Eros international

EROS INTERNATIONAL cmp 140 mcap 1280 cr

The company is mainly into film co production and distribution business. The company tries to de-risk its business model by recovering majority of its costs upfront from pre sales of overseas rights, music rights and broadcasting rights on TV, internet, 3G, movie on demand on satellite tv etc.

The company either co produces the movie or acquires the movie rights from the actual producers at various stages of production for an agreed amount.

It recovers around 35-40% of total cost from its parent Eros Intl by selling overseas rights, 10-15% of rights from music pre sales from its partner T series, and Television rights bring in another 20-25%. Hence effectively it recovers around 75-80% costs upfront and hence reduces the risk of box office performance.


Here the company pre sells the films which it has either produced or has acquired the rights of to various theatrical networks with upfront commission of 20% . Once the film is completed, Eros finances the printing and advertising expenses and distributes the movie prior to its release. The minimum guarantee and the printing and ad expenditure are recovered from the box office collection of theatres and Eros retains the sales commissions. After deducting the above expenses the balance is shared with the producer as per agreed terms.


Eros sells movies from its library for a fixed period or for a fixed number of viewings to various channels. Here it gets an upfront license fee and /or a share of the ad revenues as per the understanding with the channel involved.

Eros has a movie library of around 2000 films and is using this content to improve its profits. Recently it signed a deal with Zee Entertainment to exclusive broadcast its movie library on the latterâs channels.

The company also raises revenues by launching original DVDs , VCDs etc for home viewing.


Ayngaran Intl is a 51% subsidiary of the company and is involved in Tamil Films which it produces and distributes. It is also a strong player in the overseas Tamil Films market.

Eros is also involved in Punjabi Film, Marathi films in the regional genre of films.

OTHER REVENUE STREAMS include providing ring tones and other content for mobile phones, putting up trailers and contents on internet and you tube and getting shares of ads generated etc.

FORTHCOMING FILMS include Bangkok Blues with Irfan Khan, Game with Abhishek Bachchan, Zindagi na milegi dobara with Hrithik Roshan, Always Kabhi Kabhi, Mausam with Shahid Kapoor, Chalo Dilli with Vinay Pathak and Lara Dutta, RA One with SRK, Agent Vinod with Saif Ali Khan, Desi Boys with Akshay Kumar, John Abraham and Deepika Padukone, Rockstar with Ranbir Kapoor, etc.






9M FY 11

9m FY 10







Reported PAT*














*Actual Net Profit sometimes includes some extraordinary amounts which do not reflect true picture.

The current equity is 91.4 crores with shares of face value of Rs 10 each. Promoters hold around 78% stake with no pledging. FIIs hold around 8% and DII hold around 2%(mainly IDFC small and midcap fund). IPO was priced at Rs 175 per share.


Dominant player in the Hindi film industry with increasing market share

Successful entry into lucrative regional film industry

Strengthening its theatre and digital distribution network

High demand for film software from various TV channels

Large content library consisting of more than 2000 films which can be exploited in various ways.


Decreasing shelf life of filmsâfirst few weeks are very critical to revenue generation

Piracy of movies would eat into the companyâs revenues

Seasonality of business with Q2 and Q3 being the best quarters with Q1 and Q4 being soft quarters.

Delays in film production might lead to cost over runs.


The company is likely to report EPS in the range of 13-14 for FY 11 based on 9M figures. The company is a relatively low debt company and has shown consistent growth in sales and profits in the last four years.

Hitesh, how do you compare Eros with other film production companies like Mukta Arts, Ashtavinayak, BAG Films etc?


Management seems to be much better in Eros as compared to the other scrips.

Plus the 3-4 yr track record of Eros is certainly showing good growth.

Besides I think Eros is much bigger player as compared to the above.

17 Mar, 2011, 04.52AM IST, Rajesh Naidu,ET Bureau

Growth prospects may prompt rerating of Eros Intl stock

Following the recent decline in broader market indices, the stock of film studio company Eros International Media has dropped by over 32% from its listing price of Rs 190 six months ago.

The company reported robust numbers during the December quarter. Given its unique business model, which offers cushion against the failure of movies, the company is expected to grow at a faster clip in the coming quarters.

