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 ITEMS FROM TODAY’S FEDERAL REGISTER |
1. Treasury/OFAC: “International Criminal Court-Related Sanctions Regulations” (Source: Federal Register, 1 Oct 2020) [Excerpts] 85 FR 61816: Rule * AGENCY: Office of Foreign Assets Control, Treasury. * ACTION: Final rule. * SUMMARY: The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adding regulations to implement Executive Order 13928 of June 11, 2020 (“Blocking Property of Certain Persons Associated With the International Criminal Court”). OFAC intends to supplement these regulations with a more comprehensive set of regulations, which may include additional interpretive and definitional guidance, general licenses, and statements of licensing policy. * DATES: This rule is effective October 1, 2020. * FOR FURTHER INFORMATION CONTACT: OFAC: Assistant Director for Licensing, 202-622-2480; Assistant Director for Regulatory Affairs, 202-622-4855; or Assistant Director for Sanctions Compliance & Evaluation, 202-622-2490. * * * * * * * * * * * * * * * * * * * * |
OTHER GOVERNMENT SOURCES |
| * Commerce Department: RULES; Identification of Prohibited Transactions to Implement Executive Order 13942 and Address the Threat Posed by TikTok and the National Emergency with Respect to the Information and Communications Technology and Services Supply Chain: Preliminary Injunction Order Entered by a Federal District Court [Pub. Date: 2 Oct 2020] ( PDF) * * * * * * * * * * * * * * * * * * * * |
3. Commerce/BIS: (No new postings) * * * * * * * * * * * * * * * * * * * * |
Q: Does DDTC restrict the United States Patent and Trademark Office (USPTO) from including ITAR-controlled technical data when publishing a patent application? A: Information published by the USPTO as part of a patent application and available at any patent office is public domain information (see ITAR section 120.11(a)(5)). By definition, it is not technical data (see ITAR section 120.10(b)). Technical data submitted as part of a patent application and not published and available at any patent office is not information in the public domain and remains ITAR-controlled. DDTC does not restrict the USPTO from publishing and making available at any patent office information submitted by a patent applicant. The U.S. Government may, however, impose an invention secrecy order on certain applications for patents, such that the USPTO will withhold the publication of the application or the grant of a patent therefor. Section 120.11(a)(5) does not apply to any ITAR-controlled technical data submitted as part of a patent application that is subject to an invention secrecy order because that information is not published and available at any patent office. Note: This FAQ applies only to domestic patent applications. * * * * * * * * * * * * * * * * * * * * |
The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is adding regulations to implement Executive Order 13928 of June 11, 2020 (“Blocking Property of Certain Persons Associated With the International Criminal Court”). In addition, OFAC is amending the Weapons of Mass Destruction Proliferators Sanctions Regulations and Iranian Transactions and Sanctions Regulations. * * * * * * * * * * * * * * * * * * * * |
NEWS |
(Source: CNBC, 28 Sep 2020) [Excerpts]
The U.S. government has reportedly imposed restrictions on exports to SMIC, China’s biggest chip manufacturer, a move that threatens Beijing’s push to become more self-reliant in one of the most critical areas of technology.
Suppliers for certain equipment to SMIC will need to apply for an export license, according to a letter sent to companies by the U.S. Department of Commerce, reported by several media outlets. The commerce department claims there is “unacceptable risk” that equipment sold to SMIC may be diverted to “military end use.”
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Multilateral export regimes need to be modernized to address new export and proliferation controls surrounding emerging technologies, technology proliferation experts said. While groups such as the Wassenaar Arrangement work well to control physical categories of items, they may overlook advancements in exports and other technology areas that could lead to proliferation of dual-use goods, the experts said. |
COMMENTARY |
On September 15, 2020, the Department of the Treasury published a final rule that modifies the regulations that govern mandatory filings with the Committee on Foreign Investment in the United States (CFIUS). CFIUS is an interagency committee chaired by the Department of the Treasury and is responsible for reviewing foreign investments in, or acquisitions of, US businesses and real estate to determine if the transaction threatens to impair US national security. Although CFIUS is largely a voluntary process, CFIUS introduced mandatory filing requirements with the launch of a critical technology pilot program in November 2018 and formalized and expanded the mandatory filing requirements in February 2020. The new rule modifies the criteria that trigger a mandatory filing with CFIUS, potentially subjecting more transactions to mandatory CFIUS review. These changes will apply to transactions that have not yet entered into a definitive agreement as of October 15, 2020.
