more than an eCommerce company
10/29/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Alibaba Group. OUTPERFORM. The giant marches on
10/29/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba : Stepping more meaningfully into monetization: initiation of coverage
10/29/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited: New Report: The giant marches on. Initiating Coverage with OUTPERFORM
10/29/2014
Citi
Chong, Thomas
Alibaba Group Holding (BABA): Initiate at Buy - The Keys to China's E-commerce Kingdom
10/29/2014
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
The Alibaba Report
10/29/2014
Topeka Capital Markets Inc.
Anthony, Victor
Strong Growth Prospects; Initiate At Buy
10/29/2014
BNP Paribas Group
Ling, Vey-sern
ALIBABA GROUP - Dominant online marketplace
10/29/2014
RBC Capital Markets
Mahaney, Mark
Alibaba Group Holding Limited - Initiating Coverage: BABA-Dabba Do!
10/29/2014
BNP Paribas Group
Ling, Vey-sern
CHINA INTERNET - E-commerce: shopping for winners
10/29/2014
Wells Fargo Securities, LLC
Nemer, Matt
BABA: Initiating Coverage With An Outperform Rating
Page 1 of 4
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 82 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 83 of
102
Exhibit 4b
Alibaba Group Holding Limited
Analyst Reports Covering Alibaba
As Reported by Thomson Reuters
September 2014 to January 2015
Date
Contributor
Analyst
Title
(1)
(2)
(3)
(4)
10/31/2014
CRT Capital
Doshi, Neil
CRT: BABA - F2Q Earnings Preview and "Crib Sheet"
10/31/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : AliEveryday: autos & Sept Q preview
10/31/2014
JG Capital
Guo, Henry
BABA – FQ2 Preview; Expect Strong Results and Guidance; Reiterate OW; PT $110
10/31/2014
JPMorgan
Anmuth, Doug
Yahoo Inc : Resuming Coverage with Overweight Rating and $55 Price Target Post Alibaba IPO; Previously Not Rated
11/2/2014
RBC Capital Markets
Mahaney, Mark
Alibaba Group Holding Limited - Sep. '14Q Earnings Preview & Cheat Sheet
11/3/2014
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : Expecting Strong 2QFY15 Results With Continued Traction in Mobile Monetization
11/3/2014
Wedbush Securities Inc.
Luria, Gil
Q2 Preview: With Great Market Cap Will Come Great Scrutiny; Reiterate OUTPERFORM
11/3/2014
MKM Partners
Sanderson, Rob
GMV Growth, Mobile Monetization and Spending Outlook the Focus
11/3/2014
Morningstar, Inc.
Yao, Yue
Morningstar | On the Chinese Internet, It's Tough to Trump Tencent
11/3/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "First Shot on Goal Ahead of Holiday Season"
11/4/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: A Beat and Raised Quarter
11/4/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited. New report: Good improvement in the number of buyers; mobile monetisation gains strong traction. Maintain OUT
11/4/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Alibaba Group Holding Limited. OUTPERFORM. Good improvement in the number of buyers; mobile monetisation gains strong traction
11/4/2014
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : Buyer-driven GMV growth indicates LT sustainability; continued improvement in mobile monetization; PT raised to US$122
11/4/2014
BNP Paribas Group
Ling, Vey-sern
ALIBABA GROUP - Solid first results post IPO
11/4/2014
EVERCORE ISI
Sena, Ken
A Well-Stitched Quarter
11/4/2014
Citi
Chong, Thomas
Results: Alibaba Group Holding (BABA) - Secular LT story with mobile monetization and adjusted earnings better than our estimates
11/4/2014
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
Enter the Dragon - Solid Quarter Beat
11/4/2014
Morningstar, Inc.
Hottovy, R.J.
Morningstar | Alibaba's First Update as Public Company Adds Support to Network Effect Behind Wide Moat Rating
11/4/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : FY2Q15: small beat; mobile metrics surprise again
11/4/2014
Barclays
Yap, Alicia
Alibaba Group Holding Ltd.: Validating mobile commerce growth
11/4/2014
Citi
May, Mark
Alert: YHOO: The Path to BABA-Co
11/4/2014
Jefferies
Meng, Cynthia
Alibaba: BABA: BUY: FY2Q15 Results Review: Mobile Driving Growth
11/4/2014
RBC Capital Markets
Mahaney, Mark
Alibaba Group Holding Limited - Strong First Quarter Out Of The Gate
11/4/2014
Wedbush Securities Inc.
Luria, Gil
Reaccelerated Growth Highlights First Quarter as Public Company; Reiterate OUTPERFORM and Raise Price Target to $115 from $105
11/4/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: Quick Comment: F2Q15 Result Highlights
11/4/2014
BMO Capital Markets
Williams, Edward
BABA--Mobile Leads the Charge - Improving Monetization and Growing User Base(comment)
11/4/2014
CRT Capital
Doshi, Neil
CRT: BABA - Solid F2Q Results; Reit Buy and Raise PT to $122
11/4/2014
MKM Partners
Sanderson, Rob
Strong Quarter with Acceleration in GMV Growth and Mobile Monetization Ramp
11/4/2014
Susquehanna Financial Group LLLP
Nowak, Brian
Faster and Higher Out of the Gate
11/4/2014
BMO Capital Markets
Williams, Edward
Alibaba Group: Strong Quarter; Looking Ahead to Singles Day (flash)
11/4/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba : AliEveryday: merchant survey
11/4/2014
Wells Fargo Securities, LLC
Nemer, Matt
BABA: Strong First Quarter Out Of The Gate
11/4/2014
Cantor Fitzgerald
Squali, Youssef
Solid Quarter Out of the IPO Gate But Expect Higher Investments; PT to $110
11/4/2014
UBS Equities
Werkun, Erica Poon
First Read: Alibaba Group Holding Limited "FQ2 Quick Take" (Buy) Werkun
11/5/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba : AliEveryday: post-results NDR
11/5/2014
GUOSEN SECURITIES
Wang, Xueheng
阿里巴巴(BABA.US) 季报点评 - 首次业绩开门红，未来仍可期
11/5/2014
Rosenblatt Securities, Inc.
Zhang, Jun
Rosenblatt TMT Notes (BABA)
11/5/2014
Thomson Reuters StreetEvents
Research Department
BABA.N - Event Transcript of Alibaba Group Holding Ltd conference call, Nov. 05, 2014 / 7:30AM ET
11/5/2014
JG Capital
Guo, Henry
BABA – FQ2 Review; Revs Above; EPS In-line; Raise PT to $135; Reiterate Overweight
11/5/2014
Brean Capital, LLC
Gaugler, Michael
Growth Fueled by Mobile; Reiterate Buy and Raise TP to $115 from $110
11/5/2014
Morningstar, Inc.
Hottovy, R.J.
Morningstar | Alibaba's First Update as Public Company Adds Support to Network Effect Behind Wide Moat Rating. See Updated Analyst Note from 04 Nov 2014
11/5/2014
Topeka Capital Markets Inc.
Anthony, Victor
A- Quarter Out Of The Gate
11/5/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "Reaccelerating trends point to long term ...
11/7/2014
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : AliEveryday: Entertainment & sports
11/10/2014
Citi
Chong, Thomas
Alert: Alibaba Group Holding (BABA) - Key Takeaways from Investor & Analyst Tour (Day 1)
11/10/2014
Oppenheimer & Co., Inc.
