How did a Toronto and AMEX listed company end up offering wireless to the KKK and White

Supremacists…WHY DO YOU OWN THIS STOCK?

First off Hat Tip to Copperfield Research for beating us to the punch on Tucows (TCX).

It took the girls and I a while to pull out the duplicate information from the Copperfield report
(they are good boys!). This report is new. We have focused on the problems with Tucows that
we want to be able to share with all of you. We highlight these below. All new to the reader and
updated post Tucows 8-K on 1/8/18.

You have NEVER seen a company with this many issues before… a company that has major ethics
problem because it does business with white supremacists, and even pedophile linked
organizations. It has serious accounting irregularities relating to executive bonuses; a
devastating defeat in a law suit with a former partner; a core business that is SHRINKING,
despite an acquisition to try and delay this fact, and finally, a foolish attempt to grow a fiber
business from scratch. Tucows could be a sleepy, low margin web services business, but NO, in
the management quest to make it a growth story they have gone to great and to almost any
length to create that image and strayed way into a pasture of legal, reputation and business risk.

What you will read about Tucows is simple (ALL NEW, NOTHING REPEATED
by COPPERFIELD):
1. The company CELEBRATES White Supremacist customers, even while
other registrars refuse to do so.
2. Troubling Accounting – Oh the Games They Play! In Our Opinion Potential F-R-A-
U-D (in our view but for the SEC to decide).
3. Undisclosed Lawsuit that WILL CAUSE REVENUES TO FALL in 2018 / miss 2018
estimates/ potentially perjure itself.
4. Core business is failing and had to be bailed out by an acquisition (in which said
lawsuit arose – see #3).
5. The sexy story (WIRELESS) is about to see negative churn and growth. It too is
being temporarily bailed out by an acquisition.
6. The new “GROWTH” story – Fiber- HAS ALREADY FAILED.
Reading this report, you agree that use of Ethel’s research is at your own risk. In no event will
you hold this author or any affiliated party liable for any direct or indirect trading losses caused
by any information in this report. This report is not investment advice or a recommendation or
solicitation to buy or sell any securities.

You agree to do your own research and due diligence before making any investment decision
with respect to securities covered herein. You represent to Ethel that you have sufficient
investment sophistication to critically assess the information, analysis and opinions in this report.
You further agree that you will not communicate the contents of this report to any other person
unless that person has agreed to be bound by these same terms of service.

Conflict of Interest Advice: You should assume that on the publication date of this report, Ethel
has a net short position with respect to the shares (and/or options, swaps, and other derivatives
related to the shares) of the issuer discussed in this report. Therefore, Ethel stands to profit in
the event the issuer’s share price declines, and may incur investment losses if such issuer’s share
price increases, following the date of this report. This report, therefore, specifically emphasizes
negative aspects of the issuer that Ethel believes have not been properly reflected in the share
price of the issuer. Ethel may buy, sell, cover or otherwise change the form or substance of its
position in the issuer in its sole discretion at any time. Ethel disclaims any obligation to notify the
market of any such changes in advance.

This research and report includes forward-looking statements, estimates, projections,

assessments, beliefs, views, and opinions of Ethel prepared with respect to, among other things,
certain accounting, legal, and regulatory issues the issuer may faces and the potential impact of
those issues on its future business, financial condition and results of operations, as well as more
generally, the issuer’s anticipated operating performance, access to capital markets, market
conditions, assets and liabilities. Such statements, estimates, projections and opinions may prove
to be substantially inaccurate and are inherently subject to significant risks and uncertainties
beyond Ethel’s control.

This research and report expresses Ethel opinions, which have been solely based upon publicly
available information, as well as inferences and deductions through our research and analytical
process. Ethel believes all factual information contained herein to be accurate and reliable, and
has obtained such information from public sources believed to be accurate and reliable.
However, the issuer may possess or have access to information that materially differs from the
information presented herein.
 Part 1:

Profiting off the “Deplorables”

This is the story of how a boring business bought another boring business to cover up a declining business to make up for a FAILED
venture by selling high speed INTERNET to towns with NEO NAZIS. The girls in the gardening club were horrified by this fact. This is
a Multiple-Part story covering accounting shenanigans (cookie jar reserves); devastating lawsuits that the company has not
disclosed, crazy marketing ideas (infomercials) and a “New Business” that has already been made Obsolete by Comcast and others.
Tucows is the name of this dreadful company and we have a $15-$25 price target range.

