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	<title>Comments on: Gone Briefing</title>
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	<link>http://www.exportlawblog.com/archives/902</link>
	<description>Latest News on DDTC, BIS, OFAC, and other export law matters</description>
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		<title>By: Mike Liberto</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91940</link>
		<dc:creator>Mike Liberto</dc:creator>
		<pubDate>Fri, 13 Nov 2009 18:37:48 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91940</guid>
		<description>It is nice to learn from Contestant 1  they have attended 3 trade shows in China since 2008, just for &quot;practical purposes&quot;.  My vote is also for Contestant 1.  They should spin the big wheel at the DDTC.</description>
		<content:encoded><![CDATA[<p>It is nice to learn from Contestant 1  they have attended 3 trade shows in China since 2008, just for &#8220;practical purposes&#8221;.  My vote is also for Contestant 1.  They should spin the big wheel at the DDTC.</p>
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		<title>By: Michelle Z.</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91938</link>
		<dc:creator>Michelle Z.</dc:creator>
		<pubDate>Fri, 13 Nov 2009 15:27:54 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91938</guid>
		<description>I agree with Pat B.  A lot of them also seem to be similar in their wording.  If registration was published, I would have believed that there is a PR firm out there sending letters much along the same lines as certain (unscrupulous IMO) law firms that send out letters to recent accident victims.  

However, being that registration isn&#039;t published, I wonder if some of these companies were at the seminars I have attended where we were advised that being compliant could be used as a marketing tool and they just ran with it.</description>
		<content:encoded><![CDATA[<p>I agree with Pat B.  A lot of them also seem to be similar in their wording.  If registration was published, I would have believed that there is a PR firm out there sending letters much along the same lines as certain (unscrupulous IMO) law firms that send out letters to recent accident victims.  </p>
<p>However, being that registration isn&#8217;t published, I wonder if some of these companies were at the seminars I have attended where we were advised that being compliant could be used as a marketing tool and they just ran with it.</p>
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		<title>By: Pat B.</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91937</link>
		<dc:creator>Pat B.</dc:creator>
		<pubDate>Fri, 13 Nov 2009 14:35:44 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91937</guid>
		<description>I&#039;ve been wondering.  How many similarly breathless registration announcements do we see every year?  At least half a dozen or so?  I&#039;m skeptical that these eager new registrants would all independently and spontaneously decide to issue misleading press releases about a rather pedestrian bureaucratic event.  Are there PR or trade consultants out there actually advising clients to hype their DDTC registrations?</description>
		<content:encoded><![CDATA[<p>I&#8217;ve been wondering.  How many similarly breathless registration announcements do we see every year?  At least half a dozen or so?  I&#8217;m skeptical that these eager new registrants would all independently and spontaneously decide to issue misleading press releases about a rather pedestrian bureaucratic event.  Are there PR or trade consultants out there actually advising clients to hype their DDTC registrations?</p>
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		<title>By: jeroop</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91935</link>
		<dc:creator>jeroop</dc:creator>
		<pubDate>Thu, 12 Nov 2009 18:56:48 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91935</guid>
		<description>You would think this would make finding new enforcement cases about as tough as shooting fish in a barrel.  A few more fun ones:

&quot;ZESTRON’s ITAR renewal was the result of several weeks of planning to meet the systems crucial security requirements.&quot;  http://www.newswiretoday.com/news/52458/

&quot;HighRely is pleased to announce that the United States Department of State has awarded HighRely Incorporated full and complete ITAR registration via Registrant Code MXXXX00 valid through 2009 and beyond via HighRely’s compliance with all aspects of the International Traffic in Arms Regulations, Part 122. . . Unlike other companies who are based in the U.S. but owned by foreign companies or non-Americans and with restrictions making them ineligible for ITAR compliance, HighRely is fully owned and operated 100% by U.S. citizens as denoted by HighRely’s ITAR registration.&quot; http://www.prleap.com/pr/129466/

