Speaker 1:

From the library of the New York Stock Exchange at the corner of Wall and Broad Streets in New York City, you're inside the ICE House, our podcast from Intercontinental Exchange on markets, leadership, and vision and global business. The dream drivers that have made the NYSE an indispensable institution of global growth for over for 225 years. Each week, we feature stories of those who hatch plans, create jobs, and harness the engine of capitalism. Right here, right now at the NYSE and at ICE's 12 exchanges and six clearing houses around the world. And now welcome inside the ICE House, here's your host, Josh King of Intercontinental Exchange.

Josh King:

I remember it like it was yesterday. The Swedish flag eventually displayed on the facade of the New York Stock Exchange, along with the banner for music streaming service Spotify, which on April 3rd, last year saw its shares publicly traded for the first time through what has become branded as the New York Stock Exchange direct floor listing, a unique mechanism for going public by a company that steadfastly wanted a transparent process, democratizing investing in its shares just as it had brought music to the masses. And after that historic event, we created a special show about what we'd done there, seen and learned through the process, talking with her own John Tuttle, who helped Spotify CEO, Daniel Ek, and his team navigate this uncharted trail from private to public, instead of taking the IPO route that was introduced to the world for the first time in 1602, when the Dutch East India Company went public, offering its shares on the Amsterdam Stock Exchange.

Josh King:

Well, it didn't take long for other pioneers to follow Spotify. A few weeks ago, Slack, that's NYSE ticker symbol work, W-O-R-K, has become the second company to go the route of the direct listing, a successful offering that took place on the floor of the NYSE after co-founder and CEO, Stewart Butterfield, rang the opening bell. We thought it's the perfect time to bring John Tuttle back Inside the ICE House to explain how the direct floor listing process has created a foothold, why the NYSE is the only market that can conduct these complex transactions, and what the future is for the next company looking to tap the public markets without conducting an IPO? Our conversation with John Tuttle right after this.

Speaker 3:

Now a word from Jennifer Tejada, CEO of PagerDuty, NYSE ticker symbol, PD.

Jennifer Tejada:

PagerDuty is a digital operations management platform leveraged by developers, customer support, IT, and security to help ensure the brand experience for their end consumers runs perfectly all the time. Our organization reflects the diversity and the richness of our community. We're really excited about global impact. We chose the NYSE because it's a place where iconic companies are truly born in the company of giants.

Josh King:

Our guest today, John Tuttle, is the New York Stock Exchange's Vice Chairman and Chief Commercial Officer. John leads the exchanges global listings, capital market, and exchange traded products businesses, and is responsible for managing the Exchange's relationships with more than 2300 NYSE listed companies, and with the investment banking, private equity, venture capital and legal communities. In addition, he leads the NYSE's business development efforts for IPOs, direct listings, exchange traded funds, structured products, closed end funds, and REITs listing on the NYSE's family of exchanges. John, welcome back to Inside the ICE House.

John Tuttle:

It's great to be back Inside the ICE House.

Josh King:

It's good to have you back to dive into the direct listing process. Did you expect it would take another year for a direct listing to happen here?

John Tuttle:

We did. Many people said the Spotify listing was a one off and that there was a certain profile of company that could actually follow that path that Spotify did. And the first company that really felt like it was their time to come to market and that they could use the new innovative direct floor listing path was Slack. And that was just over a year after Spotify made its initial debut to the marketplace. That said, we look out into the pipeline of companies that are considering it. It's a deeper pipeline. It's a broader pipeline. While we've seen two so far, I think we'll see more.

Josh King:

Characterize that period after Spotify's direct listing, your conversations with entrepreneurs and business founders dipping their toe into the direct listing water. Was it like Goldilocks just looking for the right temperature?

John Tuttle:

Well, we got a lot of inquiries following Spotify's direct floor listing, and it was from companies that would have fit that profile that we've talked about before, where they have a brand name. They don't need capital at the time of their listing, but they want the other benefits of being a publicly traded company. And it's from smaller companies and even international companies that were at minimum intrigued by the new process and wanted to see how it could work for them. In the period following the Spotify listing, we shared the information that we learned from helping pioneer this process, helped educate those companies on how it could be applicable to their scenario and help them meet their objectives as they considered coming to the public markets. And we've been in constant dialogue with many of those companies since that time.

