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[liberationtech] HP SEC Disclosure on Area SpA and ZTE

Collin Anderson collin at
Mon Nov 26 07:55:42 PST 2012


The U.S. Securities and Exchange Commission posted the October 2012
response of HP to a request for information on exports to sanctioned
countries -- worth the short read; within, the company discloses that its
equipment was transshipped through partners, rather than direct sales, to
the Italian company Area SpA in the well-publicized Syrian monitoring
center project. It also hints at the aggressiveness with which the US
government (Commerce's BIS) is pursuing Chinese manufacturers known to sell
equipment to Iran -- which it appears to dodge.


October 9, 2012

Ms. Cecilia Blye
Office of Global Security Risk
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, DC  20549

Hewlett-Packard Company
Form 10-K for the Fiscal Year Ended October 31, 2011
Filed December 14, 2011
File No. 001-04423

David K. Ritenour
Vice President and
Associate General Counsel
Tel +1 650 857 3059
Fax +1 650 857 4837
david.ritenour at

Dear Ms. Blye:

This letter supplements our October 9, 2012 response (the “Response
Letter”) to your letter dated September 6, 2012 with regard to the
above-referenced filing made by Hewlett-Packard Company (“HP”).

            Pursuant to 17 C.F.R. §200.83, we are requesting confidential
treatment for this letter. *We request that this letter be maintained in
confidence, not be made part of any public record and not be disclosed to
any person as it contains confidential information. In the event that the
Staff receives a request for access to this letter, whether pursuant to the
Freedom of Information Act or otherwise, we respectfully request that we be
notified immediately so that we may further substantiate this request for
confidential treatment*. Please address any notification of a request for
access to such information to the undersigned with a copy to General
Counsel, Hewlett-Packard Company, 3000 Hanover Street, MS 1050, Palo Alto,
California 94304.

            Comment 1 of your letter cited news reports alleging that HP
equipment was sold by Area SpA (“Area”) into Syria.  As noted in the
Response Letter, HP has confirmed that Area was required under the terms of
its contract with HP to comply with all applicable export laws and was
specifically prohibited from selling HP’s products into embargoed or
sanctioned countries.  *HP has also determined that Area did not procure
the HP products believed to have been sold into Syria from HP but instead
procured those products from an HP partner that was not informed of the
ultimate destination for those products.*

*Comment 2 of your letter sought information about whether HP had received
any communications from the U.S. Department of Commerce relating to ZTE
Corporation and/or Beijing 8-Star International Company and, if so, the
current status of any resultant proceedings.*  As noted in the Response
Letter, HP has been contacted by the Bureau of Industry and Security of the
U.S. Department of Commerce (the “BIS”) relating to ZTE Corporation and
Beijing 8-Star International Company and has had several discussions with,
and provided documents to, the BIS.

Please contact me at (650) 857-3059 if you have any questions about this

Very truly yours,

   /s/  David K. Ritenour

David K. Ritenour

*Collin David Anderson* | @cda | Washington, D.C.
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