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 ITEMS FROM TODAY’S FEDERAL REGISTER |
(Source: Federal Register, 15 Oct 2020) [Excerpts] 85 FR 65610: Proposed Rule * AGENCY: Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA). * ACTION: Proposed rule. * SUMMARY: DoD, GSA and NASA are proposing to amend the Federal Acquisition Regulation to implement a section of the John S. McCain National Defense Authorization Act for Fiscal Year 2019 to change the definition of “commercial item.” * DATES: Interested parties should submit comments to the Regulatory Secretariat Division at one of the addresses shown below on or before December 14, 2020 to be considered in the formulation of a final rule. … * Discussion and Analysis As required by section 836 of the NDAA for FY 2019, DoD, GSA, and NASA are proposing to replace instances of commercial item(s) with commercial product(s), commercial service(s), or both commercial product(s) and commercial service(s). The following summarizes the proposed changes to the FAR: 1. Removed from FAR part 2 the definition of ”commercial item” and replaced it with the definitions of ”commercial product,” and ”commercial service” from the NDAA with only the minor revisions for clarification currently in the FAR definition of ”commercial item.” The clarification in paragraph 3(ii) of the proposed definition of ”commercial product” has been in FAR part 2 since the definition of ”commercial item” was incorporated by FAR case 94-790, Acquisition of Commercial Items, in 1995. Paragraphs 2(i) and 2(ii) of the proposed definition of ”commercial service” are also long standing; they stem from a FAR change published October 22, 2001, which was revised slightly in a FAR change published June 18, 2004. 2. Replaced all instances of ”noncommercial” and ”noncommercial” with ”other than commercial” as it relates to this rule. This is an editorial change and will provide consistent language throughout the FAR. 3. Removed FAR 12.102(g), and a corresponding reference at FAR 37.601(c), as obsolete. FAR 12.102(g) only applies to contracts or orders entered into before November 23, 2013. 4. Added the definition of ”established price” at FAR 16.001 to be consistent with the term as defined at the FAR clauses at FAR 52.216-2, Economic Price Adjustment-Standard Supplies, and 52.216-3, Economic Price Adjustment-Semistandard Supplies. This is an editorial change for consistency to have the definition in both the clause and the corresponding FAR part. 5. Made conforming changes to cross references, and the following Standard Forms (SF): SF 294, Subcontracting Report for Individual Contracts; SF 1443, Contractor’s Request for Progress Payment; and SF 1449, Solicitation/ Contract/Order for Commercial Items. These forms are managed by the FAR Council and were identified as containing the term ”commercial item.” This rule proposes to replace each instance of the term with ”commercial product” or ”commercial service” as appropriate. Also minor editorial changes were made as needed throughout the FAR. These revisions do not impact terms and conditions of commercial contracts or how the Government procures commercial products or commercial services.
* ADDRESSES: Submit comments in response to FAR Case 2018-018 to https://www.regulations.gov. … * FOR FURTHER INFORMATION CONTACT: Ms. Zenaida Delgado, Procurement Analyst, at 202-969-7207 or zenaida.delgado@gsa.gov for clarification of content. For information pertaining to status or publication schedules, contact the Regulatory Secretariat Division at 202-501-4755. Please cite “FAR Case 2018-018”. * * * * * * * * * * * * * * * * * * * * |
OTHER GOVERNMENT SOURCES |
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3. Commerce/BIS: (No new postings) * * * * * * * * * * * * * * * * * * * * |
(Source: DHS/CBP), 15 Oct 2020) The bi-annual Customs Broker License Exam (CBLE) was administered on October 8, 2020. The electronic exam was held nationwide at over 120 testing locations. At some testing locations, applicants encountered system issues, while other applicants tested but did not experience problems and loss of the exam time. In response to these issues Customs and Border Protection (CBP) is withholding release of the exam content until further notice in an effort to address the concerns. If you have questions regarding the 2020 broker exam, contact Headquarters Broker Management Branch (BMB) via email at brokermanagement@cbp.dhs.gov. * * * * * * * * * * * * * * * * * * * * |
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The Council today imposed targeted restrictive measures on one person engaged in and providing support for acts that threaten the peace, security or stability of Libya, including through violations of the UN arms embargo. The sanctions imposed against this person comprise a travel ban and an asset freeze. In addition, EU persons and entities are forbidden from making funds available to those listed. With this new designation, the EU now has imposed a travel ban on 16 listed individuals and an asset freeze on 20 persons and 19 entities. The Council remains gravely concerned about the situation in Libya and in particular about the acts that threaten the peace, security or stability of Libya, including through violations of the UN arms embargo, human rights abuses and violations as well as the attempted illicit export of petroleum from Libya. The EU’s sanctions complement and reinforce the sanctions adopted by the UN, which include the UN arms embargo and individual measures, including for human rights abuses. The relevant legal acts, including the names of the persons and entities concerned, have been published in the Official Journal. * * * * * * * * * * * * * * * * * * * * |
