Responsive Documents - CREW: Department of The Treasury: Regarding Communications Pertaining To "Bacardi," "Havana Club," Etc.: 7/29/2011 - Treasury FOIA Docs

Message
Hammerle, Barbara
From: Thornton, Sean
Sent: Tuesday, October 07, 2003 1:53PM
To: Hammerle, Barbara;
Subject: RE
-----Original Message-----
From: Hammerle
1
Barbara
,..,..,...-....,...,..,--,Sent: October 07
1
2003 2:43 PM
I (b )(6) I To: Monbo
Su
Sean,
Page 1 of2
l(b)(6) 1
Thornton
1
Sean;
Thanks for circulating the issue. In Iraq, we define property and property interest to include trademarks
and copyrights. 575.315. Presumably, the question is whether the GOI has an interest in the trademark at
issue. Do you have the incoming?
Barbara
From: Thornton
1
Sean
Thornton
1
Sean;
07
1
2003 2:12PM
To;
Cc:

l(b)(5) I
1/8/2008
2003-06-032 000260
Message
1/8/2008
-Sean
l(b)(6) I
l(b)(6)
i(b)(s) I
Sent: Tuesday, October 07, 2003 1:04PM
To: -..
Cc: Mills, David
Sub
IQ-2384j
Why don't you draft proposed language and send it back down for review?
Sent: October 03 PM
Cc: l(b)(6) I
IQ-2384
2003-06-032 000261
Page 2 of2
Page 1 of 1
Hammerle, Barbara
Sent:
To:
Cc: Hammerle, Barbara
j(b)(6)
Subject: Havana Club Legislation
Attachments: HR2494.pdf
l(b)(s) I
1/8/2008
2003-06-032 000262
Hammerle, Barbara
From:
Sent:
To:
Subject:
Attachments:
Barbara,
Thornton, Sean
Wednesday, March 27, 2002 2:57PM
Hammerle, Barbara
Havana Club Emails
FW: Significant Recent Events; Registration/Recognition of Trademarks
j(b)(6) I
The email on the left is one that-forwarded to us from Bacardi, and maybe it provides helpful background.
The email on the right is a revision of-latest draft, with- and my additions in red and deletions in blue.
FW: Significant Registration/
Recent Events Recognition of Tr ...
Thanks,
Sean
l(b)(6) I
I (b)(6) I
2003-06-032 000263
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
Tuchband, Matthew
Farrow, 1
Thornton, Sean; Hamm e, Barbara;
Havana Club trademark renewal request
l(b)(6) I
l(b)(6) I
i(b)(6) I
FYI--I just received a call f r o m ~ f Ropes & Gray inquiring about the status of the his April10, 2006
request on behalf of Cubaexport for ~ o n to renew the HAVANA CLUB trademark (for rum) at the USPTO. OFAC
sent this request to State on May 15. -.,oted that they must renew the mark by July 27. I let him know that the
license request was under active consideration. l(b)(6) 1
For the State folks-- please let me know if there is anything I can do to assist in your review of this license application.
Thanks.
-Matthew
2003-06-032 000264
Hammerle, Barbara
From: Tuchband, Matthew
Sent: Friday, April21, 2006 8:12AM
To:
Cc:
Subject: (Bacardi) l(b)(6) I
Barbara,
In returning a Cuba call, that Bacardi believes it has an outstanding request to meet with you on the Havana
j(b)(6)j Club matter. As you can il below, Bacardi still wishes to meet notwithstanding the letter OFAC recently sent to
Cubaexport regarding its current authorization to engage in renewal activities (including payment of fees) at the PTO.
-directed Bacardi's counsel to submit a meeting request in writing to you, but we thought we should give you this informal heads
up as well. l(b)(6) I
-Matthew
Sent from my BlackBerry Wireless Device
I
To:Tuchband, Matthew
Sent: Thu Apr 20
Subject: Call from --(Bacardi) I (b )(6) I
Matthew,
Bacardi) back this evening in response to a call she had made to our office to follow up on written
apparently sent some time ago (as she described it, the original request had been to meet with Robert Werner,
and a second follow-up request had been made about a month ago to meet with Barbara Hammerle). I explained to her that any
request to meet with Barbara was appropriately directed to Barbara, and not made via our office. Because she had mentioned that the
purpose of the requested meeting had changed since the earlier letters were sent, I suggested that she clarify the issue Bacardi would
like to discuss in any new written request. I noted that my suggestion to put the request in writing was merely to facilitate OFAC's
consideration, and that I was not in any position to respond to the substance of the request or to indicate whether a meeting would be
possible.
Best regards,
-l(b)(6) I
2003-06-032 000265
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
Tuchband, Matthew
Thursday, April 06, 2006 11 :18 AM
Thornton, Sean

j(b)(6)j
FYI -- I already received a call from ey representing Cubaexport in the Havana Club. He
received OFAC letter faxed to him this m already in the process of writing in for a specific license authorizing
Cubaexport to apply for renewal of the Havana Club trademark. He did not seem particularly annoyed, but actually
somewhat pleased that I returned his call quickly and guided him into the licensing process.
-Matthew
2003-06-032 000266
Hammerle, Barbara
Sent:
To:
Cc:
Thursday, April 06, 2006 8:07 AM
Hammerle, Barbara;- I (b)(6) I
Thornton, Sean
Subject: Re:
From: Hammerle, Barbara
To:IIIIIIIIII;Tuchband, Matthew
C C : ~ e a n
Sent: Thu Apr 06 08:42:55 2006
. .. :
Fro
Sent: ay, 06, 2006 8:15AM
To: Tuchband, Matthew; Hammerle, Barbara
Cc: Thornton, Sean
Subject: RE:
Sent: Thursday, April 06ili, 2IOIOI6i7iii:5l6iAM
Cc: Thornton, Sean
Subject: Re:
I (b)(s) I
I am. Including- now because I forgot to cc her last night.
-Matthew I (b)(6) I
To: Tuchband, Matthew
Sent: Thu Apr 06 05:54:56 2006
Subject: Re:
2003-06-032 000267
l(b)(s) I
Thanks a lot.
Sent from my BlackBerry Wireless Handheld
-----Orig ina I Message-----
To: Hammerle, Barbara
Sent: Thu Apr 06 01:04:05 2006
Subject: Re:
Hope this helps.
-Matthew
To:Tuchband, Matthew
Sent: Wed Apr 05 17:21 :24 2006
Subject:
Thanks.
l(b)(s) I
2
2003-06-032 000268
Hammerle, Barbara
From:
PM
Hammerle, Barbara
Sent:
To:
Cc:
Subject:
Monborne, Mark; ...... l(b)(6) I
RE: Bacardi
Will do.
Sent: Frida Janua 14 2005 4:43 PM
To:
Cc:
Subject:
Matthew,
I (b)(6) I
Please copy me and- on e-mails of this type. Thanks.
Barbara
From:
Sent: Friday, January 14, 2005 3:21 PM
To: Werner, Robert
Cc: Monborne, Mark
Subject: Bacardi General Counsel
Bob,
- Bacardi's General Counsel , left a message for you yesterday. I returned his
call this morning and had a brief, cordial ss1on m. He said he will be in town next week for the
inauguration and is hoping to come by to meet you and provide a background on the areas where Bacardi's
business comes into contact with OFAC. He further explained that he had a good working relationship with
Rick Newcomb and would like to continue that with you.
I explained not Newcomb) that, to the extent you are able to meet with him, it would be good
to know which he wishes to discuss. I suggested the ongoing Havana Club matter might be a
topic of interest. He agreed, but did not provide any other examples other than to say that all of Bacardi's
OFAC issues are related to the Cuba embargo. My assumption is that the Havana Club matter is the sole
thing he wishes to talk about.
l(b)(6) l1 told -that I did not know your availability next week, but would pass his request along to you.
I (b)(
6
) I Please feel free to call on me to engage. further and/or to brief you on the Havana Club matter. I think
Barbara may also be able to provide you a background on Havana Club (she lived a lot of it; I came in during
the last half, which continues-- you will not be surprised to learn-- without any apparent end in sight).
- 1 (b)(6)
2003-06-032 000269
Hammerle, Barbara
From:
Sent: 4:24PM
To: Werner, Robert; Hammerle, Barbara;- l(b)(6)
Cc: Monborne, Mark
Subject: RE: Bacardi General Counsel
l(b)(6)1 l(b)(6) I
::...J...Q,on't see any problem with meeting with- I will be here Tuesday, Wednesday, and Friday of next week.
-said he is available Tuesday between 12:30 and 3:00 and Wednesday in the morning and from 3:30 to 5:30. (He said
he was available Thursday from 11:00 to 1:00 as well, but I explained that we are off on Thursday, not to mention that it is
officially too late to get him cleared into this building). He also suggested that he can make other times available if need
be.
-- I (b)(6) I
1 (b)(6)
From: Werner, Robert
Sent: Friday, Januaq 14,2005 4:11PM -
To:
11

1
Hammerle, Barbara; I (b) ( 6)
Cc: Monborne, Mark
Subject: RE: Bacardi General Counsel
I'm willing to meet with him- along with you and Barbara and anyone else at OFAC appropriate if you think it makes
sense.
-----Original Message---
From: .
To: Werner, Robert
Cc: Monborne, Mark
Bob,
- Bacardi's General Counsel--- left a message for you yesterday. I returned his call
thiS morn1ng and had a brief, cordial said he will be in town next week for the inauguration
and is hoping to come by to meet you and provide a background on the areas where Bacardi's business comes
into contact with OFAC. He further explained that he had a good working relationship with Rick Newcomb and
would like to continue that with you.
l(b)(
6
) I I explained to---. not Newcomb) that, to the extent you are able to meet with him, it would be good to
know which wishes to discuss. I suggested the ongoing Havana Club matter might be a topic of
interest. He agreed, but did not provide any other examples other than to say that all of Bacardi's OFAC issues
are related to the Cuba embargo. My assumption is that the Havana Club matter is the sole thing he wishes to
talk about.
l(b)(6) I I that I did not know your availability next week, but would pass his request along to you.
Please feel free to call on me to engage- further and/or to brief you on the Havana Club matter. I think I (b )(
6
) I
Barbara may also be able to provide you a"'b'a'Ckground on Havana Club (she lived a lot of it; I came in during the
last half, which continues-- you will not be surprised to learn-- without any apparent end in sight).
-
______________________________________ __
2003-06-032 000270
!Withheld in full- Pursuant to FOIA exemption (b)(5)
2003-06-032 000271
!Withheld in full- Pursuant to FOIA exemption (b)(5) I
2003-06-032 000272
JWithheld in full- Pursuant to FOIA exemption (b)(5)
2003-06-032 000273
jWithheld in full- Pursuant to FOIA exemption (b)(5)
2003-06-032 00027 4
2003-06-032 000275
2003-06-032 000276
2003-06-032 000277
2003-06-032 000278
2003-06-032 000279
2003-06-032 000280
2003-06-032 000281
Hammerle, Barbara
From:
Sent:
To:
Subject:
Werner, Robert
Monday, February 07, 2005 10:08 AM
Hammerle, Barbara
RE: For 1 :00 pm meeting today
To be honest- I can't really understand the text you forwarded.
Sent: Monday, February 07, 2005 9:56AM
To: Werner, Robert
Subject: For 1:00 pm meeting today
Bob,
Though condensed, this provides some of the background on the Havana Club/Bacardi issues.
Barbara
l(b)(6)
PRIVILEGED ATTORNEY-CLIENT COMMUNICATION
2003-06-032 000282
I hope this is helpful. Don't hesitate to call on me if I have left anything out or in question. Also, please feel free to
include me in your discussions with .if you wish.,(b)(6) 1
-- I (b)(6) I
Messaqe----- l(b)(
6
) 1
Sent: Wednesday, August 20, 2003 4:23 PM
To:
Subject: PTO and USTR update
l(b)(5) & (b)(6)
- j(b)(6)j
2
2003-06-032 000283
All Redactions on this page are made pursuant to FOIA Exemption (b)(6)
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
I'm willing to meet with him -along with you and Barbara and anyone else at OFAC appropriate if you think it makes sense.
From: ..... ...
To: Werner, Robert
Cc: Monborne, Mark
Bob,
rdi's General Counsel left a message for you yesterday. I returned his call this
morning and had a brief, cordial discussion with him. He said he will be in town next week for the inauguration and is
hoping to come by to meet you and provide a background on the areas where Bacardi's business comes into contact
with OFAC. He further explained that he had a good working relationship with Rick Newcomb and would like to
continue that with you.
I explained t o ~ . not Newcomb) that, to the extent you are able to meet with him, it would be good to
know which i s s ~ e wishes to discuss. I suggested the ongoing Havana Club matter might be a topic of
interest. He agreed, but did not provide any other examples other than to say that all of Bacardi's OFAC issues are
related to the Cuba embargo. My assumption is that the Havana Club matter is the sole thing he wishes to talk about.
I told. that I did not know your availability next week, but would pass his request along to you.
Please feel free to call on me to engage. further and/or to brief you on the Havana Club matter. I think Barbara
may also be able to provide you a background on Havana Club (she lived a lot of it; I came in during the last half,
which continues --you will not be surprised to learn --without any apparent end in sight).
--
2003-06-032 000284
THESE ARE ONLY SOME KEY CAPTIONS FROM THE MOTION FOR SUMMARY
JUDGMENT FILED FRIDAY MARCH 15, 2002 WITH PTO.
Cancellation No. 24,108 Should Be Resumed With Cubaexport Substituted As The
Respondent
Cancellation No. 24,108 was suspended pending the outcome of the federal litigation
between the parties that resulted in the Partial Judgment in Havana Club Holding, SA. v.
Galleon S.A., 96 Civ. 9655 (SS), which is at issue here. That litigation has long since
concluded, appeals have been taken, and a final decision on the merits has been entered.
This judgment is final and cannot be challenged in this tribunal. Accordingly, pursuant to
TBMP 510.02(b), Cancellation No. 24,108 should now be resumed in order to give final
effect to the Cancellation Order.
Cubaexport should be substituted as the respondent in the resumed cancellation
proceeding pursuant to TBMP 512 because the assignments of the U.S. HAVANA
CLUB Registration have been stricken from the USPTO's records and HCH, the
respondent of record in that proceeding, never owned the registration at issue. The only
party, under the mandate of the Cancellation Order, with an arguable interest in
Registration No. 1,031,651 when the cancellation proceeding was originally brought was
Cubaexport. Moreover, the USPTO now erroneously lists Cubaexport as the owner
of said reeistration and on January 17, 2002, served Cubaexport with its Notice of
that date. Therefore, Cubaexport should be substituted as the respondent since
Cubaexport, not HCH, is the real party-in-interest.
But the USPTO, sub silentio, apparently regarded HCH's renewal application as valid.
However, the renewal affidavit filed by HCH must also be treated as a nullity because if
HCH was not the registrant and never acquired any ownership interest of any kind in the
subject registration- as the District Court decided - then HCH could not as matter of law
renew that application. HCH's renewal application was a dead letter just like the
assignments, so the U.S. HAY ANA CLUB Registration expired in 1996. Consequently,
there can be no valid U.S. Registration No. 1,031,651 in the name of Cubaexport on
the USPTO records now, more than five years after the statutory period for renewal
lapsed
The U.S. HAVANA CLUB Registration for "rum" issued for a period of 20 years on
January 27, 1976.
Cubaexport was, therefore, obligated to file its renewal application during the period
beginning on July 27, 1995 and ending, with the benefit of the three month additional
extension period, on April27, 1996.
2003-06-032 000285
No renewal affidavit has ever been filed by Cubaexport as is ascertainable by judicial
notice of the USPTO's own records. Although Cubaexport was notified by the District
Court of the Summary Judgment against HCH, Cubaexport has not, since the
Cancellation Order was issued, even tried to file a renewal application of its own (The
undisputed facts established in the Havana Club litigation shows Cubaexport could not
make a justifiable non-use declaration without perjuring itself). The USPTO cannot
under the Lanham Act accept a renewal affidavit from Cubaexport for the U.S.
HAVANA CLUB Registration that was filed after the April 27, 1996 statutory deadline.
Cubaexport's indisputable failure to file a renewal application is fatal to any claim that
the U.S. HAY ANA CLUB Registration should somehow be metaphysically maintained
in Cubaexport's name. The ineluctable fact is that Cubaexport did not apply to renew the
mark on or before April 27, 1996.
The renewal application by HCH, a stranger to the registration, was ineffective and null
and void as a matter of law just as the assignments to HCH were treated as null and void
and of no force and effect. There is no basis whatsoever in law or equity for the USPTO
to regard HCH's filing as Cubaexport's.
Only Cubaexport, the putative owner of the U.S. HAVANA CLUB Registration in 1996,
lawfully had the power to file the renewal affidavit.
Moreover, the Director, has no authority to accept a new or corrected renewal application
by Cubaexport now, as the statutory deadline for such a filing passed over five years ago.
Indeed, the record in the related Havana Club federal litigation establishes that
Cubaexport, could not truthfully have filed in 1996 a verified declaration showing
excusable nonuse, Cubaexport had contractually bargained away the right to sell
HAVANA CLUB rum everywhere in the world in the Convenio. Accordingly, the
essential requirement for a valid renewal, that is, a truthful declaration of excusable
nonuse, was not met and could not now be met by Cubaexport.
2003-06-032 000286
THESE ARE ONLY SOME KEY CAPTIONS FROM THE MOTION FOR SUMMARY
JUDGMENT FILED FRIDAY MARCH 15, 2002 WITH PTO.
Cancellation No. 24,108 Should Be Resumed With Cubaexport Substituted As The
Respondent
Cancellation No. 24,108 was suspended pending the outcome of the federal litigation
between the parties that resulted in the Partial Judgment in Havana Club Holding, S.A. v.
Galleon S.A., 96 Civ. 9655 (SS), which is at issue here. That litigation has long since
concluded, appeals have been taken, and a final decision on the merits has been entered.
This judgment is final and cannot be challenged in this tribunal. Accordingly, pursuant to
TBMP 51 0.02(b ), Cancellation No. 24,108 should now be resumed in order to give final
effect to the Cancellation Order.
Cubaexport should be substituted as the respondent in the resumed cancellation
proceeding pursuant to TBMP 512 because the assignments of the U.S. HAVANA
CLUB Registration have been stricken from the USPTO's records and HCH, the
respondent of record in that proceeding, never owned the registration at issue. The only
party, under the mandate of the Cancellation Order, with an arguable interest in
Registration No. 1,031,651 when the cancellation proceeding was originally brought was
Cubaexport. Moreover, the USPTO now erroneously lists Cubaexport as the owner
of said registration and on January 17, 2002, served Cubaexport with its Notice of
that date. Therefore, Cubaexport should be substituted as the respondent since
Cubaexport, not HCH, is the real party-in-interest.
But the USPTO, sub silentio, apparently regarded HCH's renewal application as valid.
However, the renewal affidavit filed by HCH must also be treated as a nullity because if
HCH was not the registrant and never acquired any ownership interest of any kind in the
subject registration -as the District Court decided - then HCH could not as matter of law
renew that application. HCH's renewal application was a dead letter just like the
assignments, so the U.S. HAVANA CLUB Registration expired in 1996. Consequently,
there can be no valid U.S. Registration No. 1,031,651 in the name of Cubaexport on
the USPTO records now, more than five years after the statutory period for renewal
lapsed
The U.S. HAVANA CLUB Registration for "rum" issued for a period of20 years on
January 27, 1976.
Cubaexport was, therefore, obligated to file its renewal application during the period
beginning on July 27, 1995 and ending, with the benefit of the three month additional
extension period, on April27, 1996.
2003-06-032 000287
No renewal affidavit has ever been filed by Cubaexport as is ascertainable by judicial
notice of the USPTO's own records. Although Cubaexport was notified by the District
Court of the Summary Judgment against HCH, Cubaexport has not, since the
Cancellation Order was issued, even tried to file a renewal application of its own (The
undisputed facts established in the Havana Club litigation shows Cubaexport could not
make a justifiable non-use declaration without perjuring itself). The USPTO cannot
under the Lanham Act accept a renewal affidavit from Cubaexport for the U.S.
HAY AN A CLUB Registration that was filed after the April 2 7, 1996 statutory deadline.
Cubaexport's indisputable failure to file a renewal application is fatal to any claim that
the U.S. HAY ANA CLUB Registration should somehow be metaphysically maintained
in Cubaexport's name. The ineluctable fact is that Cubaexport did not apply to renew the
mark on or before April27, 1996.
The renewal application by HCH, a stranger to the registration, was ineffective and null
and void as a matter of law just as the assignments to HCH were treated as null and void
and of no force and effect. There is no basis whatsoever in law or equity for the USPTO
to regard HCH's filing as Cubaexport's.
Only Cubaexport, the putative owner of the U.S. HAY ANA CLUB Registration in 1996,
lawfully had the power to file the renewal affidavit.
Moreover, the Director, has no authority to accept a new or corrected renewal application
by Cubaexport now, as the statutory deadline for such a filing passed over five years ago.
Indeed, the record in the related Havana Club federal litigation establishes that
Cubaexport, could not truthfully have filed in 1996 a verified declaration showing
excusable nonuse, Cubaexport had contractually bargained away the right to sell
HAY ANA CLUB rum everywhere in the world in the Convenio. Accordingly, the
essential requirement for a valid renewal, that is, a truthful declaration of excusable
nonuse, was not met and could not now be met by Cubaexport.
2003-06-032 000288
j(b)(6) 1
DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
November 9, 2006
Privileged Communication from Counsel
MEMORANDUM FOR OF AC STAFF AND OFFlCE OF THE CHIEF COUNSEL (FAC)
FROM: SEAN M.
CHIEF COUNSEL ASSETS CO!'-i'TROL)
SUBJECT: Records Rela_ting 1Q__lhe "HAVANA CLUB" Licensing Matter
Empresa Cubana Exportadora de Alimentos y Productos Varies (Cubaexport) has filed a
complaint against the Office of Foreign Assets Control (OFAC) with the United States
District Court (D.D.C. Case No. 1 :06CV01692) seeking declaratory and injunctive relief
arising out of certain administrative actions by OFAC concerning the trademark
HAVANA CLUB & Design.
The Department of Justice has asked OFAC to preserve records relating to this matter.
There is no need at this time to segregate, copy, or produce any 1ecords, documents,
data or information currently in your possession, care, custody or control that may
relate in any way to this matter; however, please ensure that no potcutially releYant
records, documents, data or information in your possession, care, custody or control
are disposed of or destroyed, including as part of normal records retention and
disposition procedures under the Federal Records Act.
As a precaution, please suspend the transfer of all potentially relevant records,
documents, data, or information to the Federal Records Center pending further
instruction. Also, please preserve any potentially relevant records, documents, data or
infonnation you may receive or generate in the future.
assistance. lf you have questions ,please
in the Office of the Chier Counsel at or, if she is
attorney in the Office of the Chief ounsc . not a
2003-06-032 000289
Message
All Redactions on this page are made pursuant to
FOIA exemption (b)(6).
Page 1 of 1
Hammerle, Barbara
Sent: Thursday, November 09, 2006 2:02 PM
To: Szubin, Adam; Hammerle, Barbara; C a n t ~
. Cc: Tuchband, Matthew;-
Subject: RE: Havana Club 1 (b)(5) 1
Sent: Wednesday, November 08, 2006 5:36PM
To Barbara; Canter
Matthew
Just wanted to give you a head's-up .
.. s working on the text of a short memo, which I would propose to send over my signature by email to
all OFAC & Chief Counsel staff soon, ideally tomorrow (before the long weekend).
Please let me know if you have any questions or concerns about this approach.
Thanks,
Sean
1/8/2008
2003-06-032 000290
I (b)(s) I
Hammerle, Barbara
From:
Sent:
To:
Subject:
Thornton, Sean
Thursday, October 26, 2006 5:49 PM
Hammerle, Barbara
RE: Havana Club litigation
r-1 (,...,.b)"""""( 6 ),....,I
OK. I have talked w i t h ~ over the last couple weeks about various issues, but not that.
Sent: Thursday, October 26, 2006 6:45 PM
To: Thornton, Sean
Subject: RE: Havana Club litigation
Got
SUbject: RE: Havana Oub litigation
Barbara,
l(b)(5) I
I'm sorry, I don't remember what this was about. .... I haven't communicated with-about this.l(b )(6) I
To: Thornton, Sean
Subject: Havana Oub litigation
Just a reminder you were going to forward me the e-mail exchange with
Thanks. l(b)(6) 1
1
2003-06-032 000291
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
Importance:
I just got a call
FOIA exemption (b)(6) except where otherwise noted.
Thornton, Sean
Monday, July 17, 2006 5:32 PM
Hammerle, Barbara; Canter, Virginia;-Farrow, Liz
Monborne, Mark
Havana Club Mtg Tomorrow?
High
NSC, who was calling about Havana Club.
He said he assumed I was going to a meeting at NSC tomorrow afternoon l(b)(5) I
that I was not - indeed, I wasn't aware of a.ting tomorrow -- after a pause -said that
--would be attending. -s-e did not realize tha sn't from OFAC proper, and he said OFAC should feel
free to send someone to
Thanks,
Sean
2003-06-032 000292
All Redactions on this page are made pursuant to FOIA
exemption (b)(6) except where otherwise noted.
Hammerle, Barbara
From: Canter, Virginia
Sent: Wednesday, July 26, 2006 7:00 PM
To:
Subject:
McBrien, Bob; Hammerle, Barbara; Thornton, Sean; Farrow, Liz;
Re: Havana Club
From: McBrien, Bob
To: Thornton, Sean; Canter, Virginia; Farrow, Liz:
Sent: Wed Jul26 19:39:18 2006
Subject: RE: Havana Club
Sent: Wednesday, July 26, 2006 7:03PM
To: McBrien, Bob; Canter, Virginia; Farrow, Liz
Subject: Havana Club
Thanks,
Sean
2003-06-032 000293
I (b)(s) I
Hammerle, Barbara
From:
Sent:
To:
Cc:
Farrow, Liz
Friday, June 30, 2006 3:54 PM
Tuchband,
Thornton, Sean
l(b)(6) I
Subject:
J(b)(6)
RE: Havana Club-related meeting request
The meeting sounds like a great idea. Thanks, Matthew.
Liz
l(b)(5) I
Sent: Friday, June 30, 2006 12:08 PM
To: Hammerle, Barbara Canter inia Farrow
Cc: Thornton, Sean;
Subject: Havana Cl
Barbara, Ginny, Liz, andllll
l(b)(6) I
Many weeks ago the General Counsel of Bacardi began requesting a meeting (or meetings) with GC Arnie
Havens and Barbara to discuss and argue for denial of a pending license request by Cubaexport to renew its U.S.
registration of the Havana Club trademark at the U.S. Patent and Trademark Office. The license request was
submitted on April 7, 2006, and OFAC forwarded it to State for policy guidance on May 15. OFAC is still awaiting
State's guidance. Unless Cubexport's trademark registration is renewed or USPTO takes other action to protect
the registration, the registration will expire this coming July 27.
-Matthew
2003-06-032 000294
Hammerle, Barbara
From:
Sent:
To:
Cc:
~ p r i l 06, 2006 7:15AM
Tuchband, Matthew; Hammerle, Barbara
Thornton, Sean
Subject:
RE:
Sent: Thursday, April 06, 2006 7:56AM
To: Hammerle, Barbara:-
Cc: Thornton, Sean
Subject: Re:
-Matthew
Sent: Thu Apr 06 05:54:56 2006
Subject: Re:
Thanks a lot.
Sent: Thu Apr 06 01:04:05 2006
Subject: Re:
2003-06-032 000295
Hope this helps.
-Matthew
Sent: Wed Apr 05 17:21:24 2006
Subject:
Thanks.
2
2003-06-032 000296
FOIA exemption (b)(5).
Hammerle, Barbara
Sent: Thursday, April 06, 2006 7:43 AM
Hammerle, Barbara;- Tuchband, Matthew
Thornton, Sean
To:
Cc:
Subject:
I signed the letter, by the way.
RE:
S e n ~ : Thursda , April 06, 2006 8:43AM
To: ; Tuchband, Matthew
Cc: omton, ean
Subject: RE:
Fromjililll
Sent: I 06, 2006 8:15AM
To: Tuchband, Matthew; Hammerle, Barbara
Cc: Thornton, Sean
Subject: RE:
Sent: Thursday, April 061i, 2IOIOii6i71i:5l6iAM
Cc: Thornton, Sean
Subject: Re:
Barbara,
-Matthew
To:Tuchband,Matthew
Sent: Thu Apr 06 05:54:56 2006
Subject: Re:
2003-06-032 000297
Thanks a lot.
Sent: Thu Apr 06 01 :04:05 2006
Subject: Re:
Hope this helps.
-Matthew
To:Tuchband,Matthew
Sent: Wed Apr 05 17:21:24 2006
Subject:
Thanks.
All Redactions on this page are made
pursuant to FOIA exemption (b)(5).
2
2003-06-032 000298
Hammerle, Barbara
From:
Sent:
To:
Subject:
Follow Up Flag:
Flag Status:
Attachments:
All Redactions on this page are made pursuant to FOIA
exemption (b)(5) except where otherwise noted.
Hammerle, Barbara
Friday, March 11, 2005 5:54 PM
Hammerle, Barbara
FW: New version of TSRA legislation and my comments
Follow up
Flagged
Craig Am of TSRA.pdf
From: - ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ ~ -
Sent: Wednesday, February 09,2005 5:40PM j(b)(6) I
To: Werner, Robert
Cc: Hammerle, Barbara; Stern, Rochelle E.; Monborne, Mark;
Sean
Subject: New version of TSRA legislation and my comments
Bob,
2003-06-032 000299
All Redactions on this page are made pursuant to FOIA exemption (b)(5).
-- I (b)(6) I
.
;;,
Craig Am of
TSRA.pdf (48 KB)
2
2003-06-032 000300
Message
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
l(b)(6)
Friday, November 16, 2007 10:16 AM
Szubin, Adam; Hammerle, Barbara
- Tuchband, Matthew l'"':':l(b-:-)-:-:(6:-:-)-,
Privileged -draft Cubaexport ("Havana Club") declaration
Page 1 of2
Attachments: Decision in Cubaexport.pdf; Szubin Supplemental Declaration (Cubaexport - DRAFT).doc
Privileged -Attorney Work Product
Adam,
Attached for your review please find a draft supplemental declaration in the Cubaexport
"Havana Club" litigation. I have also attached a copy of the decision and forwarded an earlier
summary below.
Barbara- I would welcome your review and comments, if you have time, as I'm sure we'd all
benefit from your experience with this matter.
Best regards,
i(b)(6) I
; ; ~ ~ ~ - - - l(b)(6) 1
Sent: Wednesday, October 03, 2007 4:28PM
To: Szubin, Adam; Hammerle, Barbara;- l(b)(6) I
Cc: Thornton, Sean; Tuchband, Matthew
Subject: FW: Decision in Cubaexport
Privileged -Attorney-Client Communication -Attorney Work Product
Adam, Barbara, and. l(b)(6) I
1/8/2008
2003-06-032 000301
l(b)(5) 1
Message
All Redactions on this page are made pursuant to FOIA Page
2
of2
exemptions (b)(S) unless otherwise noted

