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GOTHAM CITY RESEARCH LLC

THE TRUTH ABOUT EBIX, ROBIN RAINA, AND THE ROBIN RAINA FOUNDATION

"We're more Catholic than the Pope." (Former) co-Chairman Jo Lernout, of Lernout & Hauspie, September, 25 2000

"Ebix stands for integrity, in every form and fashion." CEO & Chairman Robin Raina, of Ebix, Inc., April 1, 2011

Disclaimer: By reading this report, you agree that use of GOTHAM CITY RESEARCH LLCs research is at your own risk. In no event will you hold GOTHAM CITY RESEARCH LLC or any affiliated party liable for any direct or indirect trading losses caused by any information in this report. This report is not investment advice or a recommendation or solicitation to buy any securities. GOTHAM CITY RESEARCH LLC is not registered as an investment advisor in any jurisdiction. You agree to do your own research and due diligence before making any investment decision with respect to securities covered herein. You represent to GOTHAM CITY RESEARCH LLC that you have sufficient investment sophistication to critically assess the information, analysis and opinion in this report. You further agree that you will not communicate the contents of this report to any other person unless that person has agreed to be bound by these same terms of service. You should assume that as of the publication date of this report, GOTHAM CITY RESEARCH LLC stands to profit in the event the issuers stock declines. We may buy, sell, cover or otherwise change the form or substance of its position in the issuer. GOTHAM CITY RESEARCH LLC disclaims any obligation to notify the market of any such changes. Our research and report includes forward-looking statements, estimates, projections, and opinions prepared with respect to, among other things, certain accounting, legal, and regulatory issues the issuer faces and the potential impact of those issues on its future business, financial condition and results of operations, as well as more generally, the issuers anticipated operating performance, access to capital markets, market conditions, assets and liabilities. Such statements, estimates, projections and opinions may prove to be substantially inaccurate and are inherently subject to significant risks and uncertainties beyond GOTHAM CITY RESEARCH LLCs control. Our research and report expresses our opinions, which we have based upon generally available information, field research, inferences and deductions through our due diligence and analytical process. GOTHAM CITY RESEARCH LLC believes all information contained herein is accurate and reliable, and has been obtained from public sources we believe to be accurate and reliable. However, such information is presented as is, without warranty of any kind, whether express or implied. GOTHAM CITY RESEARCH LLC, makes no representation, express or implied, as to the accuracy, timeliness, or completeness of any such information or with regard to the results to be obtained from its use. All expressions of opinion are subject to change without notice, and GOTHAM CITY RESEARCH LLC is not obligated to update or supplement any reports or any of the information, analysis and opinion contained in them. GOTHAM CITY RESEARCH LLC has filed as a whistleblower with the Internal Revenue Service and the Securities Exchange Commission.

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Table of Contents I. II. III. IV. V. VI. VII. VIII. IX. Disclaimer Summary Introduction Ebixs Accounting: Unreliable, Inaccurate, and Incomplete The Tax Strategy: Sham in Fact or Sham in Substance Ebixs Stock Deserves to be Halted Shares are Worth No More Than $5 Robin Raina Foundation: a Crumbling Wall of False Integrity End Notes

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GOTHAM CITY RESEARCH LLC

a SUMMARY OF FACTS There is a $66 million undisclosed related party loan between Ebix Singapore and an unnamed related party. Australian revenues are only 32% of the amounts stated in the SEC filings, according to Australian filings. 2010 Singapore intangible assets are misstated by $67 million. 2011 long-lived assets do not add up. The 2010 & 2011 10K filings were filed before the Singapore 2010 financial statements were signed off. The Confirmnet acquisition cost 30% more according to the India filings than it did according to the SEC filings. Ebix could not have paid for Planetsoft, without moving cash from India, unless the cash never left the US. Less than 5% of Singapores intangible assets are IPrelated, i.e. most of the assets lack economic substance. EZ-Datas IP was transferred to Singapore yet Raina says No US IP has been transferred to any other country. Ebixs Singapore and India subsidiaries financial statements for 2011 remain unavailable. Core business is declining, tax rate is rising, and goodwill write-offs and debt maturities are looming. The Robin Raina Foundations IRS filings are full of material accounting irregularities. Raina misrepresented his foundations spending by 300+%. Company: EBIX Ticker: EBIX Share price: $18.34 Market cap: $711M Enterprise value: $764M 52-week high: $26.28 52-week low: $15.26 Shares outstanding: 37.28M Float: 34.86M Avg. Daily Vol: 447K % float short (1/15): 42.2% TTM Revenue: $189M TTM Net income: $69M 2012 YTD FCF: -$5M Net debt: -$53M Tangible book: -$67M Dividend yield: 2% FYE: Dec. 31 Auditor: Cherry Bekaert Holland

GOTHAM CITY RESEARCHS OPINIONS Ebix will restate historical results likely significantly as a result of the issues covered in this report & elsewhere. Ebix stock should be halted until the financial statements are reliable, accurate, and complete. Cherry Bekaert Holland should not sign off on Ebixs 2012 financials, without Ebix Singapores 2011 and 2012 filings. Ebixs stated tax strategy is supported by sham in fact and/or sham in substance transactions. Ebix shares are worth no more than $5.00/share, & approach $0.00 as the IRS, debt, & other risks unfold.

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INTRODUCTION
GOTHAM CITY RESEARCH first heard about Ebix last October, when we saw an Ebix-related lawsuit hit our inboxes. These kinds of lawsuits are normally thrown out in federal court, but this one did not get thrown out. Our interest in the Ebix story increased as we read through the complaint. Given the alarming accusations in the lawsuit, we soon decided to investigate for ourselves, and take a fresh look into the company. We read over 10,000 pages of documents from Sweden, Singapore, India, Australia, New Zealand, & the United States pertaining to the company. We consulted with professionals from the disciplines of forensic accounting, law, transfer pricing, background investigations, finance, and software. We found assets not adding, cash disappearing, and management misrepresenting. The more we looked, the more we found reality to be far worse than the prior critics had made it out to be. For example, we discovered a $66 million undisclosed related party loan1, $67 million accounting irregularity in long-lived assets2, and Australian revenues at a fraction of what the SEC filings disclosed, per the Australian filings3. We concluded that (i) Ebixs financial statements are unreliable, inaccurate, and incomplete, (ii) their tax strategy is a sham, and (iii) the stock should be halted. We decided it was important to go public with our findings after we found out that Robin Rainas misrepresentations did not end with Ebix. For starters, he recently exaggerated to the South Asia Times (who named him man of the year) how much Robin Raina Foundation (RRF) typically gives every year4: South Asia Times: How much you give to the foundation? What is its annual outlay? Robin Raina: I hate to talk about it. But yes, a majority of the money that comes in for the foundation comes from me. In a given year, RRF will typically spend about $2 million. In fact, RRF has spent at most $3.7 million combined since inception, as the IRS Form 990s reveal5:
thousands $ Total expenses
2004 2005 2006 2007 2008 2009 2010 2011 TOTAL

($56)

($326)

($598)

($441)

($471)

($704)

($1,054)

($86)

($3,735)

Rainas bogus claims to the South Asia Times are morally reprehensible, but not illegal. We do wonder, though, about his declarations that RRFs form 990s are true, correct, and complete, made under penalties of perjury.6 As it turns out, there are, in fact, accounting irregularities found in the Robin Raina Foundations form 990s, as we discuss later in this report. As Autonomy, Lernout & Hauspie, AremisSoft, Network Associates, and other epic software frauds remind us: when you put together a bunch of bushes, you dont get a tree you get a bunch of scraggly, old bushes. We believe Ebix is no different, having grown largely due to its improper tax strategy, luck, dodgy acquisitions, and Rainas ability to fool some of the people, all of the time. We believe that the chickens are about to come home to roost for Ebix and Raina. Somebody once said that in looking for people to hire, you look for three qualities: integrity, intelligence, and energy. And if you dont have the first, the other two will kill you. Warren Buffett Page 5 of 46

Ebixs Accounting: Unreliable, Inaccurate, and Incomplete

What Ebix and CEO Robin Raina Have Said Regarding the Integrity of the Company and its Filings On April 1st, 2011 (April Fools Day), a week after a negative report was published on Seeking Alpha1, CEO Robin Raina hosted an Investor Conference. The below slide is from said conference2:

On November 5th, 2012, a Bloomberg story titled Ebix Accounting Practices Said to Be Probed by SEC3 claimed that Ebix is being investigated by the U.S. Securities and Exchange Commission for its accounting practices, four people with direct knowledge of the probe said. Ebix swiftly issued a press release4, in which Robin Raina, Chairman, CEO and President of Ebix, said: We stand behind the accuracy of our public filings. Is Robin Raina, Chairman, CEO and President of Ebix telling the Truth, the Whole Truth, and Nothing But the Truth?

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Gotham City Research Believes Ebixs Financial Statements are Unreliable, Inaccurate, & Incomplete We believe Ebixs financial statements are unreliable, inaccurate, and incomplete and that the company will have to restate historical results for the following reasons: I. Undisclosed Related Party Transactions and Assets That Dont Add There is a $66 million undisclosed related party loan between Ebix Singapore and an unnamed related company. Ebixs 2010 long-lived assets dont add up. The Singapore irregularity alone is $67 million. Thats equal to 94% of Ebixs 2011 GAAP net income and just under 10% of the companys market cap. 2011 long-lived assets on the balance sheet do not add up to the long-lived assets in note 16. The total cost of Confirmnet is off by 30+% between the Indian filings and SEC filings.