On 14 October 2020, the European Union and Cuba held the second sessions of their political dialogues on illicit trade in small arms and light weapons and other conventional weapons, as well as on disarmament and non-proliferation of weapons of mass destruction. Discussions included exchanges of views on recent developments in the area of arms control, illicit trafficking of small arms and light weapons, and non-proliferation of weapons of mass destruction. The parties also discussed lethal autonomous weapons systems. They agreed on the importance of stepping up international cooperation in these areas, and exchanged views on the assistance provided to third countries for the purpose of arms export control and non-proliferation. The EU briefed on the support it is providing, including in Latin America and the Caribbean. The parties agreed to continue exchange of information and to consider further cooperation in these areas. The Dialogues were preceded by a civil society seminar on 13 October, where representatives of Cuban and European civil society exchanged experience on the ways in which civil society can promote peace and disarmament. The EU delegation was headed by the Special Envoy for Disarmament and Non-Proliferation, Marjolijn van Deelen and included the Head of Division for Mexico, Central America and the Caribbean, Katja Afheldt, the EU Ambassador to Cuba Alberto Navarro and other representatives of the European External Action Service. Rodolfo Reyes Rodríguez, Director General for Multilateral Issues and International Law of the Cuban Ministry for Foreign Affairs led the Cuban delegation, which included the Cuban Ambassador to the EU H.E. Norma Goicochea Estenoz, as well as other officials of the Cuban Ministry of Foreign Affairs. Representatives of EU Member States also participated in the Dialogue as observers. Background The Dialogues on illicit trade in small arms and light weapons and other conventional weapons, and on disarmament and non-proliferation of weapons of mass destruction were held under the EU-Cuba Political Dialogue and Cooperation Agreement (PDCA), which was signed in December 2016 and entered into provisional application on 1 November 2017. The Dialogues are two of five political Dialogues that then HRVP Mogherini and Cuban Foreign Minister Rodriguez decided to launch during the first EU-Cuba Ministerial Joint Council under the PDCA in May 2018. The other political dialogues cover the topics of human rights (first held on 9 October 2018 in Havana), of unilateral coercive measures (first held on 19 November 2018 in Brussels) and of the 2030 Agenda for Sustainable Development (first held in Havana on 16 April 2019). * * * * * * * * * * * * * * * * * * * * |
THE COUNCIL OF THE EUROPEAN UNION, Having regard to the Treaty on the Functioning of the European Union, Having regard to Council Regulation (EU) 2016/44 of 18 January 2016 concerning restrictive measures in view of the situation in Libya and repealing Regulation (EU) No 204/2011 (1), and in particular Article 21(2) & Having regard to Council Decision (CFSP) 2015/1333 of 31 July 2015 concerning restrictive measures in view of the situation in Libya, and repealing Decision 2011/137/CFSP (1), and in particular Article 12(2) thereof, Having regard to the proposal from the High Representative of the Union for Foreign Affairs and Security Policy, Whereas: (1) On 18 January 2016, the Council adopted Regulation (EU) 2016/44. (2) On 12 May 2020, the High Representative of the Union for Foreign Affairs and Security Policy issued a declaration, on behalf of the Union, which stated that the Union remains determined to see the UN arms embargo in Libya fully respected. It was also underlined that all efforts must be made to ensure the full and effective implementation of the relevant UN Security Council resolutions, also through the land and air borders with Libya. (3) On 21 September 2020, the Council adopted Implementing Regulation (EU) 2020/1309 (2), which designated three entities involved in violating the UN arms embargo. (4) The Council remains gravely concerned about the situation in Libya and in particular about acts that threaten the peace, security or stability of Libya, including violations of the UN arms embargo. (5) In that context, one person involved in such acts should be added to the list of natural and legal persons, entities or bodies subject to restrictive measures as set out in Annex III to Regulation (EU) 2016/44. (6) Annex III to Regulation (EU) 2016/44 should therefore be amended accordingly, HAS ADOPTED THIS REGULATION: Article 1 - Annex III to Regulation (EU) 2016/44 is amended in accordance with the Annex to this Regulation and under the heading ‘A. Persons’, the following entry is added:
