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Beneficial ownership of the underlying IP does not appear to pass to the licensee under this arrangement. Advised that no filing is required. N. Ovuka concurs.

Title and risk of loss pass outside of U.S. This does not constitute sales into U.S. N. Ovuka concurs.

Advised the writer that since the burden to make any fair market valuation in connection with determining the size-of-transaction resides with the acquiring person, the PNO naturally extends this...