Josh King:

Through our conversation today, John, I want to dip into some commentary from Daniel Ek who spoke with Recode's Kara Swisher and Peter Kafka about the three reasons they used to pursue the direct listing. We're going to dip in to this conversation throughout our conversation today. And here is reason one from Daniel Ek.

Daniel Ek:

One was about transparency. One thing about the traditional process which was done in the 1970s is obviously the world has changed a lot, but it just didn't sit well with me to put out this document in this day and era when information is like this, and you can't comment on it, you can't say anything about it.

Josh King:

The document Daniel is referring to is the S1 that's used with the investment banks and to create the road show and it is available, but instead Daniel went up on stage and basically did an investor conference for everyone to watch. Transparency that was important to Spotify.

John Tuttle:

Well, transparency is important to Spotify, and it's very important to us. It's one of the reasons why the New York Stock Exchange and the US capital markets more broadly are the envy of the world, the transparency that we bring to the public markets, to companies, to investors. We're directly in line with Daniel on that point. And in the direct listing process, what's unique about it is that yes, a company like Spotify or Slack puts out its registration documents to the world, but then they also have the opportunity to host an investor day. It's open to everybody. In a traditional IPO, which again, works well for a certain profile of companies, a company will go on its road show and have many one-on-one meetings with institutional investors.

John Tuttle:

And in some cases, some retail investors, but primarily institutional investors. This was an opportunity with Spotify then with Slack, and with the direct listing to come down the pipe, for the masses to participate in this transaction, to really understand the company, have an opportunity to participate in the transaction on the day of the listing, and to have all the information that any other person in the marketplace would have on the company.

Josh King:

Let's unpack the process of the direct listing. Where did the idea come from originally and how does the lead up to listing day differ for a direct floor listing compared to a traditional road show?

John Tuttle:

That's a great question. And we're constantly thinking about how our offering can evolve to meet the demands of the marketplace and to help companies achieve their objectives as they go to market. And one of our conversations years ago with Spotify and their management team who thinks forward, they think independently, they think differently. They said, you know what? We don't need the capital at the time of our IPO. And we want to see if there's another process. We don't want to follow the path that everybody else has. Maybe there's something better for us. We rolled up our sleeves and we got to work. And we said, look, there are companies in the past that have come to market without a capital race. Think of a public company spinning off part of their business into a new publicly traded entity, think of a company emerging from the OTC markets or emerging from bankruptcy onto a national exchange and allowing their public equity to be traded on a national exchange, but not having a capital race tied to that moment.

John Tuttle:

But we said, we've never seen it with this profile of company, but we think we can do it. And we think we're uniquely positioned to do it as well because we have, again, a very transparent process here at the exchange. The way we bring companies to market, the way we open stocks is very open, transparent, and it involves human beings interacting with increasingly sophisticated technology to bring about better outcomes and better market quality and a better experience for our issuers and for investors. We rolled up our sleeves. We made the changes we needed to do to create this new pathway to the market get place. And now it seems like we've created a new product.

Josh King:

What actual work needed to happen when you rolled up the sleeves? Changing rules, changing processes. Was the name of a direct listing something that came from this building, or tell us about just the inception.

John Tuttle:

Yeah. All of the above actually. There had to be some small rule changes made with the SEC to allow this process to happen. We embarked on that journey. People needed to understand what a direct listing was, so there was an educational component of it as well to the marketplace, to investors that are out there, to companies that are out there, to all the folks that would be participating in this transaction. And I think one of the most important changes or developments that happen from your traditional IPO process was that because there was no underwritten offering, because there was no investment bank or underwriters out there allocating or placing shares with investors, we needed to make sure that there would be liquidity and diversification on the day of the listing.

John Tuttle:

Many of the backers of Spotify and of Slack and of the other companies who are considering this path, whether they be DECA unicorns or companies from different sectors or geographies, is that the current owners of the companies, while very sophisticated investors, do not necessarily have as much experience on the trading side. Educating them about the importance of the opening auction on the NYSE, of lay airing their interest, their order interest to ensure that there is a nice, fair and orderly debut for the company. It was a big task for many.

Josh King:

Let's take us back to that morning, just a couple weeks ago, of Slack's listing and this conversation on the steps of Federal Hall, right across the New York Stock Exchange, where CNBC's Andrew Ross Sorkin interviewed Slack's CEO, Stewart Butterfield.