&quot;Renowned manufacturer of circuit boards for military applications, Saline Lectronics has announced the completion of registration under the U.S. Department of State&#039;s International Traffic in Arms Regulations (ITAR).&quot;  http://www.lectronics.net/itar-registration-for-military.php</description>
		<content:encoded><![CDATA[<p>You would think this would make finding new enforcement cases about as tough as shooting fish in a barrel.  A few more fun ones:</p>
<p>&#8220;ZESTRON’s ITAR renewal was the result of several weeks of planning to meet the systems crucial security requirements.&#8221;  <a href="http://www.newswiretoday.com/news/52458/" rel="nofollow">http://www.newswiretoday.com/news/52458/</a></p>
<p>&#8220;HighRely is pleased to announce that the United States Department of State has awarded HighRely Incorporated full and complete ITAR registration via Registrant Code MXXXX00 valid through 2009 and beyond via HighRely’s compliance with all aspects of the International Traffic in Arms Regulations, Part 122. . . Unlike other companies who are based in the U.S. but owned by foreign companies or non-Americans and with restrictions making them ineligible for ITAR compliance, HighRely is fully owned and operated 100% by U.S. citizens as denoted by HighRely’s ITAR registration.&#8221; <a href="http://www.prleap.com/pr/129466/" rel="nofollow">http://www.prleap.com/pr/129466/</a></p>
<p>&#8220;Renowned manufacturer of circuit boards for military applications, Saline Lectronics has announced the completion of registration under the U.S. Department of State&#8217;s International Traffic in Arms Regulations (ITAR).&#8221;  <a href="http://www.lectronics.net/itar-registration-for-military.php" rel="nofollow">http://www.lectronics.net/itar-registration-for-military.php</a></p>
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		<title>By: LDM</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91933</link>
		<dc:creator>LDM</dc:creator>
		<pubDate>Thu, 12 Nov 2009 17:29:40 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91933</guid>
		<description>I didn&#039;t know that a &quot;political asylum&quot; could be a U.S. Person.  I&#039;m glad CA Design told me.  

Is a political asylum where the former political wonks in D.C. go to recuperate?</description>
		<content:encoded><![CDATA[<p>I didn&#8217;t know that a &#8220;political asylum&#8221; could be a U.S. Person.  I&#8217;m glad CA Design told me.  </p>
<p>Is a political asylum where the former political wonks in D.C. go to recuperate?</p>
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		<title>By: JOHN LIEBMAN</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91932</link>
		<dc:creator>JOHN LIEBMAN</dc:creator>
		<pubDate>Thu, 12 Nov 2009 17:14:25 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91932</guid>
		<description>D.C. Circuit?  Hmmm.  Sounds familiar.</description>
		<content:encoded><![CDATA[<p>D.C. Circuit?  Hmmm.  Sounds familiar.</p>
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		<title>By: Hillbilly</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91931</link>
		<dc:creator>Hillbilly</dc:creator>
		<pubDate>Thu, 12 Nov 2009 16:14:34 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91931</guid>
		<description>I think Contestant No.1 wins hands down.  The link at the bottom of its press release doesn&#039;t exist.  Their prize ought to be a &quot;company visit&quot;, which Enforcement division still insists isn&#039;t an audit.</description>
		<content:encoded><![CDATA[<p>I think Contestant No.1 wins hands down.  The link at the bottom of its press release doesn&#8217;t exist.  Their prize ought to be a &#8220;company visit&#8221;, which Enforcement division still insists isn&#8217;t an audit.</p>
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		<title>By: Pat B.</title>
		<link>http://www.exportlawblog.com/archives/902/comment-page-1#comment-91930</link>
		<dc:creator>Pat B.</dc:creator>
		<pubDate>Thu, 12 Nov 2009 15:15:09 +0000</pubDate>
		<guid isPermaLink="false">http://www.exportlawblog.com/?p=902#comment-91930</guid>
		<description>Contestant No. 1 also serves up this howler: &quot;For practical purposes, ITAR regulations dictate that information and material pertaining to defense and military-related technologies may only be shared with U.S. Persons when approval from the Department of State is received or a special exemption is used.&quot;

Wow.  Who knew?  I hope DDTC is prepared to receive a few million voluntary disclosures and license applications.</description>
		<content:encoded><![CDATA[<p>Contestant No. 1 also serves up this howler: &#8220;For practical purposes, ITAR regulations dictate that information and material pertaining to defense and military-related technologies may only be shared with U.S. Persons when approval from the Department of State is received or a special exemption is used.&#8221;</p>
<p>Wow.  Who knew?  I hope DDTC is prepared to receive a few million voluntary disclosures and license applications.</p>
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