-l(b)(6)
118/2008
2003-06-032 000302
Page 1 of 1
Hammerle, Barbara
From: Farrow, Liz
Sent: Tuesday, August 01, 2006 4:34 PM
To: Tuchband, Matthew;
l(b)(6)
l(b)(6) I
Subject: HAVANA CLUB correspondence
Attachments: Ropes and Gray letter to USPTO.pdf
l(b)(s) I
1/8/2008
2003-06-032 000303
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
l(b)(6)
Wednesday, August 30, 2006 11 :23 AM
Hammerle Barbara; Tuchband, Matthew
-in peril: Retaliation feared for U.S. refusal to accept rum brand
Trademarks in Cuba in peril: Retaliation feared for U.S. refusal to accept rum brand
Matthew Haggman - cClatchy Newspapers
National Post
MIAMI - In 1918 the Aunt Jemima trademark was registered in Cuba, and even after Fidel Castro seized power
in 1959, a steady stream ofU.S. companies from Ace Hardware to United Airlines has continued to register
their trademarks in the island nation.
Despite the decades-long U.S. economic embargo that precludes most trade with Cuba, more than 400 U.S.
companies have registered in excess of 5,000 trademarks -- everything from McDonald's Golden Arches to
Nike's famed Swoosh and Pepsi. And until recently, Cuba had no problem registering and renewing trademarks
in the United States.
Now some fear the recent U.S. refusal to renew the Havana Club rum trademark claimed by a Cuban joint
venture and Bacardi's launch of Havana Club-- a brand it also claims-- has placed the delicate balance of
respecting other nations' trademarks in jeopardy. The recent developments also raise the possibility of Cuban
retaliation, experts say.
Bacardi's fight with Cubaexport, a Cuban company that partnered with French liquor giant Pernod Ricard in
1993 to sell the rum around the world, has been simmering in U.S. courts, U.S. Congress and in the World
Trade Organization for a decade. But the United States' recent decision to invalidate Cubaexport's Havana Club
trademark registration really fanned the flames.
"Our government has done a real injustice that will come back to bite a lot of other companies," said William
Reinsch, president of the National Foreign Trade Council. The council, which is based in Washington,
represents corporate members such as Microsoft, Wal-Mart, Caterpillar and General Motors.
But Patricia Neal, a Bacardi spokeswoman, rejected the notion that the rum company's efforts endanger other
companies' trademarks in Cuba.
"All companies would fight to protect their brand," she said.
On Aug. 3, the U.S. Patent and Trademark Office said the Havana Club trademark would be
"cancelled/expired," although Cubaexport had filed its renewal application correctly with a US$500 fee and on
time.
The U.S. Patent Office refused to accept the renewal after J. Robert McBrien, the acting director of the Office of
Foreign Assets Control, wrote the office had received guidance from the U.S. State Department "informing us
that it would be inconsistent with U.S. policy."
That decision stems from a provision called Section 211 that was inserted in a 1998 budget bill. Sometimes
called the "Bacardi Bill," Section 211 has been criticized as a measure solely aimed at benefiting the rum giant.
Now the recent Havana Club denial has raised concerns that Cuba could return the favour by cancelling U.S.
1
2003-06-032 000304
trademark registrations based on the communist nation's own "policy" considerations.
Cuba could, for instance, cancel the trademarks for Levi's jeans or Heinz ketchup and sell its version in island
stores. Those products could filter into other markets, too, harming U.S. companies that have long sought to
keep fakes off store shelves abroad, said the U.S. National Foreign Trade Council.
Such a scenario could force U.S. companies to spend millions defending trademarks in many different countries
and make the Cuba market ever more difficult to enter if it ultimately transitions into a market economy. And
some think that day may be sooner rather than later due to leader Fidel Castro's shaky health.
"Some day Cuba could say, 'The heck with it, we will not honour any of these (U.S.) registrations, because you
guys are not honoring ours,'" said Jesus Sanchelima, a Miami lawyer who has represented U.S. companies in
trademark cases in Cuba.
Cuba has threatened retaliation before.
In 2001, in a heated moment during Cuba's long-standing dispute with Bacardi, Mr. Castro said he had given
instructions to the Cuban rum industry to begin producing Bacardi. And he threatened that other U.S. brand
names could be in jeopardy. "Here we can produce Palmolive, any toothpaste."
There's no evidence that he made good on that threat but Cuba did briefly produce its own Bacardi rum after the
revolution.
"This decision (on the Havana Club renewal) invites retaliation by Cuba,'' said Mr. Reinsch. "We have been
assuming that they were waiting to see the outcome of this case before doing anything. Now that there is an
outcome, they will probably come to a decision."
Ms. Neal dismissed that notion, saying, "It is an old story that has never been acted upon and is a red herring."
2
2003-06-032 000305
Withheld in full pursuant to FOIA Exemption (b)(S)
2003-06-032 000306
Withheld in full pursuant to FOIA Exemption (b)(5)
2003-06-032 000307
2003-06-032 000308
2003-06-032 000309
2003-06-032 00031 0
2003-06-032 000311
2003-06-032 000312
2003-06-032 000313
I Withheld in full pursuant to FOIA Exemption (b)(5) I
2003-06-032 000314
2003-06-032 000315
2003-06-032 000316
2003-06-032 000317
2003-06-032 000318
2003-06-032 000319
2003-06-032 000320
!Withheld in full pursuant to FOIA Exemption (b)(5)
2003-06-032 000321
2003-06-032 000322
2003-06-032 000323
jWithheld in full pursuant to FOIA Exemption (b)(5)
2003-06-032 000324
2003-06-032 000325
2003-06-032 000326
2003-06-032 000327
2003-06-032 000328
2003-06-032 000329
All redactions on this page are made pursuant to FOIA Exemption (b)(6)
Case 1 :06-cv-01692-ESH Document 25-2 Filed 05/04/2007
Ot:r'AR Tr-4!NT OF T HI!: ifl I!A.SURV
WASHING'TON1 D.C. a0120
Page 2 of 2
AUG 1 9199ij
Pen Jtr, Xr lna)ty 1
'rhia il ift ngop11 to ;o-.a htteu o! July 3 a:)4 July a:z, Ull&,
to .. cn!at counael Qt the Ottie ot
rori;n ln latter ask
=Qncarninv the in i ot tha CUban
control 31 C.P.R. 'l' (th
rirat, you ule \lhethu th1 ..........
CUba to tLl an oppQaltion to tha rilatr&tion or nav
on the tha nav intartarel v!th
riqht in ita on likoly consuaer
contli.eion.

you uk vnatller CW11 ozty llrinq a ,atithn to
prior re;iltratlon o! 1 tradeoark rtl&ttd to 1ta
attcrt1 riilter a
The authcr1J&tion tn 1 !l,.S27 ahA the parallel
ptov1aion ot.$ 515.518 ara to ,rovi4 raeiprcc&l
tor the propaTty ot and Vn1ta4
States, ltoth O! tha pro<:t$11 .. you decr1b6 .1.."1 yo\lr
concarn available to protect
in Onite4 Stataa. ror thia reas9n,
in S be rclta4 on to fila an
to the of nav t>adamark or to petition
to c&ncal s prior raqitration ot whcr that actions
to tbt protaetion of a in or CUDan
qenaral hal an interoat,
%5q.
Rabinovlt, 4 Llbrman, P.C.
740 at Altor Place
Vork lOOOJ9Sl&
2003-06-032 000330
Message
Hammerle, Barbara
From:
l(b)(6) I
Sent: Tuesday, May 08, 2007 11:55 AM
To: Szubin, Adam; Hammerle, Barbara;- l(b)(6) I
Subject: FW: Cubaexport Reply
Attachments: Cubaexport Reply.pdf; Cubaexport Reply attachment.pdf
Best regards,
-1 r-- (b---)(6---,)
To
Cc:
Subject: Cubaexport Reply
I (b)(6) I
Attached please find Cubaexport's reply brief.
Thank you,
1 (b)(6)l
118/2008
2003-06-032 000331
Page 1 of 1
Hammerle, Barbara
From:
l(b)(6)
Sent: Thursday, December 14, 2006 8:59AM
Thornton, Sean; Tuchband, Matthew
To:
Cc:
Subject: RE: Privileged - draft Cubaexport declaration
Thank you very much, I'll stop by this morning to pick it up.
ICb)(6)l
From: Szubin, Adam
Sent: ~ e r 13, 2006 7:58PM
To: j(b)(6) 1 --Hammerle, Barbara
Cc: Thomton, Sean; Tuchband, Matthew
Subject: RE: Privileged - draft Cubaexport declaration
Looks very good. I had a few questions and some suggested edits. l'llleave in a folder for you with- 1 (b )(6) 1
- - - - - O r i ~
From: .......... l(b)(6)
Sent: Wednesday, December 13, 2006 11:12 AM
To: Szubin, AdaJ11; Hammerle, Barbara
Subject: Privileged - draft Cubaexport declaration
Privileged & Confidential -- Attorney-Client Communication -- Predecisional & Deliberative
Thank you.
Best regards,
-
Draft Declaration
<<File: Szubin Declaration (Cubaexport)v6(clean).doc >>
Agency Record Certification
<< File: Cubaexport Admin Record Certification.doc >>
2003-06-032 000332
Cubaexport Complaint
<<File: Cubaexport complaint (Havana Club matter).pdf>>
2
2003-06-032 000333
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
Attachments:
l(b)(6) I
Wednesday, December 13, 2006 11:12 AM
Thornton, Sean; Tuchband, Matthew
Privileged - draft Cubaexport declaration
Szubin Declaration (Cubaexport)v6(clean).doc; Cubaexport Admin Record Certification.doc;
Cubaexport complaint (Havana Club matter).pdf
Privileged & Confidential --Attorney-Client Communication -- Predecisional & Deliberative
Adam and Barbara,
Thank you.