Unlike other companies in the entertainment business, Eros recovers more than two-third of its investment in movies even before their release. During the pre-production stage, the company earns revenues by selling television rights of the movie. It also recovers a portion of its investment through the release of DVDs and Direct-to-Home (DTH) services during the post-production stage.

Both these arrangements ensure that the company is insulated from the failure of a film project on the box office. In this arrangement, the company’s distribution network plays a key role. Through its investment in UFO Moviez, which ensures digital delivery of content, the company is in a position to release a film in 800 theatres at a time.

Besides, Eros also monetises inhouse library of over 1,000 films through syndication deals and selling satellite rights. Another source of income is presales of overseas film rights to the parent company Eros International Plc. In a fixed-rate agreement, the parent pays 30% of the cost in addition to a 30% mark-up and advances. These arrangements have helped the company secure handsome revenues from its investment.

In the December 2010 quarter, the company’s net profit increased to Rs 34 crore - a year-on-year jump of more than 200%. Net sales rose by 60% to Rs 217. Due to its strong business model, the company enjoys benefits of revenue diversification. Around 40% of the company’s revenues come from theatrical rights, and the remaining from overseas sales and satellite rights.

Though its stock has not been able to provide any meaningful returns to investors so far, it may undergo a rerating in the coming quarters, given the company’s future growth prospects.

I like this story for the reasons Hitesh and Mahesh has presented. Apart from those, I think there is another compelling point that makes it attractive, the growing number of movie based TV channels are increasing and will have to source the content from the likes of EROS. As the competition for content increases the pricing power of those holding the libraries increase as well.

I like the story and considering an exposure in EROS

Eros is at good levels currently.

In FY 13, the EPS is 16.81 and it is available at less than 10 PE.

At least in the near term, theatrical revenues would contribute a major proportion of the revenues. They have a decent content pipeline for the next 12 months.

Their involvement with the Tamil cinema industry has been deepening (In FY 13, they released 47 movies in regional languages out of which 44 was in Tamil) thanks to their subsidiary Ayngaran.

They are also derisking the content by going in for co-production deals with Endemol, Sony, Phantom films etc. As part of the tie-up with Endemol, they are also looking at entering TV.

The company is also interestingly poised to benefit from digitization. They have a tie-up with HBO and have launched premium 2 channels in End Feb. Personally I am not sure how many customers would pay Rs 59 per month for an ad-free movie channel. On the positive side, there would only be marketing related expenses for the channels. So any subscription revenue earned should contribute significantly to the bottomline.

Highlights of the Call by Capital Mkt:

  • The company for Q3 FY15 has reported 13% incline in consolidated net sales to Rs 490.73 crore. The resultant PAT increased by 21% to Rs 109.32 crore.The contribution from theatrical revenue was 41%, overseas was 31% and satellite, digital & others was 28% for the quarter.
  • During Q3, the company released 12 movies (7 Hindi & 5 Tamil Movies), including 3 high budget and 9 medium and low budget movies.Library film monetization and the release of new movies in Hindi, Tamil and other regional languages contributed to healthy growth in revenues. Theatrical revenue was driven by releases such as Lingaa (multi-lingual), Kaththi (Tamil), Action Jackson, Happy Ending.
  • The company had strong pre-sales from high profile movies in Hindi and Tamil such as Lingaa, Action Jackson and Kaththi.Happy Ending had not sold on satellite, expect it all others movies are sold.The contribution of catalog revenue was 22% during Q3 FY15 vs 15% during Q3 FY14. This has helped OPM to rise in Q3.Catalog revenue is growing by 10-15% each year.
  • Out of total catalog revenue, 10% is from digital platform.The company had forays into Malayalam market with Jeethu Joseph’s Life of Josootty.The company has inducted new people at top-management. Dinesh Modi has joined the Company as the new Group Chief Financial Officer India and he comes with over 15 years’ experience in finance. Ajit Thakur has joined the company as Chief Operating Offices.
  • ErosNow, the company’s online platform, now has 14 mn registered user worldwide, with just over 10 mn in India.The company has tied up with RailTel Corporation of India to provide ErosNow broadband streaming service to railway passengers.
  • The company has formed a worldwide content partnership with Google Chromecast, which was recently launched in India, to bring entertainment content from ErosNow to Chromecast users on their big screens.
  • The company’s’ App android version will be launch in few weeks time,
  • The company is self monetizing music under ErosNow.
  • The company will invest more money in larger and medium budget movie in FY16. The pre-sales are strong for big budget movies.Tamil, Telugu and Malayalam markets will be main regional market, before focusing on other regional markets.Eros â HBO channels are not gaining traction at this moment. It still has under 3 lakh subscribers.
  • The company’s net debt has gone up by Rs 60 crore YoY at the end of December 2014.Eros Plc has given around Rs 500 crore in Eros International, which is sitting as trade advance (in balance sheet, it is under other current liabilities). For international distribution of movies, Eros Plc don’t have to pay to the company, it will be deducted from that Rs 500 crore.
  • The capex for FY15 is Rs 1200 crore. For 9M, it has incurred capex of Rs 900 crore, of which Rs 500 â 600 crore caped is for future slate and Rs 700 crore is for FY15 release date. For FY16. the capex would be around Rs 1200 â 1400 crore.
  • The cash flow for 9M is Rs 850 crore.
  • The company sees good Q4 with upcoming films like Badlapur, NH10, Uttam Villian, The company has strong slate for FY16 which has healthy mix of big and medium-low budgets movies in Hindi and regional languages.The mgmt is looking at 18-22% contribution from catalog movies, gng fwd.