The new rule addresses a CFIUS concern that transaction parties were previously able to avoid a mandatory filing based on a relatively subjective and often imprecise limitation on the filing requirement involving certain North American Industry Classification System (NAICS) codes, despite engaging with technologies that may be considered sensitive to national security. These circumstances also yielded inconsistent regulatory restrictions whereby a foreign investor could be restricted from access to the technology of a target US business under the US export control regime, but could invest in or own the US business and potentially influence decisions about the development, production and sales of critical technology without CFIUS review. Shifting away from the relatively subjective NAICS code assessment, the rule will now be based on the national security foundations of established export control regimes. Investors from excepted foreign states, FOCI-mitigated entities as well as investment funds managed exclusively and ultimately controlled by US nationals will continue to be excluded from the filing requirement.
Foreign investors and US companies that are contemplating a transaction or joint venture arrangement that involves a foreign party should evaluate the applicability of CFIUS review and assess whether a filing is mandatory. Transaction parties would be best served by accounting for these regulatory developments in the course performing due diligence and determining realistic deal closing dates.
Export control licensing replaces NAICS codes for mandatory filing analysis Under the existing CFIUS regulations, parties to a covered transaction are required to file a declaration (or may opt to file a notice) if the transaction involves a US business that produces, designs, tests, manufactures, fabricates or develops one or more “critical technologies” that are either used by the US business in, or designed specifically for use in, one of 27 industries identified by their NAICS code. Under the final rule, the filing requirement will continue to apply to both controlling transactions and “covered investments” (ie, non-controlling investments that afford the foreign person access to material non-public technical information, board director or observer rights, or substantive decision-making power). The definition of “critical technologies” has been and will continue to be defined by reference to US export control regimes, including the Export Administration Regulations (EAR), International Traffic in Arms Regulations (ITAR), and a few other more specialized export control regulations.[FN/1]
The new CFIUS regulation alters the criteria that trigger a mandatory filing with CFIUS by eliminating the requirement that a critical technology be used in or specifically designed for use in one of the 27 NAICS code industries, instead tying the critical technologies mandatory filing requirement to export authorization requirements under US export controls. Specifically, a filing with CFIUS will be mandatory where:[FN/2]
(I) the US business involved in the transaction produces, designs, tests, manufactures, fabricates, or develops certain types of “critical technologies” and (II) a “U.S. regulatory authorization” would be required to provide such critical technology to any of the following persons, based on principal place of business, nationality (for individuals), or other reasons (eg, if the person is designated on the Entity List under the EAR): - any person that could “directly control” the US business as a result of the covered transaction
- any person that is “directly acquiring an interest” or already has a “direct investment” in the US business and is acquiring certain relevant non-controlling rights or
- any person that individually holds or is part of a group of foreign persons that holds a 25 percent or more voting interest [FN/3] in a foreign person described in (II)(1) and (2) above.
Assessing US regulatory approval requirements
For purposes of the new mandatory filing rule, the term “US regulatory authorization” is a license or other approval issued by the relevant US export control authority. Determination of whether a license or other approval is required is largely based on (1) the export classification of the critical technology and limited applicable license exceptions and (2) the nationality of the recipient. Understanding the export classification regimes under the ITAR and EAR is a critical component of the CFIUS mandatory filing analysis. Not only does the classification determine whether the products, software or technologies involved in the transaction are “critical technologies,” but the classification also drives the potential licensing requirements and applicable license exceptions, and thus the mandatory CFIUS filing obligation. Under the final rule, only three exceptions under the EAR may be considered in evaluating the applicable export licensing requirements. Specifically, products, software or technologies that are eligible for the following license exceptions will not trigger a mandatory filing:
- License Exception Technology and Software Unrestricted (TSU) (15 CFR 740.13) – authorizes the provision of limited software updates, sales technology and low-level operation technology and software to certain destinations and end users.
- License Exception Encryption Commodities, Software, and Technology (ENC) (15 CFR 740.17(b)) – authorizes the export to certain categories of end users of most standard and some non-standard encryption source code and certain other cryptographic commodities, software and components for use in network infrastructure. The current CFIUS regulations exempt encryption technology that is eligible for any part of License Exception ENC, but the final rule narrows that exemption to include only those items eligible for export under the authority of subsection (b) of License Exception ENC. Subsection (b) includes a self-classification provision for certain eligible items and mandatory written review by the Bureau of Industry and Security (BIS) for others. Thus, companies that have not submitted a written encryption classification request, where required for License Exception ENC export authorization for their technology, software and products may lose the opportunity to invoke this exemption unless they file with BIS at least 30 days before closing in most cases.