What is Tucows: It’s a tiny Canadian company comprised of three businesses – 1. Domains (aka – websites), 2. Ting Mobile a
wireless re-seller for Sprint, and 3) a fiber to the home business focused on rural towns called Ting Fiber. We think it is overvalued
and will trade much lower. It’s been hiding in plain sight, but now it’s our turn to expose it. Won’t take much. We will describe each
business, show how weak each is and give you the comparative valuations. All you have to do at the end is sell the stock.

We have to focus on the TOP CONCERN we have for Tucows and that is the widely documented support for unsavory
businesses like the KKK, Karolina Knights, and even worse organizations. Tucows claims as a registrar it is not their job to govern
what content runs on the domains the company sells. This opinion works in Debate Class, but in the real world this is and will
be bad public relations and bad business policy for Tucows. Investors who choose to ignore this issue do so at their own peril.

KKK, Karolina Knights and America’s Promise Ministries.

Ok so, in the beginning we tried to grab your attention with a headline. You might say, hey, how did this all start? WE THOUGHT it
started with Ting Fiber, a fiber to the home (FTTH) initiative that Tucows has engaged in the past three years. Ting Fiber seeks to
BOOST internet speeds for towns. For some reason, MANY of these towns have HATE groups headquartered in them, like the
Karolina Knights of the Ku Klux Klan in Holly Springs, North Carolina and America’s Promise Ministries in Sandpoint, Idaho
https://www.splcenter.org/fighting-hate/intelligence-report/2016/active-hate-groups-united-states-2015. We did not believe that
Ting is targeting fringe towns on purpose, but we do believe the existence, but as we will show, Tucows has a documented history
of engaging in business relationships with these types of organizations. Ting Fiber (Tucows) claims it is targeting remote and small
towns to offer fast internet not previously offered, but isn’t it the least bit strange that two of the first 4 cities they target are home
to white hate organizations? We are not accusing the company of anything other than being detached from REALITY.
Ting Fiber Cities

Broadbandnow .com Potential

City Coverage Custom ers "Bundled"
City State Status Population Availability Estim ate (7%) Com petition Notes

Comcast, Still listed as

Charlottesville VA Live 49,071 3%-6% 3,435 CenturyLink BRI.
Westminster MD Live 18,590 Not Listed 1,301 Comcast -
Time Warner
Cable, AT&T,
Lighttow er,
Holly Springs NC Live 24,661 Not Listed 1,726 Centurylink -
Sand Point ID In-Development 7,577 NA 530 Frontier
Level 3,
Centruylink,
Centennial CO In-Development 106,114 NA 7,428 Verizon
TOTAL 206,013 12,361
 Who has Rights? White Supremacists According to Tucows CEO Elliot Noss.
Tucows CEO has stated that “The great irony, in the Burlington (Tucows is bidding on Burlington, VT fiber network) context, is this is a
net neutrality issue.” https://vtdigger.org/2017/10/06/parent-company-burlington-telecom-bidder-registers-neo-nazi-
site/#.WgoF1luPL0M. Tucows maintains that its role is to not judge content, which may be consistent with U.S. based notions of
individual freedom, but not most other countries where the rule of law places the good of society above the good of the individual.
Contrary to Tucows, companies like Google and GoDaddy have dropped white supremacists sites like Dailystormer -
https://www.npr.org/sections/thetwo-way/2017/08/14/543360434/white-supremacist-site-is-banned-by-go-daddy-after-virginia-
rally. These groups have been forced to migrate to Tucows services, and do not seem to be getting any resistance there.

Everyone Seems to Know About White Supremacists Supported By Tucows Except Investors – or Do They?

Tucows recently tried to buy the local fiber provider in Burlington Vermont. The people of Burlington were concerned by
Tucows association with white supremacists, why are investors not concerned by this very bad behavior? Here is a link
to the article https://vtdigger.org/2017/10/06/parent-company-burlington-telecom-bidder-registers-neo-nazi-site/. We also share the
article in its entirety below.