- :l(b=)(=6)===
Draft Declaration
Szubin Declaration
(Cubaexport ...
Agency Record Certification
Cubaexport Admin
Record Certif ...
Cubaexport Complaint
2003-06-032 000334
w,
~
Cubaexport
)mplaint (Havana C.
2
2003-06-032 000335
!Withheld in full pursuant to FOIA exemption (b)(5)
2003-06-032 000336
2003-06-032 000337
OFAC ARCHIVED CORRESPONDENCE HISTORY REPORT
FAC# CU-156877
(08/15/01)
Correspondent: Michael Krinsky
Organization: Rabinowitz, .Boudin, Standard, Krinsky & Lieberman
Address: 740 Broadway at Astor Place New York NY 10003-9518
Actual party: Havana Club Holding & Havana Rum & Liquors
Subject: Request for license retroactively licensing assignments of HAVANA
CLUB trademark.
Correspondence type: Public mail
Exec. Sec.#: (no)
Enforcement #:
Other#:
I (b)(6) I
(no)
(no)
Document date: 05/09/97
Received at OFAC:05/12/97
Date out:
Date closed: 05/15/97
(DB: control TAB: REC_mail_stat_arch RPT: REC_mail_stat_arch
2003-06-032 000338
FAC No. C-156877
MEMORANDUM FOR
FROM:
SUBJECT:
ANNA M. BORG
DEPUTY ASSISTANT SECRETARY
DEPARTMENT OF
R. RICHARD NEWCOMB Q I
DIRECTOR . I
OFFICE OF FOREIGN ASSETS CONTROL
(b )(6)
AUG 1 5 2JJ01
HAVANA CLUB TRADEMARK: STATUS REPORT ON OUR
REQUEST FOR FOREIGN POLICY GUIDANCE
Attached are coples of our memoranda of May 19, 1997 and October
19, 2000 concerning the above subject. Also attached is a copy
of an .Associated Press repo:r:t on the August 6, 2001 r.uling by
the World Trade Organization on the trademark dispute between
Havana Club Holding and Bacardi.
Please provide us with an update of the continuing status of
this matter.
Attachments
2003-06-032 000339
DELETED PAGES SHEET
3 Pages withheld in full pursuant to exemption (b)( 5)
Bates page numbers 2003-06-032 000340 -
2003-06-032 000342
r
1: Rum Rumpus,0696
WTO rules for U.S. in most of Cuban rum dispute, but EU said
decision leaves room to maneuver
Eds: Similar version moved on financial wire.
By JONATHAN FOWLER=
Associated Press Writer=
GENEVA (AP) The World Trade Organization ruled Monday in favor
of the United States in most points ofits dispute with the
European Union over Cuban rum, but the EU said the decision will
allow a French company to fight for trademark rights in U.S.
courts.
A WTO panel found against the EU on 13 of 14 of its claims in
the trademark law dispute affecting alcoholic beverage giants
Bacardi, based in Bermuda, and France's Pemod Ricard.
The 142-nation group, which oversees global trade rules, was
ruling on a U.S. law known as Section 211, which denies protection
for trademarks linked to businesses confiscated by the Cuban
government since Fidel Castro's 1959 communist takeover.
Bacardi has used the J 998 law in its efforts to gain control of
U.S. rights to the' 'Havana Club" rum trademark and keep them away
from Havana Club Holding, a joint venture between French firm
Pernod Ricard and the Cuban government.
The 125-page decision involved EU complaints about the
relationship between Section 211 and the WTO's Agreement on
Trade-Related Aspects of Intellectual Property- Rights, known as
TRIPS.
A U.S. trade official, speaking on condition of anonymity,
stressed that the panel found that in most respects "U.S. law is
not inconsistent with the obligations of the United States under
WTO agreements" on TRIPS.
However, the panel said that Section 211 prevents parties from
U.S. courts to settle a trademark dispute, thereby
stripping WTO members of rights set out under the TRIPS agreement.
The European Commission, which represents the 15-member EU m
trade matters, welcomed the ruling and said it paves the way for
Pemod Ricard to take up the case in the U.S. courts.
But the commission said it would appeal part of the decision,
. which it said "could significantly reduce the level oftrademark
protection around the world by leaving each WTO member complete
freedom on determining vvho. is the owner of trademark as long as it
respects the procedural requirements of TRIPS."
. Section 211 bars U.S. courts from recognizing or enforcing
trademarks or trade names substantially similar to those used in
connection with Cuban businesses or assets confiscated by Castro;
unless the origin'al owner has given consent. The Jaw was attached
2003-06-032 000343
to a 1999 spending bill in late 1 998, after intense lobbying by
Bacardi.
The Havana Club trademark was confiscated by the Cuban
government in 1960 from its original owners, Jose Arechabala S.A.
The Arechabala family continued to own the U.S. registration of the
Havana Club trade name until1973, when they allowed ownership to
expire.
The Cuban-owned company that took over the family's property in
1960 applied for the rights to the name in the United States and
took possession in 1976.
In 1993, Pemod Ricard and the Cuban-owned company formed Havana
Club Holding to combine Pernod's distribution network with the
Cuban company's rights to the Havana Club name and sell this brand
ofrum in all parts of the world except the United States where
sales are prohibited by the embargo against Cuban imports.
StilJ, Pernod Ricard wanted to hold onto U.S. registration of
the Havana Club name in case the embargo is lifted.
While adversaries in almost every realm, the United States and
Cuba have agreed to recognize each other's intellectual property
rights under the Inter-American Trademark Convention. In 1 994,
Bacardi tried to register the Havana Club mark in the United
States, but failed because Havana Club Holding owned it.
Nonetheless, in 1996 Bacardi began to sell Havana Club rum,
distilled outside of Cuba, prompting Havana Club Holding to file a
lawsuh.
In 1997, Bacardi reached an agreement with the Arechabala family
to pay them for the rights to the name, and argued that they are
the rightful owners of the name. Havana Club Holding disagreed,
citing its own U.S. registration, and the dispute continued through
the courts.
(Copyright 200Jby The Associated Press. All Rights Reserved.)
APTV 08-06-01 1926EDT
Copyright (c) 2001 The Associated Press
Received by NewsEPGE/LAN: 8/6/01 7:20PM
;.
2003-06-032 000344
7
All redactions on this page are made pursuant to FOIA exemption (b)(6) unless otherwise noted
-------------------
From:
Sent:
To:
Subject: update
From:
Sent: Friday, August 22, 2003 5:33 PM
To: I I
Cc: Hammerle, B a r b a r a ; ~ ~
Subject: RE: PTO and USTR update
PRIVILEGED ATTORNEY-CLIENT COMMUNICATION
I hope this is helpful. Don't hesitate to call on me if I have left anything out or in question. Also, please feel free to
include me in your discussions with Rick if you wish.
-----Original
From:
Sent:
To:
Subject:
2003-06-032 000345
Message
All redactions on this page are made pursuant to FOIA Exemption (b)(6) Page 1 of 3
unless otherwise noted
Hammerle, Barbara
From:
Sent: Thursday, October 19, 2006 9:33AM
To: Hammerle, Barbara; Thornton, Sean; Tuchband, Matthew; Szubin, Adam
Cc:
Subject: RE: Cuban Embargo/ Helms-Burton arguments flop
As an update, I just spoke with
handli this matter for us.
No, just reminded of it by the Fla. litigation.
118/2008
I haven't heard yet. We'll give her a call.
Is there anyone in particular you think I should request?
Sent: Wednesday, October 18, 2006 1:02 PM
Szubin,
Cc:--Thornton, Sean;
Subject: RE: Cuban Embargo/ H
Thanks -- good work. Has-identified the attorney who will be handling the Havana
Club litigation for us?
Sent: Wednesday October 18, 2006 12:01 PM
To: Szubin,
Cc:--Thornton, Sean;
Subject: FW: Cuban Embargo/ He
2003-06-032 000346
(b)(5)
Message
l/8/2008
All redactions on this page are made pursuant to FOIA Exemption (b)(6) !Page 2 of3
Adam and Barbara,
This is not an action item, just an FYI.
I (b)(5) I
-Matthew
2003-06-032 000347
All redactions on this page are made pursuant to FOIA Exemption (b)(6) unless otherwise noted
Hammerle, Barbara
From: Werner, Robert
Sent:
To:
Subject:
Tuesday, Octob- AM
Thornton, Sean; Hammerle, Barbara; Monborne, Mark;
RE: Empresa Cu ana e a aco v. Culbro Corporation
Looping Rochelle into the discussion- I would like her to participate in the meeting today (which I cannot participate in).
From: Werner. Robert
Sent: Tuesday, October 26, 2004 9:31 AM
To: Thornton, Sean; Hammerle, Barbara; Monborne, Mark
Subject: RE: Empresa Cubana del Tabaco v. Culbro Corporation
Sent: Tuesdalc October 26, 2004 9:26AM
To Hammerle, Barbara; Monborne, Mark
Cc: Werner, obert
Subject: FW: Empresa Cubana del Tabaco v. Culbro Corporation
r-::-1 ( b-:-:-:) ( s=-:--1) I
2003-06-032 000348
All redactions on this page are made pursuant to FOIA Exemption (b)(6)
Hammerle, Barbara
From:-
Sent: Tuesday, July 18, 2006 12:37 PM
To:
Cc: Hammerle, Barbara; OFAC (b)(6)
Subject: RE: Meeting on Havana Club Trademark - 4:00 Today
Joyce:
NS O'Brien is unable to attend. I believe Barbara Hammerle and Sean Thornton will attend.
1/8/2008
2003-06-032 000349
Page 1 of 1
Message All redactions on this page are made pursuant to FOIA Exemption (b)(6) Page 1 of2
Hammerle, Barbara
From:
Sent: Monday, July 17, 2006 11:16 AM
To: O'Brien, Pat;-Hammerle, Barbara
Subject: FW: Havana Club Trademark
Pat
Per the email below and my conversation with-this is really in OFAC's lane ..... the expropriation of
Barcard.i's trademark is apparently a long-standing dispute.
Thanks
-
118/2008
2003-06-032 000350
Hammerle, Barbara
From:
Sent:
To:
Subject:
Importance:
Follow Up Flag:
Flag Status:
Attachments:
~ . 2002 8:26AM
Hammerle, Barbara
FW: Havana Club
High
Follow up
Flagged
#102727 v1 - HC- litigation risk.doc; #102753 v1 - HC questions.doc
#102727 vl- HC- #102753 vl- HC
litigation r... questions.doc ...
Barbara,
Here is the very latest from I These should incorporate our changes from yesterday. I just received them and haven't
looked through them myself y"et.
2003-06-032 000351
Message
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
McBrien, Bob
Friday, July 28, 2006 12:32 PM
Canter, Virginia; Thornton, Sean; Millerwise, Molly; Farrow, Liz;
Hammerle, Barbara
FW: Guidance has been FAXED to OFAC
Attachments: 07-28-06 Havana Club Qs and As rev 3.doc; 07-27-06 congressional talkers.doc
Page 1 of 1
(b)(6)
The OFAC letter to the applicant has been signed by me at approximately 1:25 pm. Liz Farrow will advise all
when it is fax'd to the applicant.
118/2008
2003-06-032 000352
Message
Hammerle, Barbara
From:
Sent:
To:
Cc:
Subject:
Farrow, Liz
Friday, July 28, 2006 12:38 PM
McBrien, Bob; Canter, Virginia; Thornton, Sean; Millerwise, Molly;
Hammerle, Barbara
RE: Guidance has been FAXED to OFAC
Attachments: CU-75835(Havana Club) denial letter.pdf
Page 1 of 1
The attached letter was faxed to Ropes & Gray LLP at 1:33 pm, with a follow up voice mail message to- I (b)(6) I
I (b)(6) I-
From: McBrien, Bob
Sent: Friday, July 28, 2006 1:32PM
To: Canter, Virginia; Thornton, Sean; Millerwise, Molly; Farrow, Liz;- (b)(6)
Cc: Hammerle, Barbara
Subject: FW: Guidance has been FAXED to OFAC
The OFAC letter to the applicant has been signed by me at approximately 1:25pm. Liz Farrow will
advise all when it is fax'd to the applicant.
118/2008
2003-06-032 000353
February 18, 2004
Mr. Richard Newcomb
Director
Pernod Ricard USA
Office of Foreign Assets Control
United States Department of the Treasury
Annex 2221
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220
Re: Recent Development Involving the Havana Club Trademark
Dear Mr. Newcomb:
L l :
As you may already know, the Trademark Trial and Appeal Board ("TT AB") has issued
its decision iri the cancellation proceeding involving the U.S. registration for the Havana Club
trademark. [ believe that decision to be particularly noteworthy in the Board's dismissal of the
petitioner's (i.e., Bacardi's) each and every allegation of "fraud" in the mark's acquisition,
assignment and renewal.
Among other things, the TT AB found that the acquisition in 1976 of the U.S. registration
for the Havana Club trademark by the Cuban state enterprise Cubaexport was fully . in
accordance with U.S. laws. The Board held, on the facts, that the mark became freely available
to its new owner and registrant when prior registrations "expired after their initial twenty-year
terms for failure to renew the registrations." (Emphasis added). In other words, the U.S.
Havana Club trademark registration was sin1ply abandoned by its first owner, a view long held
by Pemod Ricard. In addition, the Board held in its decision that the U.S. registration was
properly renewed in 1996.
I am enclosing a copy of the TT AB's decision tor your perusal. Should you requtre
additional information, I would be happy to supply it.
Vice President
North American Affairs
Enclosure
816 Connecticut Avenue, N.W .. Suite 900, Washington, DC 20006 Tel: (202) 833-2150 Fax: (202) 833-1733
"\ FEDERAl IMPORT PERMIT 1-466 FEDERAL BASIC PERMIT P-2356 NY. WHOLESALE LIQUOR LICENSE LL98

2003-06-032 000354
1.-.
.. ,', : ..
- - .
rAC No.:
Dated:
> Received:
;; Due date
:
CU-191235
04/20/01
04/20/01
CORRESPONDENCE COVER SHEET
Other ref:

-e--LILP(b)(6)
Org.:
,\ddress: 1585 Broadway
New York, NY 10036-8299
Havana Club Holding, S.A. Actual Party:
. Subject: Application for Specific License in Connection With Trademark Issues Following
Havana Club Holding, S.A. v. Galleon S.A.
DISPOSITION cc Special: Control Copy to Director
. - .. - .. - ...
Initial assignment Reassign 2
Reassign 3
Director
; ... _____ 1
;; Blocked Assets

;:------------------j---+-------------1-------------------.. - .............. .
Civil Penalties
Compliance
... ,, __ .. _ _;_ __ _
................. ----
Enforcement
. ---- -----"-------1-----!---- --------
lnt'l Programs
.,
,, __________ --.. ------------:---1---
-----1--- ....
,, ___ ___ o_UJ.-ls_e_l ____ -+-i --------------+---------""'------ ............... i
.. - _,_, _______ ! __ __; __________ --------'-------- ---- ........
Sr. Advisor
Stevenson
I
I
l
---' ------
....... - ------ .... __ j_ ___________________ .... -
N1F
1
otes:
1
' I
I
------.
Disposition: File name/location:
!
! Initials:
2003-06-032 000355
OFAC CORRESPONDENCE HISTORY REPORT
FAC# CU-180518
(04/20/01)
Correspondent: (b)(6)
Organization: Proskauer Rose LLP
Address: 1585 Broadway New York NY 10036-8299
Actual party: Proskauer Rose LLP
Subject: Request for license to travel to Cuba to meet with clients, Havana
Club, also to receive payment and reimbursement for services.
Correspondence type: Public Mail
Exec. Sec.#: (no)
Enforcement#: (no)
Other #: (no)
Document date: 03/17/00
Received at OFAC:03/21/00
Date out:
Date closed: 04/14/00
A licensing record is associated with this correspondence.
!Staff assignment Assignment date Action Status
(DB: control TAB: mail_assign RPT: mailhist
2003-06-032 000356
PROSKAUER ROSE LLP
April20, 2001
VIAF AX (202) 622-1657
and FEDERAL EXPRESS
- l(b)(6)1
Licensing Division
U.S. Department ANNEX 2221
1500 Pennsylvania Avenue, N.W.
lOS ANGElES
WASHINGl.ON
BOCA RATON
NEWARK
PARIS
I (b)(6) I
Re: Application For Specific License in connection with issues following Havana
Holding. S.A. v. Galleon, S.A.: No. 96 Civ. 9655 and No. 99-7582 (2d
Clr.) 1
I .
I
Dear Ms.- I (b)(6) I
As you will recall, this firm, Proskauer Rose LLP, has been by OFAC in connection
with the above-captioned case (License No. C-37302, attached),. The case is now over, but its
conclusion has raised various trademark- related issues on our clients require continued
representation. Out of an abundance of caution, we hereby appjy for a specific license to provide
and receive payment for legal services and representation to Club Holding, S.A.
("HCH") and Havana Club JntcmationaJ,S.A. ("HCI") in with trademark and unfair
competition issues relating to the "Havana Club" marks arising!from the conclusion of the above-
captioned case last year. !
I
In addition, the separate license 1 had obtained for travel to Cub'a in connection with the Havana
Club matler (C- J 9317, also atta.ched) has expired. My clients hhve asked me to travel to Cuba
within the next weeks to consult with them, and we request a license (or a revision
ofthe e:--;isting license) so thill J can travel to Cuba to meet with'my clients, as necessary, in
connection with the trademark and competition issues that hl)velarisen.
2003-06-032 000357
P.ROSKAUER ROSE LLP
April 20, 2001
Page 2
More specifically, we request that a specific license issue all necessary transactions,
including travel to Cuba, in connection with Proskauer Rose LWP's legal representation of
Havana Club Holding, S.A. and Havana Club International, s-4., Cuban nationals, for the
following purposes: 1
(i) to provide consultation and legal advice the trademark and
unfair competition issues resulting from the resolution of Hava,na Club Holding. SA., el ana. v.
Galleon, SA., eJ a/. (S.D.N.Y. 96 Civ. 9655 and 2d Cir. No.
I
(ii) to solicit and receive fee payments and for expenses
incurred in connection with the legal representation authorized py the license, provided that said
fees and expenses are paid exclusively from fresh funds outside
1
the United States; and
. I .
. (iii) for travel to Cuba in connection with the !above ..
Thank you for your attention to this matter.
attachments
2oo3-o6-o32 ooo3ss 1
I
DEPARTMENT OF 'THE TREAS!URY
License No. CU-67724
Cuban Assets Control Regulations
LICENSE . I
I
(Granted under the authority of 50 U.S.C. App. Sib), 22 U.S.f. 22 U.S.C. 6001 et seq.
E:<ecutive Order 9193, Executive Order. 9989, Proclamation 341,7, and 31 CFR Parts 501 and 515)
To:
I (b)(6) I
c o Proskauer Rose LLP (collectively, the fLicenseesM)
1585 Broadway
____ , York, NY -10036-82299
1. Pursuant to your letter dated April 20, 2001 (the
1
1