- Annexes II and IV to Decision (CFSP) 2015/1333 are amended in accordance with the Annex to this Decision and under the heading ‘A. Persons’, the following entry is added:
Yevgeniy Viktorovich PRIGOZHIN (Евгений Викторович Пригожин), Date of birth: 1 June 1961 Place of birth: Leningrad (St. Petersburg) Nationality: Russian Gender: male Article 2 This Regulation shall enter into force on the date of its publication in the Official Journal of the European Union. * * * * * * * * * * * * * * * * * * * * |
NEWS |
(Source: EU Sanctions, 14 Oct 2020) [Excerpts] In line with objectives set out in Common Position 2008/944/CFSP, the EU has adopted Council Decision (CFSP) 2020/1464. It provides that the German Federal Office for Economic Affairs and Export Control (BAFA) will implement a 2-year project to promote effective arms controls in 23 third countries across Eastern and South Eastern Europe, North Africa and Central Asia. The project will focus on (inter alia) drafting/updating/implementing relevant legislation, training in licensing and enforcement, outreach to domestic arms industries, and accession to/ratification of the Arms Trade Treaty through regional workshops, study visits, awareness raising events, and remote assistance.
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According to data released by the Department for International Trade (DIT), the UK government was the world’s second biggest arms exporter behind the US between 2010-2019. Britain signed £86 billion worth of contracts for military equipment and services. Last year, Britain exported £11 billion worth of fighter jets, radar, missiles, arms, and materiel, the second highest year for UK arms sales since 1983. While the US was by far the largest arms exporter, accounting for 47 percent of the global arms trade, the UK accounted for 16 percent, while Russia and France had 11 percent and 10 percent respectively. Sales were down from 2018’s £14 billion due to what DIT said was “the volatile nature of the global export market for defence.” The UK won “no major platform orders in 2019” and arms exports to Saudi Arabia were halted in June last year, following the Court of Appeal’s ruling that the UK government had failed to take into account whether Saudi airstrikes in Yemen that targeted civilians broke humanitarian law. While the US is Britain’s largest single arms customer, most of Britain’s arms exports (60 percent) go to the Middle East, with Saudi Arabia by far the largest buyer along with Oman, Turkey, the United Arab Emirates (UAE), Qatar, Israel, Bahrain, and Egypt. The UK government had no hesitation in greenlighting the sale of arms to countries waging war at home or abroad, including to Saudi Arabia, the Philippines, Afghanistan, UAE, Nigeria, Mexico, Iraq, Ukraine, the Democratic Republic of Congo, Kenya, and South Sudan. The list of Britain’s customers reads like a roll call of the most corrupt and blood-soaked regimes on the planet. The UK has licensed more than £6.5 billion worth of arms to the Saudi-led coalition in the five years since March 26, 2015, when the bombing began. This is likely an underestimate as many of the bombs, missiles, and aircraft components are licensed via the opaque and secretive Open Licence system that is “more flexible” than a standard licence and “avoids the need to apply for a new licence for every export.”… |
COMMENTARY |
* Principal Author: Kay C. Georgi, Esq., 1-202-857-6293, Arent Fox LLP Target areas are telecom, information security, and sensor items that can be used for censorship, surveillance, detention, and use of force. On October 6, 2020, the US Department of Commerce, Bureau of Industry and Security (BIS) released a final rule (Final Rule), taking effect the same day, revising its licensing policy for crime control and detection (CC) items, “which is designed to promote respect for human rights throughout the world.” But if you read it quickly and thought it only dealt with crime control items, look again! BIS also revised the Export Administration Regulations EAR so that a review of human rights is part of every license application review, with the sole exception of short supply (SS) items. If you think this might have something to do with the Administration’s disagreements China, you may be right. The preamble indicates abuse of human rights could involve censorship, surveillance, detention, or the excessive use of force, and BIS also states that “the revision is necessary to prevent items currently controlled for reasons other than CC, including reasons related to certain telecommunications and information security and sensors, from being used to engage in or enable the violation or abuse of human rights.” Also on October 6, 2020, BIS made another CC-related move, issuing a final rule regarding new controls on water cannon systems and related parts and components, with the preamble specifically describing riot and crowd control in Hong Kong. (Export Control Classification Numbers (ECCNs) 0A977, 0D977 and 0E977.)
