Tag Archives: CFTC

Shadow of Truth: An Age Of Deception And Fraud

If you tell a lie big enough and keep repeating it, people will eventually come to believe it. The lie can be maintained only for such time as the State can shield the people from the political, economic and/or military consequences of the lie. It thus becomes vitally important for the State to use all of its powers to repress dissent, for the truth is the mortal enemy of the lie, and thus by extension, the truth is the greatest enemy of the State.  – Joseph Geobbels,  Hitler’s Minister of Public Enlightenment and Propaganda

Put it on CNN and it’s true.  Perhaps one of the most baffling aspects of our system is the extreme dichotomy between perception and reality.  Anything reported by one of the major mainstream news sources is gobbled up and accepted as the truth by a majority of Americans.

Dr. Paul Craig Roberts wrote a brief commentary which describes how news reporting is used to control our perceptions in order to ensure the public acceptance of the Government’s agenda:  “Liberalism has helped to make Western people blind by creating the belief that noble intentions are more prevalent than corrupt intentions. This false belief blinds people to the roles played by deception and coercion in governing. Consequently, the true facts are not perceived and governments can pursue hidden agendas by manipulating news” – PCR, How They Brainwash Us.

The problem is, once you “see” the truth underlying the thick systemic facade of fraud and deception, you can’t “unsee it.”  The monthly non-farm payroll report will be released on Friday.  Every month market participants guzzle Maalox and sit on the edge of their seat in anticipation of the headline news release.  It seems beyond silly that the financial world spends an entire day discussing and analyzing the employment report, which is fictitious in its entirety.   Hell, the Government releases two different statistical versions of the employment report.  Which one is it – the Household Survey or the Payroll Survey?

It doesn’t really matter because once the unemployment rate metric hits the tape, that IS the number.  The truth is that the real unemployment rate is well over 20%.  But when everyone discusses The Number, they use the reported number which is currently 5%.  The process of reporting the monthly employment situation is extreme absurdity in its entirety.

In the Shadow of Truth’s latest “Market Update,”  we focus on the gold and silver market – or the fraudulent paper version thereof.  Like the monthly employment report, most market analysts base their assessment of the gold and silver market on the weekly Commitment of Traders report.  Of course, it makes no difference that the data in the report is already three days old by the time the report is released.  Neither does anyone seem to care that data in the report is compiled and submitted by three of the most corrupt banks in the world.  Another interesting misconception is the use of the gold/silver prices on Kitco as the “spot price.”  But that’s a fabrication as well…

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Is Gold Now Set-Up For A Move Higher?

There’s just too many loud voices – plus self-promoting self-aggrandizers like Harry Dent – screaming for $800 gold.  Last time Goldman came out with an $800 gold target, gold ran from $1100 up to $1400.    Will these carnival barkers be right this time around?  I don’t know.  As Bernanke famously said, the Fed (banks) have new technology that enables them to create electronic dollars (Comex paper contracts) in unlimited quantities in order to direct the market in the direction of their command.

Of course, we all are left wondering why Bernanke ended his Fed chairmanship a few terms earlier than he needed to and decided to not stick around to face the consequences of his actions while he was pressing the print button on his keypad.

But I digress.  As for $800 gold?  It might have to wait.  The bullion banks have quietly shifted their trading book to a net long position.   And, in wash-rinse-repeat fashion, the hedge funds and the small retail traders have taking the other side of this and have gone net short Comex gold – significantly net short Comex gold:  (click image to enlarge)

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It is very rare for the hedge funds to run a net short position. Since the CFCT/CME began disaggregating the COT report into more trading “buckets,” the hedge funds have only been net short on on two occassions – now and in July/August earlier this year.  Gold staged an 11% move in August.

In the close to 15 years that I’ve been involved in the precious metals markets, when the bullion banks take extreme positions – either long or short – remarkably the market always seems to move in their favor.  Funny thing – that – because the law of averages would suggest a remote probability of this event occurring with 100% certainty.  We know the CFTC has never seemed to be able to find any indications of malfeasance or market manipulation – wink, wink.

Currently the hedge funds have their second largest net short position in the history of COT reporting.  Back in early August the net short hit a little over 14k contracts.   This explains the erratic trading in gold this past few weeks.  I would also be willing to wager that the hedge funds will show their largest net short position ever when the COT report is released.

