CONCLUSION

After needing a full week to prepare answers to the most basic questions about its business, we believe that 

Minzhong?s response is not only inadequate, but that it also raises a host of additional red flags which further 

corroborate our underlying thesis. 

In an effort to distract the market, the Company has falsely accused us of acting mischievously and recklessly 

without due regard for the accuracy of our statements. The Company has also falsely accused us of seeking to cause 

panic and impose maximum damage on the price of the Company?s stock. We reject all of these libelous 

accusations. 

As the Company acknowledges, we are entitled to voice our opinions regarding the published results and 

performance of the Company. Our opinions of what we believe to be the true value of the Company?s shares are

based upon our analysis and due diligence. Our opinions regarding the Company are a matter of public interest, and 

publication of our opinions is justified due to the fact that investors and the capital markets are connected in a 

common interest in determining the true value of the Company and its stock price. The Company disagrees with 

our interpretation of the publicly available information, and has its own views, which are based upon its own 

information, none of which was available to us (or to anyone in the investing public). 

We have disclosed the fact that we have a short interest in the securities of the Company and stand to realize gain in 

the event that the price of the securities falls ? however, that does not in any way undermine the good faith belief in 

our opinions, nor does it support the Company?s accusation that we are trying to harm the Company or its 

shareholders. 

We did not and cannot cause investors to buy or sell shares of Minzhong. We can only express our investment 

thesis and discuss the evidence upon which we base our opinions and conclusions. We have not used any false or 

misleading language, or wrongful characterization of information that was available to us, and we believe our 

comments were entirely fair. Investors must decide for themselves if what they believe to be the true value of 

Minzhong?s shares. 

However, it bears repeating that in reviewing the Company?s response, this rebuttal and our original report, market 

participants would be well served to remember that while we rely on publicly available documents which are 

verifiable and are generated by or submitted to independent third parties such as government offices, Minzhong is 

simply relying either on non-public records or documents generated by the Company ? none of which can be 

independently verified by any investor. 

Ultimately, based on the preponderance of the available evidence, we continue to believe that the most plausible 

interpretation of the facts and documentation available in the public domain is that the Company is a fraction 

of its reported size and profitability and that it has made materially false and misleading statements to the 

public in connection with its IPO and subsequent public market activities. (Source: Glaucus Research Group)