Basic ITAR Compliance Awareness

Ann McGuire

Hello, and welcome to our latest Arena virtual event—ITAR 101 with the Trade Compliance Group. I’m Ann McGuire, Director of Product Marketing at Arena. I have a few items to review before we begin. For questions, please use the Ask a Question feature. At the end of the presentation, we’ll address as many questions as we can, and you can upvote submitted questions to increase its priority. Keep in mind that the questions are anonymous. So, if yours goes unanswered today, you can follow up with Arena or with the TCG, the Trade Compliance Group, using the information provided in the event and on the slides.

Please respond to our poll so we can get a better idea of who is here with us live today. And both the poll and Q&A are on the right side of the screen. Note that a recording of this event will be available in the app. If someone else in your organization is interested in ITAR they can sign up on the platform and watch it. That finishes the housekeeping items. We have a brief poll to learn more about you.

Ann McGuire

Please share your ITAR knowledge level. Okay, so Craig knows: A little more than half of the people have said that they have some knowledge of ITAR, that they’re familiar with it. And then the rest of them, a little less than half, said they’ve had no experience with it. Well, thank you for participating. So next I’d like to introduce our speaker today.

Ann McGuire

Craig T. Ridgley is the VP and Managing Partner with the Trade Compliance Group where he performs trade compliance assessments and develops client compliance programs under the U.S. Bureau of Industry and Security’s Export Administration Regulations. And the Directorate of Defense Trade Controls International Traffic in Arms Regulations, ITAR. Craig also conducts client compliance and business process improvement analyses to reduce costs, increase efficiencies, and promote risk mitigation.

Prior to consulting with the Trade Compliance Group, he worked in Global Trade Compliance for Symantec software company, and Flextronics, a contract manufacturer that you’re probably already familiar with. Craig is ready to get started. So, I’ll hand the mic over to him.

Craig Ridgley

Well, thank you for the intro, Ann, and welcome, everyone.

Craig Ridgley

Let me go to the next slide here.

Craig Ridgley

This session is intended to create basic awareness of ITAR compliance and highlight some of the key requirements of an ITAR compliance program.

Craig Ridgley

This session is way too short to give you an in-depth understanding of ITAR. But we’ll touch on a lot of points. And if at any point in time you have a question, go ahead and use the question function and put that up. And afterward, feel free to contact me with the information that you’ll be given—if you have a question about some aspect that we touched on but didn’t go into depth on.

But I’ll do my best to give you guys a good understanding. Okay, ITAR stands for International Traffic in Arms Regulations.

Craig Ridgley

The ITAR controls the manufacture, export, and brokering of defense articles and defense services.

Craig Ridgley

And we’ll talk more about what those actually are. Those things—defense articles and defense services—are described on the USML. The United States Munitions List. The USML is actually something that the president from a regulatory standpoint is responsible for. Obviously, he delegates that to the secretary of state, but it’s actually the president who puts things on the USML.

And because of something called export control reform that occurred over the past 10 years, some defense articles have actually been moved from the USML to the Commerce Control List. And there’s a lot about that, that I can go into but don’t have time for. But I’ll touch on it at various points through this presentation.

Craig Ridgley

Requirements for an ITAR compliance program. First of all, if you are in the business of manufacturing, exporting, or brokering, you have to register with the Directorate of Defense Trade Controls, DDTC. The fee, and I’m going to say, I believe is set at $2,750. During the worst part of the pandemic DDTC reduced the fee from $2,750 to $500. But I think that discount ended this past March, or past May, I’m not sure.

So, I think it’s still $2,750. But you have to be registered; even if you’re only in the manufacture of defense articles, you have to be registered. So, if you’re designing things for a military application, you should go off and get registered. You must have a documented ITAR compliance program. It is critical that you have a compliance program in that you document it and I’ll talk about some of the implications of that later on when we talk about consequences.

And you must not expose defense articles, services, or technical data to foreign nationals—non-U.S. persons—without authorization. And this doesn’t mean U.S. citizens, it means non-U.S. persons who can be green card holders, people here on asylum, or naturalized or natural citizens. Now there is a much stricter requirement on the sharing of classified items, items that are top secret, so on and so forth.

Those only can be shared with U.S. citizens. But the standard defense article, tech data, or services can be shared with U.S. persons, but not foreign nationals. You must have an empowered official.

Craig Ridgley

Okay, this is unique to the ITAR.