- License Exception Strategic Trade Authorization (STA) (15 CFR 740.20(c)(1)) – authorizes the provision of items subject to certain controls to a limited set of destinations that are considered to pose a lower risk of unauthorized or impermissible end uses.
All aspects of these license exceptions must be satisfied to relieve the CFIUS filing requirement, including the foreign person’s eligibility to rely on the exception. Notably, other export license exceptions that may be available under the EAR for the technology at issue are not to be considered when assessing the export licensing requirements for purposes of the CFIUS mandatory filing.
Practical impacts of the new mandatory CFIUS filing criteria The changes in this final rule may increase the burden on some US companies considering foreign investment, as it will require them to undergo a careful assessment of their hardware, software, technology, and services to determine their export control classifications and whether export licenses or authorizations are applicable or if exceptions would be available. In this regard, software or SaaS businesses will need to be especially careful in assessing the encryption features of their technology under US export controls. Notably, this mandatory filing provision may be triggered based on theoretical access to the critical technologies, meaning that no intent to provide any critical technologies to a foreign party is required. Thus, classifying products, technology and services under US export controls will be necessary for CFIUS purposes even if the US business involved in the transaction does not actually export in practice. Although the short-form declaration process provides a faster alternative to a full notice filing, even the 30-day review period (plus preparation and filing time) might delay the speed at which many investments would otherwise close – particularly in the venture capital space. Thus, to avoid timing issues should a mandatory filing be required with CFIUS, companies that anticipate foreign investment would be best positioned to consider export controls at as early a stage as possible. * * * * * * * * * * * * * * * * * * * * |
The agreement to replace NAFTA, the Canada-United States-Mexico Trade Agreement (CUSMA) came into force on July 1, 2020 and Canadian importers and exporters should be aware of how the new agreement will affect their business. This bulletin highlights some of the major differences between NAFTA and CUSMA. Rules of Origin A notable change under CUSMA is in the rules that apply to the origin of goods. While most rules of origin will remain the same under CUSMA, there have been significant changes in the automotive sector, pharmaceuticals and health care products, information technology products, cosmetics and chemicals. In many cases, the rules have become stricter, and products that used to qualify for preferential treatment under NAFTA may not qualify under CUSMA. Particularly, the rules applicable to automotive vehicles and products are more burdensome than existed under NAFTA. Every company that has been exporting or importing its products under NAFTA is well advised to review whether and how they may be affected by any changes to the rules under CUSMA. Further, the rules that traders must follow to establish the origin of a good are different under CUSMA. CUSMA moves away from a formal certification of origin and gives traders more options. However, importers that relay on origin certification by their suppliers should review their contracts with those suppliers to ensure they can claim against the supplier for any additional duty and other costs associated with improper certification. Digital Trade CUSMA’s Digital Trade chapter provides a slew of new protections for the digital economy, including eliminating customs duties on digital products distributed electronically, protection for cross-border data transfers, minimizing limits on where data can be stored and processed, limiting government’s ability to require disclosure of proprietary computer source code and algorithms, and limiting the civil liability of internet platforms for third-party content that such platforms host or process. Government Procurement While CUSMA does contain a chapter addressing government procurement, Canada is not a party to it. Therefore, once CUSMA comes into force, suppliers in Canada, the U.S. and Mexico will no longer have one trade agreement that provides a common “rule set” for government procurement in North America. Rather, there will be one agreement governing procurement between Canada and the U.S. (the World Trade Organization Agreement on Government Procurement – WTO-AGP), another between the U.S. and Mexico (CUSMA), and, when it comes into force, a third agreement between Canada and Mexico (the Comprehensive and Progressive Agreement for Trans-Pacific Partnership – CPTPP). As a result, it is important for suppliers to be aware of and understand which rules govern the procurement they are bidding on. U.S. Section 232 Tariffs on Steel and Aluminum Goods A number of side letters accompany CUSMA. Canada and the U.S. concluded a side letter to CUSMA that provides Canada with two narrow protections from tariffs imposed by the U.S.: - Section 232 Tariffs – Future Measures: One side letter requires the U.S. to delay the imposition of any tariffs or import restrictions under Section 232 of the Trade Expansion Act on Canadian goods for 60 days, during which time the two countries must attempt to negotiate an appropriate alternative.