hereby licensed:
* * * * SEE REVERSE * t * *
i
--. .,.._
the following is
2. This license is granted Upon the statements and representations made in the
Applic(;ltion, or otherwise filed with or made to the Treasur) C>epartment as a supplement to the
Application, and is subject to the conditions, among others,; that you comply in all respects
with all regulations, rulings, orders and instructions by the Secretary of the Treasury
under the authority cited above and the terms of this license.
3. The licensee shall furnish and make available
records or reports requested by the Secretary of the
or agency of the Secretary.
l
f
. I . l . f t.
or 1nspect1on-any.re evant 1n orma 10n,
I
Treasury or any duly authorized.officer
I
4. This license expires on October 31, 2001, is not is subject to the
provisions of 31 C.F.R. Parts 501 and 515, and any regulations and rulings issued
thereto and may be revoked or modi-fied at any time at the of the Secretary of the
Treasury acting directly or through the agency through whichl the license was issued, or any
other agency designated by the Secretary of the Treasury. If this license was issued as a
result of willful misrepresentation on the part of the or his duly authorized agent:,
it may, in the discretion of the Secretary of the Treasury, declared void from the date of
its isauance, or from any other date. !
I .
5. This license does not excuse compliance with any law or regulation administered
by the O"ffice of Foreign Control or another agency ( requirement)
applicable to the transaction herein licensed, nor do.es it release the Licensees or
from civil or criminal liability-for vio1ati6n'of any law or regulation.
I
Issued by direction and on behalf of the Secretary of the'Treasury:
I
OF iFOREIGN ASSETS CONTROL
By
[Attention is directed to 19 U.S.C. 1592 _and.1595a, 18 u.s.c: 545, 18 U.S.C. 1001,
50 U.S.C. App. 1c, and 31 CPR 515.701 et seq. for provisionJ relating to penalties.)
I
l
2003-06-032 000359
...
/
License No. CU-67724 - Page 2 of 2 -
SECTION 1 - AUTHORIZATION:
(a) This license authorizes the travel-related actions set forth in 31 CFR
515.560(c) and such additional tra ly in6ident to multiple
trips to, from, and within Cuba by under the auspices of I (b)(6) I
Proskauer Rose LLP for the purpose onal research and
exporting existing information and informational materials relevant to the matter
I
of Havana Club Hold1ng, S.A., et ano. v. Galleon, S.Jj., et al. (S.O.N.Y. 96 Civ.
9655 and 2d Cir. No. 99-7582), which involves blocked, interests in property
located in the United States. '
I
I
Pursuant to this authorization, the Licensees may in transactions in Cuba
including but not limited to identifying, locating, exorting existing
information and informational materials, conducting and depositions,
and written and other records relevant Authority: 31 CFR
515.545 and 515:564 {b). '
jb) The Licensees are authorized to solicit
Plaintiff or the Plaintiff's foreign counsel
costs incurred by the Licensee in connection
this License. Authority: 31 CFR 515.801.
and to payment from the
for services rendered and
with the activities authorized by
i
I
SECTION 2 - CONDITION: (a) It is a condition of this license that activities in
Cuba fully conform to the professional research actiJities as set forth in the
Application. '
i
(b) It is a condition of this License that the Licensees provide each traveler
from Proskauer Rose LLP with a written statement whidh cites No. CU-67724
and confirms that the named individual will erigage iJ authorized professional
research activities consistent with this License. rq is a further condition that
no more than a total of six individuals representing [the Licensees shall travel
under this License on any one trip to Cuba_
SECTION 3 - RECORDKEEPING AND REPORTING REQUIREMENTS: The Licensees must keep
full and accurate records of the transactions engaged in pursuant to the
in Section 1 above, tncluding a list (a) name(s) of persons
traveling under the Licensees' auspices, (b) dates and (c) expenses in
Cuba on each trip. Such records must be maintaiped for 5 years and furnished to
the Office of Foreign Assets Control upon request. The Office of Foreign Ass.ets
Control may require 2 report from the Licensees or an.y in,dividual traveling under
this License. 31 CFR 501.601 and 501;602.
SECTION 4 - WARNING: Except as authorized in Sectiol) 1 above, nothing
in this License authorizes any transaction related t tourism or
non-authorized commercial activity inconsistent withia full-time schedule
of the research and other actiVities licensed herein;
x :-:x:x xxx.x;: x >:.>: ;.:x>:>:): :-::::-:>::>::-:>:>: :x >:.:-: xxz >: >:): ;-.: ).}: ;.:x;-::-::.-: ;-::;..: ;.: ;: ;.:Y.x):xz->:
'
I
2003-06-032 000360! .
DEPARTMENT OF THE TREASL!JRY
Cuban Assets Control License No. C-19317
LICENSE
(Granted under the authority ot 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C. 6001-11,
Executive Order 9193, 0rder 9989, Proclamation 3447, and 31 CPR Parts 501 and 515)
I
1585 Broadway
New York, NY 10036-8299
1. Pursuant to your applicatio.n of March 17, 2000, th:e following is hereby licensed:
Transactions as set forth in 31 CFR 515.60(c) to travel to,
and within Cuba in connection with your of a Cuban entity,
consi.stent with Office of Foreign Assets License No. CU-373a2, in
legal proceedings taking place in the United-States District Court,
Southern District of New York, in Havana Club Holding. S.A .. and. Havana
Club International. v. Galleon. S.A .. 96 Civ. 965.5_._
This license valid for multiple trips within
1
the validity period, for
the purpose stated herein.
I
2. This license is granted upon the stat-ements and rep'resentations made in yot:Jr
a,pplication, or otherwise filed with or made to the Treasury/oepar-tment as a supplement to your
application, and is subject to the conditions, among others, I t:Mat you comply in all
with all regulations, rulings, orders and ittst:r.uc.tiGms issued by the Secretary of the Treasury
under the ;;Juthority of Section 620 (g), Public Law 87-19.5, or! under the authority of section
S(b) of the Act 0f October 6, 1917, as amended., and t'he term? of. this licen.se.
I
I
3. The license.e shall furnish and make available for inspection any information,
records or requested by the secretary of the or any duly authorized officer
or agency of the Secretary.
I
I
4. Th:j.s license expires on December 3l, 2000, is not trahsferable. is 'subject to the
of 31 C.F.R. Parts 501 and 515, and any regulations and rulings issued pursuant
thereto arid may be revoked or modified at any time at the dikcretion of the Secretary of the
Treasury acting directly or through the agency through which: the license was issued, or any
other agency designated by the Secretary of the Treasury. r.( this license was issued as a
result of willful misrepresentation on the part of the or his apthorized agent,
it m,ay, in the discr-etion of the Secretary of the Treasury, delared void from the date of
its i ssuanc.:e, or from any ether date.
S. This license does not excuse with any or regulation administered
by rhe Office of kssets Control or another agency libcludi.ng reporting requiremenc)
applicable to the oansa.ction(s) herein licensed, nm'" does it release the Licensee(s) or
third parties from civil or criminal liabil-ity for violationlof any or regulation.
I
Issued by direction and on behalf of c.he Secretary of tne
1
Treasury:.
I
CONTROL
(Attention is directed to 19 u.s.c. 1592 and 1595a, 18 u.s.ci 545, 18 u.s.c. 1001.
-sou.s.c. App; 16, and 31 CFR 515.101 et seq. for relating to penalties.]
2003-06-032 000361 i
'
DEPARTMENT OF THE TREAS:URY
WASHINGTON, D.C. 20220 I
Cuban Assets Control Regulations License No. C-37302
LICENSE
(Granted under the authority of .so u.s.c. App. 5(b). 2'2 u.s.',c. 2370(a), 22 u.s.c. 6001 et
seq .. , Executive Order 919.3, Executive Order 9989, Proclam<!ti
1
on 3447, and 31 C.F.R. Parts 501
and 515.)
To: Proskauer Rose LLP
1585 Broadway
New York, NY 10036-8299 Attn:
I (b)(6) I
I . .
1. Based on a June 10, 1999 letter to the Office of Foreign Assets Control from the law
of Proskaue r Rose, LLP (the Applicat ion l , and in'formation I ot herw.i se available to the Of f'ice
of Foreign Assets Control, the transactions and activities delineated on the reverse hereof
are hereby authorized. !
2. This license is granted upon the statements and represeAtations made in your application,
or otherwise filed with 'or made to the Treasury Department as a supplement to your
application, and is subject to the conditions, among others; that you comply in all respects
with all regulations, rulings, orders and instructions issubd by the Secretary of the
Treasury under the authority of Section 620(al, Public Law S7-195, or under the authority of
section S(b) of the Act of October 6, 1917, as terms of this license.
' I
I
3. The licensee shall furnish and make available for any relevant .information,
records or reports requested by the Secretary the or any duly officer
or of the I
4. This license is not transferable, is subject to the protisions of Title 31, Part 515 of
the Code of Federal Regulations, and any regulations and issued pursuant thereto and
may be revoked or modified at any time at the. discretion of! the Secretary of the Treasury
acting directly- or through the agency through which the was issued, or any other
agency designated by the Secretary of the Treasury. If this license was issued as a result
of willful mi&representation on the part of applicant his duly authorized agent, it
may, in the discretion of the Secretary of the Treasury; bei declared void from the date of
its issuance, or from any other date..
1
5. This license does not excuse compliance with any law or: regulation administered by the
Office of Foreign Assets Control or another agency (.including reporting requirements)
applicable to the transactionlsl herein licensed, nor it release Licensee!sl or third
parties from civil or criminal liability.for violation of law or rQgulation ..
Issued by direction and on behalf of
R.
Di
'
(Attention is directed to 19 u.s.c. 1592 and 1595a, 18 u.sJc. 545, 18 u.s.c. 1001,
SO U.S.C. App. 16, and 31 CFR 515.701 et seq. for provisiqns relating to penalties.]
2003-06-032 000362
1
I
.
. ,_
' ':.
License No. C-37302 Page 2 of 2
SECTION 1 - AUTHORIZATION: Subject to the contained herein,
the firm of Proskauer Rose, LLP (the "Licensee"), and persons employed by
or acting at the direction oi the are authorized to
provide legal services to Havana Club Holding, ?A. and Havana Club
International, S.A. in connection with J:;J.aYana____C.}ub Holding, S A y.
Galleon, SA, No. 96 Civ. 9655 (.S.D.N.Y.) and Cir.),
and to receive payment of professional fees and: reimbursement for
expenses incurred therefor fromor on behalf of:Havana Club-Holding, S.A.
and/or Havana Club r'nternational i s. A. I that. payments of fees,
retainers, or reimbursements originate from a not currently within
the United States or within the. possession or control of a person subject
to.the jurisdiction of the States to thecuban Assets
Control Regulations, 31 C.P.R. Part 515, and suc;:::h payments are not made
from a blocked account or from other blocked property.
SECTION 2 - WARNING: (a) Nothing in this 1icehse authorizes the receipt
of payment from any blocked account or the unblbcking of blocked
property.
i
(b) This license does not authorize the transfer of .any 'blocked
property, the entry of any judgment or thkt effects a transfer of
blocked property, or the execution of any judgment against blocked
property.
(c) Nothing in this,license authorizes the proyision .of servlces or the
recefpt Of payment Of fees Or reimbursement of inconnection
with services other than those delineated in 1 above:
I
SECTION 3 - REPORTING REQUIREMENT: It is. <1 cohdi.tion of this
that the Licensee comply with the reportingreqGirements of 31
501.605. I
I
I
I
I
license
C.F.R.
SEC'riQN 4 - FILING REQUIRJ;:MENT: It. is a furthei:- condition of this
license that a. copy of this license be to the relevant court or
any other decisionmaking body or forum.
I
SECTION 5 - PRECEDENCE: This license is issued! on a nonprecedential
basis. 1.
I

I
2003-06-032 000363.
From:
Sent:
To:
I (b)(6) I
Subject: FAG No. CU-191235 PAB
Thanks for the correspondence acknowledgement received today. I'd appreciate whatever
OFACcould do to expedite the license, as I cannot book on the highly limited flight from
Miami without the license in hand. Thanks.
If and when issued, a fax (to 212.969.2900) or copy by email would be much appreciated.
2003-06-032 000364
CORRESPONDENCE ACKNOWLEDGEMENT
I (b)(6) I
;. c :New York, NY 10036-8299
Tel. 212/969-3000
Fax 212/969-2900
APR 2 4 2001
LICENSING DIVISION Fax : ( 2 0 2 ) 6 2 2 - 1 6 57
OFFICE OF FOREIGN ASSETS CONTROL ("OFAC")
U.S. DEPARTMENT OF THE TREASURY
1500 PENNSYLVANIA AVENUE, N.W.
WASHINGTON, DC 20220
RE: PAC No. CU-191235 PAB
This is to acknowledge receipt of your correspondence
dated 04/20/01. Please refer to the FAC number cited above and
the date of your original correspondence if you need to contact us
or send supplemental information.
Please note that filing an application for a license or
. .
requesting-information about the tranf?action prohibitions contained
in Executive orders or regulations administered by OFAC does not
suspend or excuse compliance with the prohibitions or requirements
contained therein.
We look forward to serving you.
Note; Information on sanctions programs administered by OFAC can be retrieved at any
time from our automated fax-on-demand system by dialing (202) 622-0077, or from
our World Wide Web home page on the internet at www.treas.gov/ofac.
Fax to:
P a g ~ . 1 .of. 1 .
: .... .
2003-06-032 000365
.. .
,, --I Ul f
I

,Q (;__
- ;C
" "'
.. -.
I q
MEMORANDUM FOR
FROM
SUBJECT
DAVID D. NELSON
DIRECTOR
OFFICE OF ECONOMIC SANCTIONS POLICY
DEPARTMENT OF STATE
ROBERT W. LJ. tJ
DIRECTOR // \
OFFICE OF FOREIGN ASSETS CONTROL ("OF AC")
CUBAN LICENSE REQUEST (CU-74550)
FACTS: The law firm ofRabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C. has
requested a specific license authorizing Habanos, S.A., a Cuban entity, to file, prosecute, and pay
all fees in connection with an opposition in the Trademark Trial and Appeals Board of the U.S.
Patent and Trademark Office to a U.S. entity's application to register the trademark HAVANA
CLUB for cigars. The request also seeks authorization for the law firm to represent Habanos,
S.A. in the opposition proceeding and to receive legal fees and reimbursements from Habanos,
S.A. related to that representation. A copy of the license request is enclosed.
REGULATIONS: The Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the
"Regulations"), prohibit persons subject to the jurisdiction of the United States from dealing in
property in which Cuba or a Cuban national has an interest unless licensed or otherwise
authorized by OFAC. The general license contained in 5l5.527(a) of the Regulations, which
authorizes transactions incident to the registration or renewal of a certain patents, trademarks,
and copyrights in the United States, is not applicable.
REQUEST FOR POLICY GUIDANCE: We seek the comments of the Department of State
with respect to this application before we make a determination as to whether OF AC should
issue a specific license authorizing the proposed transactions. We have been informed that
Habanos, S.A.'s opposition must be filed no later than Wednesday, April 13. Accordingly, we
request State's comments prior to that date.
Enclosure I (b)(
6
) I

2003-06-032 000366

I (b)(6) I
i
I . . .
RABINOWITZ, B.OUDIN, STANDARD, KRINSKY & UEBERMAN, P.C.
. LEONARD B. BOUDIN 1191219B9)
MICHAEL
ERIC M. LIESERMAN
OAVIOS. GOLDSTEIN
CHRISTOPHER J. KlATEll
CARRIE CORCORAN
KEITH M DONOGHUE
ATTORNEYS AT LAW
740 BROADWAY AT ASTOR PLACE, FIFTH FLOOR
. NEW YORK, NY 10003;9518
(212) 254t 11.1-1
FACSIMILE (212) 674j614
I
I
COUNSEL
. VICTOR RABINOWITZ
MICHAEl 9. STANDARD'
LEONARD I. WEINGLASS
DEBRA EVENSON
T.ERRY GROSS
February ll, 2005
VIA U.S. MAIL
Licensing Division
Office of foreign Assets Control
U.S. Department of Treasury- ANNEX 2221

Re: Application for Specific License for Habp.nos. S.A. to Oppose An-l
Application to Register the Trademark f(A VANA CLUB in Class
34, Application Serial No. 78363024
1
Dear Ms.-
(b )(6)
I
On behalf of Habanos, S.A., a legal entity organized under Cuban 'Jaw with its offices .in
Havana, Cuba, we hereby apply pursuant to 31 C. F .R. :515.80 I (b) of the Cuban Assets Control
Regulations for a specific license authorizing:
(a) Habanos, S.A. to file and prosecute an pposition in the Trademark Trial and
Appeals Board ("TT AB") of the United States Patent and Trademark Office ("USPTO") to an
application to register the trademark HAVANA CLUB in international class 34 for cigars filed
by Anncas, inc. (USPTO Serial Number 78363024), ari.d to pay all necessary filing and other
fees in connection therewith; and ;
(b) Rabinowitz, Boudin, Standard, Krinsky andi Lieberman, P.C. to represent Habanos,
S.A. in said opposition proceedings, and for it to solici
1
t and receive legal fees from Habanos,
S.A. for said representation and be reimbursed by Habanos, S.A. for any expenses incurred in
connection with that representation. . i
I
The aforesaid application registration was puJiished by the USPTO for opposition on
December' 14, 2004. Habanos, must bJ filed no rater than April 13, '2.005. We
therefore request your urgent attention to this request. I
., .
2003-06-032 000367 l.
Habanos, S.A. exports Cuban-origin cigars the world and intends to export
Cuban-origin cigars to the United States when pennitted by United States law.
. ! .
. It will Serial No. 78363024 the grounds that the HAVANA
mark is primarily geographically deceptively misdescriptive and also deceptively misdescriptive .
when used by applicant for its cigars, which are not of Cuban origin, and that, for those reasons,
the application for registration should be denied under Section 2(e)(l) and (3) of the Lanham
Act, 15 U.S.C. t052(e)(l) and (3).
I
31 C.F.R. 515.527; the general license authohzing Cuban nationals to pursue certain
, I .
proceedings in the USPTO, is inapplicable here. its terms, section 515.527 concerns .
transactions by Cuban nationals "related" .to the "registration or renewal" of trademarks in the
USPTO in the Government of Cuba or a Cuban !national has an interest. By letter dated
August 19, 1996, a copy of which is enclosed for your !convenience, OF AC Director Newcomb
advised that section 515.527 applies to opposition in the TTAB when the opposition
"relate[s] to the protection of a trademark in which Cuba, or Ct:iban national has an interest." The
instant opposition is not related to the registration or renewal of HAVANA CLUB or anyother
trademark in the USPTO, and is not related to the protetion trademark in which Cuba era
Cuban national has an interest. Rather, Habanos, S.AYs opposition is based on its claim that
applicant's use of HAVANA CLUB for cigars wiH and confuse consumers as to the
geographic origins of its cigars, thereby damaging Haba?os, S.A. as an exporter of Cuban-origin
cigars.
Inasmuch as 31 C.F.R. 515.527 is inapplic'able, no questions. are presented here
concerning Section 2.11 of the Department of Commc:rce Appropriations Act as included in
Publi<; Law 105-277, Section 10l(b), 112 Stat. 2681, or jts implementing regulation, 31 C.F.R.
515.527(a)(2).
1
I
More specifically, we request a specific license all transactions inCident to the
l
. I
fol owmg: 1 .
. I
I. Habanos, S.A.'s filing and prosecuting an opposition in TTAB to an application to
register the trademark HAVANA CLUB in intemationaiiclass 34 for cigars filed by Anncas, Inc.
(USPTO Serial Number 78363024), and paying all necdsary filing and other fees .in connection
therewith; I
I
'
2. Rabinowitz, Boudin, Standard, Krinsky and Ljeberrnan, P.C. representing Habanos,
S.A: in said opposition proceedings, and its sol.iciting and. receiving legal fees ftom Habanos,
S.A. for said representation and its being reimbursed by Habanos, S.A. for any expenses incurred
i.n connection with that representation; and 1. .
2003-06-032 ooo36s I
,,
3. Rabinowitz, Boudin, Standard, Krinsky and peberman, P.C. 's opening and
maintai.i:ting an account in a United States. financ,ial institution for funds to be used to
cover fees and-expenses to .be incum;d in conilecti.on with the legal representation authorized by
the specific liense; and returning to its soured outside. the United States any. unused
portion of.said advances'held in said escrow accol..int.
'this matter legal proceedings, are taking the liberty of forwarding a
copy of this application to the Legal Counsel's Office of'I'OFAC.
. Thank you for your attention to this matter.
. '
' Michael
Esq., Legal Counsel's Ofticd (by facsimile Mail)
I
cc:
en c.
I.
I
i
2003-06-032 000369 i
,,.1 01 l,
-:;.
3' )',
' ;;

''
I
I
WASHINGTON, q.c. 20220
I
I
!
I
LICENSE
I
(Granted under the authority of 50 U.S.C. App. 5(b), 22 u.s.b. 2370(a), 22 U.S.C. 6001 et seq., Proclamation
344 7, and 31 CFR Parts 50 I and 5.15) I
'
To: Rabinowitz, Boudin, Standard, Krinsky & Liebertnan, P.C. (the "Licensee")
. I
740 Broadway at Astor Place, Fifth Floor
1
NewYork,NY 10003-9518 :
I
AITN: Michael Krinsky, Esq. i
i
I .
I. Pursuant to your application dated February II, zdo5 (altogether, the "Application"), the following
transaction(s) is hereby licensed: i
I
I
* * * * * SEE REVERSE * * * * *
I
2. This license is granted upon the statements and made in your application, or
otherwise tiled with or made to the Treasury Department as a! supplement to your application, and is subject to
the conditions, among others, that you comply in all respects with all regulations, rulings, orders and
instructions issued by the Secretary of the Treasury under thelauthority cited above and the terms of this license.
I
3. The licensee shall furnish and make available for any relevant information, records or
reports requested by the Secretary of the Treasury or any authorized ofticer or agency of the Secretary.
4. This license is not transferable, is subject to the prbvisions of 31 C.F.R. Parts 50 I and 5 I 5, and any
regulations and rulings issued pursuant thereto and may be revoked or modified at any time at the discretion of
the Secretary of the Treasury acting directly or through the agency through which the license was issued, or any .
other agency designated by the Secretary of the Treasury. [f this license was issued as a result of willful
misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the
Secretary of the Treasury, be declared void from the date of its issuance, or from any other date.
!
5. This license dees not excuse compliance with any l,aw or regulation administered by the Oftice of
Foreign Assets Control or another agency (including reporting requirement) applicable to the transaction(s)
herein licensed, nor does it release the Licensee(s) or third parties from civil or criminal liability for violation
of any law er regulation. I
I
[ssued by directien and on behalf of the Secretary of the Treasury:
. . I
Robert W. Werner
Director
[Attention is directed to 19 U.S.C. 1592 and 1595a, 18 U.S.C.i545, 18 U.S.C. 1001, 50 U.S.C. App. 16, and
31 CFR 515.70 I et seq. for provisions relating to penalties.] i
---'-'------ -----------
2003-06-032 000370
Licensees: Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C.
I
-Page 2 of2
'
SECTION 1 -AUTHORIZATION: (a) All necessary transactions are authorized to enable the Cuban
entity Habanos, S.A. ("Habanos"), to file and prosecute an qpposition in the Trademark Trial and Appeals
Board of the United States Patent and Trademark Office ("USTPO") to an application to register the trademark
HAVANA CLUB in international class 34 for cigars filed by Anncas, Inc. CCTSTPO Serial Number 7863024)
and to pay all necessary filing and other fees in connection trerewith.
(b) The law firm of Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C. is authorized .to provide
legal representation to Habanos in said opposition proceedirlgs, to solicit and receive from Habanos, or other
appropriate Cuban entity, legal fees for said representation a
1
nd reimbursement for any expenses incurred in
connection with that representation, provided that the payments originate from a source not currently within the
United States, within the possession or control of a person subject to U.S. jurisdiction, and such payment is not
made from a blocked account or blocked funds.
(c) The law firm of Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C., is authorized to open and
maintain an escrow account at a U.S. financial institution for funds to be used to cover fees and expenses to be
incurred in connection with the legal representation authorized by the license and to return to its source outside
the United States any unused portion of advances held in the: escrow account.
i
SECTION 2'"'"' REPORTING REQUIREMENTS: (a) Tlie Licensee must submit copies of all pleadings,
motions, memoranda, exhibits, stipulations, correspondence,! and proposed orders or judgments (including any
proposed final judgment or default judgment) submitted to court or decision-making body, and of aU orders,
decisions, opinions, or memoranda issued by the court or body to Office of Chief Counsel,
Office of Foreign Assets Control, U.S. Department of the 1500 Pennsylvania Avenue, N.W., Annex
Bldg., Washington, D.C. 20220, within ten days of filing, submission or issuance.
(b) The Licensee must report by immediate telephone call facsimile transmission to the Chief Counsel's
Office, Office.of Foreign Assets Control (tel: 202/622-241 0; I fax: 202/622-1911 ), the scheduling of any hearing
or status conference in legal proceedings whenever it appear$ that a court or decision-making body may issue an
order or judgment or default judgment or is considering or may decide any pending motion dispositive of the
merits of an action or of any claim raised in an action. See 3i1 CFR 501.605.
SECTION 3 WARNING: (a) Except as authorized in 1 above, nothing in this license authorizes
persons subject to the jurisdiction of the United States to engage in any transaction or activity prohibited by the
Cuban Asset Control Regulations. I
I
(b) Nothing in this license authorizes a debit from any blocked account.
I
SECTION 4- PRECEDENCE: The authorization in this license is limited to the facts and
circumstances specific t_o the application. [
XXXXXXXXxXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX;XXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX:
2003-06-032 000371 .
I.