Parent company of Burlington Telecom bidder registers neo-Nazi site

By Morgan True
Oct 6 2017 3 Comments

The homepage of Stormfront, a neo-Nazi website.

(This story was updated at 12:42 p.m. and may be updated again)

B URLINGTON — The parent company of a company bidding to purchase Burlington Telecom is the domain registrar for the neo-

Nazi website Stormfront, which came back online Friday.

Stormfront was forced offline by its previous domain registrar, Network Solutions, in late August for violating its terms of service — a
move that followed the deadly white supremacist rally in Charlottesville, Virginia. The website proclaims, “We are the voice of the new
white minority.”

https://vtdigger.org/2017/10/06/parent-company-burlington-telecom-bidder-registers-neo-nazi-site/

The site’s domain is now registered by Toronto-based Tucows (NASDAQ:TCX) through the third-party reseller WSMDomains. Tucows is
the parent company of Ting, a mobile phone and fiber internet service provider, which is among three finalists looking to purchase
Burlington Telecom.

Internet companies are under increasing public pressure to deny service to groups that promote hate speech but are under no legal
obligation to do so.

Tucows CEO Elliot Noss said domain registration is a “fundamental protocol” on the internet, part of its basic infrastructure, and website
content issues should be addressed by the hosting company or the reseller before a registrar considers taking action.

“I’m comfortable saying we object to the content more than most. That makes these issues even more difficult,” Noss said.

Domain registration services are akin to provisioning a network where common carriage should apply, and it’s important that such
platforms are neutral to content as a matter of policy, Noss said.

To deny Stormfront access to Tucows’ domain registration services would be the equivalent of a phone company cutting its service, or a
municipality telling them they can’t use public roadways, he said.

“The great irony, in the Burlington context, is this is a net neutrality issue,” Noss said.

Net neutrality is the principle that internet service providers should not favor certain websites or applications over others, and its among the
criteria that city residents asked officials to consider in the Burlington Telecom sale.

Noss said Tucows’ communication with the reseller and the hosting company is “a live issue” and declined to go into greater detail.

Tucows, Network Solutions and Cloudflare, which offers websites protection from distributed denial of service attacks, have all previously
cut off services to hate sites in the face of public pressure.

In August, Tucows announced it would stop providing domain privacy protection services to the Daily Stormer, another neo-Nazi website
that gained local attention when the Southern Poverty Law Center’s “Hate Map” marked a Burlington message board.

Noss said domain privacy services go beyond the infrastructure-level of the internet, as does Tucows’ smaller web hosting service, and
therefore a different set of content filters apply.
Is this Tucows Fiber expansion plan or the Southern Poverty Law Center’s Hate Group Map? Are they the same thing?
How can investors support a company that works openly with hate groups and in their communities?

Conclusion – Investing in Companies that Support Hate Groups IS Supporting Hate Groups. Is that you Mr. and Mrs. Tucows
Investor?
What are we saying here about Tucows? Is the company a Hate Group? We don’t think so. Do they profit from and openly choose
to work with hate groups. Think about that for a moment. Tucows makes money helping hate groups register web sites, produce
content and spread hateful messages. It is likely in our opinion that these hate groups will be excited customers of Tucows Ting
Fiber offering. More GOOD NEWS – for the hate groups – is that Tucows Fiber offering will be coming to one of their small town
bastions soon! The issue for investors now is, does investing in a company that provides services to hate groups, make you a
supporter of hate groups? YES, Yes IT DOES.

Tucows Next Shareholder Meeting?

END PART 1
 Part 2:
Accounting Shenanigans to Boost Management Bonuses?
Tucows support for white supremacists might be enough to convince any investor with morals to move on to other pastures. On
YOU still like this company, we will dive into the more blatant potentially illegal accounting activity the company has engaged in.

If anyone, like us, reviews Tucows financial statements what they will see is that the numbers change a lot from quarter-to-quarter,
with many adjustments. The adjustments seem to impact EBITDA measures more than revenues or cash flows. We wondered
why that was.
Then we looked at the key determinant of bonuses for the Tucows management team. To our “SURPRISE” the key measure for
Bonuses for Tucows Management is a measure called “Adjusted EBITDA”.