Oh ya.  There was one other time when the hedge funds – labelled as “Large Speculators” prior to 2006 – were net short, and it was only for a couple days:   early 2000 right before the bull market in gold was launched.

The Credibility Of Andrew Maguire

Andrew Maguire has been a controversial figure in the gold/silver world ever since he blew the whistle on JP Morgan’s silver manipulation.  The information provided by Maguire to GATA was presented by GATA’s Bill Murphy at a hearing held by the CFTC on the precious metals market manipulation in March 2010.  Maguire had originally sent an email to someone in the CFTC enforcement which detailed how the precious metals would be attacked two days later when the non-farm payroll report was released.  Maguire wrote to the CFTC after the attack:

It is common knowledge here in London among the metals traders that it is JPM’s intent to flush out and cover as many shorts as possible prior to any discussion in March about position limits. I feel sorry for all those not in this loop. A serious amount of money was made and lost today and in my opinion as a result of the CFTC’s allowing by your own definition an illegal concentrated and manipulative position to continue.

GATA has detailed the entire event in this article:  LINK.

After Bill Murphy’s testimony at the CFTC’s hearing, Jeffrey Christian – a known shill for the bullion banks – publicly slashed and burned Maguire’s reputation with highly slanderous assertions about Maguire’s background and experience.  Christian’s remarks were intentionally deceitful, but the damage was done. The fraudulent attack on Maguire opened the door of doubt in the minds of many about the credibility of market intel delivered by Maguire to the public via venues like Eric King’s King World News.

I bring this up because a friend and colleague of mine – someone who has been around the precious metals sector longer than me, sent email to a myself and one other person asking for our thoughts on Maguire’s latest interview in King World News:  A Historic Event Is About To Shock The Gold Market

The interview is worth a listen and I believe there’s a high probability that Maguire’s insight and assertions are accurate.  Having said that, I wanted to share my response to the email, because it explains why I think Maguire’s intel is good.  The first part of my response references some comments made to my colleague from someone who expressed concern about the potential for Russia and China to unload gold like Venezuela did in order to avoid financial trouble:

Goldman has been working on getting Venezuela separated from its gold for over a year. Recall about a year ago that Goldman sent VZ a proposal for a leasing transaction. VZ was an easy prey. In my opinion, the way that VZ has been squeezed out of its gold tells us just how desperate the bullion banks are to source real physical gold. This move was analogous to taking Halloween candy from a little kid. But China/Russia are a different matter.

Russia running into financial trouble? Please show me any evidence of that OUTSIDE of western propaganda reports.  Russia continues to add a lot of gold to its Central Bank position every month. It that the behavior of an entity worried about liquidity? Have you looked at Russia’s debt/GDP ratio? As of 2014, the latest data available, Russia’s debt/GDP is 13%.  Russia is not in financial trouble. The western media wants us to believe that Russia is in financial trouble.

China? C’mon. China has $3.4 trillion in diversified FX reserves that needs to be netted against is sovereign debt position. China’s outright sovereign debt/GDP is 41% as of 2014. The number does not net out FX reserves.

As of July China’s household/corporate debt was 280% of GDP. The U.S. total debt (Govt + private sector) is 340% of GDP. The highest of any country in the world. US FX reserves are about $35 billion – i.e. nothing. Does the U.S. even have title to any gold that we use to add to its FX reserves? Doubtful. If any country is in danger of going insolvent, it’s the U.S if the rest of the world refuses to take any more paper dollars.

What if China were to include its true gold holdings at market in its FX reserves number?

As for Andrew, I had a long phone conversation with Eric King this past summer about Andrew. Eric is adamant that everything Andrew says is based in fact.  [note:  I came away from my conversation convinced that Maguire’s intel was bona fide.  As Eric and I discussed, the cartel has the backing of the U.S./British/EU Governments, which makes it impossible to predict the timing on actual occurrence of the events that we know ultimately will occur]

It’s hard to know for sure because Andrew references a lot of information that we have no way of verifying independently. For instance, he asserts that liquidity is leaving the Loco London market. Is there a way to verify this other than to have faith in Andrew’s assertions? If there is I’d love to see it.

Having said that, everything Andrew is talking about is exactly what Frank Veneroso said would eventually happen back in the late 1990’s. Frank never laid out “who and how” but he said eventually the western banks/CBs would be unable to contain the physical market with paper because the demand for physical would blow up the paper suppression schemes.