Ji, Ella
A Jewel In The Crown; Initiate With Outperform
11/10/2014
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
Upcoming Singles Day Should be Bigger than Entire US Cyber Week
11/10/2014
Brean Capital, LLC
Gaugler, Michael
Singles' Day Update: Alibaba Charging Ahead of the Market
11/10/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited: Singles Day: Don't just focus on GMV, focus on how it helps Alibaba grow in the long term. Maintain OUTPERFO
11/10/2014
Macquarie Research
Shao, Jiong
Alibaba Group Holding (Neutral) - Mobile drives growth
11/11/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: Quick Comment: Double 11; Sales Reached US$9.2bn; Breaking Guinness World Record
11/11/2014
BMO Capital Markets
Williams, Edward
BABA--Scores on Singles Day(comment)
Page 2 of 4
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Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 84 of
102
Exhibit 4b
Alibaba Group Holding Limited
Analyst Reports Covering Alibaba
As Reported by Thomson Reuters
September 2014 to January 2015
Date
Contributor
Analyst
Title
(1)
(2)
(3)
(4)
11/11/2014
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
We Estimate Singles Day Could Drive 65% Revenue Growth
11/11/2014
Citi
Chong, Thomas
Alert: Alibaba Group Holding (BABA) - Key takeaways from Investor & Analyst Tour (Day 2)
11/11/2014
JG Capital
Guo, Henry
BABA - Double Eleven Shopping Day A Boon for Alibaba; Reiterate Overweight; PT $135
11/11/2014
Wells Fargo Securities, LLC
Nemer, Matt
BABA: Single's Day Exceeds Expectations
11/11/2014
HSBC
Tsang, Chi
Alibaba Group (BABA US):-Initiate at OW(V): Leading in the next growth leg of online shopping
11/11/2014
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "Singles Day: US$2bn GMV in the first hour" (Buy)
11/12/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: Takeaways from Hangzhou Trip
11/12/2014
Topeka Capital Markets Inc.
Anthony, Victor
Singles Day Takeaways, Largely Positive
11/13/2014
Oppenheimer & Co., Inc.
Helfstein, Jason
Increasing Price Target to $61 on Higher BABA Valuation
11/17/2014
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : Key takeaways from J.P. Morgan Global TMT conference
11/17/2014
Morningstar, Inc.
Warren, CFA, Greggory
Morningstar | 10 Ultimate Stock-Picker High-Conviction and New-Money Purchases
11/17/2014
Citi
May, Mark
YHOO: BABA at a 37% Discount
11/17/2014
Nomura
Wang, Chao
Alibaba Group Holding (BABA US, Buy) - Raising TP on mobile surprise (Erratum)
11/18/2014
Barclays
Yap, Alicia
Alibaba Group Holding Ltd.: 新たな挑戦、OWでカバレッジ開始
11/20/2014
Morgan Stanley
Moh, Angela
Alibaba Group Holding: 予想を上回る四半期業績
11/21/2014
Oppenheimer & Co., Inc.
Ji, Ella
Comparing Tmall Global With Amazon Overseas Direct Mail Services
11/23/2014
Crispidea
Ajmera, Shejal
Alibaba Group Holdings Ltd – Juggernaut Continues to Roll
11/24/2014
Mirabaud Securities
Han, Candy
Mirabaud Securities - Peripheral Vision -13th November 2014
11/26/2014
Morningstar, Inc.
Hottovy, R.J.
Morningstar | A powerful network effect in a rapidly growing industry makes wide moat-rated Alibaba a rare find.
12/3/2014
Thomson Reuters StreetEvents
Research Department
BABA.N - Event Transcript of Alibaba Group Holding Ltd conference call, Dec. 03, 2014 / 3:15PM ET
12/4/2014
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited: Takeaways from Credit Suisse Annual Technology Conference. Maintain OUTPERFORM
12/5/2014
Cantor Fitzgerald
Squali, Youssef
eWeekly: Holiday Shopping off to Good Start; Cautiously Optimistic on CMPR
12/9/2014
GlobalData
GlobalData
Alibaba Group Holding Limited (BABA) - Financial and Strategic SWOT Analysis Review
12/10/2014
EVERCORE ISI
Sena, Ken
Framing the World-to-China Opportunity
12/12/2014
New Street Research LLP
Boodry, Kirk
New Street: Emerging market Internet services: Funding rounds indicate EM will be uber-competitive
12/15/2014
BuySellSignals Research
Research Team
Alibaba Group Holding Ltd climbs 12% in 2014, but lagging Retailing sector
12/15/2014
PingAn Securities Co.,LTD
Wen, Xu
阿里巴巴（BABA.N）公司深度移动时代的战略大师与生态圈固守者
12/30/2014
BuySellSignals Research
Research Team
Alibaba Group Holding Ltd adds US$29.3 billion in MCap in 2014, leads Retailing sector gains
1/5/2015
Susquehanna Financial Group LLLP
N/A
Discontinuing Coverage
1/5/2015
JG Capital
Guo, Henry
BABA – Alipay Should Drive BABA Shares Higher; Reiterate Overweight Rating; PT $135
1/6/2015
Mirabaud Securities
McCahill, William
Mirabaud Securities - Letter from China 06.01.15
1/7/2015
Oppenheimer & Co., Inc.
Ji, Ella
China eCommerce 2015 Outlook
1/9/2015
GlobalData
GlobalData
Alibaba Group Holding Limited (BABA) - Financial and Strategic SWOT Analysis Review
1/12/2015
JG Capital
Guo, Henry
BABA – Juhuasuan Business Update; Reiterate Overweight; PT $135
1/12/2015
BNP Paribas Group
Ling, Vey-sern
ALIBABA GROUP - Market dominance continues
1/14/2015
Deutsche Bank Fixed Income Research
Tan, Colin
Alibaba Group Holding Limited : Well positioned for a secular growth story
1/15/2015
UOB Kay Hian Pte Ltd
Ge, Nicky
Alibaba Group (BABA US) - Proxy To Rising Consumption In China
1/15/2015
UOB Kay Hian Pte Ltd
Ge, Nicky
Alibaba Group (BABA US): Proxy to rising consumption in China. BUY
1/15/2015
Cantor Fitzgerald
Squali, Youssef
New 2015 Online Ad and E-Com Forecasts; Best Picks Highlighted
1/20/2015
Morgan Stanley
Moh, Angela
Alibaba Group Holding: F3Q15 Preview – Results Due on January 29
1/21/2015
Morgan Stanley
Moh, Angela
Alibaba Group Holding: 15年度3Q決算プレビュー： 1月29日に決算発表予定
1/22/2015
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : 3QFY15 preview
1/23/2015
Tigress Financial Partners
Feinseth, Ivan
Tigress Financial Partners Research Highlights: BABA, DLB, EBAY, SNDK, YHOO
1/23/2015
Cantor Fitzgerald
Squali, Youssef
Strong Results Expected for 3Q:FY15
1/25/2015
Citi
Chong, Thomas
Alibaba Group Holding (BABA): 3QFY15 Results Preview
1/25/2015
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "FQ3 Earnings Preview" (Buy) Werkun
1/26/2015
RBC Capital Markets
Mahaney, Mark
Alibaba Group Holding Limited - December '14Q Preview & Cheat Sheet
1/26/2015
Barclays
Yap, Alicia
Alibaba Group Holding Ltd.: 3Q FY15 preview: Expect solid results
1/26/2015
JG Capital
Guo, Henry
BABA – FQ3 Preview; Reiterate Overweight Rating; PT of $135
1/26/2015
MKM Partners
Sanderson, Rob
Vol. 2 of China eCommerce Survey Shows Positive Trends; BABA Reports this Thurs.
1/26/2015
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : 3QFY15 results preview - expecting a strong quarter ahead
1/26/2015
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited: CY4Q14 preview: Expect strong GMV growth with take rate increase. Maintain OUTPERFORM
1/27/2015
Oppenheimer & Co., Inc.