Andrew Ross Sorkin:

Long term, though, the other piece of this is sometimes there's a view that the company will do a listing and then do a secondary, which actually looks like an IPO later.

Stewart Butterfield:

Yeah, that's certainly possible for us. I think one of the things about being public is it opens up capital markets generally. Not just equity, but debt, converts, all kinds of stuff.

Josh King:

That interview with Butterfield occurred before shares even began trading on the NYSE, but Stewart was already focused on some of the potential advantages of being a public company. In the end, regardless of the vehicle IPO or direct listing or even a SPAC, it's more the destination after that day here than the journey to this point.

John Tuttle:

That's exactly right. And Stewart cited a word that we cite often and that's access. This is access to capital. In an IPO, you have access to capital, but you're raising it at the time of your listing. In a direct listing, you have access to capital, but that access could come later on down the road and in a different way as well. Maybe I'll take a step back and talk a little bit about the differences between an IPO and some of the other opportunities that a direct listing layers on top of that.

John Tuttle:

Why does a company IPO? They do it for several reasons, to raise capital that they can ultimately use to grow and expand their businesses. What that means to launch a new product, tap into a new geography, create jobs, and improve quality of life around the world, or even return capital to investors to allow them to participate and invest in the next great wave of innovative companies. Number two is they have a share currency for M&A. If they want to grow and expand their business, they don't have to use cash to do it. They can use combination of cash, stock, or maybe even entirely stock. They have a new tool in their arsenal. They want visibility. It's a huge branding opportunity for many companies, IPO-ing. On an average day, the bell ceremony at the New York Stock Exchange is the most highly viewed daily news event in the world.

John Tuttle:

That coupled with the entire suite of marketing and visibility assets that we deploy for these companies is great for their business. And the last piece of it is, this is an opportunity to create an equity incentive for their employees, to be able to make their employees, owners of the company, to allow them to buy and sell the shares as well, and not have to wait till these incremental tender periods that you have in the private markets. Now, what does a direct listing to ring on top of that? It brings you access to capital. You are now a publicly traded company. You can do as Stewart mentioned, a follow on offering, 180 days down the road at a much lower cost of capital to the company. Think about it, your traditional tech IPO pop or your IPO pop for a technology company is roughly 30 to 40%. Just around the same time that Slack came to market, we had a technology company here that raised over a billion dollars and on the day of their listing, the stock popped 70%.

John Tuttle:

That's 700 million that the company could have captured to use to grow and expand their business. And the original investors in the company gave up. There's no capital raise in a direct listing at the time. Number two, there's no dilution. You're not necessarily issuing new shares, so you're not diluting your current shareholders. And number three, and what was appealing to Stewart and others that are considering this path is that there's no lockup period, or in the last two, there has not been a lockup period, which means you don't have employees waiting until 180 days or investors or insiders waiting until 180 days to be able to come to market, sell their shares. There's access. All of the shares are public. The public can participate. Employees can participate. There's no artificial deadlines out there that could create market dislocations that don't necessarily have to be there. With the direct listing, again, not applicable for everybody, but you get a lot of the benefits of an IPO, plus those other benefits that I just mentioned, the no capital raise or raising capital later on at a lower cost of capital, no dilution, and no lockup period.

Josh King:

If we were watching on the day that Slack did its direct listing as sideline reporters covering the action, the price discovery process played out in real time on the floor, much as any other listing would, John. The night before we had our eyes glued to our computer screens, waiting for the NYSE to announce the reference price for Slack's direct listing, which ended up being $26 a share. Without the book building process, how is the reference price set?

John Tuttle:

Now it's a really good question. And I'm glad we're shifting into the mechanics of how a direct listing works, because it's something that the NYSE is uniquely qualified to do. To your point, the night before, the New York Stock Exchange is tasked with, in consultation with a company's financial advisor, coming up with a reference price. This to be clear is very different than an IPO price. In an IPO shares our trading hands. A transaction is taking place. In a direct floor listing when we establish the reference price, no shares are trading hands, but it gives the market a sense of where we can start building a book on the morning of the listing. And now, even from a technical standpoint, the reference price is important because many brokerage systems, many companies who accept orders on behalf of customers, require an input there. Usually it's an IPO price, but in this case it's a reference price.