Here’s the other key assertion that we have no way of verifying: “the aggressive and predatory bullion banks that largely infest the swap dealer category of the COT report recognize the gold market has changed and are about to split ranks and reposition more bullishly, a position they would already have if they had not accrued such large underwater proprietary positions”

If you guys have any way of verifying that assertion, then we would know that Andrew is 100% bona fide.

At this stage, I have no reason to disbelieve Andrew based on my own observations and research into the precious metals market.  I really want to believe everything that he says is happening right now, but I’ve been taking a wait and see mind-set with regard to his assertions.

JP Morgan And Citi Are Using OTC Derivatives To Manipulate Gold And Silver

Financial regulators around the world have recognized an immediate and pressing need to address possible regulatory protections in the OTC derivatives market.   – Brooksley Born, 1998 as Chairman of the CFTC – LINK

(Please note:  this scheme too will blow up in their face just like Long Term Capital, Enron, Bear Stearns, Lehman, AIG/Goldman.  The taxpayers will be bailing out the banks – and now we know why Citigroup wrote the legislation that enabled banks to move their OTC derivatives positions to their FDIC insured units – but gold and silver will go parabolic)

Back in the late 1990’s, the then head of the CFTC – Commodities and Futures Trading Commission,  the Government entity which is supposed to oversee futures and derivatives markets (enforce the laws in place to prevent criminal activity in these markets) – Brooksley Born embarked on an effort to impose oversight and regulation on the burgeoning OTC derivatives markets.  We all saw back then the dangers they impose on the system when Long Term Capital imploded and almost took down the global financial system.

I was a junk bond trader back then and vividly remember the entire affair.  In fact, Bankers Trust was the pioneer in OTC derivatives and it also had to pony up the most amount of money to bail out the system from Long Term Capital.  I also had been involved in using OTC high yield derivatives – unregulated – to hide large, risky and illiquid junk bond positions from the Bankers Trust risk management team.  We always did this right before the period in which the bank began calculating bonus pools.  In other words I know first-hand the many ways in which OTC derivatives can be used in corrupt ways to game the system and squeeze enormous profits from the markets.  “Markets” meaning, the people on the other side of your trade.

Of course, Robert Rubin,  Larry Summers and Alan Greenspan put on a full-force lobbying effort to destroy Ms. Born’s effort in Congress and the rest is history.  OTC derivatives are not only financial nuclear weapons of mass destruction, they are right now about the only source of real cash flow for the big banks.

But they are also used to inflict criminal manipulation on the gold and silver markets.  Dr. Paul Craig Roberts and I have written an article outlining the most likely way in the which the big big bullion banks – primarily JP Morgan and Citigroup – are implementing the recent massive spike up in gold and silver OTC derivatives in order to manipulate and suppress the price of gold and silver.   Bear in mind that, thanks the Rubin/Summers/Greenspan triumvirate, we have absolutely no way of knowing exactly how these securities are structured.  And yet – as we’ve seen with Long Term Capital, Enron, Bear Stearns, Lehman, AIG and Goldman – they can catastrophically effect our lives financially.

Are Big Banks Using Derivatives To Suppress Bullion Prices?

Paul Craig Roberts and Dave Kranzler

We have explained on a number of occasions how the Federal Reserves’ agents, the bullion banks (principally JPMorganChase, HSBC, and Scotia) sell uncovered shorts (“naked shorts”) on the Comex (gold futures market) in order to drive down an otherwise rising price of gold. By dumping so many uncovered short contracts into the futures market, an artificial increase in “paper gold” is created, and this increase in supply drives down the price.

This manipulation works, because the hedge funds, the main purchasers of the short contracts, do not intend to take delivery of the gold represented by the contracts, settling instead in cash. This means that the banks who sold the uncovered contracts are never at risk from their inability to cover contracts in gold. At any given time, the amount of gold represented by the paper gold contracts (“open interest’) can exceed the actual amount of physical gold available for delivery, a situation that does not occur in other futures markets.