Craig Ridgley

The other jurisdiction, the EAR, doesn’t have any such requirement for somebody designated as being responsible. But the ITAR does, and this empowered official must be an employee of the company in a position of having the authority for policy or management. He has to understand the requirements. And I apologize, he or she must understand the requirements of the regulations, the criminal and civil liabilities inherent in those, and the administrative penalties for violating the ITAR.

You can’t just take the shipping clerk and make him an empowered official and go on. You have to have somebody that really understands this stuff. And that person must have the independent authority to inquire into any aspect of an export. He must be able to verify the legality of the transaction and the accuracy of the information. And he must have the ability to refuse to sign a license application or other request for approval without prejudice or adverse recourse.

So, this is an important person in your company. Basically, he has to be able to say no, without getting fired. And so, it’s a tough job. Sorry. All right, so we talked about the munitions list.

Craig Ridgley

The munitions list, as I mentioned, contains defense articles and defense services.

Craig Ridgley

Any item specially designed or modified for military application is a defense article. And I need to mention a couple of things. One, “specially designed” is a defined term in the regulations and it has certain specific meaning with regard to being specially designed. So, if the item is specially designed, it becomes subject to the ITAR, or modified for a military application can also cause something to become subject to the ITAR.

Well in the old days, you can take a bolt, a regular bolt you can get from Home Depot, and you might cut it just like a quarter of an inch shorter than it was manufactured because you needed to bolt down a machine gun on a jeep. And so, if you modified that bolt for that military application that bolt wouldn’t become subject to the ITAR. Now I say in the old days—that was before export control reform.

And so, they have something called the “catch and release” policy that allows you to move things from the USML to the Commerce Control List. But these items that are specially designed or modified for military application may or may not have a civilian application; it doesn’t matter if they do. As I said, export control reform moves some items from USML to CCL. And a defense article will remain subject to the ITAR up to and until it is removed from the USML.

And again, this “specially designed” has this catch and release policy that can move things from the USML to the CCL. So, I guess I beat that horse to death already. So, we’ll move on.

Craig Ridgley

A defense service is the furnishing of assistance, including training, to foreign persons, whether in the U.S. or abroad in the design, development, engineering, manufacturing, production, you can read all this as well as I can.

Craig Ridgley

I highlight “use” there because this means even though you don’t have any technical information about something written or otherwise, just using a defense article can represent furnishing a defense service. So, it’s a lot more restrictive than on the commerce department side, the EAR, just the mere use of a defense article can represent the defense service.

The furnishing to foreign persons and any technical data controlled under the ITAR, whether in the United States or abroad, and then military training of foreign units and forces, including formal or informal instruction in the United States or abroad. And this can be by correspondence courses, providing technical assistance, educational, or information publications. So, all of that can be a defense service.

In the ITAR they refer to it as technical data. In the EAR we refer to it as technology.

Craig Ridgley

Basically, it’s the same stuff, information which is required for the design, development, production, manufacturing, assembly, operation, repair, testing, maintenance, or modification of defense articles, any information that you have, that is required for any one of those activities, is referred to as technical data. Now, this includes blueprints, drawings, photographs, plans, instructions, bills of material, things like that.

Classified information relating to defense articles and defense services on the U.S. Munitions List in 600-series items controlled by the Commerce Control List. So, if it’s classified information, automatically technical data, that reference to 600-series is the category in which former USML items that have been moved to the Commerce Control List, or are categorized in the 600-series. Information covered by an invention or secrecy order, and software directly related to defense articles, is all considered technical data.

Do we have any questions at this point? No. Okay. We’ll move on. All right, so what is an export under the ITAR—an actual shipment or transmission out of the U.S., including the sending or taking of defense articles out of the United States in any manner.

Craig Ridgley

So, if you’re traveling and you forget about that sample of a defense article that you have in your briefcase, and you leave the country, you’ve exported a defense article, and that would be a bad thing. Good, bad scale. It’s bad. Releasing or otherwise transferring technical data to a foreign person in the U.S. is called a deemed export. This is where the release in the U.S. of technical data to a foreign person.

And this is the interesting part on this, is deemed to be an export to all countries in which the foreign person has held or holds citizenship or holds permanent residency. What that means is, if you release technical data to somebody, let’s say who was born years and years ago in Iran, and then since moved to India, and then since moved to England and had permanent residence in England and India, he’s still going to be considered, it’s still going to be a concern and export to Iran, because that’s where he was born or had citizenship.

