China Media Express

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Pacific Asset Management Direct (206) 933-1600 Toll Free (877) 637-2767 Fax (206) 600-3175

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China MediaExpress in a Bind Against Shorts


-- In China's small-cap
cap space, the short
short-attack phenomenon is relatively new, so it is hard
ard to know what the
long-term
term effects will be on individually attacked stocks or on the space as a whole.

China MediaExpress (CCME) is the la latest


test company to be on the receiving end of a series of short-seller
short
attacks. The stock continues to trade with significant volatility on high volume, meaning that there is still a
sizable amount of disagreement between the longs and the shorts.

I have
ave recently heard of investors "betting the farm" (sometimes on margin) on CCME because they "know" it
is legitimate and should seemingly go straight back to $20 or more once it is legitimized. I also have heard
from investors who have been aggressively w writing
riting puts on the stock because they are confident it will go up,
and the option premium they receive looks relatively high.

In my opinion, CCME's future share-price


price performance could face a similar, if not worse, fate than ONP for a
number of reasons. I am not encouragin
encouragingg anyone to sell, but rather I am suggesting that the aggressive risk-
risk
takers who are "betting the farm" and writing put options take a moment to consider the potential downside
risks with CCME.

The purpose of this article is not to attack CCME (that has b been
een done enough already), but rather it is to
highlight the very real downside risk that still exists, even after the share price has fallen by 50%.

I would very much like to see CCME be completely validated. However, for those taking substantial risk
positions,
itions, I feel that investors should be aware of the potential for significant downside, potentially in a single
day, if any negative information is suddenly confirmed by the company or if research analysts change their
views.

While many of the short-sellers'


ers' claims seem to be refutable and without merit, the attack itself could be a self-
self
fulfilling prophecy for the share price. The problems are as follows:

• Problem No. 1:: The burden of proof lies with CCME and not with the short-sellers.
sellers. Short-sellers
Short
deliberately exaggerate their claims and often use dubious evidence to incite maximum panic on the
day of the report's release.

However, in the case of CCME, even if 90% of the information is wrong, that would still make CCME
C a
10% fraud, resulting in a stock price that could potentially trade near cash value, which is around $7 a
share.

The shorts only need to be 10% correct, whereas CCME needs to be 100% correct on all details.
CCME is in the media and advertising busine
business,
ss, and its operations are spread over a wide area,
making it a very difficult company to accurately audit for any auditor, Big 4 or otherwise. And as a
result of the short attacks, the company will now be under the microscope by auditors, investors, law
firms
irms and research analysts.

Pamria, LLC “Pacific Asset Management “ WA State & SEC Registered. SIPC, FDIC through C.S. & Co., Inc.
Pacific Asset Management Direct (206) 933-1600 Toll Free (877) 637-2767 Fax (206) 600-3175
600

• Problem No. 2: Long-term


term damage to the company's business prospects has already been done.
CCME is a media company, and the media industry is notoriously sensitive to any type of bad press or
negative imagery.

One claim by the shorts is that a Baidu search for CCME (in Chinese) yields very few results. That is no
longer the case. Now, a Baidu search results in numerous stories of a company potentially committing
a massive fraud. In the image
image-sensitive advertising business, this has the clear potential to scare off
tier one customers. As in the case of ONP, even if the company is ultimately validated, the smear itself
can result in permanent damage to the business and the share price.

• Problem No. 3 Deloitte is only the auditor un until it is not. Deloitte is a top-quality,
quality, Big 4 auditor, but
the reality is that in a complicated and fairly opaque business like advertising, a standard audit does
not necessarily confirm every minute detail of every piece of revenue and expenses. A standard stand audit
is not a forensic audit.

Deloitte also was the auditor for Duoyuan Printing (DYP) until just before the 2010 10-K
10 was filed
when Deloitte
tte was suddenly "dismissed."

The shares are now down by 70% and trade at a 30% discount to last reported cash on the balance
sheet. I am by no means criticizing Deloitte. The fact is that during the course of 2010, certain things
"changed" at DYP that prevented
evented Deloitte from signing off on the numbers. Just because Deloitte has
signed off on CCME's numbers in the past does not preclude the possibility that "things have changed"
for CCME during 2010, which on paper was very much a standout year.

Problem No. 4 : CCME's response to date has been very weak, and after an initial pop, the share
price has continued to fall. Investors overall are clearly not fully satisfied yet. Unlike ONP, CCME has
not had a conference call to address concerns and has released o only
nly a fairly brief statement stating
that SEC financials should be relied upon and a few other clarifications on its advertising of Apple
products via a local distributor.

The company also contradicted several factual errors in the short


short-sellers' reports. Investors are all still
waiting for a point-by- point rebuttal as well as concrete proof of client relationships, revenue and
cash.

However, it is looking like we may need to wait until the release of the 10
10-K
K in March to get full
information. The risk for
or those who are selling options or trading on margin is that many holders will
not want to bear the risk of holding until after the 10
10-K
K is released, and as a result, the share price
could see a substantial dip even before it hopefully recovers.

It is worth
rth repeating, for the good of the China small
small-cap
cap space, that I would like to see CCME be completely
validated and its share price recover. However, past experiences with short
short-sellers'
sellers' attacks on stocks including
ONP, CVVT, and TSTC have shown that the d damage
amage done can be severe and difficult to reverse, even when
the arguments of the shorts are mostly without merit. For those investors who choose to play CCME, I would
strongly suggest they consider scaling their risk accordingly.

Shawn A. Mesaros, Pacific Asset Management

Pamria, LLC “Pacific Asset Management “ WA State & SEC Registered. SIPC, FDIC through C.S. & Co., Inc.

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