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| | SECURITIES AND EXCHANGE COMMISSION |
 | | Thereafter, in April, 1999, the Company was advised by the Securities and Exchange Commission ("SEC") of a private investigation into various allegations of misrepresentations by the Company and its officers. |
 | | Specifically, the SEC sought information relating to allegations about the Company's investigational drug application for treatment of various diseases, results of clinical research, incidence of ME/CFS in the United States, the Company's patents, and Ampligen's safety and efficacy. |
 | | SAB No. 101 states that in certain circumstances the SEC staff believes that up-front fees, even if nonrefundable, should be deferred and recognized systematically over the term of the research agreement. |
| www.hemispherx.net /content/investor/filings/RepDec3199.html (9478 words) |
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