That’s much stricter than on the commerce department side, where they only regard the last country of permanent residency. So, it’s a little trickier under the ITAR. And this has implications, obviously, for your employees. If you’re going to be doing defense articles, if you’re going to be subject to the ITAR, you either have to get authorization for your foreign nationals to be exposed to the technology of your product or you need to not have foreign nationals.

So that’s another subject that I can go into in greater depth, but we don’t have time for. Transferring the registration, control, or ownership of an aircraft vessel or satellite subject to the ITAR to a foreign person, that would be considered … Releasing or otherwise transferring the defense article to an embassy, or to any of its agencies is considered an export, even if they’re in the U.S.

Performing a defense service on behalf of, or for the benefit of, a foreign person, whether in the United States or abroad. And the release of previously encrypted technical data. That’s a little obtuse. There’s a lot around things that are exported in encrypted format that are not considered an export. But if you decrypt it and then release it to a foreign national it becomes an export as well. Okay.

Ann McGuire

Craig, we did have one question come up a little bit earlier. And I think you’ve already answered it, but I just thought I’d just share with you now. Someone just quickly asked who needs ITAR compliance, like what companies need ITAR compliance?

Craig Ridgley

Yeah, as I mentioned, if you’re in the business of exporting, manufacturing, or brokering, you need to register with the ITAR. If you’re registered with the ITAR, you need an ITAR compliance program. And the short reason for that is that if you don’t have an ITAR compliance program, and you get in trouble, the State Department is going to be upset with you.

Now, I will mention that if you do have a documented ITAR compliance program, and you get in trouble, the State Department is going to be even more upset with you because you have a documented compliance program, and you’re not following it. And so, they’re going to be very serious about what they do with you. With regard to export controls, both on the EAR and the ITAR side. Ignorance actually is a defense, if you can prove you did not know.

And you can prove it, they’ll cut you some slack. But if there’s any indication that you did know and you did something wrong, the gloves come off, and that’s not a good thing. Thank you.

Ann McGuire

Good. All right, thank you.

Craig Ridgley

All right, we go to the next slide. ITAR licenses.

Craig Ridgley

There are actually several different kinds. I just want to address a couple of points about them. Applications for unclassified exports must be submitted electronically on a DSP-5. That’s the number of the electronic form. Interestingly, applications for classified exports must be submitted via paper, literally on paper—DSP-85. It’s kind of interesting that they’re old school about protecting classified information.

They don’t want it in the Cloud or in the ether. So, I thought that was interesting. Applications for the export of defense articles, including technical data, may include commodity software and technical data subject to the EAR. Because of export control reform, again, a lot of things got shifted around. And so, we’re seeing more applications for things that used to be ITAR controlled, they’re now EAR controlled, and so they can combine those in one application.

And another difference between EAR and ITAR, purchase documentation, purchase orders, contracts, letter of intent, et cetera. This is all required for both defense articles and items on the CCL, under an ITAR license application. For EAR licenses, there’s no requirement for a purchase order or contract, anything proving that you’re actually going to sell it. You can just ask for a license and say, basically, I’m going to sell these guys this, so I want to get a license for it—then they’ll issue the license.

Like I said, ITAR is a little bit more complex, even though the regs are considerably smaller than the EAR.

Craig Ridgley

All right, so there’s two other things besides the regular export license under the ITAR. One is Manufacturing License Agreement, the MLA. It’s an agreement where a U.S. person grants a foreign person an authorization to manufacture defense articles abroad and involves or contemplates the export of technical data or defense articles for the performance of the different service. And the use by foreign persons of technical data or defense articles previously exported by the U.S. person.

Basically, it’s an arrangement where you can export technical data or defense articles to a foreign manufacturer, and he can then do what he needs to do in a foreign country with these defense articles to get them manufactured. Case in point, a really good case in point was the Joint Strike Fighter JSF F-35. That was a multicountry development effort. And almost every aspect of it was covered by either the MLA or a TAA and I’ll talk about TAA in just a second.

Technical Assistance Agreement, a TAA, it’s another agreement or contract for the performance of defense services, or the disclosure of technical data, as opposed to an agreement granting a right or license to manufacture.

Craig Ridgley

Assembly of defense articles is included under this section, meaning a TAA provided production rights or manufacturing know-how are not conveyed. Okay? So, it’s limited to assisting technically, with something not necessarily manufacturing. Okay.