Cu ets Control Regulations
LICENSE
(Granted under the authority of 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C. 600 I et seq., Proclamation
3447, and 31 CFR Parts 50 I and 515)
To: Rabinowitz, Boudin, Standard, Krinsky & Lieberman, P.C. (the "Licensee")
740 Broadway at Astor Place, Fifth Floor
New York, NY I 0003-9518
ATTN: Michael Krinsky, Esq.
1. Pursuant to your application dated February 11, 2005 (altogether, the "Application"), the following
transaction(s) is hereby licensed:
* * * * * SEE REVERSE * * * * *
2. This license is granted upon the statements and representations made in your application, or
otherwise filed with or made to the Treasury Department as a supplement to your application, and is subject to
instructions issued by the Secretary of the Treasury under the authority cited above and the terms of this license.
3. The licensee shall furnish and make available for inspection any relevant information, records or
reports requested by the Secretary of the Treasury or any duly authorized officer or agency of the Secretary.
4. This license is not transferable, is subject to the provisions of 31 C.F .R. Parts 50 I and 515, and any
the Secretary of the Treasury acting directly or through the agency through which the license was issued, or any
other agency designated by the Secretary of the Treasury. If this license was issued as a result of willful
5. This license does not excuse compliance with any law or regulation administered by the Office of
of any law or regulation.
Issued by direction and on behalf of the Secretary of the Treasury:
By ______
Robert W. Werner
Director
[Attention is directed to 19 U.S.C. 1592 and 1595a, 18 U.S.C. 545, 18 U.S.C. 1001,50 U.S.C. App. 16, and
31 CFR 515.701 et seq. for provisions relating to P,enalties.]
Drafter/Division Reviewer/Division Initials/ Date
/Jf('J,-'ttt!;/(v,,. 1," ( )?i/o/',;//'")
2003-06-032 000372
MEMRANDUN FOR THE FILE
Habanos, S.A., requests a license to file and prosecute an opposition in the U.S. Patent and Trademark Office to
an application (likely filed by a U.S. company) to register the HAVANA CLUB trademark for cigars. Until
now, that trademark has been registered only for rum.
Section 515.527 of the Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Regulations"), which
authorizes by general license certain transactions with respect to the protection of Cuban intellectual property in
the United States, is not applicable because the applicant seeks only to challenge the HAVANA CLUB
application on its misdescriptive nature and the challenge allegedly is not related to the protection of any
Cuban-owned trademark in the United States. Therefore, it is a policy decision as to whether OFAC should use
515.801 authority to specifically license this opposition proceeding.
Note that, with respect to the protection of U.S. intellectual property in Cuba, there is a general license in
515.528 ofthe Regulations that authorizes the filing and prosecution of opposition or infringement
proceedings, in addition to the registration and receipt of a blocked Cuban trademark, patent, or copyright. It
may be difficult for U.S. persons to pursue opposition or infringement proceedings in Cuba if the Cuban
government perceives it does not have a similar opportunity in the United States.
Recommendation
That you sign this license to permit the Cuban entity to engage in the proposed transaction in the U.S. Patent
and Trademark Office as requested.
I (b)(6) I
2003-06-032 000373

LICENSE
(Granted under the authority of 50 U.S. C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C. 6001 et seq., Proclamation
3447, and 31 CFR Parts 501 and 515)
To:
Rabinowitz, Boudin, Standard, Krinsky & .. ______________ ---- .................. _, ___ ....... - ........ ____ _
740 Broadway at Astor Place, Fifth Floor _ ... . _ -:_-'!: _
NewYork,NY 10003-9518 <.k' ...
ATTN: Michael Krinsky, Esq. 0 .
1. Pursuant to your application dated F
transaction(s) is hereby licensed:

* * * * *
2. This license is granted upon the statement
otherwise filed with or made to the Treasury Departt
the conditions, among others, that you comply in all
instructions issued by the Secretary of the Treasury 1
3. The licensee shall furnish and make avail;
reports requested by the Secretary of the Treasury 01 .
4. This license is not transferable, is subject
regulations and rulings issued pursuant thereto and I
the Secretary of the Treasury acting directly or thrm
other agency designated by the Secretary of the Tre1
misrepresentation on the part of the applicant or his
Secretary of the Treasury, be declared void from the
5. This license does not excuse compliance
Foreign Assets Control or another agency C
herein licensed, nor does it release the Licensee(s) c
Issued by direction and on behalf of the Sec
By ______
Robert W. Werner
Director
directed to h1.U.S.C. 1592 and 1 545, 18 u.s.r. .1001_, 50 U.S.C. Ano.
1
1 fl. and

701
,-Revtewe tvJsion . l t' ifu e. ) RevJewer7DtVJSIOn Tl'utia s!Date
et seq. or provtstons re a mg to pena nes.
z . ., .... .. !!C.I ....
u
\../( ... -, l
2003-06-032 000374
-I (b)(5) I
' ..
Licensees: Rabinowitz, Boudin, Standard, Krinsky & Kieberman, P .C.
- 2 of 2 -
.. : .. ,
- ! ' .iJ J
SECTION 1- AUTHORIZATION: (a) All necessary transactions the Cuban
entity Habanos, S.A. ("Habanos"), to file and prosecute an opposition in,{he Trademark Trial and Appeals
Board of the United States Patent and Trademark Office ("USTPO") tgJegister the trademark HAVANA
CLUB in international class 34 for cigars filed by Anncas, Inc. (USTPO Serial Number 7863024) and to pay all
necessary filing and other fees in connection therewith.

(b) The law firm of Rabinowitz, Boudin, Standard, Krinsky & Kieberman, P.C. is authorizeto provide
legal representation to Habanos in said opposition proceedings, to solicit and receive from Habanos, or other
appropriate Cuban entity, legal fees for said representation and reimbursement for any expenses incurred in
connection with that representation, provided that the payments originate from a source not currently within the
United States, within the possession or control of a person subject to U.S. jurisdiction, and such payment is not
made from a blocked account or blocked funds.
Authority: 31 CFR 515.801.
SECTION 2- REPORTING REQUIREMENTS: (a) It is a condition of this license that the Licensee
submit copies of all pleadings, motions, memoranda, exhibits, stipulations, correspondence, and proposed
orders or judgments (including any proposed final judgment or default judgment) submitted to the court or
decision-making body, and of all orders, decisions, opinions, or memoranda issued by the court or decision-
making body, to: Chief Counsel's Office, Office of Foreign Assets Control, U.S. Department of the Treasury,
1500 Pennsylvania Avenue, N.W., Annex, Washington, D.C. 20220, within ten days of filing, submission or
issuance.
(b) It is a further condition of this license that the Licensee report by immediate telephone call or facsimile
transmission to the Chief Counsel's Office, Office of Foreign Assets Control (tel: 202/622-2410; fax: 202/622-
1911 ), the scheduling of any hearing or status conference in legal proceedings whenever it appears that a court
or decision-making body may issue an order or judgment or default judgment or is considering or may decide
any pending motion dispositive of the merits of an action or of any claim raised in an action.
See: 31 CFR 501.605.
SECTION 3 - WARNING: (a) Except as authorized in Section 1 above, nothing in this license authorizes
Cuban Asset Control Regulations.
(b) Nothing in this license authorizes a debit from any blocked account.
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
. ,.,
7-t: ,_.. -::---- *
/ (./ ( ... ;,J -{.,
I , ' ' _; 2003-06-032 000375
LICENSE
(Granted under the authority of SO u.s.c. App. 5(b), 22 2370(a), 22 U.S.C. 6001 et
seq., Proclamation 3447, and 31 CFR Parts 501 and 515)
To: Fish & Neave (the ''Licensee'')
1251- Avenue of the Americas
New York, New York 10020
Attn: Herbert F. Schwartz
1. Pursuant to your letter dated January 29, 2003, the following is hereby
licensed:
*****SEE REVERSE*****
2. This license is granted upon the statements and.representations made in your
application, or otherwise filed with made to the Treasury Department as a supplement to
your application, and is subject to the conditions, among others, that you comply in all
respects with all regulations, rulings, orders and instructions issued by the Secretary of
the Treasury under the authority of Section 620(a), Public Law 87-195, or under the
authority of section S(b) of. the Act bf 1917, as amended, and the terms of this
license.
3. The licensee shall furnish and make available for inspection any relevant
information, records or reports requested by the Secretary of the Treasury or any-duly
authorized officer or agency of the Secretary.
4. This license is. not transferable, is subject to the provisions of Title 31, Parts
501 and 515 of the. Code of Federal and any regulations _and rulings
pursuant thereto and may be revoked or modified at any time at the discretion of the
Secretary of the Treasury acting directly or through the agency. through which the license
was issued, or any other agency designated by the Secretary of the Treasury. If this
license was iSSUE\d aS a result of willful misrepresentation on the part Of the appli'cant or
his duly authorized agent, it may, in the discretion of the Secretary of the Treasury, be
declared void from the date of its issuance, or from any other date.
5. This license does not excuse compliance with any law or regulation. administered
by the Office of Foreign Assets Control. or another agency (including reporting
requirementst applicable to the transactions(s) herein licensed, nor does it release
Licensee(s) or third parties from civil or criminal liability for violation of any law or
regulation.
Issued by direction and on behalf of the of the Treasury:
..... '!.
OFFICE OF FOREIGN ASS$TS CONTROL
By
DAVID W. MILLS j MAR 1 0
R: Richard Newcomb/ Director
[Attention. is directed to 19 u.s.c. 1592 and 1595a, !l:oBU.s .. c. 5'\5, .. :i"B u.s.c. 1001.
50 U.S.C. and 31 CFR 515.701 et seq. for provisions relating to penalties.]
(b )(6)

2003-06-032 000376
Licensee: Fish & Neave
Page 2 of 2
SECTION 1 - AUTHORIZATIONS: All transactions are authorized to enable
Fish & Neave (the in connection with all matters related
to Galleon S.A. v. Havana Club Holding, S.A., Trademark Trial and Appeal
Board Cancellation No. 24,108, to provide legal services to, receive
payment for such services from and to receive reimbursement for expenses
related to such serv'ices from Empresa Cubana Exportadora De Alimentos y
Productos Varios (''Cubaexport"), a Cuban national.
Authorityl 31 CFR 515.801.
SECTION 2 - CONDITIONS: (a) It is a condition of this License that
Licensee shall keep a full and accurate record of each transaction
undertaken pursuant to this License, and that each such record shall be
available for examination for at least five years after the date of such
transaction.
SECTION 3 - REPORTING REQUIREMENT: Pursuant to 31 CFR 501.605 Licensee is
directed to provide all required reports, notices, copies and facsimiles.
SECTION 4 - WARNINGS: (a) Except as explicitly authorized in Section 1
above, nothing in this license authorizes persons subject to the
jurisdiction of the United States to engage in qny transaction or
activity prohibited by the Regulations.
SECTION 5 - WARNINGS: (b) Nothing in this License authorizes any debit or
from.any .blocked account.
SECT.ION 6 -PRECEDENCE: This License is issued on a nonprecedential
basis.

