Citron Exposes Elder Abuse Within Inogen's Sale Tactics

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Citron Exposes ElderAbuse Within Inogen’sSale TacticsPrice Target 46 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

BackgroundLast week, respected short seller Carson Block put out a insightful 27 page report detailing how Inogen management hasmisled the market with its wildly overstated claims on TAM. These TAM estimates originated from an obscure research firmthat Muddy Waters referred to as “amateurish”. We recommend all shareholders read the Muddy Waters piece and its 27pages of detail on how Inogen is deceiving the loads/2019/02/MW INGN 20190208.pdfWhile the original Citron report on valuation and the recent MW report on TAM are interesting, they are nothingcompared to what you will read in this presentation.Whenever a new medical device is released (e.g., portable oxygen concentrators), the potential for abuse and fraud increasesexponentially. No one will deny that portable oxygen concentrators are a great advancement for people suffering from COPD.Citron will acknowledge that Inogen was the first company to capitalize on this growing market.However, we are now unveiling the dirty secrets that we have discovered through months ofresearch. In this report, we will expose Inogen’s dirty reseller network, the systematic abuse ofelders by Inogen and resellers, and why the stock will quickly rerate lower to 46.2 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Exploiting Elders for Financial GainWhereas most people think of elder abuse as a physical act it is more often than not a financial crime that preys on thevulnerabilities of an age group that is more trusting and less internet savvy than the next generation.Elder Abuse is defined in the Older Americans Act of 2006 as:“The fraudulent or otherwise illegal, unauthorized, or improper act or process of an individual, including a caregiver orfiduciary, that uses the resources of an older individual for monetary or personal benefit, profit, or gain, or that results indepriving an older individual of rightful access to, or use of, benefits, resources, belongings, or assets.”It is important to note, that elder abuse is most commonly committed through acts that are technically legal.As stated on the Medicare website:"Elder financial abuse is big business. It’s estimated that older adults lose more than 36 billion every year to scams, fraud andexploitation.¹ It’s even more alarming that almost half of that money is lost due to tactics that – while deceptive in nature –are technically legal."In the following presentation Citron will show how Inogen along with its distribution network through legal and illegal tacticsare committing elder abuse to sell portable oxygen concentrators for the highest price without proper disclosure of benefits toseniors at the most vulnerable time of their life.3 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Disturbing Truth Why MedicareRevenue is Low For Inogen?For a company that sells a product to a customer whoseaverage age is 75 and on the lower end of the socioeconomic scale, what % of total revenue would you expectto be derived from Medicare?90% ?60% ?30% ?Less than 10%Why is this surprising?Because Medicare covers 80% of the cost as long as they are65 .4 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Dirty Deeds Done Dirt CheapInogen’s domestic B2B business has accounted for about half of thecompany’s revenue growth since its IPO. Last quarter, the domestic B2Bbusiness accounted for about one third of total revenue.This network has driven a material portion of the company’s growth.Citron believes that Inogen has conspired with the reseller network todominate Google listings and used tactics to deceive the sick elderly.Citron exposes that the top reseller of Inogen products is secretly controlledby a convicted felon who was recently released after 5 years in federal prisonfor deceptive internet marketing practices.5 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Largest Distributor of Inogen Products1st Class Medical claims to be thelargest distributor of Inogenproducts in the world. They arelisted at the top of Inogen’sauthorized internet resellers list onInogen’s website.https://www.inogen.com/internetresellersA Google search for anything relatedto portable oxygen concentratorswill bring you to the top paid ads of1st Class Medical who also owns LPT,The COPD, and SpryLyfe.6 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The SchemeCitron has proof through many transcripts that 1st Class Medical is lying to the elderly about their Medicare benefits tomake a sale. This allows Inogen to record higher margins through B2B sales at the expense of the elderly who are lied toabout their Medicare benefits. Every conversation we’ve had goes something like this.1st Class Medical Rep: Hello, thank you for visiting. Can I help you inany way?Potential Customer: hello1st Class Medical Rep : Hi therePotential Customer : i would like to get a portable oxygen machine1st Class Medical Rep : Ok any idea which one?Potential Customer : can I go through Medicare with you1st Class Medical Rep : No they do not cover these. They cover thebottles and tanks.7 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The SchemeObviously, these “oxygen specialists” are not aware of Medicare code E1392 for a portable oxygenconcentrator.Effective January 1, 2017, the Medicare allowable for stationary oxygen rentals (E1390) ranges from 66.53 to 77.16per month and the OGPE rentals (E1392) ranges from 36.14 to 41.91 per month. These are the two primary codesthat we bill to Medicare and other payors for our oxygen product rentals.– Inogen 3/000156459018003518/Inogen-10k 20171231.htmThis action is done intentionally when patients/customers are at their weakest point in life.Citron can’t expect the Medicare system to buy Google search ads to save seniors from the tactics of 1st ClassMedical and its owner Gary Luckner Gary Luckner?8 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Who 1st Class Medical Wants You to Think Runs theCompany1st Class Medical, the largest Inogen online distributor,claims on its website that it is owned and operated byCaleb Umstead.However, Caleb’s LinkedIn profile notes that he works in“customer education” at the n reality, the 1st Class Medical / Inogen scheme isoperated by Gary Luckner who was recently sentenced to90 months in prison for running a fraudulent -prison9 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Real Founder of Inogen’s Largest DistributorThe following videos prove by self admission that Gary owns and operates 1st Class Medical.Click here to watch10Click here to watch Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Real Founder of Inogen’s Largest DistributorBelow is a video of Inogen’s largest reseller bragging about how his son bought a G-Wagon from deceivingthe sick elderly.Click here to watch11 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Deception Doesn’t End With 1st Class MedicalOne of the top search results for oxygen concentrators is awebsite called https://seniorsreviews.com/, a lead gen for PureMedical.Pure Medical runs a review site for seniors. The volume of ravereviews that never mention the word “Medicare” is presented asa way to deceive seniors and most importantly keep the word“Medicare” out of the conversation.We remind the reader that the use of fake reviews is fraudulentand was part of the case that sent Gary Luckner to prison.Inogen’s distribution channel has become a collection of rogueoperators whose business is based on deception.12 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