Helfstein, Jason
Raising Target to $66 on BABA SpinCo Announcement; Maintain Outperform Rating
Page 3 of 4
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Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 85 of
102
Exhibit 4b
Alibaba Group Holding Limited
Analyst Reports Covering Alibaba
As Reported by Thomson Reuters
September 2014 to January 2015
Date
Contributor
Analyst
Title
(1)
(2)
(3)
(4)
1/27/2015
T.H. Capital Research
Hou, Tian
T. H. Data Flash – Alibaba Group – December 2014: Tmall Drove GMV Growth in 4Q14; Mobile App Downloads Remain Robust
1/28/2015
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : SAIC claims against Alibaba
1/28/2015
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
Yahoo! Delivers on Alibaba Promise
1/28/2015
Topeka Capital Markets Inc.
Anthony, Victor
Tax Free Spin of BABA; Focus Now on Core, Japan, Capital Allocation
1/28/2015
Cantor Fitzgerald
Squali, Youssef
Tax-Free Spin-Off of BABA Stake Yields $14/sh of Upside; Maint. BUY; PT to $60
1/28/2015
Macquarie Research
Schachter, Ben
Yahoo (Outperform) - 4Q’14: FINALLY! A Plan for BABA
1/29/2015
Morgan Stanley
Moh, Angela
Alibaba Group Holding: GMV Beat/Monetization Miss; Not the Whole Story
1/29/2015
Citi
Chong, Thomas
Alibaba Group Holding (BABA): Building the ecosystem for the long term
1/29/2015
Citi
Chong, Thomas
Results: Alibaba Group Holding (BABA) - Revenue Miss on Softer-than-Expected Take-Rate; Customer Experience and Long-Term Growth Are Priorities
1/29/2015
UOB Kay Hian Pte Ltd
Ge, Nicky
Alibaba Group (BABA US) - 3QFY15: Mixed Results
1/29/2015
Nomura
Wang, Chao
Alibaba Group Holding (BABA US, Buy) - LT monetisation potential intact; accumulate
1/29/2015
GF Sec. (HK) Brokerage Ltd
Fan, Alex
[GF Securities] Dim Sum Express (Jan 30)
1/29/2015
Morgan Stanley
Moh, Angela
Alibaba Group Holding: F3Q15 Net Profits Beat 18% Despite Weaker Revenue
1/29/2015
Deutsche Bank Equity Research
Hellawell, Alan
Alibaba Alert : FY3Q15: slow take-rate expansion
1/29/2015
Credit Suisse - Non-Japan Asia
Wei, Dick
Asian Daily: China - Alibaba Group Holding Limited. New report: Monetization adjustments shall lead to stronger ecosystem in long-term. Maintain OUTPERFORM
1/29/2015
Credit Suisse - Non-Japan Asia
Wei, Dick
Alibaba Group Holding Limited. OUTPERFORM. Monetization adjustments should lead to stronger ecosystem in long-term
1/29/2015
Deutsche Bank Fixed Income Research
Tan, Colin
Alibaba Group Holding Limited : Dec Qtr was good enough; maintain CreditBuy on BABA'34
1/29/2015
Wedbush Securities Inc.
Luria, Gil
Growth Continues and Margins Hold Up Even as Singles Day Pulled in Demand; Reiterate OUTPERFORM
1/29/2015
BMO Capital Markets
Williams, Edward
BABA--Results Mixed but Growth Remains Strong(comment)
1/29/2015
Morningstar, Inc.
Hottovy, R.J.
Morningstar | Alibaba's Monetization Creates Near-Term Concern, but We Believe Network Effect Remains Intact
1/29/2015
Jefferies
Meng, Cynthia
Alibaba: BABA: BUY: Balance is Key in Transitioning to Mobile Commerce; Reiterate Buy
1/29/2015
RBC Capital Markets
Mahaney, Mark
Alibaba Group Holding Limited - A Monetization Miss, But Still Strong Fundamentals
1/29/2015
MKM Partners
Sanderson, Rob
Near-term Monetization Set-Back Overshadows Impressive Volume Growth
1/29/2015
Barclays
Yap, Alicia
Alibaba Group Holding Ltd.: GMV vs. ad revenue growth
1/29/2015
CRT Capital
Doshi, Neil
CRT: BABA - Mixed F3Q15; Lower PT to $110, Reiterate Buy
1/29/2015
Cantor Fitzgerald
Squali, Youssef
Lower Monetization Offsets Solid GMV Growth; Maintain BUY; PT Lowered to $100
1/29/2015
Morgan Stanley
Moh, Angela
Alibaba Group Holding: Addressing Two Top Questions: Yahoo Spin-Off and Counterfeits
1/29/2015
BNP Paribas Group
Ling, Vey-sern
ALIBABA GROUP - Disappointing revenue growth
1/29/2015
Thomson Reuters StreetEvents
Research Department
BABA.N - Event Transcript of Alibaba Group Holding Ltd conference call, Jan. 29, 2015 / 7:30AM ET
1/29/2015
UBS Equities
Werkun, Erica Poon
First Read: Alibaba Group Holding Limited "FQ3 Quick Take" (Buy) Werkun
1/30/2015
Morgan Stanley
Moh, Angela
China Consumer/Retail Weekly
1/30/2015
Barclays
Vogel, Paul
U.S. Internet: TYMHM: Week of 01/26/15 - Superb Amphitheater Week
1/30/2015
Rosenblatt Securities, Inc.
Zhang, Jun
Rosenblatt TMT Notes (BABA)
1/30/2015
ICBC International Securities Limited
You, Na
ICBCI - Alibaba (BABA.US) - 3Q15: Soft growth vs strong performance in mobile; pay attention on SAIC & BABA’s conversation
1/30/2015
SunTrust Robinson Humphrey Capital Markets
Peck, Robert
Dec Q: Solid GMV and Profit, But Monetization Weighs on Revs
1/30/2015
New Street Research LLP
Boodry, Kirk
New Street: Alibaba Group (Neutral, TP: $97 +8%): Q3 14 results: monetisation and regulatory headwinds
1/30/2015
Brean Capital, LLC
Gaugler, Michael
Mixed FY3Q15; Long Term Fundamentals Intact; Maintain Buy; Lower TP to $110
1/30/2015
EVERCORE ISI
Sena, Ken
Strong Volumes on Good Bottom Line
1/30/2015
GF Sec. (HK) Brokerage Ltd
Ho, Joseph
[GF Securities] Alibaba (BABA US, NR)
1/30/2015
JPMorgan
Yao, Alex
Alibaba Group Holding Limited : Fine-tuning ads monetization engine for long-term growth; expecting short-term impact on take rate
1/30/2015
Wells Fargo Securities, LLC
Nemer, Matt
BABA: Revenue Miss Spooks Investors Despite EBITDA Beat
1/30/2015
UBS Equities
Leung, Stephen
Softbank "Updating SOTP model to reflect changes in Alibaba forecasts" (Buy)
1/30/2015
UBS Equities
Sheridan, Eric
Yahoo "The BABA Buying Opportunity (Thru Yahoo)" (Buy) Sheridan
1/30/2015
UBS Equities
Werkun, Erica Poon
Alibaba Group Holding Limited "Take Rate Noise Mutes Growth Potential" (Buy)
1/30/2015
HSBC
Tsang, Chi
Alibaba Group (BABA US):-OW(V): Buy the dip: pause in monetization is a buying opportunity
Notes and Sources:
Analyst report information obtained from Thomson Reuters.
Page 4 of 4
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Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 86 of
102
Exhibit 5
Alibaba Group Holding Limited
Summary of Quarterly Institutional Holdings for ADSs
September 30, 2014 to March 31, 2015
Total
Number of
Total
Institutional Holdings
Institutional
Institutional
Shares
As a Percent of
As of Date
Holders1
Holdings2
Outstanding3
Shares Outstanding
(1)
(2)
(3)
(5)
(6)
(3) / (5)
9/30/2014
604
320,446,090
2,465,006,000
13.0 %
12/31/2014
900
331,499,868
2,465,006,000
13.4
3/31/2015
924
444,709,914
2,465,006,000
18.0
Average Quarterly Holdings as a Percent of Shares Outstanding
13.2 %4
Median Quarterly Holdings as a Percent of Shares Outstanding
13.2 %4
Notes and Sources:
Data obtained from FactSet Research Systems, Inc.