Named Officer Target incentive Basis for Target incentive Bonus

  2017 2016  
100% Corporate Adjusted EBITDA for Compensation(2)
Elliot Noss $149,194 $147,210  
100% Corporate Adjusted EBITDA for Compensation
Michael Cooperman $98,292 $96,985  
100% Wholesale Domain Services targets
David Woroch $102,680 $101,315  
100% Corporate Adjusted EBITDA for Compensation(2)
Kenneth Schafer $49,146 $48,492  
25% Corporate Adjusted EBITDA for Compensation(2), 75% Ting specific objectives
Michael Goldstein $37,131 $32,027  

Footnote (2) shows us:

Adjusted EBITDA for Compensation is a non-GAAP measure and excludes depreciation, amortization of intangibles, income tax provision,
interest expense, interest income, stock-based compensation, asset impairment, net deferred revenue, which comprises the change in deferred
revenue, net of prepaid domain name registry and other Internet services fees, to reflect the material amount of cash we collect and pay for
domain registrations and other Internet services at the time of activation, gains and losses from unrealized foreign currency transactions and
infrequently occurring items. Gains and losses from unrealized foreign currency transactions removes the unrealized effect of the change in the
mark-to-market values on outstanding unhedged foreign currency contracts, as well as the unrealized effect from the translation of monetary
accounts denominated in non-U.S. dollars to U.S. dollars and infrequently occurring items. Under relevant SEC rule, we are not required to
present reconciliation of Adjusted EBITDA for Compensation to GAAP financial measures if Adjusted EBITDA for Compensation is presented
in connection with disclosure of target levels in “Compensation Discussion and Analysis.”

As you can see, Tucows has NO REQUIREMENT to explain how Adjusted EBITDA is calculated, which then opens up a world of
possibilities for Tucows to utilize, estimate, change, re-work all kinds of esoteric accounting. We engaged the help of an
accounting expert – a University Professor – to help explain and reveal what Tucows has been up to with their books.

Would Tucows Engage in Accounting GAMES? You bet.

• When reading a 10Q and you see a footnote next to REVENUE, BE AWARE.
• TCX reclassified 3Q 2016 revenue accounting in 1Q 2017. TCX removed CONTRA REVENUE recognition. You THINK THAT
LOWERED or RAISED the Revenue number in 2016…OF COURSE…it INFLATED IT. The difference of $864,324 in the
Q1’2016 revenues reported in the Form 10-Q for Q1’2017 and Form 10-Q for Q1’2016 is related to marketing credits
that were initially recorded as operating expenses in 2016, but corrected as a reduction of revenue in 2017. This
explanation is disclosed in the Form 10-Q for Q1’2017.
• Cookie Jar Reserves? Tucows created a $300K reserve for a bonus payable in 1Q 2016, but then reversed that payable
items in 3Q 2016. This resulted in higher EBITDA (in fact the highest of the year) in 3Q of $8.6M. INVESTORS BEWARE –
 TUCOWS is a COOKIE JAR MONSTER. A pattern of recording contingent losses as an expense and liability in one period
and reducing the expense and liability in later periods could be seen as “Cookie Jar Accounting”. “Cookie Jar
Accounting” is a disingenuous accounting practice where a company smooths the volatility of its earnings by creating
reserves (increasing expenses and liabilities) in periods when financial results are better than expected and releasing
reserves (decreasing expenses and liabilities) in periods when financial results are worse than expected. Regulators
and investors frown on this practice since it misrepresents a company’s performance.
• The two items we highlight – the $300K reversal and the $864K reduction of revenue ARE not revealed or explained in the
10-Q for 3Q 2017 for the nine months ended in September 2017. The table below reflects where changes were
represented by Tucows, and also where there were no changes, revealing that there are MISLEADING ACCOUNTING
numbers in Tucows financial filings.