Conference Call - from Capital Markets

Content capex for FY16 will be around Rs 1250 crore
Eros International Media held conference call to discuss the results for quarter and year ended March 2015. The key takeaways of the call are as follows:

Highlights of the Call:

    • The company for Q4 FY15 has reported 43% incline in consolidated net sales to Rs 449.1 crore. The resultant PAT increased by 25% to Rs 51.7 crore.
    • The other income increased significantly in Q4 to Rs16.5 crore (including some one-off reversal of provisions) against a loss of Rs4.3 crore in Q4 FY15 which helped net profit to grew.
    • The company for FY15 has reported 25% incline in consolidated net sales to Rs 1421 crore. The resultant PAT increased by 24% to Rs 247.1 crore.
    • During the quarter, 22 movies were released consisting of 17 Hindi and 5 Tamil/Telugu films as compared to 28 films during Q4 FY14, which included 22 Hindi and 5 Tamil/Telugu and 1 regional language film. 1 high budget, 4 medium & 17 low budget movies were released in Q4 FY15 as against 2 high budget, 3 medium & 23 low budget movies in Q4 FY14
    • 64 films were released during FY15 including 44 Hindi and 20 Tamil/Telugu films as compared to 69 films during FY14, which included 37 Hindi, 30 Tamil/Telugu and 2 regional language films. During the fiscal, 7 high budget, 10 medium & 47 low budget movies were released as against 4 high budget, 21 medium & 44 low budget movies in FY14
    • Theatrical Revenues contributed - 38%, Television & Others – 31% and Overseas Revenues – 31% as a percentage of Total Income in FY15.
    • Strong theatrical performance during the period was driven by the success of global and overseas releases namely ‘NH10', ‘Badlapur', ‘Tevar', ‘Shamitabh', 'Action Jackson', ‘Lingaa' (Multi-lingual), ‘Kaththi' (Tamil), ‘Kochadaiiyaan' (Multi-Lingual), ‘Aagadu' (Telugu), ‘Singham Returns' (Overseas), ‘Mary Kom' (Overseas), ‘Ek Villain' (Overseas), ‘Main Tera Hero' (Overseas), and other regional language releases.
    • The company's extensive film library of over 2,000+ films has been increasing its contribution year on year with FY15 catalogue revenue at 22% of Total Income
    • The content amortization cost for FY15 stood at Rs 497.6 crore against Rs460 crore in FY14. It was Rs 102 crore for Q4
    • The company launched a Motion Pictures Production Company, Trinity Pictures, which will focus on developing intellectual property in-house with special emphasis on franchise films. The company will have 100% IP on franchise films.
    • ErosNow has strong potential to draw digital revenues with over 14mn million registered users in India (a combination of free, transactional and premium users) across all its platforms.
    • The company has signed landmark deals with three major most-respected Chinese state owned film and entertainment companies to promote, co-produce, distribute and unlock value in respective intellectual properties for Sino-Indian films across all platforms in both the countries through co-productions, dubbed releases and remakes. As per the mgmt, the monetization of the co-produced movies in India will be done by it and overseas will be taken care by parent company.
    • China is the 2nd largest Box Office after the US, with a size of US$4.8 Bn. for 2014 with staggering growth rates of 34% in 2014. The number of theatre screens in China has quadrupled since 2010 with 5397 screens being added in 2014 alone taking their screen count to 23,600. As per industry projections, in 5 years time China is expected to surpass US to be the world's largest Box Office. In comparison, India's widest release till date has been across just 5,000 screens.
    • The mgmt is planning to produce 8-9 high-budget movies every year over the next two to three years as against 6 such movies released in FY15. It will gradually increase it high budget movie numbers.
    • The content capital expenditure for FY16 will be around Rs1250 crore,
    • The cash and cash equivalent stood at Rs 173.5 crore and debts at Rs 487.5 crore in the last fiscal.
    • Tax rate for FY16 will be around 24%.
    • The mgmt said that it will maintain margin around same level of FY15 in FY16.