What Citron found to be most appalling came from acompany called Main Clinic Supply, which is listed at the topof Inogen’s authorized internet resellers list on resellers/The top paid ad for portable oxygen claims “Beware ofCheap Machines”. This is a tactic used to scare the sickelderly from utilizing their Medicare benefits, which coverthese “cheap machines”.Needless to say this site is also riddled with fraudulentreviews, which get posted daily.All of the disturbing tactics of authorized internet resellershave resulted in higher revenue at the expense of the wellbeing of senior citizens and the law.13 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Inogen’s DTC Business is Running Out of AirThe Inogen scheme doesn’t stop with its distributors. DTC is Inogen’shighest margin channel, which is why the sales force has beentrained to upsell Medicare patients to cash pay.While competitors have invested in R&D (e.g., ResMed’s recentinvestment in remote patient monitoring), Inogen has invested in itssales /resmed.aspx“the [advertising] spend will continue to ramp as we hire new people.So we’ve always kind of matched our spend to our sales capacity. Soas we hire more reps, you’ve got to have more leads, or else youchoke the reps off and starve them”Inogen CEO Q1 2018 earnings callThrough a 4 month investigation and numerous conversations withInogen reps, Citron believes that these multiple sales reps steerMedicare patients away from enforcing their benefits throughevasive and deceptive tactics .14 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Inogen’s DTC Business is Running Out of AirInogen has previously capitalized on its position as the 1st DME for Medicare patients in many areas. Inogenwould take these leads from Medicare to convert them into cash sales. However, the competitive biddingprocess has changed as we read in a new risk factor in its 10Q.“On July 11, 2018, CMS released a new proposal to change the payment rules for Durable Medical EquipmentProsthetics, Orthotics, and Supplies (DMEPOS), including our portable oxygen concentrators. This includes aproposal that when the current competitive bidding contracts expire December 31, 2018, beneficiaries canobtain DMEPOS items from any enrolled Medicare supplier. ”Now that any DME can offer you a portable oxygen concentrator, Inogen will get much fewer Medicare leadsthat can be turned into cash sales.15 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Inogen’s Tactics Have Not Been Lost on the Employees“This company is very unethical and they doeverything they can to try to get over on seniorcitizens by harassing them to buy this portableoxygen concentrator for 3000 to 5000 and mostof these people see the crooked advertisementsaying the machine is covered by Medicare.” –Former Employee (August 16, 2018)“I would just say that it seems the company is overly obsessed with pumping uptheir stock price and being considered a ‘hyper growth’ company.” – CurrentEmployee (January 9, 2019)“I could no longer work here because thecompany is severely unethical.” – FormerEmployee (December 12, 2018)“They have been investigate by medicare 2 times in the last 3 years, andcurrently still are doing many things that violate medicare guidelines.” – CurrentEmployee (June 4, 2018)“Lots of rules that don’t get followed except what to say to Medicareshoppers.” – Current Employee (January 2, 2019)“Medicare should take long hard look at the business practice. Advice to any patient,read the small print. The call objective is to switch from what consumer has seen inadvertisement to CASH purchase” – Current Employee (October 18, 2017)16 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