Revised Licensing Policy A) BIS’s Changes in a Nutshell The licensing policy amends 15 CFR § 742.7 to address two issues: - License applications for items controlled for CC revisions will be considered favorably on a case-by-case basis unless there is civil disorder in the country or region of destination or if BIS assesses there is a risk that the items will be used in a violation or abuse of human rights;
- Other than items controlled for SS applications for all export-controlled items on the Commerce Control List (CCL) will be considered under this human rights framework.
B) BIS’s Change To the CC Licensing Policy
As side-by-side comparison shows how the licensing policy has been broadened under the Final Rule: | LICENSING POLICY IN EFFECT AS OF OCTOBER 6, 2020 | LICENSING POLICY IN EFFECT BEFORE OCTOBER 6, 2020 | | Applications for items controlled under this section will generally be considered favorably on a case-by-case basis, unless there is civil disorder in the country or region or unless there is a risk that the items will be used to violate or abuse human rights. The judicious use of export controls is intended to deter human rights violations and abuses, distance the United States from such violations and abuses, and avoid contributing to civil disorder in a country or region. | Applications for items controlled under this section will generally be considered favorably on a case-by-case basis unless there is civil disorder in the country or region or unless there is evidence that the government of the importing country may have violated internationally recognized human rights. The judicious use of export controls is intended to deter the development of a consistent pattern of human rights abuses, distance the United States from such abuses and avoid contributing to civil disorder in a country or region. | BIS notes that the “revision is necessary to clarify to the exporting community that licensing decisions are based in part upon US Government assessments about whether CC-controlled items may be used to engage in or enable violations or abuses of human rights including through violations and abuses involving censorship, surveillance, detention, or excessive use of force.” Notably, the change also removes the requirement that there be actual evidence of past human rights violations, leaving BIS in charge of assessing whether there is merely a risk that the items will be used to violate or abuse human rights. C) Addition of a New Licensing Policy Far more significant from the perspective of most exporters, however, is the addition of “a new subparagraph (b)(2) to make clear that BIS will consider the [human rights] licensing policy set forth in new subparagraph (b)(1) when reviewing items controlled for reasons other than CC with the exception of items controlled for short supply.” 15 CFR §742.7. The new licensing policy is in the EAR provision dealing with CC controls. We note there have been no changes in any other reason-based controls, such as the national security (NS) licensing policy, to indicate license application reviews will consider human rights concerns, and as such, we wonder if exporters of non-CC items will completely miss this new license review policy. According to BIS, the new licensing policy will now allow BIS and other reviewing agencies to consider two factors: - violations or abuses of human rights by individuals or entities other than the government of the importing country, and
- abuses of human rights by the government in addition to violations of internationally recognized human rights.
What Does This Mean for Exporters? This Final Rule is in line with the current Administration’s efforts to combat human rights violations, particularly in China, which has been off limits for CC items since the 1989 Tiananmen Square protests. If you do export CC-controlled items, this Final Rule makes it easier for BIS to deny your license applications. That said, it was not particularly hard for BIS to do this in the past, so it is unclear whether this will have much of an impact on the number of licenses denied. For the rest of the items on the CCL (except SS-controlled items) the change is more significant and far-reaching. BIS can now deny license applications for non-CC items based on human rights concerns, including those involving censorship, surveillance, detention, or excessive use of force. If you export items – particularly telecommunications and information security and sensors – that require a license and could be used for censorship, surveillance, detention, or use of force (such as arrest), you should anticipate licensing denials for certain countries and regions of the world. As a practical matter, exporters who export to such countries or regions would be well-advised to conduct additional due diligence on end users and end uses prior to filing an export license application, and should address any potential human rights risks in their license applications.