Disc: Not Invested

Highlights of the Call by Capital Mkt:
The company for Q1 FY16 has reported 96% incline in consolidated net sales to Rs 47.3 crore. The resultant PAT increased by 49% to Rs 53.4 crore.Top-line growth was led by movies like Tanu Weds Manu Returns, Uttama Villain, Masss, Dil Dhadakne Do (Overseas), Gabbar (Overseas), and other regional language releases.During the quarter, 16 movies were released consisting of 7 Hindi, 8 Tamil/Telugu films and 1 regional film as compared with 9 films during Q1 FY15, which included 5 Hindi and 4 Tamil/Telugu films.
Out of the total revenue, Rs144 crore is attributed to third-party sales to parents (excluding which, revenues were up by 36% YoY) and EBIT margins at 27% (improved YoY).Theatrical revenue was 51.5%, television & others was 21.5% and overseas revenue was 27% as a percentage of total income.Catalog revenue is 10-12% of adjusted revenue.Amortization cost for Q1 FY16 is Rs135 crore as compared with Rs170 crore in Q1 FY15.Revenue contribution of Hindi : Regional is 60:40.The mgmt said that Q2 is also expected to do better followed by the super success of Bajrangi Bhaijaan which had Rs 500 crore gross box office worldwide. The other regional movies like Uttama Villain (Tamil), Masss (Tamil) have also had a decent run in the box office. The recent Srimanthudu (Telugu) already crossed Rs 100 crore in gross box office worldwide in its first week.
The mgmt said that going forward, the pipeline looks healthy with upcoming releases like Welcome Back, Hero and Bajirao Mastani among others and first Sino-Indian film project, Da Tang Xuan Zang (Monk Xuan Zang) in collaboration with the Chinese state-owned production companyFor FY16, the mgmt is planning for 65-75 films. Going forward in next 3 to 5 years, the mgmt is planning 100-110 films in which it plans to make 30-35 Hindi language films of which 6-8 will be high-budget films per year.The company announces official marketing launch for ErosNow. It has over 26.5 million registered users worldwide. It offers users the largest library of films, premium TV, music videos and audio tracks along with premieres of latest films before their TV window. Recently announced shows are Khel, The Client and Ponniyin Selvan.
Content capex will be Rs 1000 1200 crore for FY16.Effective tax rate will be 25% in FY16 and FY17.The mgmt expects EBIT margin of 25-27% for FY16.

Eros Tanks as Wells Fargo Analyst Questions Company Metrics
Alex Sherman
October 24, 2015 — 3:33 AM SGT Updated on October 24, 2015 — 4:44 AM SGT
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Shares have retreated more than 54 percent since Oct. 12
Twitter user claims United Arab Emirates sales are fraudulent
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Eros International Plc fell for a fifth straight day after analysts at Wells Fargo & Co. said they weren’t satisfied by answers the Bollywood film producer and distributor gave investors on a call held Friday to combat accusations of fraud posted on Twitter.
Eros slid 17 percent to $14.65 at the close in New York, bringing its loss for the week to 45 percent. Wells Fargo analyst Eric Katz cut his rating on the shares to market perform, saying he wasn’t comfortable with explanations about the company’s growing business in the United Arab Emirates. Eros, based in Secaucus, New Jersey, distributes Indian-made films.
“We still don’t know the largest content buyers driving this increase, and we aren’t fully comfortable with the fact nearly half of the revenue originates outside of India,” Katz wrote in a note.
Eros management spoke with analysts on Friday in an attempt to assuage fears that a spike in revenue booked in the UAE was fraudulent. A Twitter user called Market Farce, whose profile reads, “Focused on uncovering farcical, fraudulent and dishonest financial market activity,” has claimed UAE sales aren’t legitimate and has questioned the company’s ErosNow registered users.