1 Number of institutions that reported non-zero holdings during the quarter.
2 Total calculated by summing individual institutional holdings figures from institutions that reported
holdings.
3 Daily shares outstanding figures are as of the most recent reported date. Shares outstanding figures are
used in place of ADSs outstanding figures as any shares sold by pre-IPO shareholders subsequently
become ADSs.
4 Calculated using institutional holdings data within the class period (observations September 30, 2014 and
December 31, 2014). If data immediately after the class period are used (3/31/2015), then the average
quarterly institutional holdings as a percent of shares outstanding is 14.8% and the median quarterly
institutional holdings as a percent of shares outstanding is 13.4%.
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 86 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 87 of
102
Exhibit 6
Alibaba Group Holding Limited
Summary of Short Interest
September 2014 to January 2015
Short Interest
Short
Shares
As a Percent of
As of Date
Interest
Outstanding1
Shares Outstanding
(1)
(2)
(3)
(4)
(2) / (3)
9/30/2014
20,495,121
2,465,006,000
0.83 %
10/15/2014
27,349,423
2,465,006,000
1.11
10/31/2014
37,746,230
2,465,006,000
1.53
11/14/2014
45,941,150
2,465,006,000
1.86
11/28/2014
45,325,238
2,465,006,000
1.84
12/15/2014
45,265,664
2,465,006,000
1.84
12/31/2014
43,513,696
2,465,006,000
1.77
1/15/2015
41,342,263
2,465,006,000
1.68
1/30/2015
42,303,671
2,465,006,000
1.72
Average Short Interest as Percent of Shares Outstanding 2
1.56 %
Median Short Interest as Percent of Shares Outstanding 2
1.72 %
Notes and Sources:
Short interest and shares outstanding data obtained from Bloomberg L.P.
1 Daily shares outstanding figures are as of the most recent reported date and represent
the total number of shares outstanding for Alibaba.
2 Calculated using short interest data within the class period (observations 9/30/2014 to
1/15/2015). If data immediately after the class period is used (1/30/2015), the average
short interest as a percent of shares outstanding is 1.57% and the median short interest
as a percent of shares outstanding is 1.72%.
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 87 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 88 of
102
Exhibit 7
Alibaba Group Holding Limited
Daily Market Capitalization and Float
September 19, 2014 to January 28, 20151
Insider Ownership
Closing
Shares
Market
and Other non-ADS
Float as a Percent of
Date
Price
Outstanding2
Capitalization
Shares3
Float
Shares Outstanding
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(2) * (3)
(3) - (5)
(6) / (3)
9/19/2014
$
93.89
2,465,006,000
$ 231,439,413,340
2,220,161,906
244,844,094
9.93 %
9/22/2014
89.89
2,465,006,000
221,579,389,340
2,220,161,906
244,844,094
9.93
9/23/2014
87.17
2,465,006,000
214,874,573,020
2,220,161,906
244,844,094
9.93
9/24/2014
90.57
2,465,006,000
223,255,593,420
2,220,161,906
244,844,094
9.93
9/25/2014
88.92
2,465,006,000
219,188,333,520
2,220,161,906
244,844,094
9.93
9/26/2014
90.46
2,465,006,000
222,984,442,760
2,220,161,906
244,844,094
9.93
9/29/2014
88.75
2,465,006,000
218,769,282,500
2,220,161,906
244,844,094
9.93
9/30/2014
88.85
2,465,006,000
219,015,783,100
2,220,161,906
244,844,094
9.93
10/1/2014
86.10
2,465,006,000
212,237,016,600
2,220,161,906
244,844,094
9.93
10/2/2014
87.06
2,465,006,000
214,603,422,360
2,220,161,906
244,844,094
9.93
10/3/2014
88.10
2,465,006,000
217,167,028,600
2,220,161,906
244,844,094
9.93
10/6/2014
88.31
2,465,006,000
217,684,679,860
2,220,161,906
244,844,094
9.93
10/7/2014
87.67
2,465,006,000
216,107,076,020
2,220,161,906
244,844,094
9.93
10/8/2014
88.30
2,465,006,000
217,660,029,800
2,220,161,906
244,844,094
9.93
10/9/2014
88.79
2,465,006,000
218,867,882,740
2,220,161,906
244,844,094
9.93
10/10/2014
85.88
2,465,006,000
211,694,715,280
2,220,161,906
244,844,094
9.93
10/13/2014
85.12
2,465,006,000
209,821,310,720
2,220,161,906
244,844,094
9.93
10/14/2014
84.95
2,465,006,000
209,402,259,700
2,220,161,906
244,844,094
9.93
10/15/2014
85.60
2,465,006,000
211,004,513,600
2,220,161,906
244,844,094
9.93
10/16/2014
88.85
2,465,006,000
219,015,783,100
2,220,161,906
244,844,094
9.93
10/17/2014
87.91
2,465,006,000
216,698,677,460
2,220,161,906
244,844,094
9.93
10/20/2014
88.26
2,465,006,000
217,561,429,560
2,220,161,906
244,844,094
9.93
10/21/2014
90.90
2,465,006,000
224,069,045,400
2,220,161,906
244,844,094
9.93
10/22/2014
91.63
2,465,006,000
225,868,499,780
2,220,161,906
244,844,094
9.93
10/23/2014
94.45
2,465,006,000
232,819,816,700
2,220,161,906
244,844,094
9.93
10/24/2014
95.76
2,465,006,000
236,048,974,560
2,220,161,906
244,844,094
9.93
10/27/2014
97.79
2,465,006,000
241,052,936,740
2,220,161,906
244,844,094
9.93
10/28/2014
99.68
2,465,006,000
245,711,798,080
2,220,161,906
244,844,094
9.93
10/29/2014
98.31
2,465,006,000
242,334,739,860
2,220,161,906
244,844,094
9.93
10/30/2014
98.73
2,465,006,000
243,370,042,380
2,220,161,906
244,844,094
9.93
10/31/2014
98.60
2,465,006,000
243,049,591,600
2,220,161,906
244,844,094
9.93
11/3/2014
101.80
2,465,006,000
250,937,610,800
2,220,161,906
244,844,094
9.93
11/4/2014
106.07
2,465,006,000
261,463,186,420
2,220,161,906
244,844,094
9.93
11/5/2014
108.67
2,465,006,000
267,872,202,020
2,220,161,906
244,844,094
9.93
11/6/2014
111.57
2,465,006,000
275,020,719,420
2,220,161,906
244,844,094
9.93
11/7/2014
114.56
2,465,006,000
282,391,087,360
2,220,161,906
244,844,094
9.93
11/10/2014
119.15
2,465,006,000
293,705,464,900
2,220,161,906
244,844,094
9.93
11/11/2014
114.54
2,465,006,000
282,341,787,240
2,220,161,906
244,844,094
9.93
11/12/2014
118.20
2,465,006,000
291,363,709,200
2,220,161,906
244,844,094
9.93
11/13/2014
114.84
2,465,006,000
283,081,289,040
2,220,161,906
244,844,094
9.93
11/14/2014
115.10
2,465,006,000
283,722,190,600
2,220,161,906
244,844,094
9.93
11/17/2014
114.25
2,465,006,000
281,626,935,500
2,220,161,906
244,844,094
9.93
11/18/2014
110.81
2,465,006,000
273,147,314,860
2,220,161,906
244,844,094
9.93
11/19/2014
108.82
2,465,006,000
268,241,952,920
2,220,161,906
244,844,094
9.93
11/20/2014
109.82
2,465,006,000
270,706,958,920
2,220,161,906
244,844,094
9.93
11/21/2014
110.73
2,465,006,000
272,950,114,380
2,220,161,906
244,844,094
9.93
11/24/2014
113.92
2,465,006,000
280,813,483,520
2,220,161,906
244,844,094
9.93
11/25/2014
113.47
2,465,006,000
279,704,230,820
2,194,018,006
270,987,994
10.99
11/26/2014
112.67
2,465,006,000
277,732,226,020
2,194,018,006
270,987,994
10.99
11/28/2014
111.64
2,465,006,000
275,193,269,840
2,194,018,006
270,987,994
10.99
12/1/2014
105.99
