VZCZCXYZ0007
RR RUEHWEB

DE RUEHHK #0241 0400218
ZNR UUUUU ZZH
R 090218Z FEB 09
FM AMCONSUL HONG KONG
TO RUCPDOC/USDOC WASHDC
INFO RUEHC/SECSTATE WASHDC 6845
RHMFIUU/HQ BICE WASHINGTON DC

UNCLAS HONG KONG 000241 
 
USDOC FOR 532/OEA/MNICKSON/ADYSON/TWILLIS/EHOLLAND 
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR PATRICK SANTILLO 
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS 
 
SIPDIS 
 
E.O. 12958: N/A 
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: PRE LICENSE CHECK: BIT BY BIT LIMITED 
 
REF: A) D410390 B) USDOC 00132 
 
 
¶1. Unauthorized disclosure of the information provided below is 
prohibited by Section 12C of the Export Administration Act. 
 
¶2. 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 
Bit by Bit Limited, Unit A1-05, 6/F Hang Fung Industrial Building, 
Phase 1, 2G Hok Yuen Street, Hong Kong (Bit by Bit). The item in 
question is an ISO layer 7 load balancing router for internet 
servers.  This item is classified under export control 
classification number (ECCN) 5A002 and is controlled for national 
security (NS) reasons. The license applicant is Coyote Point 
Systems, Inc. of Millerton, NY. 
 
¶3.  According to the Hong Kong Companies Registry, Bit by Bit (was 
registered in November 2007.  Its directors are Hong Kong residents 
Chiu, Wai Chung, Choy, Kam Cheong, and Li, Man Tat.  Its paid up 
share capital is the Hong Kong equivalent of USD 12. 
 
¶4.  According to the company web site (www.bitbybit.com.hk) Bit by 
Bit is an IT distribution company.  It represents a range of U.S. 
and other international IT hardware manufacturers such as the 
license applicant, Coyote Systems. 
 
¶5.  On February 2, 2009, ECO and Commercial Assistant Carrie Chan 
visited Bit by Bit and met with Mark Li, General Manager.  The 
meeting occurred at the offices of On-Time Technology, 907B, Shui 
Hing Center, 13 Sheung Yuet Road, Kowloon.  When asked why the 
meeting was held at this address, Mr. Li stated that On-Time 
Technology is related to Bit by Bit and acts as a solutions provider 
using Bit by Bit procured products.  Mr. Li stated that the 
companies are kept separate so that other solutions providers will 
not avoid Bit by Bit because of the affiliation.  Mr. Li provided 
background on Bit by Bit and stated that it focuses on the provision 
of hardware for various internet and other IT applications. 
 
¶6.  As to the specific transaction in question, Mr. Li stated that 
the customer is Myweather LLC and he provided a copy of a quotation 
provided to the company.  When asked for a Purchase Order to review, 
Mr. Li stated that Bit by Bit had never received a final purchase 
order from this company but had received payment and, for his 
purposes, this was enough to proceed.  Mr. Li further clarified 
that, in fact, it appeared the final customer/end user will be My 
Weather & Traffic Technology (Beijing) Ltd.  A review of the 
Myweather.net web site confirms that this order is likely destined 
to this end user for support of Myweather.net's expansion of its 
service into China. 
 
¶7.  ECO separately provided Mr. Li with links to the Commerce 
Control List and other know your customer guidance.  Mr. Li stated 
that he would review such information closely. 
 
¶8.  Based on the information noted above, ECO believes that Bit by 
Bit is a suitable recipient of U.S. origin controlled technology, as 
reseller. ECO can make no determination about the end-user aside 
from the comments stated herein.