You can read the rest of this here:   OTC Derivatives Are Used Manipulate Gold And Silver

Click to enlarge:

GOLD_Q1SilverOTCderivs1

Comex Paper Silver: New Record Naked Short Interest

2014 total GLOBAL mine supply 877.5 million ozs. So Comex OI is now 110% of annual mine supply. What a sick joke.  – Craig “Turd Ferguson” Hemke on Twitter

I need to make a slight correction to Craig’s analysis.  2014 silver production is already used up.  70% of all silver produced is used up in manufacturing processes.  The other 30% produced in 2014 is sitting in jewelry boxes across India and China or in fabricated bullion form in private investment hands around the globe.

Because most silver is produced as a by-product of mining base metals, and because the world economy slowed drastically or contracted, it is likely that base metal mining production declined.  It is thus likely that silver output is declining in 2015.  Therefore, the open interest in silver futures on the Comex is likely even greater than the 110% of 2014 production cited by Craig.

Please note:  any open interest in silver futures on the Comex that is in excess of the amount of silver available for delivery – i.e. the “registered” account in the Comex vaults – is considered a “naked short.”  This is because paper obligations have been issued against physical silver that does not exist to be delivered.  In any other market, this activity would be stopped immediately by the regulators – FINRA, the SEC and the Justice Department. But the regulators blatantly ignore the most manipulated in the history of the world.   Click to enlarge:

SilverOI

This table above is the silver trading and open interest data from Friday’s Comex trading session in silver.  It includes the electronic Globex trading plus the Comex floor activity.  As you can see, the total open interest moved up to 192,527 contracts.   This represents 962 million ozs of silver – 110% of 2014 global silver production but likely a much larger percentage of the current 2015 global silver production.

To put the 962 million ozs in context:  the total amount of silver reported to be in Comex vaults is 179.8 million ozs;  the “registered”  and available to be delivered amount is 57.8 million ozs.  Please note:  the numbers reported by the Comex banks are suspect as to their validity, as banks have been successfully prosecuted for reporting fraud in other areas of their business activity and JP Morgan has been fined and censured by the CFTC for its Commitment of Traders data reporting.

Based on the numbers above, the amount of naked short interest on the Comex is 904.2 million ounces, which is the amount by which the total paper open interest exceeds the amount of silver – 57.8 million ounces – that has been made available for delivery.  Anyone see a problem here with the integrity of the Comex and its regulators?

The amount of July open interest – 456.2 million ozs – is 7.8x greater than the registered silver and 2.5x greater than the total amount of silver on the Comex.  The total open interest exceeds the registered silver by 16.6x and exceeds the total amount of Comex silver by 5.3x.

This market imbalance represents first and foremost a degree of market intervention and price-setting collusion that has never been witnessed in the history of any market, let alone the history of what is supposedly a country devoted to free markets and Rule of Law.

There’s a reason the Government is enabling this illegal activity to persist and to grow more extreme.  I have a bad feeling that no one wants to see this reason and I have a worse feeling that we may find out this year.

JP Morgan’s Giant Silver Fraud

In order to figure out what the elitists are going to do next in order to loot wealth from our system, all you have to do is think like a criminal.  – Dave Kranzler, circa 2004

The Comex open interest for  May silver (the current “front month”  contract for Comex silver) is 535.6 million ounces.  The current amount of ‘registered” silver – silver that has been designated as available to be delivered – is 68.8 million ounces (LINK).   The amount of paper silver for just May is thus 7.78x greater than the amount of physical silver available for delivery.   In other words, for every ounce of physical silver held in Comex silver vaults that has been declared available for delivery, there are 7.78 ounces of paper silver issued. The paper short interest in May silver is 778% greater than the amount of physical silver available to be delivered, according to Comex records.

Never in the history of any commodity on any commodity futures exchange in the world has the ratio of paper to actual physical been even remotely close to this out of whack. Suffice it to say that silver is the most manipulated market in the history of the financial markets.  While most of us already know this based on observation, the actual data as reported by the Comex confirms the observation.

Interestingly, JP Morgan has taken delivery of 4.7 million ounces of silver for its “house” account (LINK).  This would be JP Morgan’s propriety in-house account (click to enlarge):

SilverDeliveries

The graphic above shows the month-to-date delivery notices for the Comex silver 5,000 oz. contract.  I highlighted the line entry for JPM.  The “H” means JP Morgan’s “House” account and the “S” means “Stopped.”  This line entry tells us that JPM has taken delivery of 936 contracts worth of silver, or 4.68 million ounces.  The “stopped” silver represents silver that JP Morgan is receiving based on the long position in its house account.  You see from the line just above that JP Morgan has not “Issued” any delivery notices from its house account.  Month to date, JP Morgan has taken down 54% of total silver deliveries for its own account.  Clearly JPM is accumulating physical silver.  The question is, “why?”