10Q - March 10Q - March

2017 2016
Reflects reversal of revenues.
Three months ended March 31,
Revenue $ 44,746,089 $ 45,610,413 ($ 864,324) -1.9%
Cost of Sales $ 30,397,933 $ 30,441,689 ($ 43,756) -0.1%
Gross Margin $ 14,348,156 $ 15,168,724 ($ 820,568) -5.4%
Operating expenses $ 8,086,836 $ 8,907,404 ($ 820,568) -9.2%
Operating income $ 6,261,320 $ 6,261,320 $ - 0.0%

10Q - June 2017 10Q - June 2016

Reflects reversal of revenues
bonus liability estimate
Six months ended June 30, 2016
Revenue $ 91,950,003 $ 93,076,794 ($ 1,126,791) -1.2%
Cost of Sales $ 61,957,321 $ 62,058,628 ($ 101,307) -0.2%
Gross Margin $ 29,992,682 $ 31,018,166 ($ 1,025,484) -3.3%
Operating expenses $ 17,591,236 $ 18,616,719 ($ 1,025,483) -5.5%
Operating income $ 12,401,446 $ 12,401,447 ($ 1) 0.0%

10Q - 10Q -
September September
2017 2016 WAIT! WHAT? No change
Nine months ended September reflected in 9-Months
Revenue $ 141,014,329 $ 141,014,329 $ - revenues!
0.0% HOW IS THAT
POSSIBLE?
Cost of Sales $ 94,383,774 $ 94,383,774 $ - 0.0%
Gross Margin $ 46,630,555 $ 46,630,555 $ - 0.0%
Operating expenses $ 26,990,159 $ 26,990,159 $ - 0.0%
Operating income $ 19,640,396 $ 19,640,396 $ - 0.0%

Tucows accounting is at best, not preferred, at worst it may violate some accounting norms. The use of estimates and intent will
be issues that no one can prove but we do believe that the use of reserve adjustments to hit EBITDA targets is dubious and should
raise investor concerns about what else the company may not be sharing with them – like maybe a major lawsuit that WILL
MATERIALLY impact revenues in 2018. YES! See you in Part 3.
END Part 2
 Part 3:
Lawsuits and Regulations to Crush Revenues and EPS in 2018.
Tucows has not disclosed a MATERIAL LAWSUIT with a former partner Namecheap in its SEC documents. If you search all SEC
documents that Tucows has filed over the past two years, you will only find one reference to Namecheap – a discussion of a
promissory note Namecheap provided to Tucows in 2014.

Thankfully we do not rely solely on Tucows filings for our research. On December 21st we noticed this item
www.domainnamewire.com. “Court orders Tucows to transfer 3.2 million domains to Namecheap”
https://domainnamewire.com/2017/12/21/court-orders-tucows-transfer-3-2-million-domains-namecheap/. This latest ruling is
the culmination of 9 months (9 months!!!) of legal combat between Namecheap and Tucows. In addition, in legal filings, it has
been made clear the Tucows has known of the issue at the center of this legal dispute since PRIOR to acquiring eNom. That implies
that Tucows could (should) have been disclosing this MATERIAL issue to investors since the acquisition of eNom closed.
You may ask, what is this lawsuit and why is it material? At issue are 3.5-4.0 million domains that Namecheap is requesting to have
transferred to them AWAY from eNom (AKA now Tucows). When these domains are transferred Tucows will no longer receive the
annual registration fees for these web sites. Using a low ball average of $8 per domain name calculates to a potential loss of
revenues for Tucows of $26-$32M in 2018 – ALMOST 10% of CURRENT ESTIMATED REVENUE. How is this not material?
To find the lawsuit filings you need to look into the Federal Pace system (which we have) and see the original court documents.
You will then see the case was moved to Washington State court, which would require you to get the files the old-fashioned way,
by hand. Fortunately for you dear reader, we did that legwork too and have included the lawsuit documents in our appendix of
this report.

In the Lawsuit documents, you will see that Tucows OWN EXPERT – David Woroch, Executive Vice President of Domains at Tucows-
testified that IF Tucows is ordered to perform the domain transfers that Namecheap is seeking (WHICH on DECEMBER 21st the
JUDGE ORDERED!!!) that Tucows will incur costs of $2.1M in operating costs (on only 10M shares) or roughly $0.20 per share!!!
This is commentary from Tucows own VP of Domains. How is an expected $0.20 DROP in EPS NOT MATERIAL????

Tucows will see revenues fall and costs rise in 2018, driving significant shortfalls in performance that will make the January street
estimates $361M / $2.83 look flat-out ridiculous!