Inogen’s Scheme Can be Found in Customer Reviews“These people prey on sick and generous folks, it’s inconceivable that a company in medical industry would be sounprofessional.” – Customer (January 17, 2019)“This company is suppose to cater to the elderly to me they rip off the elderly.” – Customer (August 13, 2018)“FRAUD by salesperson: Before buying a 2500 portable oxygen unit from Inogen I asked the sales rep if Medicarecovered such equipment and he said no. This was blatantly deceptive. I discovered the truth when the unit Ipurchased from Inogen with my credit card for 2500 in December 2017 failed. My oxygen level dipped into the70s and I am still having health issues (lethargy, fatigue, etc.) from the failure. I talked to another equipmentprovided who assured me that Medicare indeed covered the equipment. That company got me another unit andMedicare paid. My daughter, Valerie Mills, phoned Inogen and complained that I had been defrauded. The repconfirmed that Medicare does pay for the units but Inogen is not an authorized provider in my area. The repdeliberately withheld that information from me to make the sale.” – Customer (August 7, 2018)“I was intending to use my Medicare benefits to help with the purchase of the device it is fairly easy tounderstand what's going on. It's what is referred to as the old "bait an switch". – Customer (November 21, 2017)17 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

The Whole Bull Case of InogenThe whole bull case is predicated on aTAM number that was derived fromWinterGreen Research, whichmanagement touts in presentationsand conferences.While Carson wrote 27 pages rippingapart WinterGreen and the TAM,Citron will show just one picture.Here is a photo of the WinterGreenResearch headquarters.18 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

A Copy of This Report Has Been Sent to:CFPB’s Office for Older AmericansFederal Trade CommissionU.S. Department of JusticeNational Institute of JusticeElder Financial Protection NetworkNational Adult Protective Services AssociationNational Center on Elder AbuseNational Committee for the Prevention of Elder Abuse19 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

ConclusionHow can a company who sells portable oxygen concentrators to the elderly only get amid-single digit% of its sales from Medicare?By pushing a carefully crafted pitch to distributors that is both unethical and often illegal and is designed todeceive the sick and elderly. While this tactic has proven profitable for Inogen, it certainly cannot beconsidered a trend. Whether it be competition, oversight, or increasing customer awareness, Inogen’smargins and growth trajectory will contract and eventually its lack of R&D will leave it as an inferior playerin the increasingly competitive COPD market.Citron estimates that Inogen sells about 90% of its POC units vs. only renting about 10% through Medicare.Assuming 40% of POC units were rented through Medicare, Inogen’s revenue would decline by about 20%while EPS would decline by about 80% due to the negative mix shift to Medicare’s much lower margins.Evidently, the multiple would see meaningful contraction as well.Citron jumps into muddy waters and assigns a conservative 46 target on Inogen.20 Copyright 2019 Citron Research www.citronresearch.com All Inquiries – info@citronresearch.com

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Whenever a new medical device is released (e.g., portable oxygen concentrators), the potential for abuse and fraud increases exponentially. No one will deny that portable oxygen concentrators are a great advancement for people suffering from COPD. Citron will acknowledge that Inogen was the first company to capitalize on this growing market.

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