That is because what tends to matter most for investment performance is the initial valuation.

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Thus far, Groupon investors have been underwhelmed, with many questioning its initial valuation and whether it truly has growth potential.

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When the initial valuation was high, the subsequent average was just 3%.

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The Metropolitan Transportation Authority invited competitive bidding for the land after the Jets' initial offer fell well below its valuation.

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And centre-back Nosworthy could come in as a replacement for Sylvain Distin, who was sold to Everton on Friday, if Portsmouth up an initial offer to meet Sunderland's valuation.

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Careful analysis of the risks associated with its revenue streams almost certainly will mean that the hype and recent growth rates cannot be sustained, and that the initial offering will not be reflective of its valuation going forward.

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The IRS guidance that permits zero valuation of profits interests applies only to the initial transfer of the profits interest from the Bain fund partnership to the manager.

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The numbers represent an early glimpse into the potential valuation of the company as it lays the groundwork for an initial public offering, possibly in the second half of 2011.

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