Eros wouldn’t disclose the counterparties driving the UAE sales, citing contract confidentiality.
“We are not going to comment on an unknown person who hides behind an alias on social media to make ridiculous and outrageous accusations,” said Whit Clay, an outside spokesman for Eros.
The stock has been sinking since mid-October, when Market Farce, who declined to reveal his identity when reached by Bloomberg, began Tweeting about Eros.
Eros reported fiscal 2015 UAE revenue of $103.8 million, up from $45.6 million in 2014 and $14.5 million in 2013. The sales are based on a customer’s domiciled location, according to a company filing. Market Farce claimed on Twitter the company boosted UAE sales in quarters when “their movies don’t work.” Eros produces, acquires and distributes Indian language films and has a market capitalization of $843 million.
The company has 30.5 million registered users for Eros Now, its Netflix Inc.-like product that streams Bollywood movies and music, according to a person familiar with the matter. The company hasn’t disclosed how may of these users pay for the service or how many are monthly active users.
“We’re still feeling uncertain about the ErosNow user count,” Katz wrote. “Public websites that track app downloads (i.e. App Annie) show relatively low rankings for ErosNow vs. other Indian streaming services with lower user counts. We can’t reconcile the disparity and it’s a red flag for investors.”
Wells Fargo dropped its price target on Eros to between $20 and $22 per share from $48 to $50. Shares have fallen more than 54 percent since Oct. 12.
Analyst Tim Nollen at Macquarie Research said the shares were oversold for “no good reason.” In a note, Nollen said he spoke with Eros executives “who say nothing has changed and nothing is amiss.”
The company has been in talks with Singapore-based Fullerton Fund Management Co. on a deal that would value Eros Now at as much as $800 million, people familiar with the matter said in July. Those talks are still ongoing and a deal could be announced this month, one of the people said.

I also read this on Twitter. It was a big puzzle why Eros Plc shares are crashing in USA market. Today it got answered by Bloomberg post. Here are my understanding of this. Eros Media International and Eros PLC has just relationship of holding company. EMIL( Eros Media international, BSE listed company) has no stake in Eros Now platform. It only gets revenue from Movie production, distribution in India, TV syndication. Eros takes care of digital platform. There is no definitive agreement between these entities yet on revenue sharing.
EROS earns revenue from Digital platform and overseas distribution. As per the twitter handle Market_farce, the number of users in Eros now is over rated. He is citing sites like App annie. App annie can only track downloads done thru Market place. Eros Now has a bus app which you can down load thru wifi network. I have downloaded it in Goa trip. I guess EROS adds those number as subscription which will not be visible on App annie. I think we should take these numbers with a pinch of salt. Digital world with number of subscription is always over rated, be it Google also. I have developed app and published it and find these number funny.

I am scared of their claim of inflating numbers from UAE. It does not impact EMIL a bit. However it just raises doubt on Promoter integrity. I have contacted investor relation on this. They gave clarity to USA analysts, they should do this to Indian analyst too.

FII are net seller in Sept quarter which is also worrisome. Finger crossed.

Disc:- I have 1% portfolio holding. Was building conviction and this story pops up.

The drop in Eros PLC in last 2 weeks is around 50%…in India it is around 10%…
From recent peak correction is 30% in India and Eros Plc is 60%…I am not sure if all the drop is due to EROS Now alone…as it doesnt contribute so much revenue/PAT to Eros Plc.

Finally talked to Mr. Abhay ( Investor relation ). He was very polite and informative. He is ex - banker from top finance firms. I asked him about question raised on revenue from Dubai. He answered it well. Most of Media companies have offices in Dubai since there is tax incentive on Media contgent. Though the revenue shows in Dubai is large it does not have anything to do with number of subscribers. Infact sometimes Indian TV guys buy content in Dubai. Now the revenue number can be inflated in terms of forward booking hence receivable days are high. I am no expert in corporate finance and does not have any capacity to find if company is inflating revenue.