Craig Ridgley

Common ITAR errors.

Craig Ridgley

Once an item becomes subject to the ITAR, it remains subject throughout its life. Sans exclusion through that order of review, I referred to that, that catch and release. Making a commercial product out of an ITAR item does not remove it from the ITAR. You can’t take an ITAR item and just simply say, okay, I’m going to sell it now commercially. And therefore, it’s not ITAR. I’m sure some of you remember the first Humvees that were sold to the public in the U.S.—that was quite a while ago.

Those were ITAR items that were being sold in the U.S. And that’s fine that they could do that, nothing illegal about doing that. But you couldn’t drive that Humvee to Mexico, because it would have required a State Department ITAR license to leave the country. So, in order to take a commercial product, and some of you may be contemplating this, you’ve got an ITAR item and you want to broaden its market to the domestic commercial market.

If you want that not to be ITAR, you have to design out that which is particularly responsible for making the item subject to the ITAR. Everything that is on the ITAR has a specific reason why it’s on the USML. So, I’m going to show you an example.

Craig Ridgley

This is the selector switch on an M-16. Remarkable weapon.

Craig Ridgley

This is the selector switch over here, on an AR-15. Now notice they’re almost identically placed. The difference is, this goes from safe to fire to automatic, whereas on the AR-15, which is commercial version of the M-16, it goes from safe to semiautomatic—there is no auto. So, the absence of the auto selection on the AR-15 allows this weapon to be controlled by the Commerce Department.

Whereas this weapon is, all fully auto weapons are controlled by the ITAR. Okay. So that’s how you can take, which is exactly what happened, they took the M-16. That I was painfully familiar with back in the late ‘60s. And they simply change this selection. Otherwise, those two weapons are identical in terms of effectiveness, in terms of moving parts, so on and so forth.

And that’s the difference there. So, hopefully that makes sense. If there’re any questions?

Ann McGuire

Yes, there was a question. This is back to the ITAR compliance looking here. So just kind of a follow up on who needs ITAR compliance. And there was a question, what if you’re a multinational company? Are you somewhat exempt from some of the ITAR regulations?

Craig Ridgley

A really good question. I chuckle simply because the answer to this is so simple. No, you’re never exempt from the regulations. The multinational company, you have some serious issues you have to deal with. And this is where a lot of companies get in trouble. You have one network, you combine your ERP system and your PLM systems, and you’re on a big backbone somewhere, and everybody has access to everything, including, in one case, one of my clients.

The Chinese nationals in China had access to their ITAR files, which is like a really big no, no, and we took care of that and did the corrections. But, yeah, you have to isolate your AIAR technical data from foreign nationals, period, you just have to. On the EAR side, there are some foreign nationals that can access some technology.

But it depends on the country and the technology, and so on and so forth. On the ITAR side, it’s absolute, if you’re a foreign national, you just simply can’t have access to it. So, you’ve got to put in the firewalls, the access controls. This even translates into things like certain rooms with locked doors and cabinets with locks on them so that somebody can’t just walk into a room and pull a drawing file out and look at something.

So, the requirements on the ITAR side are actually stricter than they are on the EAR side with regard to multinational companies. Good question. Great question.

Ann McGuire

Keep them coming.

Craig Ridgley

Okay, here’s another error that happens sometimes.

Craig Ridgley

Do not incorporate ITAR technology into new or existing commercial products.

Craig Ridgley

They will simply just become ITAR controlled. This is based on a real-life example. An engineer had designed a new handheld radio for the military. And he was so proud of it, that he thought it was a good idea to minimize drawing ECO maintenance that he would just simply retrofit the new ITAR technology into the entire product line of the company’s older radios. And what he did, unbeknownst to him, because he didn’t understand ITAR, he turned the entire product line into ITAR controlled items.

And nobody caught it in the ECO process. So, there they are with a bunch of radios that they used to be able to export, but they can’t without a license now, and I’m sure he was tasked with taking all that new technology out of all those drawings. But that’s another mistake that gets made—you contaminate your commercial products with ITAR technology. And that’s something you want to avoid as well.

All right, consequences of violations.