John Tuttle:

And part of the responsibility of the exchange is to look at whether the company has had private market trading activity. Look at the volume weighted average price. Look at the last price there. Consult with a financial advisor. Or in a case where there hasn't been private market trading, work to identify what the appropriate price would be, whether through an independent valuation or other means of establishing the reference price. That's what we do the night before. We disseminate that out to the world. It's very public, very transparent. And the next morning at 9:30 AM, the market opens and the price discovery process really starts beginning in earnest. And that's where you see a lot of the activity, the action on the floor, where it took three hours to open Spotify. It took three hours to open Slack, but that's what we want to do. We don't want to rush that open. We want to make sure we have a transparent, orderly, and fair price discovery process. And that's what you saw take place on the floor those mornings.

Josh King:

Yeah. On that morning, when watching that $26 a share starting on the left side of the screen, Peter Giacchi position at Citadel Securities, where the stock was going to be opened, I'm sitting there in the back of the crowd. The media is able to watch the process unfold in real time on the trading floor. I want to go back to that day. Just take a listen to how Bob Pisani wrapped up the action.

Speaker 8:

We're going to watch Slack here as well, set to make its debut at the NYSE. Our Bob Pisani is inside post five with all the latest. Morning again, Bob.

Bob Pisani:

And we've got a new range here, 33 to 36. Joe Mecane, Head of Execution at Citadel Securities. Are we closer?

Joe Mecane:

We're getting closer. It moved up a little since we spoke a few minutes ago. We re-indicated the range 33 to $36, and it's about 10 to 15 million shares in that range that are pairing off. And it narrowed to $3 from $4. I think it's shaping up.

Josh King:

From $26 on the reference price to 33 to $36 in the new range. That was just the audio, John. Visuals of the trading floor with traders clothed in their colorful jackets and their screens glowing with the company logos, the drive, the global economy, they make for a spectacular backdrop to the hours of reporting of Slack's pricing process. But what is actually happening in the booth, that conversation with Pisani and Citadel, on the floor were humans and technology collide?

John Tuttle:

Yeah, it was quite a morning. You don't see anything like that. This is truly something special and something that can only happen at the New York Stock Exchange. What you saw happening was Peter Giacchi, who was the designated market maker that both Slack and Spotify selected to help them with their direct floor listing is there, building the order book, working with brokers, working with Spotify and Slack's financial advisors to bring order flow in and transparently communicate to the market, the indications of where the stock's going to open. And by communicating that, bringing in more order flow, and being able to tighten that range and having this very iterative and transparent process until we were able to open the stock almost three hours later.

John Tuttle:

And what's really important to underscore is that Peter's role or the role of the designated market maker in general is critical to the success of a direct listing. In an IPO, you have a lot of other parties and a lot of other capital being used to help bring a company to market. You have an underwriter. You have a stabilization agent. You don't have that in a direct floor listing. This is what the New York Stock Exchange is purpose built to do. We're executing complex transactions and helping companies meet their objectives, whether that's a complex large IPO, whether it's a carve out or a spinoff of an existing listed company, or whether it's a direct floor listing, it's the transparency and it's the interaction that takes place on our trading floor that helps ensure a fair and orderly entrance to the market for these companies.

Josh King:

Now let's go back to that conversation that we alluded to earlier with Spotify CEO, Daniel Ek, and the second reason he chose the direct listing route for his company.

Daniel Ek:

The second thing was when you really think about it, the whole process obviously openly supposed to be so that everyone has the same amount of information. Yeah. What actually happens in practice is you do this quiet road show and give some people a little bit more information, and then you open the doors and you hope that those people will then hold your stock. And I didn't want to do that. I wanted everyone to have exactly the same information.

Josh King:

John Tuttle, Daniel didn't want a road show. And I got to say, there's some chat are out there that the bankers don't like the NYSE direct floor listing for the reason that Daniel hinted at, but is that what you're hearing in your conversations?

John Tuttle:

Look, I'll just be very transparent because that's what we stand for here at this place, is that at the beginning, when we were coming up with this concept of the direct floor listing, there was not a lot of interest in disrupting the model, but over time, as we started thinking and as we started communicating with each other, people came on board because they realized that this is where the puck may be going at least for some companies. And so it's changed. The philosophy has changed. At first, there is resistance, but now there's acceptance and a willingness to really participate. And the banks in many cases are in the same boat as us. They want to ensure what's in the best interest of their clients and to help them get there. And so you've seen the banks come on board with this and realize there's an opportunity to help companies achieve their objectives.