- Section 232 Tariffs – Autos and Auto Parts: The second side letter, provides that if the U.S. chooses to impose tariffs under Section 232 of the Trade Expansion Act on Canadian automobile exports, Canada will have guaranteed, duty-free access for a specified quantity of automobiles and their parts.
Although one of the goals of CUSMA is to reduce regulatory burdens, it is important to understand that these side letters are limited in scope. For instance, the side letters have not prevented the recent Canada-U.S. trade dispute regarding imports of aluminum to the U.S. This dispute originated in March 2018, prior to the conclusion of CUSMA because the U.S. claimed that the volume of aluminum imported into the U.S. from foreign countries, including Canada, raised Section 232 national security concerns. Canada and the U.S. subsequently came to an agreement in May 2019 under which the U.S. exempted Canadian imports from the Section 232 tariffs on the condition that import levels would not rise meaningfully beyond historic levels. In August 2020, the U.S. determined that imports from Canada have risen meaningfully and in turn imposed 10 per cent tariffs on Canadian aluminum. While the U.S. has since conditionally retracted such tariffs, the threat remains if the actual volume shipments from Canada exceeds 105 per cent of the expected volume for any month. As a result, Canada will not, at this time, impose the retaliatory tariffs it had announced on August 18, 2020. However, Canada states that it remains ready to impose such retaliatory tariffs, pursuant to the May 2019 agreement, if necessary. Conclusion Although CUSMA has been hailed as both an improved NAFTA and not much different than NAFTA, neither is quite true. There are provisions that have changed significantly, and those changes will require a re-think of corporate strategy. In other areas, it will be business as usual. Canadian companies need to understand what changes affect them and what they need to do to adapt to the new trade environment. Knowing the rules can help increase revenues but also avoid costly mistakes. * * * * * * * * * * * * * * * * * * * * |
* Principal Author: Wendy Wysong, Esq., 852-3729-1804, Steptoe & Johnson LLP On September 10, 2020, Judge John Bates of the DC District Court issued a memorandum opinion dismissing a lawsuit against the US Department of Commerce filed by a US-based carrier in June 2019 in response to the Bureau of Industry and Security’s (BIS) decision to add a major Chinese telecommunications manufacturer and numerous affiliates to the Entity List in May 2019. The carrier argued that the BIS rule infringed on its due process rights because the carrier could be held strictly liable for violations of the Export Administration Regulations (“EAR”) caused by its customers. It also argued that BIS exceeded its authority under the Export Control Reform Act of 2018 (“ECRA”). The Decision Under the EAR, carriers and other intermediaries can be held liable for facilitating violations of their customers. For example, a carrier that transports US-origin goods to a person on the Entity List who is not licensed to receive those goods could violate the EAR in addition to the sender who initiated the shipment. The carrier in this case had argued that it could not know the contents of every package it transported and that holding it strictly liable for its customers’ violations would not advance US national security or foreign policy goals. It also challenged the rationality of imposing strict liability on common carriers while holding customers liable only if they “knowingly” engage in a prohibited shipment. The carrier argued that the EAR’s strict liability standard would require the company either to cease all business operations that create a reasonable risk of violating the EAR (e.g., shipping packages to persons on the Entity List) or to “proceed with its business operations and face a substantial risk that it will violate the EAR and suffer harm.” In granting the US government’s motion to dismiss the claims, Judge Bates found that BIS’s strict liability standard for carriers was “rationally related to a legitimate government interest” (i.e., US national security and foreign policy) and that it was reasonable for BIS to hold carriers to a higher standard because they are “repeat players with the institutional knowledge and scale to navigate the EAR.” Under prevailing case law, these findings were sufficient to reject the carrier’s due process claims. Judge Bates also considered the carrier’s arguments that BIS could not, per the scope of its authority under ECRA, hold carriers liable for both “transferring” items in breach of the EAR and “aiding and abetting” violations of the EAR. While conceding that the language of ECRA was “inelegant,” Judge Bates found BIS had not exceeded its authority in drafting the EAR to cover both types of conduct. Analysis The carrier’s suit was a long shot given the high bar to challenging US agency actions. However, its arguments about liability for customers’ violations of the EAR take on added urgency given BIS’s more recent changes to the EAR. These changes include amendments to the military end-use / military end-user rule, the foreign-produced direct product rule, and expanded prohibitions under the Entity List targeting all parties to a transaction, which significantly increase the compliance burden of many transactions involving goods, technology, and software controlled under the EAR. The focus is now on what carriers can do to comply with the EAR in a risk-based and reasonably efficient manner. The EAR does not mandate any particular compliance