Craig Ridgley

By the way, I saw this, not this particular scene, but I saw a very similar scene like this with an ITAR company here in Florida. The news channel was tipped off that there was going to be a raid. And so they had cameras filming the arrival of the federal agents that came to this jobsite, and all the white vans pulled up, the agents in the blue jackets jumped out, they went inside the building, they got all of the employees out of the building and into the parking lot.

Then they got the CEO of the company and brought him out in handcuffs and put him in a car and took off with him. And then the agents started unloading from the building. Every file cabinet, every computer, anything that would hold any information whatsoever, was taken away. And basically, all the employees are standing in the parking lot going, I guess I’m unemployed now. And that was because it was an ITAR shop. And he was selling ITAR controlled technology to the Chinese.

And so that was willful violation and egregious violation. And the government just doesn’t put up with it. And I’ll talk about what it would cost. ITAR civil violations, what a civil violation is, it’s where you make a mistake, and you do something wrong.

Craig Ridgley

And it wasn’t intentional, it wasn’t willful, but because it was a violation, you can be fined up to $500,000 per violation. And certainly, these fines can be imposed in addition to criminal penalties, and debarment from government contracts. And that’s for an oops, now it has to be a really bad whoops. And there’s some other things that the government would consider.

But it can be up to $500,000. Criminal violations, which means you’ve gone out of your way to do something that you know you shouldn’t have, are going to be $1 million per violation or five times the value of the export. ITT got one of those violations. Gosh, it’s been maybe 12 or 13 years ago, management in ITT decided that it’d be a good thing to sell military grade night vision technology to the Chinese military.

The fine was $120 million— $20 million of that fine was for remediation of their export compliance program. I never heard how much time that management team got in terms of prison time, but I’m sure they did. Criminal violation per officer, director, or an agent is a quarter million and/or 10 years. And this is important because for years in export compliance, the government would go after companies, and they really wouldn’t drill down to the individual violators.

And a few years ago, the office of export enforcement came out with a memo to all exporters that “we’re going to start going after people.” And there are lots of people sitting in prison today who willfully violated the laws and they’re starting to go after the individuals. Now, having said that, and I know that that puts a fear of God into some of you.

Again, you really have to go out of your way, you have to willfully violate the law, you have to make a conscious decision to do something that you know you shouldn’t do to get it to be a criminal prosecution. Oopsies are generally resolved with something called voluntary self-disclosure. Voluntary self-disclosure is where you just go to the government, say this happened, we’re sorry. This is what we’re doing to make sure that doesn’t happen again.

And this is what we’re going to do long term to solve the problem. And you self-disclose to the government and it usually winds up with a warning letter. And that warning letter says, yep, you violated the law. But we’re not going to prosecute at this time. And you basically get a slap on the wrist, if you do a VSD. And when you do a VSD, even if there are fines or penalties applied, they are way less than what you could receive, like 35% of what you could get fined.

So VSDs are very important things to be aware of; if you have a violation, it’s always best to do a VSD. So don’t let that happen to you.

Craig Ridgley

That’s my advice. And we’re at the end of this.

Craig Ridgley

So, if you have questions, let’s talk about them.

Ann McGuire

Yeah, so we still can accept questions, and you can still think there’s one unanswered question, but we still have time to answer more. The next question and actually, Craig, I wanted to bring up just while we’re on this slide, and we have your contact information, we’re going to put Craig’s contact information on the event. So, you can reach him that way as well. But he also, do you want to talk about your TCAT offer?

Craig Ridgley

Oh, yeah, yeah, great. Thank you. Those may be of interest to those of you who are trying to put a compliance program together or have a compliance program, but you don’t know if it’s good enough or if you got it right. The old way of doing assessments and compliance programs was to hire somebody like me, and pay me $15,000, $20,000 to come visit your site, and do a manual assessment, asking questions and sitting there writing notes, and so on, so forth.

Very old school. And that’s why I did assessments for 20 years. Now, I have created the Trade Compliance Assessment Tool. It’s called a TCAT. It’s all SaaS cloud-based assessment. It takes about two hours. And you can get a comprehensive assessment of your compliance program, whether it’s EAR or ITAR. And you can get all the results immediately, you can get certain reports on where the gaps are.

And all you got to do is fix those gaps to increase your score on the assessment. A very handy little tool, which through TCG’s relationship with PCT and Arena are making that available to any Arena customer for free. It’s normally a $450 annual subscription, but making it available to you guys for free. If you are interested just shoot me an email at that address.