II. Evidence that Reported Revenues and Accounts Receivable are Not Accurate or Reliable Ebixs Australia revenues, as disclosed in ASIC filings, are only a fraction of what SEC filings show. 20%-40% of accounts receivable seem of dubious quality, given the growth in unbilled receivables and odd inclusion of deferred revenue within accounts receivable. Ex-employees have raised doubts on the accuracy and reliability of Ebixs account receivables.

III. Other Critics have Voiced an Entirely Different set of Concerns about Ebixs Reported Figures: Organic growth misrepresentation5 Ebix's most recent 10Q (Q3'12) implies they misrepresented organic growth in the 10Q's filed for Q1'12 and Q2'12, and organic growth has gone negative. Past organic growth (prior to 2012) rates are suspect, likely misrepresented as well Raina says that 11 percentage points of last year's revenue growth were organic. Weak, non-existent, & inadequate internal controls Ebix has had 4 auditors in the last 8 years, and As Ebix has gotten larger, its audit firms have gotten smaller.6

While the concerns weve identified are the most serious to date, the combination of what weve uncovered and whats already out there leave us with no doubt that Ebixs financial statements are not accurate, reliable, or complete. Once revenues are suspect, everything else in the income statement is suspect, as every line-item flows through the P&L. Small changes in reported revenue have an amplified effect on EPS (the exact multiplier depending on financial and operating leverage). And once a company is not disclosing a material related party loan (in an amount roughly equal to Ebixs 2009 and 2010 tangible assets), who knows what else theyre hiding?

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The $65.8 Million Undisclosed Related Party Loan between Ebix Singapore and a Related Party One of the biggest concerns that some market participants have voiced is that they just cant seem to get around trusting Ebix. Others, such as Jeff Van Rhee of Craig Hallum, seem to trust (without verifying) Robin Rainas claims and Ebixs financial statements.7 We believe that it is actually much worse than even the skeptics think: for starters, the company has never disclosed a $65.8 million loan between its Singapore subsidiary and an undisclosed related party. From the Singapore filings8:

The loan to Singapore is outstanding as of the 2010 financial statements. We dont know of its status beyond 2010 as Ebix has yet to even file its 2011 filings9, as of the writing of this report. Both the 2009 and 2010 filings indicate that the loan is not expected to be repaid within the next 12 months:

It would seem that the loan is, by definition, a loan of indefinite duration. A loan with such lax terms does not seem remotely consistent with an arms length transaction (more on this later). The Singapore financial statements make it very clear that Ebix Singapore purchased intangible assets with the proceeds from said loan, as shown in the statement of cash flows:

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Strangely, Ebixs Australian filings Do Not Reflect any Corresponding Inflow or Outflow of Cash The following footnote reveals that most of the intangible assets were purchased from Telstra (subsidiary of Ebix Australia):

So where did the money flow? The Singapore filings imply it flowed to Australia. The Australian filings, then, should reflect the sale of intangible assets to Singapore10:

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The Investments account clearly reflects a major decline (of just under 50 million aussie dollars). That looks about right, and appears to correspond to the sale of intangible assets to Singapore. Where things get very strange: there is no corresponding increase in cash on the balance sheet; equally disturbing is that the decline in the investments account is not reflected at all in the statement of cash flows:

The liabilities section of the balance sheet shows an account with a similar decline in the same period:

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Specifically, there is a decline in Trade and Other Payables in an amount that seems on the same order of magnitude as the decline in investments account. The specific sub line-item is called amounts payable to related parties. Mathematically, the decline in the investment account mirrors the decline in amounts payable to related entities. They appear to cancel each other out to balance the balance sheet. Heres the problem: neither the decline in the investments account (as mentioned), nor the decline in payables is found in the statement of cash flows. Nor is there a footnote that explains these declines. Gotham City Research believes in three possible explanations (and none of them bode well for Ebix): 1. The undisclosed related party loan and (corresponding IP purchase transactions) are sham in fact transactions, i.e. they never actually occurred; 2. Ebix Singapore did receive said loan from an undisclosed related party, but the money is unaccounted for; 3. Ebix Singapore did receive said loan from an undisclosed related party, and sent proceeds off to some completely unmentioned entity, lets call party X, who then forgave the Ebix Australias payables. In either 3 scenarios, the simple question is why? We cant think of any good reasons, but we can think of plenty bad reasons. The best case scenario we can think of is scenario number 3. But in that case, the (I) absence of any disclosures to US investors, (II) lack of any disclosures regarding this hypothetical party X in the Singapore filings, and (III) no inflow of cash or explanation in the footnotes of Australian filings lead us to believe that these lies of omission were motivated by some (economically) rational reason: namely, to improperly minimize taxes. For more, see the tax section. Ebixs Australian Revenues and Profits are only a Fraction of What SEC filings Show, per ASIC filings We examined the financial statements of Ebix Australia (VIC) Pty Ltd, made available by the Australian Securities and Investment Commission (ASIC) & found that Ebixs revenues & pre-tax profits, according to the ASIC filings, are only a tiny fraction of whats stated in Ebixs SEC 10Ks11:
SEC vs. ASIC FILINGS - 2011 Financial Statements thousands $ SEC ASIC VARIANCE Cash Long-lived assets Revenue pre-tax income $7,605 $1,286 $31,991 $2,734 $8,467 $1,040 $10,161 $1,127 -10.2% 23.7% 214.8% 142.6%

Notes: Cash for Australia from the SEC filings is as of 3/12/2012, not 12/31/2012, for unknown reasons. I assume for simplifying purposes 1 Aussie dollar equals 1 US dollar. US AUD in fact did vary around 1:1 in 2011, so it's a reasonable assumption.

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The revenue and pre-tax income irregularities are particularly odd given that the long-lived assets, cash balances, and employee count look far more similar, between the SEC and ASIC filings. For example the 2011 Australian filing claims 74 employees (they mysteriously did not fill out and reveal employee count in the 2010 ASIC filing), while the 10K 2010 claims 77 employees (Ebix stopped reporting employees by geographic segment in 2011 10K).12 Also, while Ebix does disclose having 3 total subsidiaries in Australia, Ebix Australia Pty,. Ltd., Ebix Australia (VIC) Pty. Ltd., and Ebix Exchange-Australia PTY LTD, Ebix Australia (VIC) Pty Ltds financial statements clearly show that it fully owns Ebix Australia Pty,. Ltd. and Ebix Exchange-Australia PTY LTD:

Recall, Australia is the only country where Ebix has any significant revenues outside of the US:

Ex-employee Statements and the Composition + Quality of Accounts Receivables Cast Doubt on the Reliability and Accuracy of Ebixs Reported Revenues Ex-employees have questioned the reliability and accuracy of Ebixs receivables13: Unable to determine which customers had made payment for which projects. A former Ebix account manager, who had worked for E-Z Data prior to the acquisition and continued to work for Ebix until early 2011, confirmed declining growth. As of last quarter, our accounts receivable area became a major concern to senior management and to our stockholders. A former senior executive of Connective Technologies, Inc., confirmed not only the experience of Peak with respect to Ebixs inability to provide accurate financials on which to base his earn out "Constant errors" in "billing and administrative processes" left Ebix's employees "unable to properly produce invoices to customers in a timely manner." "Ebix's accounting procedures were plagued by errors. Ebix was consistently unable to properly bill customers, tie customer payments to invoices issued by Ebixprovide basic financial data, or calculate Peak's revenue."

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"As a result of the significant billing problems caused by Ebix, Peak did not properly allocate sales and revenue into the appropriate accounting periods. As a result, upon information and belief Peak overstated its accounts receivable." "Ebix was consistently unable to tie customer payments to specific invoices. As a result of Ebix's failure to account for customer payments, Ebix was unable to manage accounts receivable for Peak, & Ebix is unable to create & maintain accurate books and records."

20%-40% of Accounts Receivables Seem of Dubious Quality, per Close Examination of the SEC filings GOTHAM CITY RESEARCH believes at least 20-40% accounts receivables are of dubious quality. We believe Ebix is utilizing a toxic combination of aggressive accounting rising unbilled receivables, a shrinking reserve for doubtful accounts, and unusual inclusion of deferred revenue within receivables. Unbilled Receivables Unbilled receivables have been used as a classic financial shenanigan to aggressively recognize revenue, especially when its growth has outpaced overall A/R growth and revenue growth14. Ironically (or perhaps not), Ebixs auditor authored a white paper on unearned receivables15. The below table shows how unbilled receivables growth outpaced total receivables growth recently16:

Unbilled Receivables Growth Outpaced Total Accounts Receivables Growth 2011 Q4 2012 Q1 2012 Q2 2012 Q3 thousands $s Revenue $44,050 $43,827 $47,716 $53,804 Gross accounts receivable $32,852 $30,572 $34,291 $38,519 Unbilled receivables $5,200 $6,100 $7,700 $9,100 Revenue % growth (0.5%) 8.9% 12.8% Gross accounts receivable % growth (6.9%) 12.2% 12.3% Unbilled receivables % growth 17.3% 26.2% 18.2%
Despite all the issues that employees have identified regarding Ebixs receivables, allowance for doubt accounts has actually been trending down, as a percentage of receivables, even as unbilled receivables as a percentage of receivables has been rising.