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U.S. importers of products manufactured in China and subject to Section 301 Lists 3 and 4A may still file actions in the Court of International Trade (CIT) requesting tariff refunds. The numerous lawsuits already filed allege that the U.S. Trade Representative (USTR) overstepped its authority in promulgating Lists 3 and 4A. USTR’s Section 301 investigation found that U.S. exports were unfairly burdened by Chinese intellectual property policies and therefore recommended $50 billion in retaliatory tariffs. Those tariffs were issued pursuant to List 1 ($34 billion) and List 2 ($16 billion). The lawsuits filed allege that the imposition of Section 301 duties on List 3 ($200 billion) and 4A ($116 billion) goods was outside USTR’s original authority, as they were promulgated in response to other issues including currency manipulation and cyber theft. In addition, Section 304 of the Trade Act of 1974 requires USTR to determine what action to take, if any, within 12 months after initiation of that investigation. USTR issued List 3 and List 4A beyond the 12-month period. If successful, the actions could result in refunds to plaintiffs for all duties paid under Lists 3 and 4A up until the case is resolved. There is a two-year statute of limitations to file for refund cases under 28 USC §1581(i). USTR’s List 3 was published in the Federal Register on Sept. 21, 2018. Therefore, many companies filed for refunds by Sept. 21, 2020. List 4A was not published until August 2019, so the deadline will be August 2021. The cases filed after Sept. 21, 2020, allege that under the Administrative Procedure Act (APA) a plaintiff has standing once it suffers an “injury in fact.” Each entry and duty payment can be considered an injury in fact; therefore, importers may well have standing under the APA to sue beyond Sept. 21, 2020. Based on prior CIT actions, it is unclear whether the court will consider the date of publication of the Federal Register Notice or the date of payment of duties as the start of the two-year statute of limitations period. Even though it is uncertain whether the CIT will approve of using the APA to establish standing, importers of merchandise on List 3, who have not yet filed, may want to consider submitting a complaint requesting Section 301 tariff refunds using the APA to establish standing. * * * * * * * * * * * * * * * * * * * * |
* Principal Author: Şafak Herdem, 90-212-2884959, Herdem On October 13, 2020 Turkey set the news procedures and principles regarding the approval of the Certificate of Import and End Use requested from the importer by the exporting country / exporter to import dual-use materials and technologies that can be used in the manufacture, development, processing, storage, transportation and distribution of weapons of mass destruction into Turkey on basis of export control regime. The new rules are also applicable to imports to Turkey from free zones. Accordingly, it is regulated that the Certificate of Import and End-Use requested from the importer by the exporting country or exporter is subject to the approval of the Ministry of Trade General Directorate of Import. The validity period of both certificates is six (6) months and not subject to extension. Moreover, the validity period of the certificates processed by the authorities of the exporting country is not considered in import transactions. For Certificate of End-Use, if the end user is different from the importer, the information of both importer and end-user shall be stated in the certificate as they are hold jointly responsible. Applications shall be electronically through E-Government platform or website of Ministry of Trade (www.ticaret.gov.tr) In case the goods subject to Import and End Use Certificates are to be transferred to a third country, a Permit Letter / Permit from the exporting country / exporter shall be obtained and sent to the General Directorate of Import of the Ministry of Trade by the importer and this Letter / Document must be sent to the General Directorate of Import of the Ministry of Trade.
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The rapid development of dual-use emerging technologies has magnified the importance of reconciling technological leadership, economic competitiveness, and national security objectives. While trade controls on dual-use technology transfer can promote peace and mitigate security threats, overly cumbersome policies may impose economic burdens on the private sector that threaten competitiveness and innovation. Striking a balance between these opposing agendas has become especially challenging in the context of emerging technologies that have elicited significant interest in both the military and civilian markets. The dilemma has also been complicated by the merging of economic security discourse and policy with national security. Policymaking mechanisms should be calibrated at the level of individual technologies to avoid security and/or economic consequences of under or over-regulation. This report offers policymakers data, findings, and recommendations to strengthen the effectiveness of individual policies and to work towards a comprehensive technology strategy. In order to develop trade policies that can achieve the intended security benefits without unwarranted damage to economic competitiveness and technology innovation, policymakers must recognize technology-specific development characteristics and the associated global sectoral composition – companies, universities, research institutes, and public-private collaborations – worldwide. This report applies a mapping methodology to three emerging technologies whose level of emergence and security relevance qualifies them as “chokepoint” technologies: position, navigation, and timing (PNT), quantum computing, and computer vision. Entities in each technology category were selected and analyzed using open source information in order to identify trends with respect to global dispersion, foreign involvement (including partnerships, commerce, and investment), and specific technology focus area. A second level of analysis was conducted to compare and contrast the key trends for each of the three sectors to determine how technology-specific factors impact innovation and market establishment and to illustrate the importance of technology-specific trade policies. Analysis of the data shows clear differences among the three technologies that have important implications for the desirability and feasibility of strategic trade controls: Position, Navigation, and Timing: - Many existing PNT technologies are commercially available, but new research approaches that offer significant improvements to precision are in a more nascent development stage.