2003-06-032 000377
......
'
File Summary of CU-21 0950
The two licenses are in response to a request from Fish & Neave who seek authorization to
represent and be paid .for it (expenses mcluded) the named Cuban organization.
"I:he legal matter arises out of Bacardi's filing to cancel the Havana Club trademark. As of 1/21/03
the Trademark Trial and Appeal Board joined the named Cuban organization as an additional
respondent.
I (b)(s) I
I
.,
Page 1 of l
Correspondence Cover Sheet
Doc 10: CU-210950 Received: 31-JAN-03
Due Date: Exec Sec No.: -
From:
Organization: Fish & Neave
I (b)(6) I
Address: 1251 Avenue of the Americas
New York, NY 10020
Disposition cc Special:
Initial Assignemenl
Director
Deputy Director
Civil Penalties
Compliance
Enforcement
FTAT
IT
lnt'IPrograms
Plans & Policy
Chief Counsel
Sr. Advisor/Records
Notes:
Dis_gosition :.
Dated: 29-JAN-03
Enforcement No.: - Other Ref No.: -
Actual Party: Galleon S:A. v. Havana Club Holdings, SA
Subject: Req. for a lie. to provide and receive payments for legal
services and representation to Cubana Exportadora De
Alimentos y Productos Varios.
Control Copy to Director
Reassign 2 Reassign 3
http:/iofacoraprod/pls/fac/OF ACRprts.CoverSheet?p _ docid==2l 0950
2003-06-032 000379
l/31/2003 .
(b)(6)
OFAC FACDB System
OFAC Correspondence History Report
DOC ID: CU-177922
Report Date: January 31, 2003 User:- I (b)(6) I
OOCIO: CU-177922
Correspondent: Philip M. Crane
Organization:
Address:
Actual Party:
Subject:
House of Representatives
, Washington 20515-1308
. Havana Club; Cut>aexport
Recommends careful consideration of relevant facts
and implications of denial of license to transfer US
registration of the Havana Club trademark
Page l of I
Corresondence Type: Mail (Congress/ASE) Document Date: 08-DEC-99
Exec. Sec.#: 1999-SE-013142 Received atOFAC: 08-DEC-99
Enforcement #.:
Other No:
(None)
(None)
Date Out:
Date Closed: 11-JAN-00
http://ofacoraprod/pls/fac/OF ACRprts.HistoryRpt?p _ d o c i d ~ I 77922
2003-06-032 000380
113112003
FISH & NEAVE
DIRECT DIAL.
DIRECT FAX
E-MAIL
January 29, 2003
I (b)(6) I
HerbMf.Schwartz
Erie C. Wog/cm
John E. Nathan
RobM C. Morgan
Kenneth B. Herman
Robert A. JaCkSon
Jesse J Jenner
w. Edward Bailey
.Patricia A. Martone
ROOerick A. McKel.,.ie
f Haley. Jr.
Richard M. Bames
Lawence S. RQIJOrs
frederick P fish 18551930
Chart<sNeave 18671937
VIA FACSIMILE (CONF. BY FEDEX)
David W. Mills
Chief of Licensing Office of Foreign Assets Control
U.S. Department of Treasury
ANNEX 2221
Vincent N. Pa!!adino Jane A. Massaro Steven Chemy
Raben J. Goldman' OuaneDIMd Hough JosepH!. Guiliaoo
Thomas L Secrest Marl< D. Rowland' Jeanne C. Curtis
Daniel M. Galln E<lNard J. Defranco J. flattmann, Jr
Norman H. Beamer Eric R. Hubbafd Kevin P.B. Jo/)(lson'
Kellin J. Cufijgan Kelsey!. Teuence J.P. Kearnef
Glenn A. Ousterhout Wii!iam'J. McCabe Robert w. Morns
.Susan Progott Marta E. Gross Avinash S. Lela'
MargaretA. Pieui JohnM. HinU Jane T. Gunnisoo
Douglas J. Gibert Richard A. lnl Richard L. Rainey""
Denise L. Ll)'in<J Frances M. Lynch Jamos E. Hopenletd"
Jeffrey H. lngerman Christopher J. Ham en Pablo D. HenciC!
Mark H. Bloomllerg A. Joy Amold Brian C. Cannon"
RE: Application For Specific License in connection with Galleon S.A. v. Havana Club
Holding. SA .. Trademark Trial and Appeal Board Canceilation No. 24,108
Dear Mr. Mills:
Of Counsol
Kenneth A. GenC(li
Gene w. Lee
senior Attome)'!
A. Peter Adler
Thomas J. vener
CllartesOuinn
usa E. CriSial
GibrieHe E.
Fish & Neave hereby applies for a specific license to provide and receive payment for legal
services and representation to -Em pres a Cub ana Exportadora De .y Productos Varios,
S.A., dba CCubaexport") in connection with the above-captioned
proceeding pending before the Trademark Trial arid Appeal Board CTTAB") of the u.s-. Patent
and Trademark Office. By such proceeding, Bacardi seeks to cancel U.S. trademark registration
No. I ,03 I ,651, which is owned by Cubaexport and covers the mark HAVANA CLUB &
Design. We seek this license in light of a decision issued by the TT AB on January 21, 2003
(copy enclosed) which joined Cubaexport as an additional respondent to the proceeding.
We specifically request that a specific license issue authorizing all necessary transactions in
connection with legal representation by Fish & Neave of Cubaexport, a Cuban national, for the
following purposes:
(i) to defend to completion the cancellation proceeding entitled Ca!leo11 S.A.,
Bacardi-Marlini U.S.A, Inc, and Bacardi & Company Limited v. Havana Club Holding, S.!l.,
1251 AVENUE OF 'THE AMERICAS, NEW YORK, NY 10020 "'J'EL 212.596.9000 FA'X 212.596.9090
525 UNIVERSITY AVENUE, PALO ALTO, CA 94301 TEL 650.617.4000 FAX 650.617.4090
1825 I STREET, NW. SUITE: 400, WASHINGTON DC 20006 TI:L 202.S57.5222 FAX 202.657.5237
2003-06-032 000381
FISH &. NE;A."'V'E.
David w. Mills
January 29, 2003
Page 2
dba HCH, S.A., and Empresa Cubana Exportador De Alimentos y Productos Varios, S.A., elba
Cubaexport, joined as a defendant (TT AB Cancellation No. 24,1 08), including appeals;
(ii) to solicit and receive fee payments and reimbursements for expenses incurred in
connection with the legal representation authorized by the license; provided that said fees and
expenses are paid exclusively from fresh funds outside the United States; and
(iii) for travel to Cuba by attorneys at this firm and others acting under their
supervision and control, for the purposes ofconununicating with our client in connection with
the above.
We make the instant application for a license without prejudice to our position that tfle Office of
Foreign Assets Control lacks statutory authority to require a license for a Cuban national to
defend a proceeding of the nature involved here and to defend the same to conclusion.
Inasmuch as this matter concerns legal proceedings, we are taking the liberty of forwarding a
copy of this application to the Office of Chief Counsel, OF A C.
cc:
I (b)(6) I
Esq., Office of Legal Courtsel,.OFAC
Licensing Division, OF AC
2003-06-032 000382
,. SHINGTO> :.c. :e.0220
Gorrespondence Acknowledgment
Date: February 04, 2003
,_ l(b)(6)1
1251 Avenue of the Americas
New York, NY 10020.
tjCENSING DIVISION
Tel: 212 596 9000
Fax: 212 596 9090
OFFICE OR FOREIGN ASSETS AND CONTROL ("OFAC")
U.S. DEPARTMENT OF TREASURY
1500 PENNSYLVANIA AVENUE, N.W.
Re: Doc 10. CU-210950
This is to acknowledge receipt of your correspondence dated 29-
JAN-03. Please refer to the FAC Number cited above and the
date of your original correspondence if you need to contact us or
. send supplemental information. Please note that filing an
application for a license or requesting information about the
transaction prohibitions contained in Executive Order or
regulations administered by OFAC doesnotsuspend or excuse
compliance with th'e prohibitions or requirements contained
within. We look forward to serving you
Note: Information on sanctions programs administered by OFAC can be
retrieved at any time from our automated fax-on-demand system by dialing
(202)622-0077 or from our World Wide Web home page on the internet at
www.treas.gov/ofac.
Fax To:
' : :
. ,'.
. . . . . . .
' I ':, ,' ', ' ", w, :-. .- .,... ,.;.., ': ...... ..,.. .... :.. ;": :: .... ... .. c: :., ,' - -:--:f . ,,J. :. ;' ' .......
.. '
.. ' . f . '
. .
. ... '':.
..... ' .. .-._,< :: '
._i
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...
Cuban Assets Control Regulations License No. CU-71417
LICENSE
(Granted under the of 50 U.S.C. App. S(b), 22 U.S.C. 23iO(a), 22 U.S.C. 6001 et
seq., Executive Order 9193, Proclamation 3447, and 31 CFR Parts 501 and 515)
1. Pursuant to your application materials dated January 29, 2003 the following is
hereby licensed:
2. This license is granted upon the statements and representations made in your
application, or otherwise filed with or made to the Treasury Department as a to
respects with all regulations, rulings, orders and instructions issued by the Secretary of
authority of section S(b) the Act of October. 6, 1917, as amended, and the terms of this
license.
information, records or reports requested by the .secretary of the Treasury any duly
4. This license on March 2004, and is not transferable, is to
provisions of Title 31, Parts 501 .and 515 of the Code of Federal Regulations, and any
regulations and rulings issued pursuant thereto and may be revoked or modified at any time
at the discrhioh 'of the -'Treasury' acting. directly or through the agency>
through which the .license was issued, or any. other. agency design"a\;:ed>by thb'sec'retary :ol
the ... this. lice:t:Jse. _was issued as a r.esult o( wiilful. misrepresentation OJ) ..
part o'f. th'e "a:Prn idWt: b'r. hi!s C(fui? authoriied. ."''i-t' ,
1
irlC:the 'of (the:,-:-::' .. -!<;
Secretary of the Treasury, be declared void from the date of its issuance, or from any
other date.
5. This license does not excuse compliance with any law or regulation administered
by the Office of Foreign Assets Control or another agency (including reporting
requirements) applicable. to the transactions(s) herein licensed, nor does it release
Licensee(s) or third parties from civil or criminal liability for violat{on of any law or
regulation.
Issued by and on behalf of the Secretary of the Treasury:
_ OFFICE OF FOREIGN ASSETS CONTROL
-. ::----- / . 1- /r .3;<-
.. : I ,
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David W. Mills, Chief' of Licensing
[Attc:ntion ?i,rect:e,d to }9 U.S.C. _1592 and .1595a, 18 U.S.C. 545, 18 U.S.C. 1001,
50 U.S,c. App, 16, and'3l . .CFR515.701et for.pro-0-isions relatirig,to
6 -.>
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2003-06"032'00.0384 .
License
Fish Neave
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Page 2 of 2
SECTION 1 - AUTHORIZATION: (a) This license authorizes att0rneys and
others acting under their supervision and control under the auspices of
Fish & Neave (the ''Licensees'') to engage in travel-related transactions
in Cuba as set forth in 31 CFR and such additional
transactions as are directly incident to performing professional research
and participating in professional meetings with Empresa Cubana
Exportadora De Alimentos y Productos Varios (''Cubaexport") in
connection with all matters related to Galleon S.A. v. Havana Club
Holding, S.A., Trademark Trial and Appeal Board Cancellation No. 24,108.
(b)_ This license authorizes multiple trips during the validity period of
the license.
Authority: 31 CFR 515.560(c) and 515.564(b).
SECTION 2 - CONDITION: (a) It is a condition of this license that the
Licensees shall adhere to a full-time schedule of professional research
and professional meeting activities consistent with 31 CFR 515.564(b).
(b) It is a coridition of this License that Licensee shall keep a full and
accurate record of each transaction undertaken pursuant to this License,
and that each such record shali be for examination for at least
five years after the date of such
SECTION 3 - WARNING: (a) This license does not authorize travel-related
transactions related to commerc:ial or tourist'ic activities that are
inconE?istent. a full . ., U ... me agenda of: professional resea:r;Fh and
prot: ing: .activities .
. . . . ' . . '. . ' ' . .. ' I . . ' .. ' :
(b) no,t.' authorize the.
services described in 31 CFR 515.572(a) (1) to other organizations.
specific travel service provider authorization is required for this
purpose based on an application that must be filed and processed through
OFAC's Miami office.
SECTION 4 - INFORMATION: The Department of State publishes consular
information sheets (and, when necessary, travel warnings) on every
country and territory in the world, including Cuba, which'are available
on the Internet at http://travel.state,_ggy, or through the State
Department's fax-on-demand service at (202) 647-3000. An abridged
version of consular information sheets can be heard by calling (202) 647-
5225.
SECTION 5 - PRECEDENCE: This license is issued on a non-precedential
basis.
. . ' ,. ' ' ., . : : . . . . . .. . . . . . . : ' . . . ' . . . . : . . . ' . . . . . . . . . .. . .
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2003-06-03:;t 000385
.,,
DEPARTMENTOFTHETREASURY
LICENSE
,1;'
(Grante5 under the authority of 50 U.S.C. App. S(b), 22 u.S.C. 2370(a), 22 U.S.C. 6001 et
Executfve Order 9193, Proclamation 3447, and Parts 501 and 515)
New York, New York 10020
Attn:
1. Pursuant to your application materials dated January 29, 20D3 the following is
licensed:
2. This license is granted upon the statements and representations made in your
application, or otherwise filed with or made to the Treasury Department as a supplement to
respects_ with all regulations, rulings, orders and instructdons issued by the Secretary of
authority of section S(b) of the Act of October 6, 1917, as amended, and the terms of this
license.
information, records or reports requested by the Secretary of the or any duly
authorized or agency of the Secretary.
4. This license on March l, 2004, and is not transferable, is subject to the
provisions of Title 31, Parts 501 and 515 of the Code of Federal Regulations, and any
at the discretion of the Secretary of the Treasury acting directly or through the agency
through which the licen.se.was issued, 'or any.ot'her agency designated by the Secretary of
tl'ie Treaf3ury .. If this. license was issued as a 'result misrepresentation on. the
of the applicant or hies duly agent:, it. may,.. in': the, discret-ion' of thE! , ,i:
Secretary of the Treasury, be declared void from the date of its issuance, or from any
other date.
5. This license does not excuse compliance with any law or r.egulation administered
by the Office of Foreign Assets Control or another agency (including reporting
requirements) to the transactions(s) herein licensed, nor does it release
Licensee(s) or third parties from civil or criminal iiability for violation of any law or
regulation.
Issued by and on behalf of the Secretary of the Treasury:
u,s.c.
I (b)(6) I 0/l..VlO w MILLS MAR. 0 6 2003
W. Mills, Chief of Licensing
is directed to 19 u.s.c. 1592 and is95a, 18 u.s.c. 545, 18
App. 1'6/ and 31 CFR515:701 et seCJ. for prov.isions relating to penalties.!.
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Page 2 of 2
SECTION 1 - AUTHORIZATION: (a) This license authorizes attorneys and
.. others acting under their supervision and control under the auspices of
i Neave (the ''Licensees'') to engage in travel-related transactions
in Cuba as set forth in 31 CFR 515.560(c) such additional
transactions as are directly incident to performing professional research
and participating in professional meetings with Empresa Cubana
Exportadora De Alimentos y Productos Varies ( "Cubaexport'') in
connection with all matters related to Galleon S.A. v. Havana Club
Holding, S.A., Trademark Trial and Appeal Board Cancellation No. 24,108.
(b) This license authorizes multiple trips during the validity period of_
the license.
Authority: 31 CFR 515.560(c) and 515.564{b).
SECTION 2 - CONDITION: (a) It is a condition of this license that the
Licensees shall adhere to a full-time schedule of professional research
and professional meeting activities consistent with 31 CFR 515.564(b).
(b) It is a condition of this License that Licensee shall keep a full and
accurate r.ecord of each transaction undertaken pursuant to this License,
and that each such record shall be available for examination for at least
five years after the date of such transaction.
SECTION.3 - WARNINGi (a) This license does not authorize travel-related
ttansactions.related to commercial or touristic activities ar.e
inconsistent with a agenda of professional.
professional meeting activities.
(b) This license does not authorize the Licensee to prov).de ,the travel
servi.ces descrlb:ed-: ln '3 l cFR' 515. 5.7.2 (a) 'ci'), to
Specific travel service provider authorization is required for this
purpose based on a-n application that must be filed and processed through
OFAC's Miami office.
SECTION 4 - INFORMATION: The Department of State publishes consular
information sheets (and, when necessary, travel warnings) on every
country and territory in the world, including Cuba, which are available
on the Internet at http://travel.state.gov, or through the State
version of consular information sheets can be heard by calling (202) 647-
5225.
SECTION 5 - PRECEDENCE: This license; is issued on a non-precedential
basis.
*************************************************************************
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File Summary of 0950
The two licenses are in response to a request from Fish & Neave who authorization to
represent and be paid for it (expenses included) the named Cuban organization.
The legal matter arises out of Bacardi's filing to cancel the Havana Club trademark. As of 1/21/03
the Tradem<uk Trial and Appeal Board joined the named Cuban organization as an additional
respondent.
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Page I of 1
Doc ID: CU-210950 Received: 31-JAN-03
Due Date: Exec Sec No.: -
From:
Organization: Fish &.Neave
New York, NY 10020
cc Special:
Initial Assignement
Director
Deputy Director
Civil Penalties
Compliance
Enforcement
FTM
IT
DisP-osition:
File Name/Location:
Remarks
'... <'
Dated: 29-JAN-03
Enforcement No.: - Other Ref No.: -
Actual Party: Galleon S.A. v. Havana Club Holdings, SA
Subject: Req. for a lie. to provide and receive payments for legal
services and representation to Cubana Exportadora De
Alimentos y Productos Varies.
Control
Reassign 2 Reassign 3
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Initials: Date:
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OFAC FACDB System
OFAC Correspondence History Report
DOC ID: CU-177922
Report Date: January 31, 2003 User:- I (b)(6) I .
DOCID: CU-177922
Correspondent: Philip M. Crane
Organization:
Address:
Actual Party:
Subject:
House of Representatives
, Washington 20515-1308
Havana Club; Cubaexport
Recommends careful consideration of relevant facts
and implications of denial of license to transfer US
registration of the Havana Club trademark
Page I of I
Corresondence Type: Mail (Congress/ASE) Document Date: 08-DEC-99
Exec. Sec.#: 1999-SE-013142 Received at OFAC: 08-DEC-99
Enforcement #:
Other No:
(None)
(None)
.... -;_:.:]:<"]:.:\: ' .
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Date Out:
Date Clos.ed: 11-JAN-00
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OF TH.ETREASURY
Cuban Assets Cont.rol Regulations License No. CU-71416-a
UCENSE
(Granted under t\le autuority of 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C. 6001-lO, Proclamation 3447,
and 3 I CFR Parts 50 I and 515)
To: Fish & Ncave (the "Licensee")
1251 A venue of the Americas
New Y NY I 0020
ATTN: :. ' "'!
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'T. ''Pursuirtt to your application o(Npdi 27/20o4;'as suppiemented May 7, 200;i((aitdgethtr, . '
"Application"), the following is hereby
;_,_; ...
* * * * * SEE REVERSE * * * * *
.. 2 .. This license is granted up'on the arid made iii' your a:p'plic.ai:ion,
otherwise filed with or made to the Treasury Department as a supplement to your application, ;md is subject to
theconditions, among others, that you comply in all respects with all regulations, rulings, orders and
instructions issued by the Secretary ofthe Treasury under the authority cited above and the terms of this license.
3. The licensee shall furnish and make available for inspection any relevant information, records or
requested by the Secretary of the Treasury or any duly authorized officer or agency of the Secretary.
4. This license is not transferable, is subject to the provisions of 31 C.F.R. Parts 501 and 515, and any
other agency designated by the Secretary ofthe Treasury. lfthis license was issued as a result of willful .
Secretary of the Treasury, be declared void from the date of its issuance, or from any other date ..
herein licensed, nor does itrelease the Licensee(s) or third parties from civil or criminal liability for violation
OFFICE OF,KOREIGN ASSETS CO!'JT,.?L
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By ----- .. I J/ <, ...--/ { r ) r I
David W. Mills
Chiefof Licensing
[Attention is directed to 19 U.S.C. 1592 and 1595a, 18 U.S.C. 545, 18 U.S.C. 1001, 50 U.S.C. App. 16, and
31 CFR 515.701 et seq. for provisions relating to penalties.]
2003-06-032 000391
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License No. CU-71416-a
Licensees: Fish & Neave
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Page 2 of2
SECTION 1- AUTHORIZATION: The Licensee is authorized to receive payment from Cuban entities
named in the Application in connection with the Licensee's p-rovision of services for their legal representation
in the following litigation: Bacardi & Company Limited and Bacardi U.S.A., Inc. v. Empressa Cubana
Exportadora de Alimentos v Productos Varios d/b/a/ Cubaexport and Havana Club Holding SA. d/b/a HCH,
SA. (filed in the District Court for the District of Columbia) and Galleon S.A., Bacardi-Martini U.S.A., Inc.,
and Bacardi & Companv Limited v. Havana Club Holding, S.A., d/b/a HCH. S.A., and Empresa Cuban
Exportadora De Alimentos v Productos Varios, S.A., d/b/a Cubaexport (Tradernark Trial and Appeal Board
Cancellation No. 92024108).
Authority: 31 CFR 515.512 .
:.. , : ... h ............ _ .: ..... : .. .. ..... J. ; . : . . . .. "(ft..,-_. __ ;_ . ;J.: .. .. <i\ ... .. .
'' sECTION.2- CONDITIONS:. (a) lt'is a condition of this license that the s\lbJTiitcopies of ;ill
. - pleiidtngs, mptions, ineniotarida, exhibits, -stipulatio:rls, correspondence, _arid proposed orders or jti,dgmeilts
(including any ftnaUudgmerit o( default judgtnen_t) body,
and of all orders, decisions, opinions, or memorat1da issueq :py the court .or body, to: ;Chief
Counsel's Office, Office of Foreign Assets Control, U.S: Department ofthe Treasury, 1500 Pennsylvania
Avenue, N.W., Annex, Washington, D.C. 20220, within ten days of filing, submission or issuance.
_ (b) It is a further condition of-this the Licensee report by immediate telephone ()r _facsilJlile
transmission to the CliiefCol!-nsel's Office, Offic;e ofForei'gn Control (tel': fax: 202/622-
-1911 ), the of any heapng or.st<!-tuS conference in whenever it appears that a court
any pending motion dispositive of the merits of an action oro( any claim raised in an action.
See: 31 CFR 501.605.
SECTION 3- WARNING: (a) Except as authorized in Section l above, nothing in this license authorizes
regulations.
(b) This license does not authorize any-debit to a blocked account. Any payment received from a Cuban entity
pursuant to the authorization in Section l above must be from fresh funds.
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxxx
000392
. ..
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..

DEPARTMENT OFTHE TREASURY
LICENSE
.. ,. '
- ..... .<' '::-- .
(Granted under the authority of 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a), 22 U.S.C. 600 l-1 0, Proclamation 3447,
and 3 l CFR Parts 50 I and 5 l 5)
To: Fish & Neave (the "Licensee")
NewY
AttN: I (b)(6) r
. l. Pursuant to your application of April27, 2004, as supplemented May 7, 2004 (altogether, the
"Application"), the following transaction(s) is hereby licensed:
* * * * * SEE REVERSE * * * * *
2. This license is granted upon the statements and representations made in your application, or
filed with or made to the Treasury Department as a supplement to your application, and is subject to
instructions issued by the Secretary of the Treasury under the authority cited above and the tenns of this license.
3. The licensee shall furnish and make available for inspection any relevant infonnation, records or
reports requested by the Secretary of the Treasury or any duly authorized officer or agency of the Secretary.
4. This.license is not transferable, is subject to the provisions of 31 C.P.R. Parts 50 I and 515, and any
other agency designated by the Secretary of the Treasury. If this license was issued as a result of willful
misrepresentation on the part of the applicantor his duly authorized agent, it may, in the discretion of the
By ________
David W. Mills
Chief of Licensing
[Attention is directed to 19 U.S.C. 1592 and !595a; 18 U:S.C. 545,.18 U.S.C. 1001,50 U.S.C. App. 16, and
31 CFR 515.701 seq. for provisions relating to penalties.]
./
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2003-06-032 000393
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Licensees: Fish & Neave
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Page 2 of 2
SECTION 1- AUTHORIZATION: The Licensee is authorized to receive payment from Cuban entities
named in the Application in connection with the Licensee's provision of services for their fegal representation
in the following litigation: Bacardi & Company Limited and Bacardi U.S.A .. Inc. v. Empressa Cubana
Exportadora de Alimentos y Productos Varios d/b/a/ Cubaexport and Havana Club Holding S.A. d/b/a HCH,
S.A. (filed in the District Court for the District of Columbia) and Galleon SA .. Bacardi-Martini U.S.A., Inc.,
and Bacardi & Companv Limited v. Havana Club Holding, SA., d/b/a HCH, SA., and Empresa Cuban
Exportadora De Alimentos v Productos Varios, SA., d/b/a Cubaexport (Trademark Trial and Appeal Board
Cancellation No. 92024/08).
'' .
_. Qf an
.... pleadings, motions; memoranda, eXhibits; stipulations; e:orresportdence; arid- proposed orders 'dr judgments
(including any proposed final judgment or default judgment) submitted to the court or decision-making body,
and_ofall orders, decisions, opinions, or memoranda issued by the court or decision-making body, to: Chief
. Counsel's Office, Office ofForeignAssets Control, U.S. Department of the 1500-Pennsylvania
Avenue, N.W., Annex, Washington, D.C. 20220, within ten days of filing; submission or issuance.
(b) It is a further condition of this license that the Licensee report by iqnnediatt: telephone call or facsimile
transmission to the Chief Counsel's Office, Office of Foreign Assets Control (tel: 202/622-2410; fax: 202/622-
1911 ); the scheduling of any hearing or status conference in legal proceedings whenever it appears that a court
any pending motion dispositive of the merits of an action or of any claim raised in an action.
See: 31 CFR 501.605.
SECTION 3- WARNING: (a) Except as authorized in-Section 1 above, nothing in this license authorizes
regulations.
(b) This license does not authorize any debit to a blocked account. Any payment received from a Cuban entity
pursuant to the authorization in Section l above must be from fresh funds.
XxxXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXXX
.. 2003-06032 000394
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Doc 10: CU-225755 Received: 03-MAY-04 Dated: 27-APR-04 Initials:
Due Date: Exec Sec No.: Enforcement No.: Other Ref No.:
From: Actual Party: Fish & Neave
Organization: Fish & Neave
Subject: Apllicaation for extensinon of License No. CT-1943 or new
specfic license
New york, , NY 11020
Disposition cc Special:
II
Control Copy to Diret:;tor
Initial Assignment Reassign 2 Reassign 3
Director
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Enforcement
II:
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FTAT.
IT
lnt'l Programs
icensing
Plans & Policy
Chief Counsel
Sr. Advisor/Records
Notes:
Disposition:
File Name!Locatioo: Initials:
Remarks
http://ofacoraprod/pls/fac/OF ACRprts.CoverSheet?p _ docid=2257 55 6/2/2004
. . . ; . .- :_., . : 2003-06-032 000395
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,