He was very firm in denying the allegation. He believes that they are target of short sellers who are creating rumor mongering. Same thing was done on netflix stocks in USA market.

I appreciate his willingness to talk to a small share holder. Got other insights on this stock.

Disc:- Have position in the stock.

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As far as india is concerned - financials are not impacted. Only concern is corporate governance which infact is larger one if its true.
Otherwise business is going fantastic and with so many tailwinds flowing in terms of digitisation, cross border deals, internet, rich library - eros has a bright future ahead. Eros has a niche position in industry with wide competitive advantage vis-a-vis others.
Can you provide other details of communication with Mr. abhay.
Disc: has taken position will increase with confidence.

Read this. This solves to complete puzzle. It is turning out to be another Raju Story as done in India. Finger crossed.


Ever wonder why that is only out after the Wells Fargo paranoid report? It is just a case of American paranoia with the Middle East (Dubai in this case). If there’s an audience there which Eros caters to, there shouldn’t be a problem. Right? And the fall on NYSE was underway before the report came out.

Disclosure: Not invested

I found an outstanding and instrucutive analysis on Eros group that concludes with compelling evidence that:

a) The accounting is extremely aggressive in an industry with intangible and volatile assets (films and rights) with ill qualified auditors. Free cash flow is lagging profits which are flattered by aggressive revenue booking (in some subsidiaries receivables increases are higher than sales for the year!) and capitalisation of costs to lower reported expenses

b) Complicated corporate structures and high related party transactions including surprisingly bank guarantee provided by the listed entity to the related entity! Imagine I own a listed firm which does business with my privately owned entity and I ask the listed entity to provide Bank Guarantee to it! Shows my own confidence in the listed entity.

Here’s the link - Eros

Lets assume the company has done accounting mispracticed.

Lets for a minute think rationally. This year we had Bajrangi Bhaijaan accounting for 500 CR + business. Last year we had PK.

As per capita incomes rise from $1500 to about $2500, entertainement spends do increase. Look at indonesia and phillipines. India is not unique. Indians love entertainment. We love bollywood, cricket and weddings.

2011 Disney offered $454 Million for 49.56 % stake in UTV. So value the company at about $ 900 Million.

2011 the highest grossing movie was Ra One and Don 2 about 200+ CR each.

The absolute size of the market is going to grow exponentially with higher spendings.

Eros has some sort of a business model which allows it to be market leader in distribution and co-production.
Creating a brand name in entertainment world is not easy otherwise Ambanis, Birlas and Tatas would be the market leaders.

Yes the company is not a FCF generatring. Distribution companies have to advance acquire content and keep their content library fresh everytime to attract the viewers. Sometime down the line we will see EROS FCF generating but it might take some time.

With todays closing price you are getting the market leader in india movie industry for less than $500 Million.

Be fearfull when other are greedy and be greedy when others are fearfull!!!

Disclosure - Invested

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Disc: No short/long positions

Financialfactfinder blog’s rejoinder is weak and seems to refute not the facts but the conclusions. In general the refutation is weak.

For instance it quotes Bhajrangi Bhaijan’s 600 cr grosser as if from a third party source ( even as the source says 320 crores and the rest are again assumptions :smile:). We do not know the veracity of this figure, how much of this was accrued and when was it realized.

Similarly it points out that Grant Thornton is the auditor for Eros Intl. which is reputed in their view. But it fails to address the fact that substantially material transactions happen in the subsidiaries which Grant Thornton does not audit. And yes an auditor having a gmail address, apartment like address and with little staff is more likely suspect than not.

On related party transactions the Financialfactfinder just says that because Eros has said that all transactions are at arm’s length and disclosed, they are. Facts put out by alphaexposure give instances to the contrary like an unexplained bank guarantee to a related entity for instance.

In a book called Spy the Lie by ex-CIA officer /s, the authors offer clues on how to know if someone is saying the truth. He says (not verbatim) that when facts are not your ally you are forced to answer a factual question indirectly. For instance, if you ask a suspect if he killed X, a killer would say, ‘Do you think I look like one?’, whereas others would just say no!

Overall Financialfactfinder uses this tactic at places where it tries to address facts. Its refuge is to say that what has been done is within the law and the rules. That is almost always the refuge for any one because democratic law always holds anyone innocent unless proven guilty by due process of law.

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