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If you find meaningful or important information in a cable, please link directly to its unique reference number. Linking to a specific paragraph in the body of a cable is also possible by copying the appropriate link (to be found at theparagraph symbol). Please mark messages for social networking services like Twitter with the hash tags #cablegate and a hash containing the reference ID e.g. #06HONGKONG3589.

Reference ID	Created	Released	Classification	Origin
06HONGKONG3589	2006-09-07 07:59	2011-08-30 01:44	UNCLASSIFIED	Consulate Hong Kong

VZCZCXYZ0023
RR RUEHWEB

DE RUEHHK #3589 2500759
ZNR UUUUU ZZH
R 070759Z SEP 06
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 8497
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 003589 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132/FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETTC
SUBJECT: EXTRANCHECK: POST SHIPMENT VERIFICATION: 
ALCATEL BUSINESS SYSTEMS C/O ZI CORPORATION LTD 
 
REF: A) USDOC 04512 
 
¶1. Unauthorized disclosure of the information provided 
below is prohibited by Section 12C of the Export 
Administration Act. 
 
¶2. As per reftel A request and at the direction of the 
Office of Enforcement Analysis (OEA) of the Bureau of 
Industry and Security (BIS), Export Control Officer 
(ECO) Philip Ankel and BIS Special Agent (SA) John 
McKenna conducted a post shipment verification (PSV) 
at ZI Corporation Ltd. (Zi Corp.) on August 17, 2006. 
This PSV concerned intellectual property software 
exported by Wind River Systems, Inc. of Alameda 
California (Wind River) classified under ECCN 2D002 
and valued at $6,143.  ECCN 2D002 is controlled for 
national security and nuclear nonproliferation 
reasons. 
 
¶3. Zi Corp.'s web site (www.zicorp.com) includes the 
following background on the company: 
Begin Text: Zi Corporation has a singular focus: to 
make mobile devices smarter and easier to use. Zi 
makes intelligent interfaces - software products that 
simplify data entry and interaction on communications 
devices. The result is richer, more personalized 
interaction for quicker, easier communication in 54 
different language databases for use around the world. 
End Text. 
 
¶4.  On August 17, 2006 Export Control Officer (ECO) 
Philip Ankel and Special Agent (SA) John McKenna 
visited ZI Corp. at Unit 2003, 20/F, Lippo Center 
Tower 1, Hong Kong and met with Kenny Leung, Senior 
Software Engineer. Mr. Leung stated that Zi Corp. has 
seven employees at this location and they develop and 
provide communications software.  Leung further stated 
that Alcatel Business Systems (Alcatel) had purchased 
the software from Wind River for use by Zi Corp. in 
its software development on behalf of Alcatel.  Mr. 
Leung stated that Zi Corp. had no intention of 
reexporting or transferring this software. 
 
¶5.  According to the Shippers Export Declaration (SED) 
filed by Wind River, this software falls under ECCN 
2D002.  This software had recently been exported (June 
13, 2006) to ZI Corp. and was still in its original 
packaging.  The ECO and SA reviewed the package 
containing the software and verified that it contained 
the same model software identified on Wind River's 
shipping documents. 
 
¶6. Mr. Leung also provided a copy of the packing slip 
for this order to the ECO and SA for review.  Based on 
the software and documentation provided by Mr. Leung 
and the support documentation provided by OEA, the ECO 
was able to confirm that the software located at Zi 
Corp. appeared to be the same software that had been 
exported by Wind River. 
 
¶7. Note: The ECCN cited by Wind River on the SED 
(2D002) would appear to require a license for export 
to Hong Kong even though the item was shipped NLR (No 
License Required).  The ECO recommends that an 
Outreach visit be conducted at Wind River to determine 
if Wind River is exporting its commodities in 
compliance with U.S. export regulations. The ECO also 
requests guidance on whether this item is controlled 
pursuant to NSG/Wassenaar control lists.  If yes, the 
ECO may reach out to the Hong Kong authorities on this 
matter as import of multilaterally controlled items 
absent a Hong Kong import license would appear to 
represent a violation of Hong Kong law. 
 
¶8. At the time visited, the consignee (Zi Corp.) 
appeared to be a suitable recipient of the commodities 
shipped since the consignee cooperated with the PSV 
and provided all requested documentation.  Further, 
the SA and ECO were able to physically inspect the 
software to confirm that the applicable serial numbers 
on the software matched those on the shipping 
documents.  The ECO recommends that this PSV be 
classified as Favorable. 
Cunningham

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