Evolutionary history of plants phloem on the outside. Since xylem cells comprise dead, lignified tissue, subsequent rings of xylem are added to those already present, forming wood. The first plants to develop secondary growth and a woody habit, were apparently the ferns, and as early as the Middle Devonian one species, "Wattieza", had already reached heights of 8 m and a tree-like habit. Other clades did not take long to develop a tree-like stature. The Late Devonian "Archaeopteris", a precursor to gymnosperms which evolved from the trimerophytes, reached 30 m in height. The progymnosperms were the first plants to develop true wood, grown from
Naked short selling a May 2010 discussion on the inclusion of 'counterfeiting' in the charges filed against Icelandic bankers, the host Max Keiser speculated that the charge might refer to naked short selling because "naked short-selling is the same as counterfeiting, in that it is selling something that doesn't exist." A 2014 study of fails to deliver, published in the Journal of Financial Economics, which found no evidence that fails contributed to "price distortions or the failure of financial firms during the 2008 financial crisis." Naked short selling Naked short selling, or naked shorting, is the practice of short-selling a tradable asset of