Update to NameCheap Lawsuit:

On January 9th after the market close, Tucows FINALLY disclosed the lawsuit with Namecheap (would they have if Copperfield had
not brought this to light?) via in 8-K. In the 8-K Tucows stated “In an order dated January 4, 2018 and issued January 5, 2018 (the
“January 5, 2018 Order”), the court in Namecheap, Inc. v. Tucows, Inc., et al., No 17-2-26522-5-SEA (Wash. King Cty. Sup. Ct.), clarified an
injunction order against Tucows, Inc. (the “Company”) pursuant to which the Company has complied by taking steps to transfer certain domain
names from the eNom, LLC platform to the Namecheap, Inc. (“Namcheap, Inc.”) platform using a method called a Bulk Transfer After Partial
Portfolio Acquisition.”

We underline and highlight the key phrase “using a method called a Bulk Transfer After Partial Portfolio Acquisition” (AKA BTAPPA).
After almost a year of non-compliance and obstruction Tucows has, as a result of the court order, transferred the Namecheap
domains.

Tucows own attorney, Elisa P. McEnroe of the firm Morgan Lewis in a letter dated August 25, 2017 and sent to Namecheap’s
attorney Eugene Rome of Rome & Associates, stated the BTAAPA transfer (which was ordered and appears to have been
completed per last night’s 8-K) is “would be an order of magnitude larger than any previous transfer Tucows has done for
Namecheap” and “fraught with potential problems……..” She also states that the BTAPPA is “neither practical or required”.
Now we know that the BTAPPA has occurred and Tucows has complied. Whew! What Tucows did not disclose was how much
revenue is now GONE in 2018 as a result of this transfer and how much did this BTAPPA process COST. See it either cost the $2M
that Tucows testified it would UNDER OATH, which will MATERIALLY hurt earnings in 2018, OR Tucows LIED UNDER OATH and the
transfer process cost a lot less than what Tucows told the judge in the lawsuit. WHICH IS IT TUCOWS? As we all know you can’t be
a Cyclone and a Hawkeye, it’s got to be either one or the other.

Oh Yeah, one more thing - GDPR – YET ANOTHER PROBLEM for TUCOWS in 2018.

GDPR stands for General Data Protection Regulation (GDPR). GDPR begins on May 25, 2018.

The new GDPR regulations apply to ANY company, ANYWHERE that handles personal data of EU citizens. The collection of any
personal data must be agreed to by users and the company involved must PROVE CONSENT for the data to have been collected.
Even for Children parental consent must be given.

The GDPR states that a person/user will be able to move their personal data to and from different data collection systems (Google,
Twitter, FB, etc.). Users also have the “right to be forgotten” called “Right o Erasure.” The GDPR also requires records be kept of
all processing of personal information and must be available to the EU authorities on demand.

The GDPR appears to require new positions at companies that deal with private information – search companies, web companies,
e-commerce, social media, etc. Data controllers must be put in place for each company. There is also software and systems that
need to be created to become compliant with the new GDPR standards. Companies like Microsoft and Box are offering GDPR
compliant systems, while many companies are offering to design and create internal GDPR compliant systems for companies.

Fines for violating GDPR act in Europe will be 4% of a company’s revenue or 20M euros, whichever is bigger.

The impact on Tucows could be increases in SG&A tied to hiring data controllers and building out GDPR compliance systems. The
other impact could be that Tucows reduces its business in Europe as the threat of serious fines and costs of compliance become
too high. We believe that Tucows highlighting of the GDPR issue on the company’s 2Q conference call suggests they see
compliance as being meaningfully expensive and potentially impactful to revenues from Europe.

End Part 3.

Part 4:
Shrinking Core Business, Shrinking Wireless Business, Non-Growing Fiber Business
Tucow’s original core business was that of a registrar – acquiring and selling web domains to customers for $8-$12 per year.
Tucows was the smaller, less relevant GoDaddy. In an attempt to create growth the company began and grew a mobile virtual
network operator business called “Ting”. Then the company entered into the fiber to the home (FTTH) business three years ago as
Ting wireless began to slow down. Finally Tucows bought a similar sized registrar business – Back to Square 1? – Which has
provided the “appearance” of growth for Tucows over the past three quarters.