2,465,006,000
261,265,985,940
2,194,018,006
270,987,994
10.99
12/2/2014
109.89
2,465,006,000
270,879,509,340
2,194,018,006
270,987,994
10.99
12/3/2014
110.64
2,465,006,000
272,728,263,840
2,194,018,006
270,987,994
10.99
12/4/2014
109.17
2,465,006,000
269,104,705,020
2,194,018,006
270,987,994
10.99
12/5/2014
107.90
2,465,006,000
265,974,147,400
2,194,018,006
270,987,994
10.99
Page 1 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 88 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 89 of
102
Exhibit 7
Alibaba Group Holding Limited
Daily Market Capitalization and Float
September 19, 2014 to January 28, 20151
Insider Ownership
Closing
Shares
Market
and Other non-ADS
Float as a Percent of
Date
Price
Outstanding2
Capitalization
Shares3
Float
Shares Outstanding
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(2) * (3)
(3) - (5)
(6) / (3)
12/8/2014
$ 105.07
2,465,006,000
$ 258,998,180,420
2,194,018,006
270,987,994
10.99 %
12/9/2014
107.48
2,465,006,000
264,938,844,880
2,194,018,006
270,987,994
10.99
12/10/2014
103.88
2,465,006,000
256,064,823,280
2,194,018,006
270,987,994
10.99
12/11/2014
104.97
2,465,006,000
258,751,679,820
2,194,018,006
270,987,994
10.99
12/12/2014
105.11
2,465,006,000
259,096,780,660
2,194,018,006
270,987,994
10.99
12/15/2014
104.70
2,465,006,000
258,086,128,200
2,194,018,006
270,987,994
10.99
12/16/2014
105.77
2,465,006,000
260,723,684,620
2,194,018,006
270,987,994
10.99
12/17/2014
109.02
2,465,006,000
268,734,954,120
2,194,018,006
270,987,994
10.99
12/18/2014
109.25
2,465,006,000
269,301,905,500
2,194,018,006
270,987,994
10.99
12/19/2014
110.65
2,465,006,000
272,752,913,900
2,194,018,006
270,987,994
10.99
12/22/2014
108.77
2,465,006,000
268,118,702,620
2,194,018,006
270,987,994
10.99
12/23/2014
105.52
2,465,006,000
260,107,433,120
2,194,018,006
270,987,994
10.99
12/24/2014
105.95
2,465,006,000
261,167,385,700
2,194,018,006
270,987,994
10.99
12/26/2014
105.95
2,465,006,000
261,167,385,700
2,194,018,006
270,987,994
10.99
12/29/2014
105.98
2,465,006,000
261,241,335,880
2,194,018,006
270,987,994
10.99
12/30/2014
105.75
2,465,006,000
260,674,384,500
2,194,018,006
270,987,994
10.99
12/31/2014
103.94
2,465,006,000
256,212,723,640
2,188,544,137
276,461,863
11.22
1/2/2015
103.60
2,465,006,000
255,374,621,600
2,188,544,137
276,461,863
11.22
1/5/2015
101.00
2,465,006,000
248,965,606,000
2,188,544,137
276,461,863
11.22
1/6/2015
103.32
2,465,006,000
254,684,419,920
2,188,544,137
276,461,863
11.22
1/7/2015
102.13
2,465,006,000
251,751,062,780
2,188,544,137
276,461,863
11.22
1/8/2015
105.03
2,465,006,000
258,899,580,180
2,188,544,137
276,461,863
11.22
1/9/2015
103.02
2,465,006,000
253,944,918,120
2,188,544,137
276,461,863
11.22
1/12/2015
101.62
2,465,006,000
250,493,909,720
2,188,544,137
276,461,863
11.22
1/13/2015
100.77
2,465,006,000
248,398,654,620
2,188,544,137
276,461,863
11.22
1/14/2015
99.58
2,465,006,000
245,465,297,480
2,050,584,937
414,421,063
16.81
1/15/2015
96.31
2,465,006,000
237,404,727,860
2,050,584,937
414,421,063
16.81
1/16/2015
96.89
2,465,006,000
238,834,431,340
2,050,584,937
414,421,063
16.81
1/20/2015
100.04
2,465,006,000
246,599,200,240
2,050,584,937
414,421,063
16.81
1/21/2015
103.29
2,465,006,000
254,610,469,740
2,050,584,937
414,421,063
16.81
1/22/2015
104.00
2,465,006,000
256,360,624,000
2,050,584,937
414,421,063
16.81
1/23/2015
103.11
2,465,006,000
254,166,768,660
2,050,584,937
414,421,063
16.81
1/26/2015
103.99
2,465,006,000
256,335,973,940
2,050,584,937
414,421,063
16.81
1/27/2015
102.94
2,465,006,000
253,747,717,640
2,050,584,937
414,421,063
16.81
1/28/2015
98.45
2,465,006,000
242,679,840,700
2,050,584,937
414,421,063
16.81
Average Float as a Percent of Shares Outstanding
11.11 %
Median Float as a Percent of Shares Outstanding
9.93 %
Notes and Sources:
Closing price, shares outstanding, and ADS outstanding data obtained from Bloomberg L.P.
Insider holdings data obtained from FactSet Research Systems, Inc.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September 19, 2014 to January 29, 2015. However, since
the final disclosure occurs before the market opened on January 29, 2015, January 28, 2015 is taken to be the end of the class period.
2 Daily shares outstanding figures are as of the most recent reported date. Shares outstanding figures are used in place of ADSs outstanding
figures as any shares sold by pre-IPO shareholders subsequently become ADSs.
3 This figure includes both insiders who held Alibaba ADSs other ordinary shares that have not been affirmatively identified as ADSs.
Insider holdings figures for Alibaba ADSs are not reported prior to September 30, 2014. In this analysis, it is assumed that insider holdings
of Alibaba ADSs from September 19, 2014 to September 29, 2014 are equal to the figures reported as of September 30, 2014.
Page 2 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 89 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 90 of
102
Exhibit 8a
Alibaba Group Holding Limited
Percent of Days with Statistically Significant Returns on News Days as Compared to Non-News Days for ADSs
September 22, 2014 to January 27, 2015 1
Using the EMQQ Emerging Markets Internet Index 2
News Days
Non-News Days
Difference between News Days and Non-News Days
Total
Number
Number with
Significant
Excess Returns3
Percent of Days with
Significant Excess
Returns
Total Number
Number with
Significant
Excess Returns3
Percent of Days with
Significant Excess
Returns
Difference in
Percentages
z - Statistic4
Different from Zero
at 5% Significance
Level?5
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(2) / (1)
(5) / (4)
(3) - (6)
Earnings Dates6
1
1
100.0%
87
8
9.2%
90.8%
2.98
Yes
Dow Jones Newswires 7
69
8
11.6%
19
1
5.3%
6.3%
0.81
No
Dow Jones Newswires - Top 50%8
51
8
15.7%
37
1
2.7%
13.0%
1.98
Yes
Dow Jones Newswires - Top 10%9
8
3
37.5%
80
6
7.5%
30.0%
2.67
Yes
Dow Jones Newswires - Top 10% Excluding Selected Articles10
4
2
50.0%
84
7
8.3%
41.7%
2.69
Yes
Notes and Sources:
Data obtained from Bloomberg L.P., Factiva Dow Jones, and FactSet Research Systems, Inc.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September 19, 2014 to January 29, 2015. However, since Alibaba's initial public offering occurred on September 19, 2014, the first trading day for which daily
returns can be calculated is September 22, 2014. Therefore, September 22, 2014 is taken to be the first day of the analysis. Additionally, as the disclosure that SAIC had released a white paper on Alibaba's business practices occurs after
market close on January 27, 2015, January 28, 2015 is excluded from this analysis.