Allowance for Doubtful Accounts is Trending Down, even as Unbilled Receivables Trends Up 2011 Q4 2012 Q1 2012 Q2 2012 Q3 thousands $s Gross accounts receivable $32,852 $30,572 $34,291 $38,519 Allowance for doubtful accounts $1,719 $1,221 $1,195 $1,316 Allowance for doubtful accounts as % of A/R 3.9% 2.8% 2.5% 2.4% Unbilled receivables as % of A/R 15.8% 20.0% 22.5% 23.6%
Deferred Revenue as a Component of Accounts Receivable Ebix started including deferred revenue into its accounts receivable account (even though it reports a separate deferred revenue account as a liability) as soon as Cherry Bekaert Holland became its auditor in Page 13 of 46

200817. The amount of deferred revenue Ebix includes within accounts receivable is buried in the notes, making it difficult for most investors who dont read the notes. The below table shows how the deferred revenue included within accounts receivable has grown at a faster clip than accounts receivable:

Deferred Revenue Included Within A/R Has Grown Faster than Total A/R 2011 Q4 2012 Q1 2012 Q2 2012 Q3 thousands $s Revenue $44,050 $43,827 $47,716 $53,804 Deferred Revenue $16,460 $16,211 $18,060 $17,845 Deferred rev included in A/R $5,200 $6,100 $7,700 $9,100 Revenue % growth (0.5%) 8.9% 12.8% Deferred Revenue % growth (1.5%) 11.4% (1.2%) Deferred rev included in A/R % growth 17.3% 26.2% 18.2%
The inclusion of deferred revenue within the accounts receivable account is exceedingly rare, based on our experience. Rather than relying on our judgment, however, we consulted a few accounting experts, who have been studying these issues for decades. We asked Dr. Edward Ketz, Professor of Accounting at Penn State University, and author of Hidden Financial Risk and Accounting Ethics: Have you ever seen a company include a portion of their deferred revenue in accounts receivable? He said18: Never. Deferred revenue means you have received cash but have not provided the product or the service to the customer, so you recognize the liabilitythe fact that you owe them a product or a service. If you have a receivable instead, I think this falls into the category of executory contracts. The customer is promising to pay you and you are promising them something in exchange. The profession has a bias against recognizing such mutual promises, as the profession seems not to recognize most executory contracts. According to another accounting expert we spoke with, he stated that it is exceedingly rare and unusual for a company to include deferred revenue in A/R. He added that it does occur in cases where a company nets it out of accounts receivable. However, the same accounting expert said hes never seen deferred revenue included within accounts receivable in the event there is a separate deferred revenue account (which Ebix has). Based on our independent research, the evidence seems to support Professor Ketz and the other expert we spoke to: we found less than 5 cases where deferred revenue is included within accounts receivable; in most of the cases, it was netted out due to an absence of a deferred revenue account.

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Ebixs 2010 Long-Lived Assets Dont Add Up. The Singapore Irregularity Alone is $67 Million (94% of GAAP 2011 Net Income and Just Under 10% of the Market Cap) Contrary to Mr. Rainas claims suggesting that all Ebixs public filings are accurate, we subsequently found material irregularities in the reporting of 2010s long-lived assets. The irregularity in the Singapore long-lived assets alone is $67 million, which is roughly equal to Ebixs entire 2011 GAAP earnings. The table below shows the irregularities, that is the 2010's long-lived assets as reported in the 2010 10K vs 2011 10K19:
2010's Long-Lived Assets - As reported in the 2010 10K vs 2011 10K
thousands $ 2010 10K 2011 10K VARIANCE

The Americas Australia Singapore New Zealand India TOTAL

$98,190 $545 $134,993 $0 $0 $233,728

$169,833 $1,525 $67,781 $40 $3,339 $242,518

$71,643 $980 ($67,212) $40 $3,339 $8,790

Note 1: EBIX previously reported "goodwill and intangible assets" in note 16 by geographic segment in the 2010 10K. In the 2011 10K , EBIX reported "long-lived assets" in lieu of "goodwill and intangible assets". Despite the name change, they are substantially equivalent, as there are no material long-lived assets beyond goodwill and intangible assets. Note 2: In the 2010 10K, EBIX reported 'The Americas' whereas in the 2011 10K started to break out by specific region, i.e. US, Canada, & Latin America.

We highly doubt that these accounting irregularities were made by accident; Ebix has had plenty of time, and has filed 5 amended 10Ks just in the last 2 years. In fact, none of the amended 10Ks correct these irregularities, nor has there been an amended filing been released for 2010s 10K. If they wanted to get this right, we believe they wouldve done so by now, especially given all the extra public scrutiny the company has received in the last 2 years. Three Different Numbers for the 2010 Singapore Long-Lived Assets A superficial examination of the 2011 10K would lead many to believe that Ebix and/or Cherry Bekaert Holland corrected the 2010 long-lived asset numbers in the 2011 10K. We believe the 2010 long-lived assets numbers from both the 2010 and 2011 10Ks remain unreliable and inaccurate, for the simple reason that the 2010 Singapore long-lived assets number does not agree with the figures provided in the 2010 and 2011 10Ks20:

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The 2010 Singapore Long-Lived Assets from 3 Sources

2010 10K 2011 10K Singapore Filing

In US Dollars In Singapore Dollars

$134,993 $173,379

$67,781 $87,055

$77,407 $99,418

The Singapore Dollar (SGD) to US Dollar on 12/31/2010 = 0.7786. The low for the SGD USD in 2010 was 0.7028, which means currency does not explain the variance between the 2010 long-lived asset # from the 2011 10K and the 2010 Singapore financial statements.
No matter which exchange rates you use to convert from USD to SGD and visa versa (within the range that the SGD USD actually traded in 2010), the 2010 Singapore long-lived assets number reported in the 2011 10K does not equal that found in the Singapore 2010 filings. We believe these irregularities point to a much more serious problem: Ebixs reported financials are unreliable and inaccurate. If the goodwill and intangible assets are materially unreliable, then Ebixs profits by segment are materially unreliable, as they directly impact amortization expense, which materially and directly impact segment profits. If the Singapore intangible Asset Numbers are Suspect, so is the Alleged Singapore Tax Scheme The company claims21: The Company also has a relatively low income tax rate is in Singapore in which our operations are taxed at a 10% marginal tax rate as a result of concessions granted by the local Singapore Economic Development Board for the benefit of in-country intellectual property owners. The irregularities shown above cast a shadow over Ebixs stated tax strategy in Singapore. After all, if there are three different numbers for the 2010 Singapore long-lived assets (and most of the long-lived assets are intangible assets), is not the stated tax strategy suspect as well? The basis of said tax scheme is intellectual property (which is included in the intangible assets), according to Ebix. As we discuss in greater depth, it turns out this is only the tip of the iceberg, as there are bigger problems with Ebixs claimed tax strategy.

2011 Long-lived Assets on the Balance Sheet Show One Number, while Note 16 Shows Another After uncovering the 2010 long-lived asset irregularities discussed, we then looked to verify and cross check the long-lived asset figures disclosed in note 16 (of the 2010 and 2011 10Ks) to the long-lived asset figures that could be derived from the consolidated balance sheet.

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We found that 2011s long-lived assets as calculated from the consolidated balance sheet do not equal the total long-lived assets number found in note 16. The 2010 numbers add up; 2011s do not as shown below22:

Long-lived assets from the 2011 10K thousands $ 2010 2011 From Note 16 $242,518 $346,287 Derived from Balance Sheet $242,518 $347,365 Variance $0 ($1,078)
No matter how we calculate long-lived assets, either (I) subtracting current assets from total assets or (II) adding up the long-lived assets one by one, neither calculation equals long-lived assets found in note 16. In our experience studying and uncovering some of the great accounting-related frauds in the last 20 years, one common characteristic many have shared: basic, straight-forward numbers that should add up, dont. Even if these specific discrepancies are small in isolation, they are indicative of much bigger problems. How much did Ebix pay for Confirmnet (including earnouts)? The Ebix India filings Say One Thing, the SEC Filings Another Ebixs Indian subsidiarys filings and SEC filings tell the same story as far as how much was paid for Confirmnet (including earnouts) in 2008 and 2009. In 2010, however, they do not. They differ by at least $5 million, as shown in the below table23:

Total Cost of Confirmnet Acquisition: the SEC Filings vs. the Indian Filings 2008 2009 2010 Investment in Confirmnet $2,975 SEC FILINGS (in 1,000s $) $7,294 $3,279 INDIA FILINGS (in 1,000s $) $7,526 $3,310 $8,233 INDIA FILINGS (in 1,000s Rupees) 361,849 153,965 367,532 From India Balance Sheet INDIA FILINGS (in 1,000s $) $7,237 $10,316 $17,667 INDIA FILINGS (in 1,000s Rupees) 361,849 515,814 883,346 Assume the INR USD is 0.0208, 0.0215, and 0.0224 for year end 2008, 2009, and 2010 respectively.
Gotham City Research is not sure which numbers are correct. Either the 10Ks are correct, the India filings are correct, or neither are correct. Just like the Singapore long-lived assets, however, the clear implication here is that the Ebix financial statements are not reliable, accurate, or complete.

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Ebix Taxes: Sham in Fact or Sham in Substance

What Ebix and CEO Robin Raina Have Said Regarding Alleged Ebixs Tax Strategies Robin Raina says that Ernst & Young International has ensured that Ebix follows India's regulations in its transfer payments. "The government has given a pretty good tax rate to us," says Raina. "We are not running a tax shelter."1 He has also said No US IP has been transferred to any other country as shown below2:

Gotham City Research does not trust the companys account of its tax strategy. We believe it is a sham in fact, if not in substance for the following reasons: The $66 million undisclosed related party loan seems to serve no purpose other than to reduce taxes; the loan seems to violate the arms-length principle, in nearly every way possible. The purchase/transfer of IP assets from Australia/US to Singapore financed with the proceeds from the undisclosed loan doesnt seem to serve any economic role other than tax minimization. Intellectual property is a very small percentage of Singapores intangible assets. Nearly 90% of the intangible assets purchased were Goodwill and Contractual/Territorial Relationships.

