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Pratt & Whitney Violates “Deemed Export” Rule: Settles Charges of Illegal Transfers of Technology

June 29, 2004

The U.S. Department of Commerce recently announced that Pratt & Whitney (Pratt) of East Hartford, Connecticut, agreed to pay a $150,000 civil penalty to settle charges that it committed 42 violations of the Export Administration Regulations (EAR), despite the fact that Pratt voluntarily self-disclosed the violations and cooperated fully with the investigation.

The Commerce Department's Bureau of Industry and Security (BIS) charged that between August 1998 and September 1999, Pratt failed to obtain the required Department of Commerce export licenses for controlled technical data relating to material coating and gas turbine engine components.

According to Commerce, some of the charges stemmed from violations of the "deemed export" provisions of the EAR for releasing controlled technology in the United States to foreign nationals from various countries, including Germany, the Netherlands, and Spain without first obtaining a validated license.

The "deemed export" provision of the EAR states that an export license is required to release technology to a foreign national in the United States if a license would be required to export that technology to his/her home country.   For more information on this subject, click on the following: "Deemed Export" Rule.

For more information on the Pratt & Whitney notice, click on

If you have questions on any of the issues raised in this newsletter, please contact George R. Tuttle, III at (415) 288-0428 or via email at

George R. Tuttle, III is an attorney with the Law Offices of George R. Tuttle in San Francisco. The information in this article is general in nature and is not intended to constitute legal advice or to create an attorney-client relationship with respect to any event or occurrence, and may not be considered as such.

Copyright 2005 by Tuttle Law Offices.

All rights reserved. Information has been obtained from sources believed to be reliable. However, because of the possibility of human or mechanical error by our offices or by others, we do not guarantee the accuracy, adequacy, or completeness of any information and are not responsible for any errors, omissions, or for the results obtained from the use of such information.


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