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Does NASDAQ look to the underlying shares for American Depositary Receipts (“ADRs”) and American Depositary Shares (“ADS”) to determine compliance?

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Does NASDAQ look to the underlying shares for American Depositary Receipts (“ADRs”) and American Depositary Shares (“ADS”) to determine compliance?

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Excluding bid price, NASDAQ will look to the underlying shares if the ADRs or ADS do not qualify on their own merits. For example, in calculating the market value of listed securities, NASDAQ will include the value of all ordinary securities listed on the company’s home market, not just the value of the ADRs or ADS. Listing Rule 5215(b) addresses this issue.

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