- The advanced PNT sector is concentrated in a relatively small number of countries and maintains close ties to government entities due to dual-use applicability.
- Extreme hardware requirements for new approaches, including cold atom, nuclear magnetic resonance, and other forms of quantum navigation make rapid dispersion of small, low-cost advanced PNT unlikely in the near future.
- These factors suggest that trade controls on cutting-edge technologies in the area are feasible.
Quantum Computing - The quantum computer sector is at a relatively nascent stage of development but is expanding rapidly as newer companies seek to capitalize on the civilian applications.
- Hardware is consolidated into a narrow group of companies, with many software companies identifying creative approaches for sharing time and usability of quantum computers in order to make them more widely available to diverse industries.
- Due to the large upfront cost of quantum computing hardware, this trend is unlikely to change in the foreseeable future.
- Access to the actual quantum computers could be restricted based on user or application by targeting quantum clouds, or platforms that share access to quantum computers.
Computer Vision - The computer vision sector already has a global commercial reach, with a large number of software companies being served by a fairly tight circle of hardware companies, and accommodates both military and civilian market demands.
- The majority of the computer vision technology innovation has already occurred, and systems are cost-effective and commercially available. This means that computer vision is likely not a suitable target for trade controls.
- However, as indicated by the BIS ruling on geospatial imagery software in January 2020, heightened security concerns over data collection and analysis methods may result in controls on applications that utilize computer vision technologies.
- Recent calls for controls on facial recognition indicate that other end uses of the technology may be ripe for politically desirable trade controls, even if technology dispersion has already occurred.
The results from the three technology analyses highlight the importance of technology-specific trade policy development. Trade controls must be applied with consideration given to unique characteristics of each independent emerging technology sector, including the breakdown of hardware and software supply chains, the stage of development, foreign availability, and the scope of the civilian market. One of the major trends that the authors identify across the technologies is the role of software as a means to connect technologies to specific industries. But even in the context of this overarching trend, individual technology security risks and commercial benefits must guide policymakers’ solutions to control intangible technology transfers or accumulated data that present security risks, without cutting into civilian applicability. The research, data, analysis, and findings presented in this report are useful to the formulation of an effective policy approach to emerging technologies and the development of a comprehensive technology management regime. The report findings are relevant to: - Formulating effective export and investment controls;
- Identifying targets for policy and industry outreach;
- Understanding potential threats to economic and national security that stem from technological competition;
- Identifying foreign partners for a global technology management strategy;
- Assessing impacts related to changes to ownership and entity structures;
- Establishing a mapping methodology that can be applied to emerging technologies.
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EX/IM TRAINING EVENTS & CONFERENCES |
* What: Live Stream Webinar “ITAR for the Empowered Official & Compliance Personnel” — Agenda * When: Tue-Thu 10-12 November 2020 * Where: Your computer * Presenters: Jenny Hahn, President, FD Associates. * Register HERE, call 1-703-847-5801, or email info@fdassociates.net. * * * * * * * * * * * * * * * * * * * * |
| EDITOR’S NOTES |
16. Bartlett’s Unfamiliar Quotations
(Source: Editor) * Mikhail Lermontov (Mikhail Yuryevich Lermontov; 15 Oct 1814 – 27 Jul 1841; was a Russian Romantic writer, poet and painter, sometimes called “the poet of the Caucasus”, the most important Russian poet after Alexander Pushkin’s death in 1837 and the greatest figure in Russian Romanticism.) – “Many a calm river begins as a turbulent waterfall, yet none hurtles and foams all the way to the sea.” * Friedrich Nietzsche (Friedrich Wilhelm Nietzsche (15 Oct 1844 – 25 Aug 1900; was a German philosopher, cultural critic, composer, poet, and philologist whose work has exerted a profound influence on modern intellectual history. He became the youngest person ever to hold the Chair of Classical Philology at the University of Basel in 1869 at the age of 24. At age 44, he suffered a collapse and afterward a complete loss of his mental faculties. He lived his remaining years in the care of his mother.) – “There are no facts, only interpretations.“ – “It is not a lack of love, but a lack of friendship that makes unhappy marriages.” * * * * * * * * * * * * * * * * * * * * |
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