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Ebixs flow of cash, profits, composition of assets, and certain operational details dont agree with Ebixs explanations of its tax strategies. Singapores balance sheet contained no intangible assets prior to 2009, which is not supportive of Rainas claims that Singapore had IP structures in place many years back Singapores director wears way too many hats, some which seem of a conflicting nature. Ebix Indias cash declined by $11 million between 5/7/2012 and 8/7/2012, with no explanation. Confirmnet acquisition was financed by an Indian subsidiary, which seems a taxable event. We estimate Ebix must have repatriated cash from India to the US to pay for its Planetsoft Acquisition. Or the cash never left the US. Interest income on cash seems low for a company that should be swimming in cash offshore. E-Z Data, wholly owned subsidiary of Ebix, transferred US intellectual property to Ebix Singapore, contrary to Rainas claim No US IP has been transferred to any other country.

We believe Raina and Ebix were motivated by the desire to minimize taxes, fund acquisitions with funds that otherwise belong to taxpayers, support the stock via dividends and stock buybacks with funds that otherwise belong to taxpayers, and self-enrichment. Ebixs taxes looked suspicious even before we uncovered the above stated facts. Specifically3: Ebix had the lowest effective tax rate of its peers in 9 of the last 10 years. Ebixs tax rates in 2009 and 2010 were 3% and 1% respectively, even as CRM, IBM, AAPL, GOOG, and MSFT tax rates were between 21%-41% in the same period. Ebixs geographic allocation of pre-tax profits over 2008-2011 appears at odds with geographic location of its assets and the sourcing of its revenues. Revenue vs. profits vs. PP&E disparity could draw scrutiny from IRS. Uncertain tax reserve seems exceptionally low, at 1.6% of total pretax income (in last 4 years), is one of lowest of companies analyzed. IRS has not received years 2007-2011; if unfavorable review, may not have sufficient reserve to offset the assessment. Aspects of Ebix's tax provision do not conform to GAAP. Since 2002, Ebix has provisioned $5 million in GAAP taxes in total, despite being profitable from a GAAP perspective each quarter.

Source: http://www.sabrientsystems.com/files/pdf/Effective-Tax-Rates.pdf

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The Singapore Undisclosed Related Party Loan and the Arms Length Principle The arms length principle, despite its informal sounding name, is found in Article 9 of the OECD Model Tax Convention and is the framework for bilateral treaties between OECD countries, and many nonOECD governments, too. Article 9 states4: [Where] conditions are made or imposed between the two [associated] enterprises in their commercial or financial relations which differ from those which would be made between independent enterprises, then any profits which would, but for those conditions, have accrued to one of the enterprises, but, by reason of those conditions, have not so accrued, may be included in the profits of that enterprise and taxed accordingly. Said differently, a transfer price should be the same as if the two companies involved were indeed two independents, not part of the same corporate structure. According to the Singapore Inland Revenue Authority of Singapore (IRAS), to determine the arms length interest rate, some factors to consider include5: the nature and purpose of the loan, market conditions at the time the loan was granted, the principal amount, tenure and terms of the loan, etc.

We believe the undisclosed related party loan between clearly violates the arms length principle for the following reasons: 1. No independent party would ever have made such a loan of this size, and with such absurd loan to value, interest coverage, and other debt ratios. An underwriter would simply reject such a loan request. As a result, there would be no loan, and no market clearing interest rate. 2. No independent party would lend on such lax and fuzzy terms, i.e. an indefinite term loan. 3. Market conditions in 2009 only add to our beliefs stated in 1. And 2. 4. The purpose of the loan was to acquire intangible assets; we believe the intangibles assets were transferred for little to no reason other than to avoid US and Australian taxes. No Independent Party Would Approve the Singapore Loan This loan not only lacks precedent transactions, but its absurdly uneconomic nature is not consistent with an arms length transaction: The interest coverage and loan to asset ratios are quite comical6:
Undisclosed Related Party Singapore Loan: Debt Ratios 2006 2007 2008 thousands SGDs Revenue $3,715 $2,785 $2,695 Profit before tax $832 $268 ($338) Total Assets $4,277 $5,068 $4,398 Loan to revenue 23.3x 31.1x 32.1x Interest coverage 0.11x 0.03x -0.04x Loan to assets 20.23x 17.07x 19.67x

2009

$2,721 $1,496 $17,822 31.8x 0.19x 4.85x

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No independent Party Would Lend to Ebix Singapore PTE LTD on Such Lax and Ambiguous Terms Ebix Singapore PTE LTDs 2009 & 2010 filings provide little information regarding the terms of the loan:

We deduce that is not expected to be repaid with the next twelve months indicates that the loan has no clear maturity date, as the 2009 and 2010 contain the same language. That is, this is a loan of indefinite duration. Based on precedent transactions and underwriting standards, the terms are not consistent with an arms-length transaction. A Closer look at the Singapore Operations

Raina claims, Our world-wide development and IP structure was established in these places many years back as a globalization need.7 The facts with respect to Singapore suggest otherwise, as Singapore had no intellectual property on its balance sheet in 20088:

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Singapore only had 6-11 employees prior to its purchase of intangible assets from Australia/US9:
Employee Count
2008 2009 2010

Americas Australia Zealand India Singapore Total

308 63 9 251 6 637

412 66 9 460 11 958

533 77 12 530 27 1179

Ebix Singapores Director, John Graham Prior, seems to wear way too many hats, as he is10: Ebix Singapores 1 of 2 Directors (who signed off on the last two financial statements) Corporate Senior Vice President of International Business and Intellectual Property Primary point of contact for all inquiries And primary sales contact

Legitimate businesses separate the sales function from the accounting/audit function. But in the case of Ebix, the same person who signs off on the audited financial statements is also the primary sales contact, and the primary contact for general inquiries. That seems improper, and indicative of negligible infrastructure. So in short, the facts dont support Robin Rainas claim that, Our world-wide development and IP structure was established in these places many years back as a globalization need.11 In fact, all the above mentioned facts suggest Ebix only modified Singapores organizational structure in order to reap the rewards of the favorable tax structure (contrary to Rainas claim otherwise). Over 95% of Singapores Intangible Assets Have Nothing to Do with Intellectual Property Robin Raina would have you believe that Ebix is swimming in intellectual property, and that Singapore is some mecca of intellectual property. So lets look at what the numbers say12: Page 22 of 46

Singapore Intangible Assets - Breakdown by Type 2008 2009 thousands of Singapore $s Goodwill $0 $53,551 Contractual/Territorial Relationships $0 $21,053 Intellectual Property rights $0 $3,897 Developed technologies $0 $638 Trademarks $0 $225 Customer relationships $0 $3,584 Database $0 $0 TOTAL INTANGIBLE ASSETS, GROSS $0 $82,947

2010

$52,060 $21,053 $3,897 $874 $225 $4,884 $268 $83,261

As more clearly shown below, most of Ebixs intangible assets are unrelated to IP assets:
Singapore Intangible Assets - % Breakdown by Type
2008 2009 2010

Goodwill Contractual/Territorial Relationships Intellectual Property rights Developed technologies Trademarks Customer relationships Database TOTAL

0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0% 0.0%

64.6% 25.4% 4.7% 0.8% 0.3% 4.3% 0.0% 100.0%

62.5% 25.3% 4.7% 1.0% 0.3% 5.9% 0.3% 100.0%

We will go a step further: goodwill and contractual/territorial relationship are largely worthless, if they were marked to market, as Ebix is a roll-up, with declining organic growth. It seems that Ebix Singapore bought goodwill and contractual/territorial relationships from Australia (possibly the US), for reasons we cannot fathom. The only reason we can come up with are : (1) Ebix wanted to give off the appearance that it owns a large amount of IP (hoping no one would look at the footnotes, and discover the truth) (2) and fool the Singapore government into approving a low tax rate. We dont see how the paper ownership of paper assets that have little value beyond the paper its written on, somehow magically enables Ebix to avoid US taxes. Recall that we have three different numbers for 2010s Singapore intangible assets, as we discussed earlier. All in all, it all seems way too good to be true. Our belief is that these funny looking transactions serve little to no purpose other than to minimize taxes for Ebix, inc. Ebix Indias Cash Declined by $11 Million Between 5/7/2012 and 8/7/2012, With No Explanation One of the tell-tale signs of transfer pricing schemes run by some of the more well known companies such as Apple, Google, etc. is that foreign profits in favorable tax regimes remain offshore, not just on paper. The precise reason transfer pricing has gotten so much attention is that in the event these funds are repatriated back onshore, these companies have to pay taxes on them (follow the recent Dell headlines, for example)13.