Tucows BIGGEST division (Domain Registration) sells websites to people, like www.shortthisstock.com. Tucows is basically a poor
man’s GoDaddy. The domain registration business reported nearly 10% negative organic growth on a pro forma basis after
acquiring a company called eNom from Rightside. Thus raising the question – what did Tucows actually acquire besides a business
in run-off? This is important as the stock has skyrocketed behind the false assumption of growth. 1+1 should at least equal 2. Yet in
TCX’s case it’s less. Unsuspecting investors are missing a declining business for acquired growth, but we are not.
 1Q 2017 Pro Form Revenues

1Q 2017 1Q 2016

Revenues 74.03 81.894

% Change -9.6%
2Q17 Pro Forma = NEGATIVE 5%

  Unaudited Unaudited
Three m onths ended Six m onths
  June 30, ended June 30,
Pro Form a
  2016 2017 2016 Decline %
         
Net revenues $ 84,243,541 $ 158,253,585 $166,228,230 -4.8%

We can be sure that eNom business shrank in 1Q, as Tucows called out some organic growth in its own domains business in 1Q.
The -9.6% change in pro forma revenues indicates that eNom fell even greater than 10% year over year. eNom actually SHRANK in
2016, as compared to 2015, so it is not a surprise to see the business continue to shrink, the rate, at 10% should scare investors, as
it shows an ACCELERATING PACE of decline for the domains business.

Don’t be fooled by TCX trying to walk you through their POST FASB 805 deferred accounting games. Trying to say “the growth in
2018 will be is as if (the acquisition) never happened” is pure baloney. Now what did happen is you bought a declining business to
cover up the fact that your core business was in decline. 2018 will be a year the street and investors see TCX for the ROLL UP JOKE
that it really is.

The takeaway is two commodity, low-margin businesses in decline are not a growth business together. The real PRO FORMA will be
exposed in time, we are simply bringing it to the forefront.

Ting Wireless Heading for Negative Growth.

Tucows operates a wireless re-seller business – using Sprint Wireless network- called Ting Mobile. Ting offers a low-frills service
and utilizes social media to win customers. Ting mobile had a nice run of growth in 2014 and 2015. However, over the past six
quarters, Ting has resorted to acquiring blocks of potential subscribers from failed MVNO’s P-Tel and RingPlus. Given the low rate
of organic growth in net subscribers (sub 3%) we saw total wireless subscriber growth turn NEGATIVE in 2Q!

INORGANIC ADDS! INORGANIC ADDS!

1Q FY16 2Q FY16 3Q FY16 Q4 FY16 1Q FY17 2Q FY17 3Q FY17 {A} 4Q FY17 {E}
Net Wireless Sub Adds 12,000 3,000 3,000 4,000 24,000 -5,000 1,500 -1,000
Non-Organic Adds 7,000 0 0 0 18,500 -4,500 -3,500 -3,000
Net - ORGANIC - Adds 5,000 3,000 3,000 4,000 5,500 5,500 4,500 2,000
Organic Grow th % 2.1% 2.1% 2.7% 3.6% 3.1% 2.6% 1.2%
Total 140,000 144,000 147,000 151,000 175,000 170,000 171,500 170,500

The Wireless business was fun and exciting and using Facebook to drive subs at the start. And yes it reached 100k subs, but as you
can see above, the game is over. They are now buying subs out of BK (sound familiar, buying growth) and we see this business in
massive decline in 2018. So much so we think is has nearly Zero value. For you accounting buffs, Ting has negative churn - SAC/CAC
is higher than the LTV of the customers acquired. For those of you who aren’t accounting buff’s, that’s called “throwing good
money after bad”.
 Ting Wireless Not Even Competitive!
Sprint to Partner With Comcast / Charter. That’s right, open up the Wall Street Journal headline story.
HOW can Tucows compete with a Fiber offering and a wireless offering (utilizing Sprint) against Comcast and Charter if they also
use Sprint’s network? The answer they cannot and will not. As you can see, an unlimited plan from Sprint is CHEAPER for an
average American consumer than Ting Wireless.