Josh King:

The conversation with Bob Pisani and Citadel that we've played earlier, that was from about 11:00 AM. You mentioned the long period of time that it ultimately took to open Slack stock. At 12:08 PM, the wait was over and the stock opened at $38.50 a share on 45.5 million shares. And that opening cross was a 1.8 billion trade. How does that compare to Spotify's direct listing and past IPOs.

John Tuttle:

Josh, it was a beautiful opening. I'll be honest with you, that was a beautiful opening day of a stock. That was a nearly 1.8 billion dollar transaction, the opening trade in Slack, and that made it the third largest opening rate of all time, only behind Alibaba and Facebook. Now, Spotify was also a very large trade, almost a billion dollars, and that put it at number six. And so these are very visible, very important, but very orderly transactions that take place. And going back to Slack's listing, it opened at 38.50 to your point. It closed at 38.62. It was smooth trading the entire day and afterward. It was a beautiful entrance to the marketplace and it caused a lot of skeptics of the direct floor listing to start scratching their head and wanting to learn more.

Josh King:

That first huge trade occurred. Stewart's mother rang the first trade bell, but trading continued under the watchful eye of the DMM throughout the day and closed in the way that you said. But in some ways these are historic moments when a CEO's mother is there to rap the opening bell, but almost wasn't planned that way.

John Tuttle:

That's right. And just two points I would make. First is that there was no stabilization agent, so that was the DMM there supporting that stock and helping ensure smooth and orderly trading throughout the day, which is very good for bringing on investor confidence. But to your other point about it being a monumental moment, so for our two direct floor listings that have taken place, the first one, Pete Giacchi's mother was down on the floor. And for the second one Stewart Butterfield's mother's on the floor.

Josh King:

As we get to our halfway point in our conversation, John, both Spotify and Slack had successful direct floor listings, but what were some of the fears around direct floor listing mechanism? And how has the NYSE's market model been able to waylay some of those concerns that people might have had going into this?

John Tuttle:

I think the primary fear that we heard from many market participants prior to the first direct floor listing, and even prior to the second direct floor listing was, would this be very volatile? There was no obligation to participate in the opening auction. There was no stabilization agent exercising the green shoe or an over allotment option. And those are real fears and understandable fears. But what we realized during those transactions is the in critical role that the designated market maker plays. And it's unique to the NYSE. The designated market maker has a regulatory obligation to be on the bid and the offer of that company's shares at all times. He or she cannot step away.

John Tuttle:

They have to have layered interest in the order book to dampen volatility as the stock moves up and down. Look, the stock is always going to find its natural price. It's just like, we're on the sixth floor inside the ICE House right now, if we want to get down a street level, we can jump out the window or we can take a flight of stairs down. We're ending up in the same place, but it's a very different experience. But investors care about that. And because of those regulatory obligations that the designated market maker has, and that are unique to the NYSE, we helped ensure fair and orderly trading in those companies shares.

Josh King:

After the break, John and I turn our attention to the attention that the Slack list thing garnered from Wall Street and private companies looking to access the NYSE's liquidity from across the globe. That's right after this.

Speaker 3:

And now a word from Charles Harrington, Chairman and CEO of Parsons, NYSE ticker, PSN.

Charles Harrington:

We offer technology, digitally enabled solutions to the defense, intelligence, and critical security markets. We see a lot of growth and opportunity in cyber and intelligence and geospatial intelligence, as well as solving network problems for critical infrastructure. It feels great for Parsons to be a newly traded public company once again. When I joined a company in 1982, we were publicly traded on the New York Stock Exchange. And here we are, 35 years later, publicly traded once again.

Josh King:

Welcome back. Before the break, John Tuttle the New York Stock Exchange's Vice Chairman and Chief Commercial Officer gave us the play by play of Slack's recent direct listing and how the mechanism of this uniquely NYSE model for going public actually works. And I want to return, John, as we come back now, one more time to that conversation with Spotify's CEO, Daniel Ek, for his third reason for pursuing a direct listing for his company's shares.

Daniel Ek:

Certainly more importantly, as part of this, I didn't want to put anyone in a different boat. Most often what happens is that the investors gets to sell early on. The employees do not. I did not want that at all. I wanted everyone to have the same opportunity to sell or buy, by the way, day one.