2 EMQQ Emerging Markets Internet Index returns are adjusted to remove the weight of Alibaba ADS prices in the index. Data on Alibaba's weight in the EMQQ Emerging Markets Internet Index are not available prior to November 18, 2014.
Therefore, it is assumed that Alibaba's weight in the index prior to November 18, 2014 is equal to its weight on November 18, 2014.
3 Days for which the excess return was statistically significant at the 5% level. Returns are predicted using a regression of the returns of Alibaba ADS prices on the returns of the EMQQ Emerging Markets Internet Index run over the period
from January 30, 2015 to January 29, 2016 [N = 252]. Because no returns can be calculated before the class period, the estimation period is assumed to be the year starting the trading day after the last day of the price reaction to the final
disclosure of the class period. For more information, see Exhibit 8b.
4 The z-statistic is a test statistic for a two-sample test of binomial proportions. It measures the probability of obtaining results as or more extreme as those observed if the returns for news and non-news days were drawn from the same
distribution. The further the z-statistic is from zero, the less likely that the observed difference could have been seen if the returns for news and non-news days were drawn from the same distribution.
5 A 5% significance level means that the difference in percentages in column (7) is of a magnitude that would be observed no more than 5% of the time if there is no difference in market reaction to news and non-news days.
6 Earnings dates obtained from I/B/E/S Consensus EPS Surprise History via FactSet Research Systems, Inc. and verified via Factiva Dow Jones.
7 News days are defined as days on which there was at least one news article on Alibaba published by Dow Jones Newswires as downloaded from Factiva Dow Jones. News stories were obtained through a search of "'Alibaba' or 'Baba'"
between September 1, 2014 and February 15, 2015. The search included news stories published by Dow Jones Newswires, searching headlines only, excluding "republished news," "recurring pricing and market data," and "Obituaries,
sports, calendars...." On days when news came out after 4:00PM or when there was news on a non-trading day, the next trading day was considered the effective date.
8 News days are defined as days in the top 50% of all Dow Jones Newswires news days, ranked by number of articles on Alibaba published by Dow Jones Newswires per day from September 22, 2014 to January 27, 2015, inclusive.
9 News days are defined as days in the top 10% of all Dow Jones Newswires news days, ranked by number of articles on Alibaba published by Dow Jones Newswires per day from September 22, 2014 to January 27, 2015, inclusive.
10 Exhibit 8d is a list of news days that were excluded as they contained only news stories reporting stock price movements or volume, news stories that appeared to be duplicates of previously reported news, and news stories deemed to be
non-material because they reported data irrelevant to the value of the Company.
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 90 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 91 of
102
Exhibit 8b
Alibaba Group Holding Limited
Statistical Model of Daily Logarithmic Returns of Alibaba ADSs
Estimation Period: January 30, 2015 to January 29, 20161
Log Return of
=
(0.00) 2 +
0.87
3 *
Log Return of EMQQ Emerging
Alibaba ADS Price
(0.84)
13.13
Markets Internet Index4
Observations
=
252
R-Squared5
=
40.81%
Adjusted R-Squared6
=
40.57%
Standard Error7
=
1.64%
Notes and Sources:
Data obtained from Bloomberg L.P.
t-statistics are shown in italics. Statistically significant coefficients (at the 5% level) are shown in bold.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September 19, 2014 to
January 29, 2015. However, since Alibaba's initial public offering occurred on September 19, 2014, the first
trading day for which daily returns can be calculated is September 22, 2014. Therefore, September 22, 2014
is taken to be the first day of the analysis. Additionally, since the final disclosure occurs before the market
opened on January 29, 2015, January 28, 2015 is taken to be the end of the class period.
Because no returns can be calculated before the class period, the estimation period is assumed to be the year
starting the trading day after the last day of the price reaction to the final disclosure of the class period.
2 The constant is the expected value of the dependent variable (Alibaba ADS returns) if the independent
variable (EMQQ Emerging Markets Internet Index returns) equals 0.
3 This coefficient measures the change in the dependent variable (Alibaba ADS returns) associated with a
one unit change in the independent variable (EMQQ Emerging Markets Internet Index returns).
4 EMQQ Emerging Markets Internet Index returns are adjusted to remove the weight of Alibaba ADS prices
in the index.
5 R-squared is the percent of the variance in the dependent variable (Alibaba ADS returns) that is explained
by the variance of the independent variable (EMQQ Emerging Markets Internet Index returns).
6 Adjusted R-squared is the percent of the variance in the dependent variable (Alibaba ADS returns) that is
explained by the variance of the independent variable (EMQQ Emerging Markets Internet Index returns),
adjusted for the number of predictors in the market model.
7 Denotes the standard error of the regression model, which is a statistical measure of the variability of
predictions made with the regression model.
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 91 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 92 of
102
Exhibit 8c
Alibaba Group Holding Limited
Absolute Value of Excess Returns on News Days as Compared to Non-News Days for ADSs
September 22, 2014 to January 27, 2015 1
Using the EMQQ Emerging Markets Internet Index 2
Kolmogorov-Smirnov Test of the Equality of
News Days
Non-News Days
Distributions of News Days and Non-News Days 4
Total
Number
Average Absolute
Value of Excess
Returns3
Total
Number
Average Absolute
Value of Excess
Returns3
Kolmogorov-
Smirnov
Distance5
p-value6
Different in
Distribution at 5%
Significance Level?7
(1)
(2)
(3)
(4)
(5)
(6)
(7)
Earnings Dates8
1
0.0344
87
0.0145
0.954
0.114
No
Dow Jones Newswires 9
69
0.0150
19
0.0136
0.130
0.927
No
Dow Jones Newswires - Top 50%10
51
0.0162
37
0.0127
0.171
0.488
No
Dow Jones Newswires - Top 10%11
8
0.0206
80
0.0142
0.338
0.321
No
Dow Jones Newswires - Top 10% Excluding Selected Articles12
4
0.0248
84
0.0143
0.536
0.157
No
Notes and Sources:
Data obtained from Bloomberg L.P., Factiva Dow Jones, and FactSet Research Systems, Inc.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September 19, 2014 to January 29, 2015. However, since Alibaba's initial public offering occurred on September
19, 2014, the first trading day for which daily returns can be calculated is September 22, 2014. Therefore, September 22, 2014 is taken to be the first day of the analysis. Additionally, as the
disclosure that SAIC had released a white paper on Alibaba's business practices occurs after market close on January 27, 2015, January 28, 2015 is excluded from this analysis.
2 EMQQ Emerging Markets Internet Index returns are adjusted to remove the weight of Alibaba ADS prices in the index.
3 Returns are predicted using a regression of the returns of Alibaba ADS prices on the returns of the EMQQ Emerging Markets Internet Index run over the period from January 30, 2015 to
January 29, 2016 [N = 252]. Because no returns can be calculated before the class period, the estimation period is assumed to be the year starting the trading day after the last day of the price
reaction to the final disclosure of the class period. For more information, see Exhibit 8b.
4 The Kolmogorov-Smirnov test is a nonparametric test of the equality of continuous distributions. It quantifies a distance between the empirical cumulative distributions of two samples and
tests the null hypothesis that both samples are drawn from the same distribution.