Voice Text
Lines Minutes Messages Data Total Bill
Average U.S. Consumer*^ 1 696 100 2.5GB
Sprint Unlimited Plan $50 - - - $50
Ting Mobile $6 $18 $3 $30 $57

*https://www.statista.com/statistics/184121/minutes-of-use-per-subscriber-of-mobile-voice-services-in-the-us/
^Source: Device Atlas, https://deviceatlas.com/blog/16-mobile-market-statistics-you-should-know-2016

In Tucows desperate efforts to grow Ting, the company has not only been acquiring other failed “MVNO” but also engaged in
INFORMERCIALS! In a DROP the MIC moment: The TING infomercial. What a joke. And on YOUTUBE is has 467 views. “WINNER
WINNER TURDUCKEN DINNER”…how did that not work? Great job team TING! Sidenote: the girls have actually asked for a great
Turducken recipe if anyone has one to share.

A GIGABYTE Fiber business with ZERO ‘Documented’ Revenue, and DUBIOUS CLAIMS of CUSTOMER ACCEPTANCE.
Tucows has also started a fiber to the home (FTTH) business called Ting Fiber. Yes we agree, this company is all over the place. Ting
Fiber partners with small cities who own fiber networks. Ting Fiber finishes connections to homes and then sells 1GB internet
access for $89 per month to homes. On August 6th, 2015 (almost two whole years ago) Tucows CEO Elliott Noss stated “Those
benchmarks assume a 20% take up rate in the first year and a 50% take up rate over five years”. As we judge these comments
today, it is safe to say that 20% has not been hit, because Tucows would have broken out subscriber numbers or some revenue
contribution from Ting Fiber by now, since we are now in YEAR 3 of the Charlottesville roll-out. Wait how do you judge success? Is
there a service to specifically tell you penetration in metro markets? Why yes there is. And 3-6% (NOT 20%) is where TING lies.
Thanks Broadbandnow.com.

In Ting Fiber’s first 2 markets – Charlottesville, and Westminster, MD, Comcast is the primary competition. Game-Set-Match if
Sprint partners with Comcast. Ting is competing with Comcast for internet. So can they bundle TV? Nope. Can they bundle phone?
Again no. Is Comcast in fact cheaper, in fact yes. Comcast offers unbundled Gigabit Internet for $70 vs Ting’s $89.

Features: Ting Fiber v. Com cast

Internet Phone TV
Ting X
Comcast X X X

Cost: Ting Fiber v. Com cast

Internet Access Only Price
Ting Fiber $ 89.00
Comcast - "Best Deal" 1GB $ 70.00

Like we said, this is more about shedding some light than solving any theorem. “I’m here all week folks”.
This business is costing TCX $30m in Cap Ex per year. They will run out of money if they continue along this path.

BEST CASE - $15-$25. (that’s our Price target. 60% downside return).
Tucows is worth between$15-$25 per share in our most generous assessment. On a comparative basis, we see Tucows falling to a
peer group average at a minimum, which would be 13x EBITDA, down from 21x currently. This would represent a 40% decrease in
Tucow’s share price, conservative in our opinion, since we ultimately see Tucow’s shares falling 60%. Below you will see the comp
tables for domain registration business. That’s the only business that has value in our opinion and it is IN DECLINE REMEMBER. The
EBITDA in this study is a point in time and in our opinion the highest point in time, as the future is filled with CHURN and FAILURE.

Tucows Valuation
Com pany Nam e TEV/Total TEV/EBITDA LTM -
Revenues LTM - Latest
Latest

VeriSign, Inc. (NasdaqGS:VRSN) 7.9x 12.2x

GoDaddy Inc. (NYSE:GDDY) 2.1x 18.8x
Web.com Group, Inc. (NasdaqGS:WEB) 2.1x 11.4x
United Internet AG (DB:UTDI) 2.5x 11.9x
Rightside Group, Ltd. (NasdaqGS:NAME) 2.7x NA

Peer Average 3.5x 13.6x

Tucow s Inc. (NasdaqCM:TCX) 3.2x 21.7x

 This is the chart, boosted by Tucows add to the Russell 2000. DOES THIS LOOK READY TO ROLL BACK OVER OR
WHAT? If you look at the rebalance of the Russell 2000 in 2Q17 TCX had a once in a lifetime add.

If not for accounting shenanigans and the roll up of businesses, would Tucows even have been a candidate for inclusion in this
index?