Josh King:

The same opportunity to sell or buy on day one. Do we lose anything when we don't have these lockup periods?

John Tuttle:

Every company's different. Every transaction's different. Market conditions are different. Profiles of investors in these companies are different. But what we've seen is by not having a lockup period and allowing all the shares to float, not just a very small section of the company, not locking up insiders or employees, that 180 days down the road, you're not having employees looking at some quasi-artificial deadline that's just been put in place and watching the stock and hoping that they can sell the next day. They're focused on running the business. They're shareholders. They have liquidity, but they're focused on running the business. And that's one of the benefits of not having that lockup period.

Josh King:

Beyond the three reasons that Daniel has highlighted and what we've been listening to, one, transparency, two, no road show three, no lockups. What are other reasons that come up in your conversations with CEOs about why a direct listing might make sense for them?

John Tuttle:

Well, certainly those three reasons, and of course the opportunity to not have dilution for existing investors, but then of course, the other benefits of being a publicly traded company are discussed far further down the list is fees. You read articles saying this is a much more cost effective way for companies to come to market. That makes good headlines. It can be correct, but every deal's different. The advisors the company chooses are different. Now, if you look at the economics of an IPO versus a direct listing, they are different. Let me break it down a little bit. On an IPO, your underwriters are traditionally paid a percentage of the amount they're underwriting. Historically, it's been around 7%. For the larger transactions you get down, it can be negotiated down into the low single digits as well.

John Tuttle:

In a direct floor listing because there is no underwritten offering, there's no fee to collect from there. Instead, the bankers collect an advisory fee. Now on a traditional IPO, particularly a large high profile IPO, there may be 20 banks on the cover of a company's registration statement, so their S1 or their F1. In a direct floor listing, what we've seen is far fewer banks listed. In fact, in Spotify's, there is three on there. They're paid an advisory fee.

Josh King:

Given all of that, the listing day is exciting for both the new public company and all of us at the exchange, but by the afternoon of June 20th, Slack's executives were back in California, hosting a customer event, and you were back in your office. Does it help to have evangelists like Daniel Ek and Stewart Butterfield making the rounds of Silicon Valley, talking up the experience of the direct floor listing. And also there's this community of CFOs people like Barry McCarthy and Allen Shim who are so instrumental in the process.

John Tuttle:

These executives, these leaders of Spotify, Slack, and other companies that are considering this route are taking a path that is not well worn. And they're taking a risk and we are there to help support them achieve their objectives. And so when they're back out there telling people that we partnered with them to help them achieve their objectives, as they position their company for success, as they position their employees and their customers for success, that's what we really love to hear.

Josh King:

Despite this validation from people like Barry McCarthy and Allen Shim, the truth is honestly that this process isn't for everyone. When you're talking to a founder or investor interested in pursuing a direct floor listing, what is your advice to them?

John Tuttle:

My advice to them is be clear about your objectives of going public. Why are you going public? Do you need that capital at the time of the IPO? Are you okay with having a slightly different investor base than you would get on a traditional IPO allocation process? Are you comfortable with a little bit more ambiguity? Because there are no obligations to participate in opening auctions or have the certainty and support of a stabilization agent there. And many of these folks, they got to where they are because they're very thoughtful and they're independent thinkers, and we're going to work with them if this is the path they choose to go down.

Josh King:

John Tuttle, a lot happening at the NYSE today. Thanks so much for joining us inside the ICE House.

John Tuttle:

Thank you, Josh.

Josh King:

That's our conversation for this week. Our guest was John Tuttle, the New York Stock Exchange's Vice Chairman and Chief Commercial Officer. If you like, what you heard, please rate us on iTunes, so other folks know where to find us. And if you've got a comment or a question you'd like one of our experts to tackle on a future show, email us at [email protected] or [inaudible 00:30:53] ICE House podcast. Our show is produced by Pete Asch and Teresa [inaudible 00:30:58] with production assistance from Stephen Romancik and Ian [inaudible 00:31:01]. I'm Josh king, your host signing off from the library of the New York Stock Exchange. Thanks for listening. Talk to you next week

Speaker 13:

The information in contained in this podcast was obtained in part by publicly available sources [inaudible 00:31:17]