What makes this more interesting is the fact that JP Morgan also happens to be, by far, the largest portion of the short interest on the Comex.  Based on the most recent COT report (LINK),  the total “commercial” short interest is 89,361 contracts. Unfortunately, the Comex position reporting is prohibitively opaque in that it prevents us from seeing the breakdown of individual firm long/short positions.   However, using just “pro rata” analysis, I have estimated that JPM’s pro rata share of the commercial short position is around 24,000 contracts (JP Morgan’s silver vault has 39.2 million total ounces, which is 27% of the total amount of the 178 million ounces of silver reported in Comex vaults).

This “pro rata” attribution gives JP Morgan the benefit of assuming that its share of the trading is “pro rata.”  Most of us have reason to believe that JP Morgan’s share of trading and of the short interest is far higher than just “pro rata.”  But, having said that, based on the numbers we have, we can estimate that JP Morgan is short 120 million ounces of paper silver (24k contracts x 5,000 ozs per contract).  Against 8.5 million ounces of silver in its registered account,  this means that JP Morgan is short  14 ounces of paper silver for every ounce of silver in its registered account.

The bottom line issue in all of the above analysis is the fact that the CME permits JP Morgan to aggressively short paper silver in order to drive down the price and then turn around and aggressively take delivery of physical silver at a price which has been artificially manipulated a lot lower than it would be if the CME, CFTC, SEC and Justice Department enforced the rules that are in place to prevent market manipulation.   Yet, the market manipulation in Comex silver is by far the most blatant and extreme inthe history of all markets.

Circling back to my quote at the top, the Comex is one of the most corrupted criminal enterprises operating in this country.  Given the nominal amount of dollars involved, it makes any of the endeavors of the Mafia look petty by comparison.  JP Morgan is being allowed by our Government – which has rules in place to prevent this – to drive down the price of silver on the Comex using fraudulent paper silver and then turn around and accumulate millions of ounces for its own proprietary account.

In applying my “think like a criminal” theorem to the situation with JP Morgan’s silver activity on the Comex, I came to the conclusion about a year ago that, more than likely, a couple of these big bullion banks that appear to be catastrophically short paper gold and silver have actually been accumulating a lot of physical gold and silver that is being safekept at the large new gold/silver depositories in Singapore and Hong Kong.

When the time comes when the hedge funds who are holding the long side of the huge paper short positions held by JP Morgan, HSBC and Scotia, ask for delivery of the metal represented by those contract, the little known “force majeure” clause buried in Comex metal contracts will enable these banks to settle with printed U.S. monopoly paper.

Gold was an objective value, an equivalent of wealth produced. Paper is a mortgage on wealth that does not exist, backed by a gun aimed at those who are expected to produce it. Paper is a check drawn by legal looters upon an account which is not theirs: upon the virtue of the victims. Watch for the day when it becomes, marked: ‘Account overdrawn.’   – from Francisco’s “money speech” in “Atlas Shrugged.”

 

 

Justice Department Investigating Ten Big Banks For Precious Metals Rigging?

Did you have to watch “Peanuts” 5,000 times before you figured out that Charlie Brown was not going to kick that footlball?   – John Titus, “Bailout Films”

The Wall Street Journal reports this evening that “prosecutors in the Justice Department’s antitrust division are scrutinizing the price-setting process for gold, silver, platinum and palladium in London, while the Commodities Futures Trading Commission has opened civil litigation”  (Wall Street Journal).    Ten of the biggest banks in the world are allegedly under “scrutiny:”  HSBC, Bank of Nova Scotia , Barclays, Credit Suisse, Deutsche Bank, Goldman Sachs, J.P. Morgan, Société Générale, Standard Bank and UBS.

The first question that comes to mind, is “does the Justice Department even have jurisdiction to go after banks for possible illegal market activity conducted in London?” The simple answer is that it does if the banks were conspiring in their price-fixing activities in offices in the U.S.