5 The Kolmogorov-Smirnov distance is a statistic that quantifies the maximum distance between the distributions of news and non-news days.
6 The p-value represents the probability of measuring a test statistic as or more extreme than the calculated test statistic assuming that the null hypothesis is true.
7 A 5% significance level means that the distance in column (5) is of a magnitude that would be observed no more than 5% of the time if there is no difference in the distributions of news days
and non-news days.
8 Earnings dates obtained from I/B/E/S Consensus EPS Surprise History via FactSet Research Systems, Inc. and verified via Factiva Dow Jones.
Page 1 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 92 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 93 of
102
Exhibit 8c
Alibaba Group Holding Limited
Absolute Value of Excess Returns on News Days as Compared to Non-News Days for ADSs
September 22, 2014 to January 27, 2015 1
Using the EMQQ Emerging Markets Internet Index 2
9 News days are defined as days on which there was at least one news article on Alibaba published by Dow Jones Newswires as downloaded from Factiva Dow Jones. News stories were
obtained through a search of "'Alibaba' or 'Baba'" between September 1, 2014 and February 15, 2015. The search included news stories published by Dow Jones Newswires, searching headlines
only, excluding "republished news," "recurring pricing and market data," and "Obituaries, sports, calendars...." On days when news came out after 4:00PM or when there was news on a
non-trading day, the next trading day was considered the effective date.
10 News days are defined as days in the top 50% of all Dow Jones Newswires news days, ranked by number of articles on Alibaba published by Dow Jones Newswires per day from September 22,
2014 to January 27, 2015, inclusive.
11 News days are defined as days in the top 10% of all Dow Jones Newswires news days, ranked by number of articles on Alibaba published by Dow Jones Newswires per day from September 22,
2014 to January 27, 2015, inclusive.
12 Exhibit 8d is a list of news days that were excluded as they contained only news stories reporting stock price movements or volume, news stories that appeared to be duplicates of previously
reported news, and news stories deemed to be non-material because they reported data irrelevant to the value of the Company.
Page 2 of 2
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 93 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 94 of
102
Exhibit 8d
Alibaba Group Holding Limited
News Dates Removed1,2
September 22, 2014 to January 27, 20153
Date
(1)
9/22/2014
9/23/2014
10/28/2014
10/29/2014
Notes and Sources:
Articles downloaded from Factiva Dow Jones.
1 News days are defined as days the top 10% of all Dow Jones Newswires news days, ranked by number
of articles on Alibaba published by Dow Jones Newswires per day from September 22, 2014 to January
27, 2015, inclusive. Articles as downloaded from Factiva Dow Jones were obtained through a search of
Alibaba' or 'Baba' between 9/1/2014 and 2/15/2015. The search included The search included news
stories published by Dow Jones Newswires, searching headlines only, excluding "republished news,"
recurring pricing and market data, and "Obituaries, sports, calendars...." On days when news came out
after 4:00PM or when there was news on a non-trading day, the next trading day was considered the
effective date.
2 News dates were excluded because they contained only news stories reporting stock price movements
or volume, news stories that appeared to be duplicates of previously reported news, and news stories
deemed to be non-material because they reported data irrelevant to the value of the Company.
3 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September 19,
2014 to January 29, 2015. However, since Alibaba's initial public offering occurred on September 19,
2014, the first trading day for which daily returns can be calculated is September 22, 2014. Therefore,
September 22, 2014 is taken to be the first day of the analysis. Additionally, as the disclosure that SAIC
had released a white paper on Alibaba's business practices occurs after market close on January 27,
2015, January 28, 2015 is excluded from this analysis.
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 94 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 95 of
102
Exhibit 9
Alibaba Group Holding Limited
Daily Bid-Ask Spread
September 19, 2014 to January 28, 2015
Spread as a
Closing
Bid-Ask
Percent of
Date
Price
Bid
Ask
Spread
Closing Price
(1)
(2)
(3)
(4)
(5)
(6)
(4) - (3)
(5) / (2)
9/19/2014
$
93.89
$
93.30
$
93.39
$
0.09
0.10 %
9/22/2014
89.89
89.90
89.92
0.02
0.02
9/23/2014
87.17
87.02
87.10
0.08
0.09
9/24/2014
90.57
90.31
90.40
0.09
0.10
9/25/2014
88.92
88.71
88.76
0.05
0.06
9/26/2014
90.46
90.16
90.20
0.04
0.04
9/29/2014
88.75
88.64
88.71
0.07
0.08
9/30/2014
88.85
88.60
88.63
0.03
0.03
10/1/2014
86.10
86.09
86.11
0.02
0.02
10/2/2014
87.06
86.88
86.90
0.02
0.02
10/3/2014
88.10
88.10
88.12
0.02
0.02
10/6/2014
88.31
88.25
88.26
0.01
0.01
10/7/2014
87.67
87.75
87.78
0.03
0.03
10/8/2014
88.30
88.25
88.27
0.02
0.02
10/9/2014
88.79
88.77
88.79
0.02
0.02
10/10/2014
85.88
85.88
85.93
0.05
0.06
10/13/2014
85.12
85.03
85.07
0.04
0.05
10/14/2014
84.95
84.90
84.95
0.05
0.06
10/15/2014
85.60
85.54
85.57
0.03
0.04
10/16/2014
88.85
88.71
88.76
0.05
0.06
10/17/2014
87.91
87.83
87.87
0.04
0.05
10/20/2014
88.26
88.26
88.27
0.01
0.01
10/21/2014
90.90
90.87
90.88
0.01
0.01
10/22/2014
91.63
91.60
91.63
0.03
0.03
10/23/2014
94.45
94.44
94.45
0.01
0.01
10/24/2014
95.76
95.76
95.77
0.01
0.01
10/27/2014
97.79
97.81
97.84
0.03
0.03
10/28/2014
99.68
99.74
99.75
0.01
0.01
10/29/2014
98.31
98.45
98.46
0.01
0.01
10/30/2014
98.73
98.68
98.70
0.02
0.02
10/31/2014
98.60
98.74
98.75
0.01
0.01
11/3/2014
101.80
101.97
102.00
0.03
0.03
11/4/2014
106.07
106.17
106.19
0.02
0.02
11/5/2014
108.67
108.67
108.72
0.05
0.05
11/6/2014
111.57
111.60
111.65
0.05
0.04
11/7/2014
114.56
114.39
114.42
0.03
0.03
11/10/2014
119.15
119.17
119.19
0.02
0.02
11/11/2014
114.54
114.57
114.62
0.05
0.04
11/12/2014
118.20
118.20
118.25
0.05
0.04
11/13/2014
114.84
114.87
114.89
0.02
0.02
11/14/2014
115.10
115.05
115.08
0.03
0.03
Page 1 of 3
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Exhibit 9
Alibaba Group Holding Limited
Daily Bid-Ask Spread
September 19, 2014 to January 28, 2015
Spread as a
Closing
Bid-Ask
Percent of
Date
Price
Bid
Ask
Spread
Closing Price
(1)
(2)
(3)
(4)
(5)
(6)
(4) - (3)
(5) / (2)
11/17/2014
$ 114.25
$ 114.12
$ 114.18
$
0.06
0.05 %
11/18/2014
110.81
110.86
110.90
0.04
0.04
11/19/2014
108.82
108.56
108.62
0.06
0.06
11/20/2014
109.82
109.82
109.83
0.01
0.01
11/21/2014
110.73
110.73
110.77
0.04
0.04
11/24/2014
113.92
113.90
113.91
0.01
0.01
11/25/2014
113.47
113.18
113.22
0.04
0.04
11/26/2014
112.67
112.57
112.63
0.06
0.05
11/28/2014
