Opaleye Management Inc.

Allegations: AN ADMINISTRATIVE COMPLAINT WAS BROUGHT ON MARCH 9, 2011 AGAINST JAMES A. SILVERMAN, RISK REWARD CAPITAL MANAGEMENT CORP., RRC MANAGEMENT, LLC AND RRC BIO FUND, LP ("RESPONDENTS") BY THE ENFORCEMENT SECTION OF THE MASSACHUSETTS SECURITIES DIVISION OF THE OFFICE OF THE SECRETARY OF THE COMMONWEALTH ("DIVISION"). THESE ENTITIES ARE NOW KNOWN AS OPALEYE MANAGEMENT INC., OPALEYE GP LLC AND OPALEYE, L.P. RESPECTIVELY. IN THE COMPLAINT, THE DIVISION ALLEGED A LACK OF PROCEDURES REGARDING MATERIAL NON-PUBLIC INFORMATION AND NON-COMPLIANCE WITH RESPECT TO MAINTENANCE OF BOOKS AND RECORDS. ON SEPTEMBER 24, 2014, THE PARTIES ENTERED INTO A CONSENT ORDER WHEREIN THEY AGREED TO SETTLE THE MATTER. RESPONDENTS NEITHER ADMITTED NOR DENIED THE ALLEGATIONS CONTAINED IN THE ORIGINAL COMPLAINT. Status: Final Sanction Detail: RESPONDENTS JOINTLY AND SEVERALLY PAID A FINE OF $50,000 ON OCTOBER 1, 2014. Summary: ON SEPTEMBER 24, 2014 , OPALEYE MANAGEMENT INC., OPALEYE GP LLC AND OPALEYE, L.P. ENTERED INTO A CONSENT ORDER ("ORDER") WHEREIN THEY AGREED TO SETTLE THIS MATTER. RESPONDENTS NEITHER ADMITTED NOR DENIED THE ALLEGATIONS CONTAINED IN THE ORIGINAL COMPLAINT. THE ORDER REQUIRED RESPONDENTS TO COMPLY WITH 203(A) AND 203A OF THE MASSACHUSETTS ACT AND MASSACHUSETTTS REGULATIONS, THAT RESPONDENTS VERIFY THAT BETWEEN OCTOBER 29, 2011 AND OCTOBER 29, 2013 THAT RESPONDENTS DID NOT USE ANY MATCHING OR EXPERT NETWORK SERVICES AND THAT THE RESPONDENTS PAY A FINE OF $50,000. THE ORDER DID NOT CONTAIN OR CONSTITUTE ANY LEGAL OR FACTUAL FINDINGS OR CONCLUSION, INCLUDING WITHOUT LIMITATION, ANY FINDING OF ANY VIOLATION OR LAW OR REGULATION THAT PROHIBITS FRAUDULENT, MANIPULATIVE OR DECEPTIVE CONDUCT AND PROVIDES NO STATUTORY DISQUALIFICATION.