SCHEDULE: Broadwood Boosts STAAR Surgical Stake to 30.2%

Broadwood Partners and affiliated entities have increased their beneficial ownership in STAAR Surgical Company to 30.2% through recent open market purchases.

Summary

• Broadwood Partners, Broadwood Capital, and Neal C. Bradsher collectively beneficially own 15,019,491 shares of STAAR Surgical Co. common stock, representing approximately 30.2% of the outstanding shares.
• Neal C. Bradsher's total beneficial ownership, including personal shares, is 15,045,391 shares, also representing 30.2%.
• The shares outstanding figure used for calculation is 49,751,953 as of October 31, 2025, as disclosed in the Issuer's Quarterly Report on Form 10-Q filed on November 5, 2025.
• Broadwood Partners made open market purchases totaling 1,599,000 shares in the past sixty days.
• Purchases occurred on November 19, 2025 (309,132 shares at a weighted average price of $26.41641), November 20, 2025 (393,382 shares at a weighted average price of $27.13732), and November 21, 2025 (797,486 shares at a weighted average price of $27.86113).
• Funds for the purchases came from Broadwood Partners' working capital and Mr. Bradsher's personal funds; no borrowed funds were used for the purchases, other than any used for working capital purposes in the ordinary course of business.

Sentiment

Score: 8

Explanation: The filing indicates a significant increase in ownership by an activist investor group, Broadwood Capital, through open market purchases at increasing prices. This suggests strong confidence in STAAR Surgical's future prospects and potential for value creation, which is generally a very positive signal for the stock.

Positives

• A significant increase in ownership by an institutional investor group, Broadwood Capital, indicates strong conviction in STAAR Surgical's value.
• Open market purchases at increasing prices suggest a positive outlook on the stock's trajectory and potential for further appreciation.
• Broadwood Partners now holds a substantial 30.2% stake, potentially signaling increased activist engagement or influence on corporate strategy, which could unlock shareholder value.

Future Outlook

The filing does not provide explicit forward-looking statements or guidance from the company. However, the increased stake by Broadwood Capital, an activist investor, may signal potential future engagement regarding the company's strategic direction or operational improvements.

Management Comments

• After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Industry Context

This filing reflects an increased stake by a significant institutional investor in STAAR Surgical, a company operating in the medical device industry, specifically ophthalmic surgical products. Such an increase in ownership by an activist fund like Broadwood Capital often precedes calls for strategic changes, operational efficiencies, or board representation, which could impact the company's competitive positioning within the industry.

Comparison to Industry Standards

• Broadwood Capital's increased stake to 30.2% is a substantial position, indicating a high level of conviction or an intent to exert significant influence, which is common for activist investors seeking to unlock value in companies they believe are undervalued or underperforming relative to peers in the medical device sector.
• The open market purchases at rising prices suggest that Broadwood perceives the stock as having further upside, contrasting with typical passive investment strategies.
• While specific comparable companies or projects are not mentioned in the filing, the accumulation of such a large stake by an activist investor often implies a belief that STAAR Surgical's performance or valuation lags behind its potential or industry leaders in the ophthalmic market.

Stakeholder Impact

• Shareholders: Potential for increased shareholder value if Broadwood's activism leads to strategic improvements or better financial performance. Increased institutional ownership can also provide stability.
• Management/Board: May face increased scrutiny and pressure from Broadwood Capital to implement changes or consider strategic alternatives.

Next Steps

• Broadwood Partners may continue to engage with STAAR Surgical's management and board regarding strategic initiatives.
• Potential for Broadwood Partners to seek board representation or influence corporate governance.

Key Dates

Recommendation

The substantial increase in beneficial ownership by Broadwood Capital, an activist investor, to over 30% of STAAR Surgical's outstanding shares, coupled with open market purchases at escalating prices, signals strong conviction and a potential catalyst for value creation. Such a significant stake often precedes strategic engagement or demands for operational improvements, which can unlock shareholder value. This aggressive accumulation by a sophisticated investor suggests a belief that the stock is currently undervalued and has significant upside potential.

Keywords

STAAR Surgical, Broadwood Capital, Schedule 13D, Shareholder Activism, Equity Stake, Open Market Purchase, Institutional Ownership, Common Stock, SEC Filing, Investment