Antipodean Advisors Llc

Allegations: THE REGULATORY ACTION RELATED TO A VIOLATION OF RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. RULE 105 GENERALLY PROHIBITS BUYING AN EQUITY SECURITY IN A SECONDARY PUBLIC OFFERING IF THE BUYER SOLD SHORT THE SAME SECURITY DURING A RESTRICTED PERIOD (GENERALLY DEFINED AS FIVE BUSINESS DAYS BEFORE THE PRICING OF THE OFFERING), REGARDLESS OF WHETHER ANY INTENT TO VIOLATE THE RULE EXISTED. Status: Final Sanction Detail: THE CIVIL PENALTY OF $65,000, DISGORGEMENT OF $27,970 AND PREJUDGEMENT INTEREST OF $702.83 WERE PAID TO THE UNITED STATES TREASURY ON SEPTEMBER 22, 2014. Summary: ON OR ABOUT SEPTEMBER 16, 2014, ANTIPODEAN AGREED, WITHOUT ADMITTING OR DENYING ANY ALLEGATIONS, TO A SETTLEMENT WITH THE SEC RELATING TO RULE 105 OF REGULATION M UNDER THE SECURITIES EXCHANGE ACT OF 1934. RULE 105 GENERALLY PROHIBITS BUYING AN EQUITY SECURITY IN A SECONDARY PUBLIC OFFERING IF THE BUYER SOLD SHORT THE SAME SECURITY DURING A RESTRICTED PERIOD. THIS PROHIBITION CONTAINED IN RULE 105 OF REGULATION M APPLIES REGARDLESS OF WHETHER ANY INTENT TO VIOLATE THE RULE EXISTED. ANTIPODEAN AGREED NOT TO VIOLATE RULE 105 IN THE FUTURE AND PAY DISGORGEMENT OF $27,970, PREJUDGMENT INTEREST OF $702.83, AND A CIVIL MONEY PENALTY IN THE AMOUNT OF $65,000 TO THE UNITED STATES TREASURY. SUCH PAYMENTS WERE MADE ON SEPTEMBER 22, 2014. ANTIPODEAN DOMESTIC PARTNERS, LP, THE ENTITY THAT EFFECTED THE TRADING IN QUESTION AND RECEIVED THE APPLICABLE PROFIT, PAID THE DISGORGEMENT PORTION. ANTIPODEAN ADVISORS LLC PAID THE CIVIL PENALTY AND PREJUDGMENT INTEREST