111.64
111.48
111.49
0.01
0.01
12/1/2014
105.99
105.91
105.96
0.05
0.05
12/2/2014
109.89
109.89
109.91
0.02
0.02
12/3/2014
110.64
110.54
110.57
0.03
0.03
12/4/2014
109.17
109.05
109.06
0.01
0.01
12/5/2014
107.90
107.89
107.90
0.01
0.01
12/8/2014
105.07
105.08
105.14
0.06
0.06
12/9/2014
107.48
107.53
107.56
0.03
0.03
12/10/2014
103.88
103.76
103.81
0.05
0.05
12/11/2014
104.97
105.02
105.04
0.02
0.02
12/12/2014
105.11
105.14
105.17
0.03
0.03
12/15/2014
104.70
104.75
104.76
0.01
0.01
12/16/2014
105.77
105.82
105.84
0.02
0.02
12/17/2014
109.02
108.98
109.00
0.02
0.02
12/18/2014
109.25
109.23
109.25
0.02
0.02
12/19/2014
110.65
109.95
109.96
0.01
0.01
12/22/2014
108.77
108.77
108.80
0.03
0.03
12/23/2014
105.52
105.45
105.46
0.01
0.01
12/24/2014
105.95
105.94
105.95
0.01
0.01
12/26/2014
105.95
105.91
105.93
0.02
0.02
12/29/2014
105.98
105.94
105.96
0.02
0.02
12/30/2014
105.75
105.75
105.79
0.04
0.04
12/31/2014
103.94
103.94
103.95
0.01
0.01
1/2/2015
103.60
103.59
103.60
0.01
0.01
1/5/2015
101.00
101.00
101.02
0.02
0.02
1/6/2015
103.32
103.43
103.44
0.01
0.01
1/7/2015
102.13
102.12
102.13
0.01
0.01
1/8/2015
105.03
105.03
105.04
0.01
0.01
1/9/2015
103.02
102.97
102.98
0.01
0.01
1/12/2015
101.62
101.65
101.68
0.03
0.03
1/13/2015
100.77
100.75
100.76
0.01
0.01
1/14/2015
99.58
99.50
99.53
0.03
0.03
1/15/2015
96.31
96.25
96.29
0.04
0.04
Page 2 of 3
Case 1:15-md-02631-CM Document 54-1 Filed 03/12/18 Page 96 of 101
Case 1:21-md-02989-CMA Document 566-7 Entered on FLSD Docket 06/07/2023 Page 97 of
102
Exhibit 9
Alibaba Group Holding Limited
Daily Bid-Ask Spread
September 19, 2014 to January 28, 2015
Spread as a
Closing
Bid-Ask
Percent of
Date
Price
Bid
Ask
Spread
Closing Price
(1)
(2)
(3)
(4)
(5)
(6)
(4) - (3)
(5) / (2)
1/16/2015
$
96.89
$
96.79
$
96.82
$
0.03
0.03 %
1/20/2015
100.04
100.07
100.08
0.01
0.01
1/21/2015
103.29
103.30
103.31
0.01
0.01
1/22/2015
104.00
103.92
103.93
0.01
0.01
1/23/2015
103.11
103.11
103.13
0.02
0.02
1/26/2015
103.99
103.99
104.00
0.01
0.01
1/27/2015
102.94
102.85
102.88
0.03
0.03
1/28/2015
98.45
98.28
98.30
0.02
0.02
Average Bid-Ask Spread as a Percent of Closing Price
0.028 %
Median Bid-Ask Spread as a Percent of Closing Price
0.023 %
Notes and Sources:
Data obtained from FactSet Research Systems Inc.
Closing bid and ask ADS prices are taken from the NYSE.
Page 3 of 3
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Exhibit 10a
Alibaba Group Holding Limited
One-Day Autocorrelation of Daily Log Returns for ADSs
September 22, 2014 to January 28, 20151
Autocorrelation
in Daily Actual
Window
Log Returns2
t-statistic3
(1)
(2)
(3)
Class Period
September 22, 2014 to January 29, 20151
(0.10)
(1.68) *
Year4
2014
(0.11)
(1.88) *
2015
0.11
0.38
Notes and Sources:
Data obtained from Bloomberg L.P.
1 The Amended Consolidated Complaint dated July 1, 2015 lists the class
period as September 19, 2014 to January 29, 2015. However, since Alibaba's
initial public offering occurred on September 19, 2014, the first trading day for
which daily returns can be calculated is September 22, 2014. Therefore, September
22, 2014 is the first date included in this analysis. Additionally, since the final
disclosure occurs before the market opened on January 29, 2015, January 28, 2015
is taken to be the end of the class period.
2 This is the coefficient of the independent variable in the autocorrelation model.
3 Two stars (**) represent significance at the 5% level, and one star (*) represents
significance at the 10% level.
4 Only days within the class period (September 22, 2014 to January 28, 2015)
are used.
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Exhibit 10b
Alibaba Group Holding Limited
Runs Test for ADSs1
September 22, 2014 to January 28, 20152
Number of
Window
Observations
Runs3
z-statistic4
p-value
(1)
(2)
(3)
(4)
(5)
Class Period
September 22, 2014 to January 28, 20152
89
42
(0.75)
0.456
Year5
2014
71
34
(0.60)
0.551
2015
18
12
0.97
0.331
Notes and Sources:
Data obtained from Bloomberg L.P.
1 A runs test is a non-parametric test whereby the number of sequences of values above and below
the median value of the data set is tabulated and compared against its sampling distribution under
the random walk hypothesis.
2 The Amended Consolidated Complaint dated July 1, 2015 lists the class period as September
19, 2014 to January 29, 2015. However, since Alibaba's initial public offering occurred on September
19, 2014, the first trading day for which daily returns can be calculated is September 22, 2014.
Therefore, September 22, 2014 is the first date included in this analysis. Additionally, since the final
disclosure occurs before the market opened on January 29, 2015, January 28, 2015 is taken to be the
end of the class period.
3 A run is defined as a series of values above or below the median value of the data set.
4 The z-statistic is a test statistic for a test of binomial proportions. It measures the likelihood of
observing results as or more extreme than those actually observed if the data were generated by a
theoretical process with no autocorrelation. Two stars (**) represent significance at the 5% level;
one star (*) represents significance at the 10% level.
5 Only days within the class period (September 22, 2014 to January 28, 2015) are used.
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0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
3.5%
4.0%
4.5%
5.0%
Percent of Daily Option Series Satisfying Put-Call Parity Conditions
Percent Trading Costs on Stock Transaction
Notes and Sources:
Options data obtained from iVolatility. Stock price data obtained from Bloomberg L.P. Interest rate data obtained from the Federal Reserve website.
1 Alibaba options began trading on September 29, 2014.
Exhibit 11a
Alibaba Group Holding Limited
Percent of Daily Options Series in Options Data Sample Satisfying Put-Call Parity Conditions
For a Given Percent Trading Cost on the Stock Transaction
September 29, 20141 - January 28, 2015
Using Only Daily Options Series with Nonzero Bid and Ask Prices
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0.0%
10.0%
20.0%
30.0%
40.0%
50.0%
60.0%
70.0%
80.0%
90.0%
100.0%
0.0%
0.5%
1.0%
1.5%
2.0%
2.5%
3.0%
3.5%
4.0%
4.5%
5.0%
Percent of Daily Option Series Satisfying Put-Call Parity Conditions
Percent Trading Costs on Stock Transaction
Notes and Sources:
Options data obtained from iVolatility. Stock price data obtained from Bloomberg L.P. Interest rate data obtained from the Federal Reserve website.
1 Alibaba options began trading on September 29, 2014.
Exhibit 11b
Alibaba Group Holding Limited
Percent of Daily Options Series in Options Data Sample Satisfying Put-Call Parity Conditions
For a Given Percent Trading Cost on the Stock Transaction
September 29, 20141 - January 28, 2015
Using Only Daily Options Series with Nonzero Bid and Ask Prices and Nonzero Volume
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