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So how is it that Ebix can use or move $11 million of cash (cash by geographic segment shown below) from India with no explanation, between May 7, 2012 and August 7, 2012?14
Cash & ST Investments by Geographic Segment thousands $s 3/12/2012 5/7/2012 8/7/2012 11/5/2012 US $9,356 $7,489 $8,450 $14,009 CANADA $751 $979 $979 $2,609 LATIN AMERICA $1,067 $1,508 $1,905 $1,603 AUSTRALIA $7,605 $3,123 $3,855 $6,673 SINGAPORE $1,962 $871 $1,508 $1,579 NEW ZEALAND $861 $467 $585 $1,655 INDIA $9,962 $15,875 $4,511 $1,316 EUROPE $1,936 SWEDEN $15 $16 $15 $15 TOTAL $31,579 $30,328 $21,808 $31,395 NON US $22,223 $22,839 $13,358 $17,386

It would seem that the $11 million was either used in India or used elsewhere. It does not appear to have been transferred over to another region, as 8/7/2012 total cash shows a meaningful decline. The $11 Million Not Used Within India Indias long-lived assets actually declined in India between 3/30/2012 and 9/30/2012 (long-lived assets by geographic segment shown below), despite announcing Ebix Purchases Two New Buildings in India, to Build a Office Campus Over 4000 Square Meters on 8/27/1215:
Long-Lived Assets by Geographic Segment 3/30/2011 6/30/2011 9/30/2011 12/31/2011 3/30/2012 6/30/2012 9/30/2012 $237,464 $245,051 $247,174 $258,347 $261,713 $315,847 $320,124 $0 $0 $0 $0 $8,925 $9,290 $18,180 $18,664 $18,599 $14,179 $14,452 $12,632 $12,908 $1,506 $1,458 $1,292 $1,286 $1,441 $1,401 $1,542 $70,922 $61,959 $52,549 $63,866 $65,749 $71,456 $71,180 $36 $202 $186 $233 $260 $240 $245 $3,674 $7,245 $6,824 $8,376 $11,064 $10,376 $10,422 $13,696 $334,579 $326,624 $346,287 $354,679 $420,877 $439,407

thousands $s US CANADA LATIN AMERICA AUSTRALIA SINGAPORE NEW ZEALAND INDIA EUROPE SWEDEN TOTAL $331,782

Ebix was Highly Acquisitive in 2012, perhaps thats where the $11 Million Ended Up Acquisitions16 $34 mm Planetsoft 6/5/2012 Aliso Viejo, CA based , as further explained below $10 mm Trisystems 8/15/2012 London based $5 mm Taimma 4/2/2012 Montreal based $5 mm Fintechnix 6/1/2012 Australia based , explains the decline Australias cash balance $2 mm curepet investment NY based Page 24 of 46

If Ebix used the $11 million from India to finance any of the above transactions, we wonder if it paid any taxes related to the necessary repatriation of those funds. It is Unclear How Ebix Financed its Planetsoft Acquisition Without Repatriating Cash from India Most of Ebixs revenue is generated in the US and Australia; the cash somehow makes its way to Singapore and India. Thats fine, but if the funds then return to the US or other regions to finance acquisitions, without any payment of taxes we wonder if its too good to be true. You can keep the cash onshore, and pay a higher tax rate, or you can move the cash offshore, and keep it there; you cant have it both ways (the only way one might be able to have it both ways is via some special financing facility. However, Ebix has never mentioned or disclosed in its filings; furthermore, Ebixs balance sheet doesnt seem able to support such an arrangement). Planetsofts total cost is $40 million, of which $34-35 million was paid in cash. Ebix funded using a mix of internal cash reserves and the Bank credit line available to Ebix.17 The problem with this explanation is it would imply that Ebixs US cash balance would have gone negative to finance this transaction, even with their credit line fully maxed out according to our calculations18:
SOURCES OF CASH Debt CFFO Cash TOTAL USES OF CASH Buyback Other acquisitions + capex Planetsoft Dividend TOTAL COMMENTS $31,000 Net addition to debt. $21,000 CFFO is for full period, acquisition closed earlier. $8,000 US cash estimate, avg. between 5/7 and 8/7 $60,000 OTHER COMMENTS: $9,400 The uses of cash exceed sources of cash. $15,000 India is only country where cash declines from 5/7 to 8/7. $34,000 $3,300 $61,700

Note that the calculations shown dont factor in the following (source of funds would decline): Not all revenues are derived from US, which means not all cash flow is US based. Planetsoft seems to have closed before 6/30, which means Ebix did not have the full periods cash flow to pay for it.

A more plausible explanation is that Ebix used monies from India (without paying taxes). It would make more sense from a business perspective, as most businesses maintain a certain minimum level of operating cash to support operations. The other possibility is that the funds never left the US. As discussed in the prior section, Ebixs cash disclosures by country shows India is the only region where Ebixs cash actually declined in relevant period. Page 25 of 46

Ebixs Yield on its Cash is Low, Given it Should be Swimming in Interest Earning Assets Offshore With much higher prevailing interest rates in India, Australia, and Latin America, we struggle to understand why Ebix has only yielded 1.7%-2.2% on its cash19:

Interest Income 2010 thousands $ Cash + ST investments $29,690 Interest income $519 GCR estimate $1,191 Reported yield 1.7%

2011

$25,100 $557 $1,007 2.2%

We believe this means that the cash never really leaves the US (& is instead used to make acquisitions), it leaves only when it has to (for tax compliance purposes), or the cash moves around frequently. The Undisclosed Related Party Loan in Singapore Further Shields Taxable Income Based on our calculations, the undisclosed related party loan reduces Singapore taxable income by around $7,000,000 (Singapore dollars) annually20, so long as the loan (of indefinite duration) remains outstanding. This is in addition to the tens of millions of dollars in taxes the loans helped save, via the purchase of intangible assets. We think the indefinite duration of the loan serves no purpose other than to shield taxes indefinitely.

Also note how the interest expense from this loan exceeds the net interest expense of Ebix, inc. by around 5x:

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Ebix Software India Private Ltd paid for ConfirmNet, Apparently without Paying Taxes Ebix appears to have paid 100% cash for Confirmnet, through its Ebix Software India Private Ltd subsidiary.21 Were not aware of any taxes Ebix paid for this transaction, even though an Indian entity paid for a US entity, suggesting funds flowed from India to the US (what appears to be a repatriation event). If Dell has to pay taxes on funds it returns to the US from various offshore locations, shouldnt Ebix? Recall that it is not clear how much exactly Ebix paid for Confirmnet in the first place, as the India filings say one thing, and the SEC filings another (as discussed earlier in this report).

Ebix Singapore PTE LTD Purchased Intellectual Property, Apparently without Paying Any Taxes It would seem that Ebix Singapore PTE LTDs purchase of E-Z Datas intellectual property resembles Ebix Indias purchase of Confirm-Net, i.e. both subsidiaries used foreign funds (that was originally earned onshore) to finance US acquisitions, apparently without any tax consequences. Raina claimed in a 2011 investor day (a week immediately after Copperfield Research publicized their first report on Ebix): "No US IP has been transferred to any other country".22 The Singapore filings and SEC filings suggest otherwise (see the transfer of intangible assets line item; were certain the E-Z Data transaction is contained with the $76 million)23:

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Ebixs Stock Deserves to be Halted

On November 5th, 2012, a Bloomberg story claimed that:1 Ebix is being investigated by the U.S. Securities and Exchange Commission for its accounting practices, four people with direct knowledge of the probe said. Ebix swiftly issued a press release, in which Robin Raina, Chairman, CEO and President of Ebix, said2: The Ebix senior management team has not been advised of nor is it aware of an any SEC investigation regarding the Companys previous filings. Whatever the case, investors should seriously doubt the accuracy, reliability, completeness of Ebixs financial statements, disclosures, and past remarks. We doubt CBH obtained reasonable assurance that Ebixs financial statements & schedules were free of misstatement, contrary to their claims otherwise. We believe that Ebixs stock should be halted, until its financial statements are reliable, accurate, and complete. We also believe the current auditor has to go, as theyre not doing their job. The following serve as the bases of our opinions: Ebix never filed its Singapore subsidiarys 2011 financial statements with the Accounting and Corporate Regulatory Authority of Singapore (ACRA), likely as a result of heightened scrutiny. Ebix never filed its India subsidiaries 2011 financial statements with Indias Ministry of Corporate Affairs, likely for the same reasons it did not file with Singapore regulators. Ebix Singapores 2010 and 2009 financial statements were signed off well over a year after each respective years fiscal year end, even though filings prior to 2009 were all filed within a year. Ebix filed the 2010 and 2011 10Ks without Singapores 2010 audited financial statements signed off (Ebix Singapores 2010 financial statements were signed off on March 20, 2012). Unclear how CBH obtained reasonable assurance that Ebixs financial statements & schedules were free of misstatement, without the audited Singapore financial statements. Robin Raina claims Ebix parted ways with KPMG, while SEC filings indicate that KPMG resigned. We wonder how independent Cherry Bekaert Holland is, given the cozy relationship that exists between CBH, EBIX, STSI (CBHs 2nd largest publicly traded client), & tennis star John Isner. Ebix added a new Risk Factor "If we fail to maintain an effective system of internal controls, we may not be able to accurately determine our financial results or prevent fraud." Ebix has flooded the SEC with amended 10Ks, without correcting the irregularities we pointed to. Captive and impotent Board of Directors & audit committee. None reside in the United States. 58 comment and response letters filed with the SEC, between 2007 and 2012. Ebix, formerly known as Delphi, was a posterchild of bad behavior. It was in the red and indulging in revenue recognition practices that got its audit partner banned/censured by the SEC.