measures. However, as pointed out by the plaintiff in this case, failing to take steps could expose a carrier to liability if its customer is engaged in prohibited conduct. Examples of compliance measures would include screening the names of all parties to a shipment and scrutinizing shipments involving parties on the Entity List. The EAR does not prohibit all shipments, and shipments of items that are not subject to the EAR would fall outside BIS’s jurisdiction entirely. However, a carrier would not ordinarily know the contents of a package or be in a position to evaluate whether a particular item is subject to the EAR, if the shipment originated outside the United States. Ultimately, a carrier’s real liability will depend on how BIS goes about enforcing the EAR in the context of the Entity List. Although the plaintiff in this case has a history of EAR violations, this challenge did not relate to a specific BIS enforcement action. BIS could resolve some of the ambiguity by issuing guidance clarifying the application of the EAR to carriers. In that regard, the agency has received considerable feedback from a wide range of companies in response to recent rulemakings demanding clarifications. In some ways, carriers are now in a similar position as financial institutions, which can also be held accountable for their customers’ violations of sanctions regulations issued by the US Treasury Department’s Office of Foreign Assets Control (“OFAC”). OFAC has alleviated some of the industry’s concerns through guidance about liability of intermediary financial institutions and expectations for due diligence. Carriers may soon look to financial institutions for models of how to build risk-based programs for compliance with the EAR.
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(Source: Thomsen & Burke, 30 Sep 2020) [Excerpts] * Principal Author: Roszel C. Thomsen II, Esq., 1-410-539-2596, Thomsen & Burke LLP Regulatory Updates Revisions to the EAR to Implement 2018 Wassenaar Changes to the Encryption Regulations The U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) published a final rule amending the the Export Administration Regulations (“EAR”) to implement changes made to the Wassenaar Arrangement List of Dual-Use Goods and Technologies and Munitions List (“Wassenaar Arrangement List”). BIS published a final rule on May 23, 2019, implementing certain new controls on emerging technologies, as decided at the 2018 Plenary meeting. This rule harmonizes the Commerce Control List (“CCL”) with the remaining decisions reached at the 2018 Plenary meeting by revising Export Control Classification Numbers (ECCNs) controlled for national security reasons in each category of the CCL. IoT Exemption BIS is adding a new exclusion to ECCN 5A002.a for certain IoT items: j. Items specially designed for a ‘connected civil industry application’, meeting all of thefollowing: j.1. Being any of the following: j.1.a. A network-capable endpoint device meeting any of the following: j.1.a.1. The “information security” functionality is limited to securing ‘non-arbitrary data’ or the tasks of “Operations, Administration or Maintenance” (“OAM”); or j.1.a.2. The device is limited to a specific ‘connected civil industry application’; or j.1.b. Networking equipment meeting all of the following: j.1.b.1. Being specially designed to communicate with the devices specified by paragraph j.1.a. above; and j.1.b.2. The “information security” functionality is limited to supporting the ‘connected civil industry application’ of devices specified by paragraph j.1.a. above, or the tasks of “OAM” of this networking equipment or of other items specified by paragraph j. of this Note; and j.2. Where the “information security” functionality implements only published or commercial cryptographic standards, and the cryptographic functionality cannot easily be changed by the user. . . . Cryptographic Activation BIS is revising the language used to describe items that perform cryptographic activation. ECCN 5A002.b now covers “cryptographic activation tokens”. A new Technical Note offers the definition: Technical Note: A ‘cryptographic activation token’ is an item designed or modified for any of the following: (1) Converting, by means of “cryptographic activation”, an item not specified by Category 5-Part 2 into an item specified by 5A002.a or 5D002.c.1, and not released by the Cryptography Note (Note 3 in Category 5-Part 2); or (2) Enabling, by means of “cryptographic activation”, additional functionality specified by 5A002.a of an item already specified by Category 5-Part 2; ECCNs 5D002.b and 5E002.b include corresponding changes for software and technology items. Decryption Note BIS is updating the definition of “cryptography” in Part 772 by amending a Note to clarify that “cryptography” includes decryption. Online resources: Additional changes are found in the linked Regulatory Summary. WeChat and TikTok Prohibitions Earlier in the month, the Commerce Department issued a Press Release announcing prohibitions on transactions relating to mobile applications (apps) WeChat and TikTok to safeguard the national security of the United States. According to the Press Release, the following transactions related to these apps are prohibited: As of September 20, 2020, the following transactions are prohibited: - Any provision of service to distribute or maintain the WeChat or TikTok mobile applications, constituent code, or application updates through an online mobile application store in the U.S.;
- Any provision of services through the WeChat mobile application for the purpose of transferring funds or processing payments within the U.S.