Herten F
Eric C. Woqi<XTl
Robert J Goldman
Thcmas L Secrest
Daniel M. Ganrt
NOfmao H. Beamer
Kevin J. Culligan
Gtcnn A. OustertlOut
Susan Progaff
Margare1 A. Pierri
Douglas J. Gilbel1
Denise L Loring
Jefhey H. lnqerman
Mark H. 8/oomoerg
Jane A. Massa10
DuaneDevid Hou9h
Mark D. R(){llancr
Kevin P.B . .J<:Ilnsoo'
Terrence J. P Kearney
Roten W. Morris
AvlnaSII S. Lele'
Ot Counsel
Albert E. Fey
Kenneth A.
Gene W.Lee
FISH & NEAVE
DIRECT DIAL
DIRECT FAX
E-MAIL
April 27, 2004
(b )(6)
Rollei1 C. Morgan
Kenneltl B. Herman
ROO.n R Jackson
Jesse J. Jenner
W.ECiwarOBaley
PauiciaA. Martt:{le
R.
James f. Haley Jr.
fktlar6M.Barnes
laUii!nce S. Rogers
Vmcen! N. Palladino
FredertcK P. fiSn 18551930
Chartes Neave 1867-1937
VIA FACSIMILE (CONF. BY FED EX)
Mr. David W. Mills
Chief of Licensing
Licensing Division
U.S. Department of the Treasury
Washington, DC 20220
Eric R. Hubbard
J. McGalle
JollnM.Hintz
A.lf\l
Fra!1Ces M. Lynch
Chflstocner J. Harnett
A. Ji>! Arnokl
Steven Cherny
Josepil M. Guiliano
Jeanne C. Curtis
Gerald J. Flanrnann. Jr.
Jane T. Gunnison
RicM!O l.. RaiM'("
James E. Hopenlelo-
Pabfo 0. Hendler
Brian C. Cannon
Roten 8 l\llson
Re: Application for extension of License No. CT-1943 or new specific license
Dear Mr. Mills:
Martin A. Ler<11
Oaniet M. Bcck.er
Senior Attorneys
A. Peter Adler
Thomas J. Vetter
Chartes QUinn
usa Eo Ctistal
E.
fhomas o. Burke
Fish & Neave, a law firm, is currently the licensee under License No. CT-1943 (dated February
20, 2004 and set to expire on March 31, 2005) pertaining to authorization for (a) Fish & Neave
to "engage in travel-related transactions involving Cuba set forth in 31 CFR 515.560(c) of the
Cuban Assets Control Regulations (the 'Regulations') and.such additional. transactions as are
directly incident to professional research relevant to legal proceedings in the United States,
including but not limited to conducting interviews and depositions, and creating written and
other records, as described in your application ... ", (b) Fish & Neave to "provide legal services
to, and to. receive payment for such services from" Empresa Cubana Exportadora de Alimentos
y Productos Varios, a Cuban national, and (c) "multiple trips during the validity period of the
license." A copy of License No. CT-1943 is enclosed at Tab 1.
Section 6 of License No. CT -1943 states that "[t ]he authorization contained in this license is
limited to the facts and circumstances specific to the application." In Fish & Neave's
626 IJNIVERSITY AVENUE, PALO ALTO, CA 94301 TEL 850.817.4000 FAX 860.817.4090
1:Z51 AVENUE OF THE AMERICAS, NEW YORK, NV 100:ZO TEL :.!12.596.9000 FAX :Z1 :.!.596.9090
1899 PENNSYLVANIA AVENUE, NW, WASHINGTON, DC 20006 TEL 202.303.:.!400 FAX 202.303.2490
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FISH .S.. N EAVE
Mr. David W. Mills
April 27, 2004
Page 2
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February II, 2004 application for License No. CT-1943, Fish & Neave requested a renewal or
extension of License No. CU-71417 (which was set to expire on March 1, 2004), or in the
alternative, a new specific license. License No. CU-71417 pertained to authorization for
(a) "attorneys and others acting under their supervision and control under the auspices of Fish &
Neave (the 'Licensee') to engage in travel-related transactions in Cuba as set forth in 31 CFR
515.560(c) and such additional transactions as are directly incident to performing professional
research and participating in professional meetings with Empresa Cubana Exportadora De
Alimentos y Productos Varios ('Cubaexport') in connection with all matters related to Galleon
S.A. v. Havana Club Holding, S.A., Trademark Trial and Appeal Board Cancellation
No. 24,1 08," and (b) "multiple trips during the validity period of the license." A copy of the
license is enclosed at Tab 2. Fish & Neave's February 11,.2004 application also referred to
License No. CU-71416 (a copy of which is enclosed at Tab 3) which pertained to authorization
of all transactions "to enable Fish & Neave (the 'Licensee'), in connection with all matters
related to Galleon S.A. v. Havana Club Holding, S.A., Trademark Trial and Appeal Board
Cancellation No. 24,108, to provide legal services to, receive payment for such services from
and to.receive reimbursement for expenses related to such services from Empresa Cubana
Exportadora De Alimentos y Productos Varios ('Cubaexport'), a Cuban national." (Emphasis
added.)
The aforementioned cancellation proceeding is captioned "Galleon S.A., Bacardi-Martini
U.S.A., Inc., and Bacardi & Company Limited v. Havana Club Holding, S.A.,_ dba HCH, S.A.,
and Empresa Cubana Exportadora De Alimentos y Productos Varios, S.A., dba Cubaexport,
joined as a defendant" (Trademark Trial and Appeal Board Cancellation No. 920241 08). The
cancellation proceeding was initiated by Bacardi and relates to Cubaexport's U.S. Trademark
Registration No. 1,031,651 ofHAVANA CLUB & Design.
On March 29, 2004, Bacardi & Company Limited and Bacardi U.S.A., Inc. filed a complaint
against Empresa Cubana Exportadora De Alimentos y Productos Varios and Havana Club
Holding, S.A. in the U.S. District Court for the District of Columbia. The complaint relates in
part to an appeal from a decision in the aforementioned cancellation proceeding pertaining to the
HAVANA CLUB & Design trademark. A copy of the complaint is enclosed at Tab 4.
Since the issuance of License No. CT-!943, Fish & Ncave has undertaken the following
activities pursuant to License No. CT-!943: (i) Fish & Neave has continued to provide legal
advice pertaining tomatters relating to Galleon S.A., Bacardi-Martini U.S.A., Inc., and Bacardi
& Company Limited v. Havana Club Holding, S.A., and Empresa Cubana Exportadora De
Alimcntos y Productos Varios, S.A., Trademark Trial and.Appeal Board Cancellation
No. 92024108, and (ii) Fish & Neave has received payment in connection with such services
pursuant to License No. CT -1943.
,'; 2D03-06-032 000397 '
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FISH & NEA'VE
Mr. David W. Mills
April 27, 2004
Page 3
Fish & Neave hereby requests an extension of License No. CT-1943, or in the alternative, a
new specific license, for purposes of enabling Fish & Neave personnel, in connection with all
matters relating to Bacardi & Company Limited and Bacardi U.S.A., Inc. v. Empresa Cubana
Exportadora De Alimentos y Productos Varios d/b/a Cubaexport and Havana Club Holding,
S.A. d/b/a HCH, S.A. (filed in the U.S. District Court for the District of Columbia) and Galleon
S.A., Bacardi-Martini U.S.A., Inc., and Bacardi & Company Limited v. Havana Club Holding,
S.A., dba HCH, S.A., and Empresa Cubana Exportadora De Alimentos y Productos Varies,
S.A., dba Cubaexport (Trademark Trial and Appeal Board Cancellation No. 920241 08), to
(a) in travel-related transactions involving Cuba set forth in 31 CFR 515.560(c) of the
Cuban Assets Control Regulations and such additional transactions as are directly incident to
professional research n:!levant to legal proceedings in the United States, including but not
limited to conducting interviews and depositions, and creating written and other records,
(b) provide legal services to, receive payment for such services from, and receive reimbursement
for expenses related to such services from Empresa Cubana Exportadora De Alimentos y
Productos Varios, a Cuban national, and (c) make multiple trips during the validity peri<;>d of the
license.
In as much as this matter concerns legal proceedings, we are taking the liberty of forwarding a
copy ofthis application to the Office of Chief Counsel, OFAC.
Thank you for your attention to this matter. If we can be of further assistance, please do not
hesitate to call me a I (b)(6) I
Enclosures
cc: Office of Legal Counsel, OFAC
Licensing Division, OF AC
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OF THE TREASU-RY .
WASHINGTON, D.C. 2022C
LICENSE
(Granted under the authority cicso u.s.c. App. S(b), 22 u:s.c. 2370(a), 22 u.s.c. 6001 et
seq., ExeGutive Order 9193, Proclamation 3447, and 31 CFR Parts.501 and 515)
Avenue of the Americas
New
Attn:
.I (b)(6) 1
. .
1. Pursuant. to your application materials dated Ja.h\iaf,; :29, 2bo8 the following is
hereby licensed:
1,
2. This license is g.ranted upon the statement!3 and representations made iri your
application, otherwise. tiled with or to the Treasury Department a.supplemerit to
your application, and is subject to the tonditions, among others, that you comply in all
respects with all regulations, rulings, and insttuctions issued by the Secretaty of
the Treasury under the authority of Section 620(a), Public or under the
authority of section '5'(b) of the Act of October 6, 1917, as amended, and the terms of. this
license.
3. The shall furnish and make avaflBble for inspection any relevant
records or rep0rts requested by the Secretary of the Treasury or any duly
authorized officer or of the
\' _.,
4. This license expires on March 1, 2004, and is not transferable,. is subject to the
provisions of Title 31, Parts 501 and 515 of the Code of Federal Regulations, and any
at the discretion of the Secretary of the Treasury acting directly or through the agency.
through which the license was issued, or any other agency designated by the Secretary.of
the Treasury. If this license was issued as a result of willful misrepresentation on the
part of the applicant or his duly authorized agent, it may, in the discretion of the
Secretary 0f the Treasury, be declared.void from the. date of its issuance, 0r from
other date.
5. This does not excuse compliance with any law or regulation
by the Office of Foreign Assets Control or another (including reporting
requirements) applicable tO the transactions(&) herein licensed, nor does it release
Licensee(s) or thirdpartles from civil or criminal liability for violation of law or
regulation.
by direction and 6n behalf of the Secretary of the Treasury:
OFFICE OF ASSETS CONTROL
--....,..., ' ! , l! 3/r t
' \ . I
-'\.../, __ __. :' I
6

David W. Mills, Chief of Licensing
(Attention is directed to 19 U.S.C. 1592 and 159Sa, 18 U.S.C. 545, 18 U:S.C. 1001,
50 U.S.C. App. 16, and 31 CFR 515.701 et seq. for provisions to penalties.]
.. -2003-06"032 00039.9
;. '
.. - ... ' -:.
...
.......
..
No. CU-71417 Page 2 of 2
Licensee: 'Fish & Neave
,. SECTJON 1 - AuTHORIZAT.ION: (a) This licel"lse authori.zes and
others.acting under their supervision and control under the.auspices of
Fish &"Neave (i::he "Licensees'') to engage in.trayel-related.i::ransa'ctions
in as set forth in 31 CFR 515.560(c) and additional
transa:ctions as are directly incident to performing profe.ssional research
and part i cip'at'ing in professional meetings with Empresa Cubana.
De Alimentos y Productos_Varios (""Cubaexport'') in
connedtion with all matters rela-ted to Galleon S.A. Havana Club
s: .. A:; Trademark T-r-ialand Appeal No. 24,-ios.
i; (b) Thi's .. license aut}1orizis' multiple :trips during the validity period of.
the 1
CFR 515.560(c) anc:i. 51S.564(b).
It''
SECTIO:N - CONDITION: (a} It is a condition of this license that the
Licensees shall a full-time schedule of research.
artd professional cnsistent with 31 CFR 515.564(b).
(b) rt.is of this that keep a full and
accurate record .of each transaction undertaken pursuant to this License,
and each such record shall be available for examination for at least
five years after the date of such
SECTION 3 - WARNING: (a) This licehse does not authorize travel-related
transactions related to commercial or activities that are
inconsistent a full-time agenda research and
professional meE;ting .activities.
(b) This license does not authorize.the to the travel
services described in 31 CFR 515.572(a}.(l) to other organizatiqns.
Speci.fic travel servi'ce provider authorization is required for this.
purpose based on an application that must be filed and pr6cessed through
QFAC' s Mi'ami office.
SECTIO.N 4 -INFORMATION: The-Department of State publishes consular
information sheets (and,. when necessary, travel warnings) on every
country and territory in the world, including Cuba, which are a0ailable
on the Internet at b_ttp: //travel. or through the State '
version of consular information can be heard by calling (202) 647-
5225.
SECTION 5 - PRECEDENCE: This license is issued on a noh-precedential
basis.

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2003-06-032 000400
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DEPARTMENT'OF THE TREASURY
'.
LICENSE
0nder the of SO U.S:C. App. S(b), .22 U.S.t. 2370(i); 22 U.S.C. 6001 .et
Proclamation 34A7, and 31 CFR Parts 501 and
To: Fish & (the ''.Licensee'')
New Yo Y
l(b)(6)1
.1 P\.!rsuant to .-:. . following :is hereby
. . . . , ..... - ..... -.r: .. :1.
licensed'

2. This license is granted upon the statemerits. and representations made in your
application, or otherwise f,iled with or ma:de to the Treasury Depal:jtment as a supplement to
respects with all reg\.ilat ions, rulings, orders and instruct ions issued by t[le Secretary of
the Treasury.under the authority of Section 620(a), Public or under the
authori.ty of section 5 I b) of. the Act of October 6, 1917, as amended, and the terms of this
license.
3. The 1 icensee shall furnish and make availab.le for inspection any relevant
information, tecorddor. requested by the Secretary of the Treasury or any duly
4. This is not is subject to the provisions of Title 31, Parts
501 and 515 of the Code of Federal Regulations, and any re.gulations and rqlings issued
pursuant thereto and may be revoked or modified at any time at the discretion of the
Secretary of the Treasury acting directly or through the agency through which the license
was issued, or any other agency designated by the Secretary of the Treasury. If this
license was issued as a result of willful misrepresentation on the part of the applicant or
his duly authorized agent, it may, in the discretion of the Secretary of the Treasury, be
declared void from.the date of its or from any other date.
s. This license does not excuse compliance with law'or regulation administered
by Office of Assets Control or another (including reporting
requirements) applicable to the transactions(s) herein licensed, nor does it release
Licensee(s) or third parties from civil or criminal liability for violation of any law or
regulation.
by direction and on behalf of the Secretary of the TreasurY:
[Attention
50 u.s.c.
..
( By,--:-:: . I '
'\c..r-: R. Richard Newcoinb, Director
I I C)
'I
is directed to 19 U.S.C. l592 and 1595a, 18 U.S.C. 545, 18 U.S.C. 1001,
App. 16, and 31 CFR 515.701 et seq. for provisions relating to penalties.)
000401.
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License No. CU-71416.
Licensee:.Fish.& Neave
Page 2 of 2.
SECTION. 1 - AUTHORIZATIONS: All t'ransi:wt :ions. are au.thori :::cd to enable
Fish .& Neave (the in. connection with all mat.ters .
to Galleon S.A. v. Havana Club Hpldingl S.A., Trademark Trial and Appeal
Board Cancellation No. to pr6vide legal services to, receive
such services from and to receive reimbursement for expenses
related to such services from Empresa Cubana De Alimentos y
Produtos
1
Varios I a Cuban
,. .. 31 C}\R ..
._ . '. . ... . ,,__ "' . . :;: '. . . . . ' ' '. . ' .
. . .
.. 's:EctiON.2 .(a) It. if3 a condition of 'this License .that
shall keep a full and accurate record. of each transaction
pursuant to this License, and that each record shall be
. for examination for at least five years the date such
. transaptiQn ..
. t,\, .
. . SECTION\:3 REPORTING REQUIREMENT: Pursuant to 31 CFR 501.605 Licensee is
direct.ed to provide all required reports I notices 1 copies and facsimiles
SECTION 4 - WARNINGS: (a) Except as explicitly authorized in 1
nothing in this l icens.e. authorizes. subject to the
of.the United States to engage in any transaction or
activity prohibited by the Regulations.
SECTION 5 - WARNINGS: (b) Nothing in License authorizes any debit or
credit. from any blocked account.
SECTION 6 -PRECEDENCE: This License is issued on a nonprecedential
basis.
************.*******************************************************
..... . :' -.' : ... ::.-"7-.,
,., .. ,. 2003-06-032 000402
....
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FISH & NEAVE
DIRECT DIAL
DIRECT FAX
E-MAIL
May 7, 2004
Herbert F. Sctlwaltz
Et!cC. 1'/oglom
Rooert c. Morgan
Kennetl'l B. Herman
Robert R. Jacksoo
Jesse J. Jenne<
w. Ecmard Bailey
. Patricia A Martone
Ro::erick R.
James F. Haley, Jr.
Richard M. Barnes
Laurence S. Rcqers
frederick P. fish 1855193()
GoMes Neave 18611937
Vincent N. Palladioo
Robert J. Goldman
Tllrusl. Secres1
Daniel M. Gann
Noonan H. Beall'lar
Kevin J. Gunigan
Glenn A. Ousterhoot
Susan ProgoH
Mar9aretA Piern
llo<J91as J. Gilbert
Oenisa L. LOiing
Jeffrey H. lri<Jerman
Mar1<H.B-rg
Jane A. Massaro
Duane David Hrugn
f.larl< 0. Rowlanlf
Efic R. Hubba!d
William J. McCabe
John M. H1nZ
RicllardA.IM
Frances M.Lyncfl
CtuisOOPfler J.Hamett
A J<Ji
Steven Cttemy
Joseph M. Guiliano
Jeanne G. Curtis
Geralo J. flanmann. Jr.
Terrence J. P.l\earney'
Rooen IV. Monis
AvinaSll S. Lere
Jane r. Gunnisoo
Ric/lara l. Rainey"
James E. H<>oenleld"
Pablo 0. Hendlet
Bnan C. CannM
Robert B IWson
' .
---
Of Counsel
Albert E. Fey
Kenneth A. Genoni
Gene W.Lee
Martin A. Ler{7f
Dan:eiM. Beeker"
Senior Anomeys
A. PO!er Mer
fhomas J. Vetter
Cnanes Ouill(l
lisa E. Crista\
GaOfielle E. Higgins
ThOmas P. Bur<e
VIA FACSIMILE (CONF. BY FED EX)
..... .
I (b)(6) I
Re: Application for extension of License No. CT -1943 or new specific license
Dear- I (b)(6) I
_,
--
t, ..
I am writing to you as a follow-up to our conversations this week pertaining to Fish & Neave's
April 27, 2004 application requesting either an extension of License No. CT -1943 or a new
specific license. As I mentioned to you this week, Havana Club Holding, S.A. ("HCH") has
also requested that Fish & Neave represent it in connection with_ the same matters described in
our April 27th application. HCH, a Luxembourg company owned by Havana Rum & Liquors,
S.A (a Cuban company) and Pemod Ricard (a French company), is a party to the same
cancellation proceeding and district court action referred to in our April 2ih application.
understand from our conversations this week that License No. CT-1943 already covers Fish &
Neave's activities with respect to Cubaexport in the matters referenced in the April 27
1
h
application. We would like to confirm that License No. CT-1943 also covers Fish & Neave's
activities with respect to HCH in those same matters.
For your reference, on May 3, 2004, Fish & Neave submitted on behalf of Cubaexport and HCH
a "Stipulation And Order To Extend Time To Answer Or Otherwise Respond to Complaint" in
the above-referenced district court action. On May 4, 2004, Fish & Neave submitted on behalf
1251 AVENUE OF THE AMERICAS, NEW YORK, NY 10020 TEL 212.596.9000 FAX 212.596.9090
625 UNIVERSITY AVENUE, PALO ALTO, CA 94301 TEL 650.617.4000 FAX 650.617.4090
1899 PENNSYLVANIA AVENUE, NW, WASHINGTON, DC 20006 TEL 202.303.2400 FAX 202.303.2490
2003-06-032 000403
.. : :: "' ..... . . .. :-' -. .
F'tS.H &.. NEA"-/E.
Mr. Lee Miller
May 7, 2004
Page 2
. - ...... : . : . .j . .'". . : ........ -
ofCubaexport and HCH a "Petition For Extension OfTime Pursuant To 37 C.F.R.
2.145(e)(i)" in connection with the above-referenced cancellation proceeding. Copies of these
P,apers are enclosed.
Thank you very much for
hesitate to call me at
(b )(6)
If you have any questions, please do not
cc: David W. Mills, Licensing Division, OF AC
Office of Legal Counsel, OF AC
'"'"'""'-""' OF AC
2003-06.-032 000404
. ......... -: .-
Page 1 of I
:--
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1
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th(;! renewal ofCT" 1943, granted to foimer-
.totrayel to CJ,Jba, to contini1e representation of
. ......
suqject:
. rt(f..ct-4A-1,Q: . ' . . ' . . -
., ..... ' ...
O_>rtesponctence Public mail
Exec. Sec.#: (N?ne)
Enforcement#:
Other No:
(None)
(None)
Legislative Affair No: (None)
FOIA No: (None)
Document Date: 26.:JAN-05
Received at OFAC: 27-JAN-05
Date Ou't:
Date Closed: 04-MAR-05
I (b)(6) I
Remarks_
I (b)(6) I
Reporting requirement dated 12/14/05 sent to Lie by IIIII on 12/14/05.
http://ofacoraprod.do.treas.gov/pls/fac/OF ACRprts. HistoryRpt?p _ docid=23 8413
2003-06-032 000405
4/13/2006
FedEx I Ship Manager I Label 7903 8618 4338
From: Origin 10: (212)5%-9000
Ropes i Gray LLF
1251 AVENUE OF THE AMERICAS
NEW YORK, NY 10020
SHIP TO: (202)622-2480 BILL SENDER
Licensing Division
Office of Foreign A ~ s e t s Control
1500 Pennsylvania Avenue, NW, Annex
I
I ~
Shipping Label: Your shipment is complete
Ship Dale: 07APR05
AdWgt: 1 LB
System#: 1 085608/INET2400
Accounl#: S ... .....
REF: 001214-0001
Page l of 1
lllllllllllllllllllllllllllllllllllllllllllllllllllllllllllll!lllllll! II II !lllllllll! 111111111111
Delivery Address Bar Code
TRK# 7903 8618 4338
FORM
0201
MON
DeliVef By:
10APR06
lAD AA
20220 -DC-US
ZM JPNA
1. Use the 'Print' feature from your browserto send this page to your laser or inkjet printer.
2. 'Fold the printed page along the horizontal line.
3. Place label in shipping pouch and affix it to your shipment so that the barcode portion of the label can be read and scanned .
. Warning: Use only the printed originattabel for shipping. Using a photocopy of this label for shipping. purposes is fraudulent
and could result in additional billing charges, along with the cancellation of your FedEx account number.
Use of this system constitutes your agreement to the service conditions in the current Fed Ex Service Guide, available on fed ex .com. Fed Ex will not
be responsible for any claim in excess of $100 per package, whether the result of loss, damage, delay, non-delivery, misdelivery, or misinformation.
unless you declare a higher value, pay.an addlional charge, document your actual loss and file a tmely claim. limitations found in the current FedEx
Service Guide apply. Your right to recover from Fed Ex for any loss, including intrinsic value of the package, loss of sales. income interest. profit,
attorney's fees, costs. and other forms of damage whether direct, incidental, consequential, or special is limited to the greater of $100 or the
authorized declared value. Recovery cannot exceed actual documented loss. Maximum for items of extraordinary value is $500. e.g. jewelry,
precious metals. negotiable instruments and other items listed in our Service Guide. Written claims must be filed within strict time limits, see current
FedEx Service Guide.
https://www.fedex.com/cgi-bin/ship_it/unity/5GgYs2BdWs3CaUx6GbUq5AgZr8GgYs2Da... 4/7/2006
2003-06-032 000406
'.
'
To:
LICENSE
under tl_le authority qf 50 U.S.C. App. 5(b), 22 U.S.<::; .. 2370(a),
2:2-.u.s:c. 1 et seq., Proclamati_on 344 7, and 31' CFR Parts 50 r 5.15)
Ropes & Gray LLP (the "Licensee")
. th .
700 12 Street, NW, Suite 900
W DC 20005-3948
I (b)(6) I
I. Pursuant to an application dated January 26, 2005, the following transactions are hereby licensed:
2. This license is granted upon the statements and representations made in your application, or otherwise filed
with or made to the Treasury Department as a supplement to your application, and is subject to the conditions, among
others, that you comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of the
Treasury under the authority cited above and the tem1s of this license.
3. The Licensee shall furnish and make available for inspection any relevant information, records or. reports
4. This license expires on March 31, 2006, and is not transferable, is subject to the provisions of Title 31, Part
515 of the Code of Federal Regulations, and any regulations and rulings issued pursuant and may be revoked or
modi tied at any time at the discretion of the Secretary of the Treasury acting directly or through the agency through
which the license was issued, or any other agency designated by the Secretary of the Treasury. If thislicense was issued
as a result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion
of the Secretary of the Treasury, be declared void from the date of its issuance, or from any other date.
5. This license does not excuse compliance with any law or regulation administered by the Office of Foreign
Assets Control or another agency (including reporting requirements) applicable to the transactions(s) herein licensed,
nor does it release Licensee(s) or third parties from civil or criminal liability for violation of any law or regulation.
By ____________________________ ___
David W. Mills
Chief of Licensing
[Attention is directed to 19 U.S.C. 1592 and l595a, 18 U.S.C. 545, 18 U.S.C. 1001,
50 U.S.C. App. 16, and 31 CFR 515.701 et seq. for provisions relating to penalties.]
?::.t;MIVO/G ....... )/:((.. I (b)(
6
) I
-1/Dr
J/-{/ 2003-06-032 000407
Licensee: Ropes & Gray LLP
Page 2 of2
Authority: .31
SECTION 2 RDKEEPING REQUIREMENTS: The Licensee is required to keep a record of all
transactions ..., ..
1
=. .... in to the authorization (Section 1) of this license. Such records shall be made .
available for exa tion, upon demand, by the Office of Foreign Assets Control (or at least five years from the
date of each trans
to the jurisdiction
Control Regul
l<b)(5)1 (b)
funds through
United States.
SECTION 4-
circumstances s
GS: (a) Except as authorized above, nothing in this license authorizes person$ subject
f the United States to engage in any transaction or activity prohibited by the Cuban Assets
31 C.F.R. Part 515, as amended.
ing in this license authorizes the transfer of
its or credits to blocked accounts subject to the jurisdiction of the
RECEDENCE: The authorization contained in this license is limited to the facts and
fie to the application.
****************************************************************************
c;;...,./ h"c:;v-c.,c; Cl .... A,/r;'_j.J.J J: /J. 0 , /'r<><P(!c!yJ
;., U....l"<' Jfctti: ..-e I< fl<' f.. t<r. /1/f'v/JtV/i c_t. 0/J