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The Missing 2011 Singapore Financial Statements Given how crucial Singapore is to Ebixs alleged tax strategy (as detailed earlier in this report), we were disappointed to find that Ebix has yet to file its 2011 filings with the Accounting and Corporate Regulatory Authority of Singapore (ACRA)3:

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We also find it funny that Ebix filed for what appears to be a 1-2 month extension in May 2012:

Its been over 9 months since Ebix Singapore for an extension, and still no 2011 financial statements. The Missing 2011 India Financial Statements; Ebix filed its 2011 10K before Ebix Indias 2011 Filed We unsuccessfully tried obtaining the 2011 financial statements for the two India subsidiaries (though by 2011, we believe they were to be merged, or amalgamated into one entity4), using three independent India-based contacts, over the last 3 months. All mentioned that Ebix had technically filed some of the forms for 2011, but did not file the financial statements. All three sources stated Ebix did not release any useful information for 2011. Note that CBH and Ebix signed off on the 2011 10K before the India filings have been released. Ebix Singapore PTE LTD Filed its 2010 Financial Statements after Ebix, inc. Filed the 2010 & 2011 10Ks Ebix somehow released its 2010 & 2011 10Ks before Ebix Singapore released its 2010 financial statements. The table below shows the dates the filings were signed off:5
Ebix's 10Ks 2010 and 2011 10Ks were Signed Off before the Singapore 2010 Financial Statements was Signed Off 2004 2005 2006 2007 2008 2009 2010 2011 Singapore Filings 9/14/2005 8/14/2006 6/14/2007 7/15/2008 7/30/2009 6/13/2011 3/20/2012 NOT FILED 10Ks 3/18/2005 3/10/2006 4/9/2007 3/28/2008 3/30/2009 3/16/2010 3/16/2011 3/15/2012 Days filed after 10Ks 180 157 66 109 122 454 370 NOT FILED Director Richard Richard Andrew Baey Baey Graham Graham NOT FILED Who Signed Off* Baum Baum Wakefield Cheng Song Cheng Song John Prior John Prior NOT FILED Ebix Auditor BDO BDO BDO HA&W CBH CBH CBH CBH * Director other than Robin Raina who signed off on the Ebix Singapore filings. The dates for the 10Ks are the dates when the 10K was originally filed; does not include date of any subsequent amended.

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Its unclear how Cherry Bekaert Holland signed off on either the 2010 or 2011 10Ks without the audited Singapore 2010 filing. Its also unclear how CBH signed off on the 2011 10K without the 2011 Indian and Singapore filings. Also note: Ebix Singapores 2010 and 2009 financial statements were signed off well over a year after each respective years fiscal year end. Prior to 2009, however, the Singapore filings were all filed within a years time. We would like to point out that 2008 is when CBH entered the picture. We wonder if this is a mere coincidence, or sign of something more sinister. Ebixs Peculiar New Risk Factor Ebix snuck in a peculiar new Risk Factor6: "If we fail to maintain an effective system of internal controls, we may not be able to accurately determine our financial results or prevent fraud." If we or our independent auditors discover a material weakness in our controls over financial reporting, the disclosure of that fact, even if immediately remedied, could significantly reduce the market value of our common stock. In addition, the existence of any material weakness or significant deficiency would require management to devote significant time and incur significant expense to remediate any such weaknesses, and management may not be able to remediate same in a timely manner. Captive and Impotent Board of Directors None of the members of the board of directors reside in the United States, and none of the audit committee members seem fit to do their jobs. It should concern shareholders that this is the public face of Ebixs BOD & audit committee (note that Hans has no demonstrated accounting or finance skills):

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We dont believe that any of the members of the audit committee are fit to do the job. Two are unqualified and one does not have the time nor is in proximity to do the job7: Hans U. Benz has no demonstrated accounting background or skills; based in Europe. Hans Ueli Keller has no demonstrated accounting background or skills; based in Europe. Pavan Bhalla, the chairman of the audit committee, is an MBA with no CPA credentials, and resides in India. He is currently a managing director of Aon Hewitts outsourcing operations. We dont think he has the time, dedicated resources, or proximity to chair the audit committee.

Ebix has Filed 10 Amended 10Ks In The Last 10 Years, and 7 Before That:

Robin Raina Claims Ebix Left KPMG, Not the Other Way Around Robin says they went with BDO because BDO gave an offer they couldnt refuse, they were moving to Atlanta (from Illinois), and there was to be a KMPG partner change. His tone and words make it sound like it was on the companys initiative, not KPMGs8: The fee structure was high. And BDO came in and offered not to exceed 200K. A deal for 2 years, across the world Why dont we move in to BDO? That was the reason we changed from KMPG, there was no negativity. Yet SEC filings clearly show KMPG resigned9: "KPMG LLP resigned as the independent registered public accounting firm of our Company" "(1) delegation of authority and what KPMG considered to be inadequate reviews by a person other than the preparer of accounting information, (2) the lack of a formalized contract review process to ensure proper revenue recognition, (3) the lack of a complete understanding of the Companys income tax positions and related accounts, (4) inadequate documentation for certain unusual transactions (including the basis for the Companys accounting conclusions), and (5) internal control matters (documented and testable control environment) under the Sarbanes-Oxley Act"10 Page 32 of 46

Cherry Bekaert Hollands Opinion on Ebixs Internal Controls is at Complete Odds with the Opinions of Former Employees and Former Auditors CBH has claimed11: In our opinion, Ebix, Inc. maintained, in all material respects, effective internal control over financial reporting as of December 31, 2011, based on criteria established in Internal Control Integrated Framework issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). CBH has also made similar claims in prior years 10K filings. The senior billing analyst in the Peak complaint makes claims at complete odds with CBHs statement.12 One of Ebixs former auditors, BDO Seidman, also "identified certain significant deficiencies relating to the Companys internal control over financial reporting"13 As mentioned in the prior page, KPMG expressed similar concerns as BDO. Then on December 12, 2008, Ebix, Inc. received notice from Habif, Arogeti & Wynne, LLP of its decision not to stand for re-appointment as Ebixs independent registered public accountant.14 Ebix would seem to be a prized client for Habif, so it seems quite odd to us that it voluntarily left Ebix. And in the meantime, Ebixs business has grown in complexity (i.e. there are more subsidiaries). Therefore, past concerns about its internal controls seem more relevant today, than in the past. Its one thing for Ebix to have different auditors for different subsidiaries (which itself is a red flag), but if CBH is signing off on Ebixs 2010 and 2011 financial statements without the Singapore 2010 and 2011 filings, that seems like a clear violence, in substance, if not form, of CBHs duty as an auditor. The Cherry Bekaert Holland, Ebix, John Isner Connection Ebix sponsors John Isner, the #22-ranked tennis player in the world. His website says plainly that it is powered by EBIX.15 (see upper right hand corner of the image below). It also mentions that they recently signed-on with Star Scientific:

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The name Star Scientific (STSI) stuck out because they are CBHs 2nd largest publicly traded company client, after Ebix.16 STSI signed Isner to promote their ant-inflammatory product, even though Star Scientifics mission is to promote maintenance of a healthy metabolism and to reduce harm associated with the use of tobacco at every level.17 Seems like a funny thing for a tennis player to sponsor himself.

The two operative words for Star Scientific is stock promotion. It is in their DNA. The founder and CEO, Jonnie Williams is a case in point. Mr. Williams has a long history of stock promotion that led to SEC sanctions18. On January 7, Chief Judge Joseph L. Tauro, U.S. District Court for the District of Massachusetts, entered Orders of Permanent Injunction against Jonnie R. Williams (Williams), a Sarasota, Florida stock promoter. The Commission's complaint alleged that the defendants were involved in a fraudulent scheme to promote Spectra's securities through false publicity in violation of Section 17(a) of the Securities Act of 1933 and Section lOeb) of the Securities Exchange Act of 1934 and Rule lOb-5 thereunder. Williams was also charged with violations of the beneficial ownership provisions by his alleged failure to report his sales of Spectra's stock during the course of the publicity campaign. Unsurprisingly, there was a recent negative article titled, Star Scientific's Made-Up, Misleading Relationship With Johns Hopkins by Adam Feuerstein19 (hes the widely followed Senior Columnist at TheStreet, who covers biotech/drug stocks)

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Shares Are Worth No More Than $5.00

Ebix is, according to Robin Raina1:

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Is Ebix a good Business? Lets Look at the Facts What Robin Raina is not telling you: Ebix Has Not Generated Lasting Free Cash Flow Raina2: "Our cash-generating rate continues to increase. The story of Ebix is a cash story." Yet Ebix has actually burned cash during the Reign of Raina:
Ebix's Free Cash Flow
1999 2000 2001 thousands $ Cash Flow from Operations ($13,333) ($7,663) ($3,239) Capital Expenditures ($894) ($138) ($520) Acquisitions ($50) $0 $0 Free Cash Flow ($14,277) ($7,801) ($3,759) Cumulative Free Cash Flow ($14,277) ($22,078) ($25,837) 2002 2003 2004 2005 2006 2007 2008 2009 2010 2011 YTD

($742) ($538) $0 ($1,280) ($27,117)

$3,343 ($555) $0 $2,788 ($24,329)

$2,810 ($366) ($8,156) ($5,712) ($30,041)

$5,483 ($484) $0 $4,999 ($25,042)

$4,375 ($537) ($15,091) ($11,253) ($36,295)

$15,039 $26,825 $33,877 $52,779 ($1,754) ($615) ($3,129) ($1,754) ($14,138) ($73,191) ($44,035) ($18,151) ($853) ($46,981) ($13,287) $32,874 ($37,148) ($84,129) ($97,416) ($64,542)

$71,286 $54,002 ($2,829) ($1,468) ($18,522) ($57,600) $49,935 ($5,066) ($14,607) ($19,673)

Ebix Has a Poor Balance Sheet Working Capital less Debt is Very Negative & Declining
Ebix's Negative Value as a "Net-net"

thousands $ Current assets Current liabilities Working Capital Debt Net-net

2006

2007

2008

2009

2010

2011

YTD

$13,899 $20,008 ($6,109) ($6,109)

$59,405 $25,017 $34,388 $20,486 $13,902

$25,524 $53,854 ($28,330) $15,290 ($43,620)

$46,515 $75,097 ($28,582) $671 ($29,253)

$60,782 $39,085 $21,697 $25,205 ($3,508)

$63,817 $49,779 $14,038 $40,218 ($26,180)

$76,426 $60,661 $15,765 $71,745 ($55,980)

