Pulse failed to achieve an FDA 510(k) clearance which it had previously described as a “foundation for future clearances”. The current direction of the company seems highly uncertain. The company and several directors have been subpoenaed as part a newly disclosed SEC investigation into potential insider trading around a company news release. Any future avenues are likely to be capital-intensive. Per the 10-K, “…we plan to raise additional capital in the future”. Bottom line: Pulse is focused on a technology that doesn’t seem to work well. Limited oncological studies show poor to mixed results. Aesthetic applications thus far have insignificant potential. We think Pulse is stuck in a precarious position, and the current stock price in no way reflects the risks, capital needs, and the looming regulatory overhang facing the company.