But let’s face it.  This is just another episode of the U.S. Government’s Kabuki Theatre version of “let’s show the public we’re cracking down on the illegal activities of the big bad banks.”   I can guarantee everyone reading this that, at best, the Justice Department will issue some small wrist-slapping sized fines and pat the banks on the butt and send them on their way.   This is just wash, rinse and repeat of the “crackdown” on mortgage and foreclosure fraud.

How come the Justice Department and the CFTC are not investigating the obvious illegal price rigging activities going on their own backyard at the Comex?  I’ll tell you why. Because every single legal professional at the Justice Department and the CFTC have either worked in the in-house legal teams at every Too Big To Fail Bank OR want to work on the legal teams at those banks.

You think I’m exaggerating?  Watch this:   How Eric Holder Turned “Justice” Into a Wall Street Criminal Protection Racket.

The moral of the story here is that the gold and silver investment community should not get their hopes up that this “investigation” will be anything other than just another insider mob-operated tribunal which completely disregards and parodies Rule of Law.

And no, I only had to watch “Peanuts” twice to figure out that Charlie Brown would never get to kick that football.

 

The CFTC Commitment Of Trader Data Is Rigged After All

Myself and a few others – primarily GATA – have been suggesting for quite some time that contract open interest data the CME reports for the Comex is rigged.  While certain newsletter peddlers adamantly maintain the reports are accurate and honest in order to preserve their franchise, there’s nothing like a the CFTC imposing a fine on JP Morgan for fraudulently reporting “large trader” data:   CFTC Charges JP Morgan With Reporting Fraud.

JP Morgan has finally been caught and sanctioned for playing games with its position reporting in gold and silver in order to hide the true magnitude of its unhedged short positions on the Comex.    That JP Morgan does this is obvious to anyone who has spent several years studying and trading the Comex.

After all, how are the CFTC’s COT reports compiled?  They come from big banks who are the primary Comex market-makers, of course.  There’s no independent audit of the numbers.  The reports  are sourced from the banks then submitted to the CME and the CFTC.   It’s a “trust us” job – wink wink.

IF JP Morgan et al were to be honestly and accurately reporting the data published by the CME and CFTC, it would be the ONLY area of their financial reporting that is not completely engulfed with fraud.

Anyone who chooses to believe otherwise either has ulterior motives – like making a lot of money selling newsletters – or still believes in Santa Claus.

In fact, while the COT report still holds some small degree of validity in terms of showing us what was happening a week ago on the Comex, I believe that the COT is now largely useless for the purposes of making money on the information.

First and foremost, the numbers are to some degree fraudulent.   The second reason is that the  informational content for trading purposes has lost value.

Ten years only a few crazy gold and silver bugs looked at the COT reports and used them to trade.  Back then the informational content had market value as a source of informational “inefficiency” derived from the fact that so few “brains” and so little money on a relative basis was using the information to trade.

Now, everyone under the sun who follows the precious metals market looks at the COT reports and incorporates the information conveyed into their trading strategies and investment outlook.   Because so many “eyeballs” and a lot more money is involved, it can be said that the market has become more “efficient” with respect to this information – any informational “edge” that used to be offered from analyzing the COT is no longer available.

 

The Action In The Metals Is Getting Interesting

That big spike up today that Zerohedge is saying is $450mm worth of paper gold occurred exactly at 8:15 a.m. EST, 5 mins before the Comex gold floor opens.  Someone either wanted to cover a big short or, less likely, a big fund decided to get very long.  I couldn’t see any news or event-related triggers. But the tape-action reflects a fear-driven trade if it was short-covering OR probably some sort of inside view of information not yet public if it was a trade to establish a long.

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TF Metals report  (link) that GATA published yesterday contained excellent sleuthing by Mr. Ferguson.  When I saw that JPM had become quite net long gold futures several months ago, my first impulsive thought was that they were getting long in order to be able to turnaround and dump big quantities of contracts to control the Comex price at some point.  TF Metals illustrates this is likely what occurred with the published data as evidence. (CFTC Bank Participation Report).

HOWEVER, it occurred to me that – perhaps – IF JPM has to resort to building up long positions in paper gold to enable the banks to turn around and dump the contracts in order to execute effectively its Fed-mandated policy goal of capping the price of gold, is this yet another indication that the bullion banks are running out of physical supply to throw at the market?

In my opinion, it is.