Tangible Book Value is Very Negative, and Declining

Ebix's Negative Tangible Book Value

thousands $ Book value goodwill Intangibles Tangible book value

2006

2007

2008

2009

2010

2011

ytd

$26,166 $23,118 $7,867 ($4,819)

$60,126 $36,408 $7,318 $16,400

$70,142 $88,488 $21,824 ($40,170)

$170,743 $157,245 $49,728 ($36,230)

$231,268 $180,602 $53,126 ($2,460)

$316,115 $352,825 $259,218 $337,249 $68,839 $82,281 ($11,942) ($66,705)

Ebixs Equity is at Risk of Heading to Zero, given Ebixs Poor Balance Sheet, If: 1. The US IRS, SEC, and other regulatory agencies reclaim cash that belongs to taxpayers 2. Outstanding litigations cost Ebix more than expected 3. The foreign counterparts to the SEC and IRS take action 4. We estimate the IRS liability alone can easily exceed $100 million
Potential Back Taxes Owed 2007 2008 2009 $13,199 $28,699 $39,832 $533 $1,385 $1,010 4.0% 4.8% 2.5% 34.0% 34.0% 34.0% $4,488 $9,758 $13,543 $3,955 $8,373 $12,533

thousands $s Net Income Before Taxes Provision for Income Taxes Effective tax rate Statutatory tax rate Statutatory tax rate Potential back taxes owed

2006 $6,645 $680 10.2% 34.0% $2,259 $1,579

2010 $59,654 $635 1.1% 35.0% $20,879 $20,244

2011 $73,495 $2,117 2.9% 35.0% $25,723 $23,606

YTD 58,543 6,719 11.5% 35.0% $20,490 $13,771

TOTAL $280,067 $13,079 4.7% 35.0% $98,023 $84,061

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Ebix is Worse than Autonomy; a Would-be Acquirers Expected IRR is at Best -80% The following factors suggest that the expected return on an Ebix LBO or acquisition is quite poor: The numbers are unreliable, inaccurate, & incomplete Why buy something without clarity on the true economics of the business? Unclear why someone wants to volunteer to be the next Hewlett Packard or Caterpillar3 (who both recently wrote off nearly their entire investments in Autonomy and a Chinese acquisition respectively) The fundamentals, as reported, are poor Negative organic growth, debt, negative tangible book value, and no lasting free cash flow generation, leave no room for error. A true turnaround would require significant increases in R&D and Sales & Marketing spend Ebix does not invest in its own business; R&D and marketing spend would need to rise significantly just to play catch-up with comparable businesses. This would eat away at margins and also take a lot of time. Why do business with Robin Raina, who makes inaccurate claims about his business & charity? Tax situation could mean game over; going private does not mitigate this risk a strategic or financial buyer would inherit the tax bill, interest, and penalties, that an IRS and others impose. An unusual provision renders going private unappealing Ebix's board "unanimously approved" a change in control provision4, whereby Robin Raina is guaranteed a cash payment of 20% of the difference between the transaction price and the valuation of the company at $7.95 per share in the event of a change in control. Ebix shares are worth no more than 1.0x sales or $5.00/share Businesses with declining sales tend to trade for no more than 1.0x sales (see Hewlett Packard, which trades at 0.25x sales). Ebix trades at over 3.0x sales. Couple the decline in the core business with all the event and structural risks identified in this report, and Ebix easily trades in lower single digits.

So we don't really -- everything that's so entangled in each other, that's so difficult for us to read. Robin Raina in the most earnings call, when asked about organic growth5

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Robin Raina Foundation: a Crumbling Wall of False Integrity The public is led to believe that Robin Raina is1

Desiclub.com Top 50 Coolest Desis of 2012 We can also boast about the do-gooders in our community, such as the mega successful Robin Raina, for building homes for those not as fortunate as the rest of us.2

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Robin Raina Tells Investors (and Some Believe Him)3:

The Company holds its directors, officers and employees to the highest ethical standards in both its business operations, and in its efforts to achieve long-term value for its shareholders. Ebix March 25, 2011 press release4 Robin Raina Foundation Contrary to conventional wisdom, the great fraudsters of our time Enron, Stanford, Madoff, etc. all surrounded themselves with charity and other walls of false integrity5 to fool and distract their victims: White collar criminals build walls of false integrity around them by showcasing their good deeds, while living a parallel life of crime. Sam Antar, former CFO of Crazy Eddies Yet lies have a way of eventually catching up with fraudsters. We believe that time is near for Raina. Robin Raina blatantly misrepresented to the South Asia Times about how much his foundation, the Robin Raina Foundation (RRF), typically gives annually. RRFs 2004-2010 tax returns contain material financial irregularities & inaccuracies.

We believe Mr. Raina is worthy of a formal investigation and indictment, given the clear patterns of misrepresentation as both CEO of Ebix, and Founder/CEO/CFO of the RRF. Page 39 of 46

Robin Raina Misrepresents his Foundations Level of Giving/Spending We believe that Robin Raina overstated his foundations spending by at least 300%. South Asia Times: How much you give to the foundation? What is its annual outlay?6 Robin Raina: I hate to talk about it. But yes, a majority of the money that comes in for the foundation comes from me. In a given year, RRF will typically spend about $2 million. In reality, RRF has spent at most $3.7 million combined since 2004 (the year of its inception), as the RRFs form 990s reveal7:
RRF's Total Revenues vs. Total Expenses thousands $ Total revenue Total expenses
2004 2005 2006 2007 2008 2009 2010 2011 TOTAL

$192 ($56)

$422 ($326)

$714 ($598)

$611 ($441)

$1,615 ($471)

$2,122 ($704)

$1,728 ($1,054)

$1,070 ($86)

$8,474 ($3,735)

The most RRF ever spent in a single year was $1 million 2010 half of what he claims theyve been spending in a typical year. The foundation spent less than $100,000 in 2011 less than 5% of the typical $2 million he claimed, and a decline of over 90% from the prior year. What makes things look much worse is that most of total expenses consists of funds transferred to the Robin Raina Charitable Trust (RRCT), Rainas India-based non-profit. Which raises the question: Is Robin Raina Foundation a Charity?8
RRF's Questionable Spending Breakdown thousands $ Parties, shows, & other admin expense Funds moved to RRCT Total questionable spending Total expenses Questionable spending as % of total
2004 2005 2006 2007 2008 2009 2010 2011 TOTAL

($56) n.m.

($145) ($27) ($172) ($326) 52.8%

($392) ($6) ($398) ($598) 66.6%

($160) ($182) ($342) ($441) 77.6%

($104) ($234) ($338) ($471) 71.8%

($40) ($590) ($630) ($704) 89.5%

($981) ($981) ($1,054) 93.1%

($86) n.m.

($841) ($2,020) ($2,861) ($3,735) 76.6%

Over 75% of RRFs total spending consist of (I) non-charitable spending on parties, shows, and other administrative expenses and (II) a transfer of funds to RRCT. If Raina will misrepresent his foundations charitable spending to the South Asia Times, we dont see whats to stop him from doing worse. And it gets worse. The Robin Raina Foundations Tax Returns are Full of Material Accounting Irregularities We found several different varieties of accounting irregularities, while combing through RRFs form 990s. One variety of discrepancy: RRFs net assets (i.e., cash) do not add up for 2004-2007s filings:9
RRF NAV Variance Analysis
2004 2005 2006 2007

As stated in Part I $136,177 $232,293 $348,793 Part IV or Part X $136,714 $232,292 $246,292 Variance (537) 1 102,501 % Difference -0.39% 0.00% 29.39%

$402,727 $246,794 155,933 38.72%

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We examined the irregularities from different angles, and believe the mistakes are not innocent or accidental. At least $250,000-$500,000 is unaccounted for. We also believe Robin Raina is a very intelligent and capable man. As a result, it would take extraordinary evidence for us to believe he did not sign off on these form 990s without knowing they were false. Well leave it to readers and regulators to guess where the money is. Another accounting irregularity we found is that 2008s net assets at the end of the year do not reconcile with its stated beginning of the year net assets adjusted for revenue less expenses10:

RRF 2008's NAV Variance

2008

Net assets, Beginning of the year revenue less expenses Net assets, End of the year (calculated) Net assets, End of the year (reported) Variance

$246,794 $1,144,581 $1,391,375 $1,560,795 ($169,420)

Note that Robin Raina signed, under penalty of perjury, that he examined the returns, and that they are true, correct, and complete11: Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. Signed, Robin Raina, for the form 990s 2004 2011 Unlike lying to the South Asia Times about your charitable activities, lying to the government is a serious criminal (not civil) offense. We believe there is a strong case for an indictment of, and investigation into Robin Raina, given: (I) (II) he has a clear, documented history of misleading and deceiving investors, the IRS, the SEC, business partners, employees, and the general public at large, and There is a clear pattern of material irregularities found in the form 990s. Perjury is likely only the tip of the iceberg.

To summarize, Robin Raina and Ebix: Provide investors with inaccurate, unreliable, and incomplete financial statements. Use funds that belong to taxpayers to instead fund acquisitions and excess CEO compensation. Engage in transparent tax avoidance schemes.

