VZCZCXYZ0015
RR RUEHWEB

DE RUEHHK #0417 0440659
ZNR UUUUU ZZH
R 130659Z FEB 07
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 0470
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000417 
 
SIPDIS 
 
USDOC FOR 532/OEA/LHINES/DFARROW 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM 
ZARIT 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: PRE-LICENSE CHECK: APS 
Paintball Ltd. 
REF: A) USDOC 00886 B) EXP.LIC. D370258 
 
¶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 USDOC 
Bureau of Industry and Security (BIS), Export Control 
Officer Philip Ankel (ECO), conducted a pre-license 
check (PLC) at APS Paintball Ltd., Blk B, 22/F, 77-87 
Wang Lung St., Richwealth Industrial Building, Tsuen 
Wan, Hong Kong (APS).  The purpose of the PLC was to 
determine the suitability of APS to be the recipient 
of various C-More gun sights.  The items (ECCN 0A987) 
are valued at approximately USD $14,000 and are 
controlled for crime control (CC) reasons. The 
license applicant is C-More Systems of Manassas, 
Virginia. 
 
¶3.  According to the Hong Kong Companies Registry, 
APS Paintball Limited has been in existence since 
March, 2003 (previous name APS Paintball Supply 
Limited).   Mr. Chi Keung Lee (Hong Kong resident) 
and Mr. Guodong Liang (mainland Chinese national) are 
listed as directors.  The registered address is the 
primary business location of the company. 
 
¶4.  On February 6, 2006, the ECO visited APS at the 
address above and met with Mr. Chi Keung Lee, Sales 
and Marketing Director.  Mr. Lee described the 
business of APS as the provision of paintball guns 
and related supplies to Hong Kong customers as well 
as other customers in the United States and 
elsewhere.  Approximately 60-70% of sales are exports 
to the United States.  The paintball guns are 
produced in mainland China.  APS has a branch office 
in the United States serving the U.S. market 
(including the law enforcement market).  All 
information provided by Mr. Lee was consistent with 
information on the company's web site 
(www.apsram.com). 
 
¶5.  Mr. Lee stated that APS intends to use the items 
that are subject to the license on paintball guns for 
sale within Hong Kong and for export back to the 
United States (as part of a package deal). He stated 
that he presently uses Aimpoint sights for this 
purpose that he imports from Sweden but those sights 
are substantially more expensive than the C-More 
units.  Other sights produced in mainland China are 
much less expensive but not as highly sought by his 
customers. 
 
¶6.  Mr. Lee stated that he understands the sights may 
not be reexported into mainland China and may require 
additional licenses if reexported to other 
destinations.  He stressed that he does not export 
his products back into mainland China because of the 
very strict licensing rules for guns in China (he 
stated that, in mainland China, paintball guns are 
subject to the rigorous licensing rules that govern 
real guns).  Mr. Lee was keen to comply with U.S. 
export restrictions and requested additional 
information concerning restricted destinations and 
end-users.  ECO provided BIS guidance on reexports 
and other contact information. 
 
¶7.  APS was very forthcoming during the PLC visit. 
Mr. Lee provided information on the underlying 
transaction and provided the ECO information 
concerning his business and his intent to comply with 
U.S. export controls.  The ECO recommends that this 
PLC be considered Favorable. 
Cunningham