Tell me you want a promo code and I’ll send you a promo code and the URL and where to go and how to get it. So, thank you for reminding me of that. And I appreciate that.

Ann McGuire

Oh, yeah, you’re welcome. I’ll check back on the platform. But for now, we do have one more question. And I guess the TCAT is part of this, is someone said, how do you develop an ITAR compliance program for like a smaller or mid-sized company?

Craig Ridgley

The requirements come right out of the regs, I mean, they’re the regulations, say you must do this or that or the other thing. What the regs don’t tell you is how to do that. It doesn’t say that for a small company you do it this way, for a big company, you do it another way. But that’s a very important distinction. Your compliance program should be not a burden to your business processes, you shouldn’t even see your compliance program unless there’s an issue.

It should run in the background, everything should be as basically automatic and intuitive as possible, and shouldn’t, like I say, it shouldn’t be a burden. In order to do that, you have to tailor the compliance program to the business. And that’s part of what the TCAT does. It allows you to figure out where your risks are versus your exposure. And in that can help you understand if your exposure is high, but your risk is low, maybe you’re going to focus on only certain aspects of your compliance program.

Whereas if your risk is high and your exposure is high, you’re going to put some money into your compliance program. But the bottom line is it has to be tailored to the business, it has to meet the regulatory requirements, but nothing more. And I’m really adamant about that. You want to do exactly what you have to do, given your business, but not an iota more, because if you get hypervigilant, and try to be super, super compliant, you’re going to be spending money you don’t need to spend or you’re going to be exposing your company to risks that aren’t your responsibility.

So, a tailored compliance program is what you want. It’s what Trade Compliance Group does. We don’t have a one-size-fits-all compliance template, like some of the big consulting companies do. We come in, we understand your business, we understand what is required, what would you need to do for your business? And then that’s how we help you develop that.

Ann McGuire

Yeah. And it sounds like the TCAT being a self-assessment would inform that as well, that kind of gets you set up for how big of a project it’s going to be?

Craig Ridgley

Yeah, it identifies your gaps, it tells you exactly how to fix all the different areas, whether it’s a bad-guy screening, or embargo screening, or classification, or applying for licenses. Every aspect of your complaints program is looked at, and it will tell you, the TCAT will tell you, what you need to do to fix whatever is wrong. If it’s relevant to your business.

Ann McGuire

Yeah, no, that’s terrific. All right. Well, there are no more questions from the audience. So again, you can contact Craig at the Trade Compliance Group. And also just to this group is, remember, Arena does now have a GovCloud offering. So, contact Arena if you are interested in the ITAR, but the ITAR … I’m not going to say the right word, but a system that’s for the defense companies.

And let’s see, so …

Craig Ridgley

Yeah, can I say one last thing?

Ann McGuire

Sure.

Craig Ridgley

Yeah, I’m a consultant, but feel free to call me or email me if you have a question. I’m not a lawyer, I don’t bill in a point an hour. I’ll be glad to answer your questions. And you can either call me or email me, and I’m glad to help you out. Just so you know, you’re not going to get a bill for calling.

Ann McGuire

Yeah, I mean, that’s one of the reasons why we have the Trade Compliance Group, why Arena has the Trade Compliance Group as a partner, because obviously, they’re super knowledgeable, and just even Craig’s background relates so closely to what many of you are doing. But also, they’re just super easy to work with.

Ann McGuire

So, we also put our stamp of approval on that. Yeah, let’s head to the next slide. What’s next? So, like always, we’re going to have a recording available. And then for you to watch later or for you to pass on, if there’s other people from your organization, you just keep in mind that everyone who works at an Arena customer, whether or not they’re a direct user, can be part of this Arena platform.

So then they can watch the recording too. And then I wanted to also point out our next event. We’re really excited about it, called Arena: A Look Ahead. And our new CEO, PTC CEO, Jim Heppelmann, will speak live to our customers at this event, again about the future of Arena. A little bit about behind the scenes, why did PTC choose Arena, that kind of thing. And we are really excited about it and hope you can come. Again, we encourage you to invite others in your organization to join.

Another note that is not on the bullets, but we are changing our support email address to a PTC, so it’s [email protected]. And then finally, if you have ideas or comments about the events, you can always contact me through the event platform or you can email me at [email protected] and a lot of our events are ideas that start with a customer comment or customer email.

And the last slide is, thank you. So, thank you for coming and we look forward to seeing you on November 2nd. Bye-bye.