As of September 20, 2020, for WeChat and as of November 12, 2020, for TikTok, the following transactions are prohibited: . . . The U.S. Department of State released guidance to assist U.S. companies seeking to prevent their products or services with surveillance capabilities from being misused by foreign government end-users to commit human rights abuses. … The full guidance document can be found here: https://www.state.gov/key-topics-bureau-of-democracy-human-rights-and-labor/due-diligence-guidance. Enforcement Actions OFAC announced two settlements totaling $583,100 with Deutsche Bank Trust Company Americas (DBTCA). The settlements resolve OFAC’s investigations into apparent violations of the Ukraine-Related Sanctions Regulations. Specifically, DBTCA agreed to pay $157,500 for processing a large payment, related to a series of purchases of fuel oil, through the United States that involved a property interest of a designated oil company in Cyprus. At the time it processed the payment, DBTCA had reason to know of the designated oil company’s potential interest, but did not conduct sufficient due diligence to determine whether the designated oil company’s interest in the payment had been extinguished. Separately, DBTCA agreed to remit $425,600 for processing payments destined for accounts at a designated financial institution. DBTCA failed to stop the 61 payments because it had not included in its sanctions screening tool the designated financial institution’s Society for Worldwide Interbank Financial Telecommunication (SWIFT) Business Identifier Code (BIC), and DBTCA’s screening tool was calibrated so that only an exact match to a designated entity would trigger further manual review. OFAC determined that neither case was voluntarily self-disclosed to OFAC, and that the apparent violations constitute non-egregious cases. Comtech Telecommunications Corp. (“Comtech”), based in Melville, New York, and its wholly owned subsidiary, Comtech EF Data Corp. (“EF Data”), headquartered in Tempe, Arizona, which sell advanced communications systems, software, and services, have agreed to pay $894,111 to settle their potential civil liability for their sales and services to Sudan. These companies indirectly exported warrantied satellite equipment and facilitated services and training to a government-owned entity in Sudan, despite OFAC’s Sudan sanctions program that prohibited such transactions at the time. … Thomas Harris Jr. of Croydon, Pennsylvania was arrested and charged by Indictment with multiple firearms trafficking offenses stemming from his scheme to sell almost 40 guns to a buyer on the island of St. Lucia. Specifically, the defendant was charged with making false statements to a federal firearm licensee, dealing in firearms without a license, delivery of firearms to a common carrier without written notice, and smuggling goods from the United States. … A federal grand jury has indicted two Iranian men with participating in a conspiracy to procure and illegally send export-controlled computer servers to Iran. Ebrahim Azadegan and Alireza Alvandi were named in a 10-count indictment returned on September 25 that charges them with violating the International Emergency Economic Powers Act (IEEPA) and the Iranian Transactions and Sanctions Regulations, which restrict the export of goods and services from the United States to foreign nations. Azadegan and Alvandi were also charged with conspiracy, wire fraud, smuggling goods out of the United States, and money laundering. … * * * * * * * * * * * * * * * * * * * * |
EX/IM TRAINING EVENTS & CONFERENCES |
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| EDITOR’S NOTES |
13. Bartlett’s Unfamiliar Quotations
(Source: Editor) * Rufus Choate (1 Oct 1799 – 13 Jul 1859; was an American lawyer, orator, and Congressman. – ” Happy is he who has laid up in his youth, and held fast in all fortune, a genuine and passionate love of reading.” – “A book is the only immortality.” * Daniel J. Boorstin (Daniel Joseph Boorstin; 1 Oct 1914 – 28 Feb 2004; was an American historian at the University of Chicago who wrote on many topics in American and world history. He was appointed the twelfth Librarian of the United States Congress in 1975 and served until 1987. He argued in The Genius of American Politics (1953) that ideology, propaganda, and political theory are foreign to America.) – “Time makes heroes but dissolves celebrities.” – “Technology is so much fun but we can drown in our technology. The fog of information can drive out knowledge.” * * * * * * * * * * * * * * * * * * * * |
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