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Meanwhile, Robin Raina and the Robin Raina Foundation: Misrepresent its activities, claiming to give at least 5x more than it does. Submits tax returns to the IRS with blatant accounting irregularities, inaccuracies, and incomplete information. Spends 75% on its funds on non-charitable and questionable activities. Gotham City Research is NOT making this up12

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End Notes
INTRODUCTION 1. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2010 and 31 December 2009; obtained via ACRA website: http://www.acra.gov.sg/ 2. Ebix 2010 10K, 2011 10K, and Ebix Singapore PTE LTD Financial statements for 2010. 3. Ebix Australia (VIC) Pty Ltd, Annual Financial Report for the Financial Year Ended 2011, 2010, and 2009, filed with the ASIC http://www.asic.gov.au/ 4. The South Asian Times, Vol. 5 | No. 37 | January 5-11, 2013 5. Robin Raina Foundation IRS Form 990, 2004 2011 6. Robin Raina Foundation IRS Form 990, 2004 2011 Ebixs Accounting: Unreliable, Inaccurate, and Incomplete 1. Seeking Alpha, EBIX: Not a Chinese Fraud, But a House of Cards Nonetheless, Copperfield Research, March 22, 2011 2. Ebix, Investor Conference CEO Presentation, April 1, 2011 3. Greg Farrell, Bloomberg News, Ebix Accounting Practices Said to Be Probed by SEC, Nov 7, 2012 http://www.bloomberg.com/news/2012-11-05/ebix-accounting-practices-said-to-be-probed-bysec.html 4. Ebix press release, Ebix Responds to Bloomberg Article, Nov 5, 2012, http://www.ebix.com/pressrelease_text.aspx?artid=252 5. Organic growth goes negative, recent 10Qs suggest past 10Qs were inaccurate a. If The SEC Cometh the SEC Will Findeth Or So We Suspect, , Copperfield Research, December 5, 2012 b. Prolonging a Foreign Tax Holiday by Bill Alpert of Barrons , July 17, 2011 6. Prolonging a Foreign Tax Holiday by Bill Alpert of Barrons , July 17, 2011 7. Anonymous Article Smells Like Market Manipulation At Its Finest, Jeff Van Rhee, Craig-Hallum, March 25, 2011 8. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2010 and 31 December 2009; obtained via ACRA website: http://www.acra.gov.sg/ 9. From ACRA search http://www.acra.gov.sg/ 10. Ebix Australia (VIC) Pty Ltd, Annual Financial Report for the Financial Year Ended 2011, 2010, and 2009, filed with the ASIC http://www.asic.gov.au/ 11. Ebix 2010 10K, and Ebix Australia (VIC) Pty Ltd, Annual Financial Report for the Financial Year Ended 2011 12. Ebix 2011 10K, and Ebix Australia (VIC) Pty Ltd, Annual Financial Report for the Financial Year Ended 2011

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13. Isaac et al v. Ebix Inc, docket number 2:11-cv-00450, Consolidated class action docket number 1:11-CV-02400-RWS 14. Financial Shenanigans, by Howard Schilit 15. Do You Have a Handle on Your unbilled accounts receivables (a/r)? , by Dave Lundsten and Susan Moser, Partners with Cherry Bekaert Holland http://www.ncmahq.org/files/Articles/5AE31_CM0907_Finance.pdf 16. Ebix 10Q filings for Q4 2011, Q1 2012, Q2 2012, and Q 2012. 17. From the 2007, 2008, and 2009 10Ks. 18. From Email correspondences with Professor Ketz, January 29, 2013 19. Ebix 2010 10K and 2011 10K ; the amended 2011 filings did not change long-lived assets 20. Ebix 2010 10K, 2011 10K, and the Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2010. 21. Ebix 2011 10K 22. Ebix 2010 and 2011 10Ks 23. Ebix 2008, 2009 and 2010 10Ks. Ebix Software India Private Limited 2008, 2009, and 2010 filings. The Tax Strategy: Sham in Fact or Sham in Substance 1. Prolonging a Foreign Tax Holiday by Bill Alpert of Barrons , July 17, 2011 2. From Investor Conference CEO Presentation, as presented by Robin Raina on April 1, 2011 3. The prior tax-related red flags were mentioned by: a. An Examination of the Risks Associated With Abnormally Low Effective Tax Rates (ETRs), Gradient Analytics, May 23 2012. http://www.sabrientsystems.com/files/pdf/EffectiveTax-Rates.pdf b. Seeking Alpha, EBIX: Not a Chinese Fraud, But a House of Cards Nonetheless, Copperfield Research March 22, 2011 4. Article 9 of the OECD Model Tax Convention 5. Related Party Loans and Related Party Services, Inland Revenue Authority of Singapore http://www.iras.gov.sg/irashome/page04.aspx?id=10588 6. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2009, 2008, 2007, and 2006; obtained via a Singapore contact via the ACRA website: http://www.acra.gov.sg/ 7. Ebix, Investor Conference CEO Presentation, April 1, 2011 8. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2008, via the ACRA website: http://www.acra.gov.sg/ 9. Ebix 2008, 2009, and 2010 10Ks 10. The John Graham Prior information was found in the following places: a. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2008, 2009, and 2010. b. SEC filing form 3, dated October 9, 2012. http://www.sec.gov/Archives/edgar/data/1559511/000118143112054195/xslF345/rrd3 56973.xml Page 44 of 46

11. 12. 13. 14. 15. 16. 17. 18. 19. 20. 21.

22. 23.

c. The Contact Us and Sales Inquiries sections within http://www.ebix.com.sg/ Ebix, Investor Conference CEO Presentation, April 1, 2011 Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2008, 2009, and 2010. Dells Tax Dodge?, February 6, 2013 http://finance.fortune.cnn.com/2013/02/06/dells-taxdodge/ Ebix 2011 10K, and the 3 most recent 10Qs. Ebix Purchases Two New Buildings in India, to Build a Office Campus Over 4000 Square Meters, August, 27 2012 http://www.ebix.com/br/pressrelease_text.aspx?artid=248 From the SEC filings and press releases. Ebix Acquires PlanetSoft for $40 Million, June 5, 2012 http://www.ebix.com/br/pressrelease_text.aspx?artid=238 Ebix 2011 10K, and the 3 most recent 10Qs. Ebix 2010 and 2011 10K Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2010. Facts and deductions regarding ConfirmNet not paying US taxes a. Ebix Confirmnet Merger Agreement b. 10K 2008, 2009, and 2010 filings c. EBIX Software India Private Ltd 2008,2009, and 2010 filings Ebix, Investor Conference CEO Presentation, April 1, 2011 Singapore filings and SEC filings show Ebix Singapore purchasing US IP (from E-Z Data) a. Ebix Singapore PTE LTD Report of the Directors and Financial Statements for the financial year ended 31 December 2009 and 2010. b. IP ASSET PURCHASE AGREEMENT SINGAPORE E-Z DATA, form 8K, September 30, 2009

Ebixs Stock Deserves to be Halted 1. Ebix Accounting Practices Said to Be Probed by SEC, Greg Farrell, Bloomberg News, Nov 7, 2012 http://www.bloomberg.com/news/2012-11-05/ebix-accounting-practices-said-to-be-probed-bysec.html 2. Ebix Responds to Bloomberg Article, November 5, 2012 http://www.ebix.com/br/pressrelease_text.aspx?artid=252 3. From the ACRA website: http://www.acra.gov.sg/ 4. Ministry of Corporate Affairs, India, http://www.mca.gov.in/DCAPortalWeb/dca/MyMCALogin.do?method=setDefaultProperty&mo de=12 5. Ebix 10Ks 2004 2011, Ebix Singapore PTE LTD financial statements 2004 2010 6. Ebix 2011 10K 7. Based on linkedin profiles and biographies according to the Ebix proxy statements 8. Audio recording to the Ebix, Investor Conference CEO Presentation, April 1, 2011 9. Ebix SEC Filing Schedule 14A, November 21, 2005 Page 45 of 46

10. 11. 12. 13. 14. 15. 16. 17. 18.

Ebix 2004 10K Ebix 10K filings Isaac et al v. Ebix Inc, docket number 2:11-cv-00450 Ebix 2004 10K Ebix 8K, December 18, 2008 http://www.johnisner.com/ Capitaliq STSI 10Ks SEC News Digest, Issue 94-17, January 27, 1994 http://www.sec.gov/news/digest/1994/dig012794.pdf 19. Star Scientific's Made-Up, Misleading Relationship With Johns Hopkins, TheStreet, Adam Feuerstein, January 23, 2013 http://www.thestreet.com/story/11820016/1/star-scientificsmade-up-misleading-relationship-with-johns-hopkins.html

Shares are Worth No More Than $5 1. Ebix, Investor Conference CEO Presentation, April 1, 2011 2. Prolonging a Foreign Tax Holiday by Bill Alpert of Barrons , July 17, 2011 3. Wrong Way to Admit You Blew Millions of Dollars, Jonathan Weil, Bloomberg News, January 24, 2013 http://www.bloomberg.com/news/2013-01-24/wrong-way-to-admit-you-blew-millions-ofdollars.html 4. Ebix Proxy filing form 14A, October 18, 2010 5. Ebix Q3 2012, Conference Call Transcript, November 8, 2012 Robin Raina Foundation: a Crumbling Wall of False Integrity 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. The South Asian Times, Vol. 5 | No. 37 | January 5-11, 2013 http://www.desiclub.com/community/culture/culture_article.cfm?id=1071 Ebix, Investor Conference CEO Presentation, April 1, 2011 Ebix press release, March 25, 2011 http://www.whitecollarfraud.com/white-collar-crime-and-criminals.html The South Asian Times, Vol. 5 | No. 37 | January 5-11, 2013 Robin Raina Foundation IRS Form 990, 2004 2011 Ibid Robin Raina Foundation IRS Form 990, 2004 2007 Robin Raina Foundation IRS Form 990, 2008 Robin Raina Foundation IRS Form 990, 2004 2011 From Robin Rainas twitter and facebook accounts a. @RobinRaina1, November 15, 2012 https://twitter.com/RobinRaina1/status/269261187366137856 b. https://www.facebook.com/photo.php?pid=11217167&l=bc5dfc2d8c&id=610711645

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