?
2003-06-032 000408
LICENSE
License No.
(Granted under the authority of 50 U.S. C. App. S(b), 22 U.S.C. 2370(a),
22 U.S.C. 600 I et seq., Proclamation 3447, and 31 CFR Parts 50 l and 515)
To: Ropes & Gray LLP (the "Licensee")
New York, NY 10036
Attn: I (b)(6) I
l. Pursuant to your application dated December 3, 2007, the following transactions are hereby licensed:
Treasury under the authority cited above and the terms of this license.
3. The Licensee shall furnish and make available for inspection any relevant information, records or reports
4. This license expires on December 31, 2008, is not transferable, is subject to the provisions ofTitle 31, Parts
50 I and 515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may be
revoked or modified at any time at the discretion of the Secretary of the Treasury acting directly or through the agency
through which the license was issued, or any other agency designated by the Secretary of the Treasury. If this license was
tssued as a result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the
discretion of the Secretary of the Treasury, be declared void from the date of its issuance, or from any other date.
Assets Control or another agency (including reporting requirement) applicable to the transaction(s) herein licensed, nor
does it release the Licensee(s) or third parties from civil or criminal liability for violation of any law or regulation.
0
I (b)(6) I
B
[Attention is directed to 19 U.S.C. 1592 and 1595a, 18 U.S.C. 545, 18 U.S.C. 1001,
50 U.S.C. App. 16, and 31 CFR 515.701 et seq. for provisions relating to penalties.)
2003-06-032 000409
License No. CT-10948
Page 2 of2
SECfiON 1- AUTHORIZATION: (a) This license authorizes the r:epresentatives of Ropes & Gray LLP to
engage in travel-related transactions involving Cuba set forth in 31 CFR 515.560(c) of the Cuban Assets
Control Regulations (the "Regulations") and such additional transactions as are directly incident to professional
research and professional meetings, including but not limited to conducting interviews and depositions, and
creating written and other records, incident to the representation of Empresa Cubana Exportadora de Alimcntos
y Productos Varios (Cubaexport) in legal proceedings in the United States District Court for the District of
Columbia against the United States Department of the Treasury, Office of Foreign Assets Control, described in
the application, subject to the conditions set forth in Section 2 below.
(b) This license authorizes multiple trips during the validity period of the license.
SECTION 2- CONDITIONS: It is a condition of this license that the Licensee engage in a full-time schedule
ofprofessional research activities consistent with 31 CFR 515.564(b) and described in the license application.
SECTION 3 -WARNINGS: Except as explicitly authorized in Section 1 above, nothing in this license
authorizes any person subject to the jurisdiction of the United States to engage in any transaction or
activity prohibited by the Regulations. This license only authorizes travel-related transactions consistent
with a full-time schedule of activities authorized by this license.
SECTION 4- RECORDKEEPING REQUIREMENTS: The Licensee shall keep a record of the
transactions under this license. Such records shall be made available for examination upon demand for at least
five years from the date of each transaction. The Office of Foreign Assets Control may require the submission
of a report from the Licensee or any individual traveler concerning the activities undertaken pursuant to the
license. A report from the Licensee is required on activities undertaken pursuant to this license in conjunction
with an application to renew or extend this license.
SECfiON 5- INFORMATION: (a) For information concerning the categories of travel for which licenses
may be issued, please refer to our Comprehensive Guidelines for License Applications to Engage in Travel-
Related Transactions Involving Cuba on our Internet website at www.treas.gov/ofac (Sanctions Programs &
Country Summaries- Cuba, Guidelines and Information).
(b) The Department of State publishes consular information sheets (and, when necessary, travel warnings) on
every country and territory in the world, including Cuba, which are available on the Internet at
http://travel.state.gov, or through the State Department's fax-on-demand service at (202) 647-3000. An
abridged version of consular information sheets can be heard by calling (202) 647-5225.
SECTION 6- PRECEDENTIAL EFFECT: The authorization contained in this license is limited to the facts
and circumstances specific to the application.
******************************************************************************************
2003-06-032 00041 0
Cuban Assets Control Regulations License No. CT -10948
LICENSE
(Granted under the authority of 50 U.S.C. App. 5(b), 22 U.S.C. 2370(a),
22 U.S.C. 6001 et seq., Proclamation 3447, and 31 CFR Parts 501 and 515)
1211 Avenue ofthe Americas
New York, NY 10036
Attn: (b)(6)
I. Pursuant to your application dated December 3, 2007, the following transactions are hereby licensed:
4. This license expires on December 31,2008, is not transferable, is subject to the provisions of Title 31, Parts
501 and 515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may be
revoked or modi fled at any time at the discretion of the Secretary of the Treasury acting directly or through the agency
issued as a result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the
50 U.S.C. App. 16, and 31 CFR 515.70 I et seq. for provisions relating to penalties.]
Date

Licen.se No. CT-10948
Page 2 of2
SECTION 1- AUTHORIZATION: (a) This license authorizes the representatives of Ropes & Gray LLP to
engage in travel-related transactions involving Cuba set forth in 31 CFR 515.560(c) ofthe Cuban Assets
Control Regulations (the "Regulations") and such additional transactions as are directly incident to professional
research and professional meetings, including but not limited to conducting interviews and depositions, and
creating written and other records, incident to the representation of Empresa Cub ana Exportadora de Alimentos
y Productos Varios (Cubaexport) in legal proceedings in the United States District Court for the District of
Columbia against the United States Department of the Treasury, Office of Foreign Assets Control, described in
the application, subject to the conditions set forth in Section 2 below.
SECTION 2- CONDITIONS: It is a condition of this license that the Licensee engage in a full-time schedule
of professional research activities consistent with 31 CFR 515.564(b) and described in the license application.
SECTION 3 -WARNINGS: Except as explicitly authorized in Section 1 above, nothing in this license
SECTION 4- RECORDKEEPING REQUIREMENTS: The Licensee shall keep a record of the
transactions under this license. Such records shall be made available for examination upon demand for at least
five years from the date of each transaction. The Office of Foreign Assets Control may require the submission
of a report from the Licensee or any individual traveler concerning the activities undertaken pursuant to the
license. A report from the Licensee is required on activities undertaken pursuant to this license in conjunction
with an application to renew or extend this license.
SECTION 5- INFORMATION: (a) For information concerning the categories of travel for which licenses
******************************************************************************************
2003-06-032 000412
ROPES & GKAY LLP
\;'11 .WENUl UF ;Hl AMERICAS NEWYCiRK. "lY 10036 59(,.90Xl '21; 'X"J90
ROSTON NEW YORK I'Al0 ALTO SAN FRANCISCO rr..JKYO WAStjiN(,TiJN. D<". .vww
DIRECT DIAL
DIRECT FM
EMAIL
(b)(6)
December 3, 2007
VIA FACSIMILE- CONFIRMATION BY FEDEX
I (b)(6) I
Licensing Section
U.S. Department ofTreasury
1500 Pennsylvania Avenue, N.W.- Annex
Attn: Licensing Division
Renewal Application For Specific License No. CT -8962 in Connection with the
Representation of Cubaexport
Dear Ms.- 1 (b)(6) 1
- ' -
;__,- : ..
The law finn of Ropes & Gray is currently the licensee under License No. CT-8962
authorizing "representatives of Ropes & Gray L LP to engage in travel-related transactions
involving Cuba set forth in 31 CFR 515.560(c) of the Cuban Asset Control Regulations (the
''Regulations") and such additional transactions as are directly incident to professional research and
professional meetings, including but not limited to conducting interviews and depositions, and
creating written and other records" in connection with the representation of Emprcsa Cubana
Exportadora De Alimentos y Productos Varios. S.A., dba Cubaexport (''Cubaexport") in Civil
Action No. 06-1692, pending in the U.S. District Court for the District of Columbia (the "Action").
License No. CT-8962 is set to expire on December 31, 2007. For your convenience, a copy of the
license is enclosed.
The Complaint tiled on behalf of Cubaexport is still currently pending against the
United States Department of Treasury, Office ofForeign Asset Control ("OFAC"), Henry M.
Paulsen, Jr., as Secretary of Treasury, Adam J. Szubin, as Director of OF AC, and the United States
(collectively, the "Defendants"). On December 21, 2006, the Defendants in the Action filed a
2003-06-032 000413
ROPES & GRAY LLP
December 3, 2007
Page 2
motion to dismiss Cubaexport's Complaint. Pursuant to License No. CT-8962, Ropes & Gray
attorneys traveled to Cuba on two separate occasions, in February and March 2007, to gather
infonnation from and participate in meetings with Cubaexport in order to oppose Defendant's
motion to dismiss. On September 27, 2007, the Court partially denied Defendants' motion to
dismiss, retained jurisdiction, and remanded the Action to t.Re Department of Treasury for the
limited purpose of supplementing the administrative record. In accordance with the Court's Order,
the Department ofTreasury filed a supplement to the administrative record on November 27, 2007.
As a result, the Action has automatically reopened and the Court will set a briefing schedule for
dispositive motions.
The renewal of this license is, therefore, necessary because Ropes & Gray
representatives will have a continuing need to engage in the aforementioned transactions in
connection with its representation of Cubaexport in this Action. Because the Court has
automatically reopened this Action and will set a briefing schedule for dispositive motions, we
expect to have to travel to Cuba as we did in connection with opposing Defendants' earlier
dispositive motions. Thus, Ropes & Gray hereby requests a renewal or extension of License No.
CT-8962 or, in the alternative, a new license authorizing it to continue to engage in the
aforementioned licensed transactions.
- l(b)(6)1
cc: Matthew Tuchband, Esq., Office of Legal Counsel, OF AC
Liz Farrow, OFAC
(each via facsimile and FedEx)
2003-06-032 000414
I (b)(6) I
104815
I!&
OEPAR'TMENT OF THE TREASURY
WA.SHINGiON, O.C. 20220
Control Regulations
License No.
To:
LICENSE
(Granted under the authority of SO U.S. C. App. S(b), 22 U.S.C. 2370(a),
22 V.S.C. 6001 eueq., Proolamation 3447, and 31 CFRPa.rtS 501 and SIS)
Ropes & Gray LLP (the "Licensee")
1251 Avenue of the American
New
Attn: I (b)(6) I I
-8962
P.01
I. to yow application dated September 29, 2006, the following transactions are licensed:
I
SEE REVERSI:*"***
. I
2. This license is granted upon the statements and representations made in your otherwise filed
with or made to the Treasury Department as a supplement to your application, and is subjoct to the co ditions, among
others, that you comply in all respect& with aJL replationB, rulings. orders and instructions issued by e Secretary of
the Treasury under the authority of citod above and the termS of this license. 1
I
3. Tht: licensee shall furnish and mab available for inspection any relevant information. or reports.
requested by the Secretary of the Treasuzy or any duly authorized officer or agency of the Secretary. !
i
4. This license on Deeember 31, :!007, is not transferable, is subject to the provision" ofTitle 31,
Pans SO I and 51 S of the Code of Federal Regulations and any regulations and rulings issued pursuan then:to, and may
be revoked or modifled at any time at the discretion of tho Secretary of the Tmssury acting ditcetly otthrougb tbe
agency through which the license was issued, or any other agency designated by the Secretary of the reasury. If thls
license was issued as a result ofwillf\.tl misrepresentation on the part of the applicant or his duly auth rized agent, it
may, in discretion of the Sect"etary of the Treasury, be declared void from the date of its issuance, r from any other
date. '
S. This license docs not excuse compliance with any law or regulation administered by the of Foreian
Assets Control or another agency {including reporting requirements) applicable to the transactions( a) erein licensed,
nor does it Tel ease Licenaee(s) or third parties from civil or orimlnal liability for violation of any law , r regulation.
OFFICE OF FOREIGN ASSETS CONTR
r-1 (,.,..,.b)..,...,..( 6.,.....,) I
I
[Auention is directed to 19 U .. S.C. 1592 and 18 U.S.C. 54S, 18l.f.S.C. IOOli
50 U.S.C. App. 16, and 31 CPR 515.701 et seq. or provisions relatina to penalties.J
Received 09:02pm
Frar-!04815 To-ROPES & GRAY LLP
Pac 001
----------------
2003-06-032 000415
I
I
I
License No. CT-8962 Pagel of l
Licensee: Ropa & Gray LLP J
SECTION 1- AUTBORIZA TION: (a) This license authorizes the representatives Gray LLP
to engage in travel-related transactions involving Cuba set forth in 31 CPR S 1 S.S60(e) of the uban Assets
Control Regulations (the "Regulations") and such additional transactions as are directly incid nt to
professional research. and professional meetings, including but not limited to conducting interyiews and
depositions, and creating written and other records, incident to the representation ofEmpresa }:ubana
Exportadora de Alimentos y Produetos Varios ("Cubacxport'') in legal proCeedings in the ed States
District Court for the District of Columbia against the United States Department of the Treas , Office of
Foreign Assets Control, described in the application, subject to the conditions set forth in Se . on 2 below.
I
Authori.ty: 31 CFR !1!.!60(c) ancl 515.!64(b).
I
I
!
SECTION 2- CONDITION: It is a condition of this license that the Licensee engage in a r4n-time
schedule of professional research activities consistent with 31 CFR 515.564{b) and described fn the license
application. !
SECTION 3 WARNINGS: Except as explicitly authorized in Section 1 above, nothlne$ this license
authorizes any person subjeet to the jurlsdlctlon of tbe United States to enaaae ln any tr nsactlon or
activity problblted by the Regulations. Thls license only authorizes travel-related trans Ions
consistent with a fuU-tlme schedule of activities authorized by this Ueenae. !
' .
SECTION 4- RECORDKEEPING REQUIREMENT: Tbe Licensee shall keep a =the
transactions under this license. Such reoords shall be made available tor examination upon de for at
least five years from the date of each ttansaction. The Office of Foreign Assets Control may uire the
submission of a report from the or any individual traveler concerning the activities
pursuant to the. license. A report from the Licensee is rcquirod on activities undertaken purswrt to this
license in conjunction with an application to renew or extend this license. i
SECTION 5 -INFORMATION: (a) For information concerning the categories oftravel which
licenses may be Issued, please refer to our ComprehensiVf Guidelines for Licsn.se A.pplicaticnJ_to in
Trava/.RelaUJd Transactions Involving Cuba on our Internet website at www.treas.aoy/ofac (inct1ons
Programs & Country Summaries- Cuba, Guideline8 and Information). 1
I
(b) The Department of State publishes consular information sheets (and, when necessary, wamings) on
every country and territory in the world, including Cub8t which are available on the Internet a
httu://ttavcl.state.goy, or through the State Department's faX-on-demand service at (202) 647- 000. An
abridged version of consular information sheets can be. heard by calling (202) 647-522.5. .,
i
SECTION 6- PRECEDENTIAL The authorization contained in this license is t+ruted to the
facts and circumstances specific to the application. 1

TOTAL P.02
Received DecZS-08 Fro.-104815 To-ROPES l GRAY LLP Paa 002
2003-06-032 000416
FACSIMILE TRANSMITTAL COVER SHEET
DATE:
TOTAL NUMBER
OF PAGES:
TO:
FROM:
COMMENTS:
RECIPIENT'S
FAX NUMBER:
January 22, 2007
3
Ropes & Gray LLP
Ph: 212 596-9000
..... " ~ ~ ~ ~ ~ . n g n
Fax: (202) 622-0447
FAC No. 318201
In response to your letter dated January 5, 2007, I am forwarding a
copy of License No. CU-76234, which hopefully has been received
through the mail now. This license authorizes the collection of
legal fees from Cuba in connection with your firm's representation
of Cubaexport. License No. CT -8962 mentioned in your letter,
authorizes travel-related transactions involving Cuba in connection
with the same representation. We have done separate licenses
inasmuch as one is needed for banking purposes and the other for
travel service providers and Customs.
Please feel free to phone me at
further questions.
Thank you.
(212) 596-9090
-- .20().3_".06-032 000417
for you have any
MJLE: " !'EMORY TRANSMISSION
15:39
END-JAN-22 15!40
FILE N0.702
STN NJ. CCt1M. f'iSfR
STAT! ON
PAGES DURATION
003/003 oe:oe:46
001 a
86467282621
-US T"EASlRY
**********"'************************* -CFAC
- ***** -
104815- *********
WAiiiHINGTON, C.C. 2022.0
FACSil\ULE TRANSMITTAL COVER SHEET
DATE: January 22.2007
TOTAL NU;\-lDER
OF PAGES: 3
TO:
FROM:
C0:\1MENTS:
RECJPIE="T' S
I'AX NL;\tBER:
l(b)(6)1
Ph: 5969000
Office or Forelcn As&ets Control
Fax: (202)622-0447
FACNo. 3182QI
I (b)(6) I
In response to your letter dated January 5, 2007, I am forwarding a
copy of License No. Cl..l-76234, which hopefully has been reived
through the mail now. This license authorizes the collection of
legal fees from Cuba in connection with your firm's representation
ofCubaexport. License 1\o. CT-8962 mentioned in your letter,
authorizes travel-related transactions involving Cuba in
with tl1e same representation. We have done separate
inasmuch as one is needed for banking purposes and the for
travel service pro\;ders and Customs.
Please feel free to phone me at (202) 622-2480, for you havd any
further questions.
Thank you.
(212) 596-9090
000418
LICENSE
1251 A venue of the Amercas
New York, NY 10020
Attn: I (b)(6) I
1. Pursuant to your application dated September 29, 2006 (the "Application"), the following transactions are
hereby licensed:
* * * * * SEE REVERSE * * * * *
Treasury under the authority of cited above and the tenns of this license.
3. The licensee shall furnish and make available for inspection any relevant information, records or reports
4. This license expires on December 31, 2007, is not transferable, is subject to the provisions of Title 31, Parts
501 and 515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may be
revoked or modified at any time at the discretion of the Secretary of the Treasury acting directly or through the agency
issued as a result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the
Assets Control or another agency (including reporting requirements) applicable to the transactions(s) herein licensed, nor
does it release Licensee(s) or third parties from civil or criminal liability for violation of any law or regulation.
By c.
Eli eth W. Farrow
Assistant Director for Licensing
[Attention is directed to 19 U.S. C. 1592 and 1595a, 18 U.S. C. 545, 18 U .S.C. I 001,
2003-06-032 000419 -----------------
Licensees: Ropes & Gray LLP
Page 2 of 2
SECTION 1- AUTHORIZATION: All transactions are authorized to enable the Licensee, in connection
with the legal representation ofEmpresa Cubana Exportadora de Alimentos y Productos Varios ("Cubaexport")
in legal proceedings in the United States District Court for the District of Columbia against the United States
Department of the Treasury, Office of Foreign Assets Control ("OFAC"), described in the Application, to
receive payment of professional fees for such services and reimbursement of incurred expenses related to such
services from Cuban nationals through banking channels, provided the funds are routed from Cuba to the
United States via a third-country bank.
SECTION 2- CONDITION: It is a condition of this license that payments of fees or retainers pursuant to
paragraph (a) above are made exclusively from fresh funds originating from a source not currently within the
United States or within the possession or control of a United States person, including its overseas branches, and
that such payments are not made fonn a blocked account or from other blocked property.
SECTION 3- RECORDKEEPING REQUIREMENT: The Licensee shall keep a record of the transactions
under this license. Such records shall be made available for examination upon demand for at least five years
from the date of each transaction.
SECTION 4- WARNINGS: (a) Except as explicitly authorized in Section I above, nothing in this license
authorizes any person subject to the jurisdiction of the United States to engage in any transaction or activity
prohibited by the Cuban Assets Control Regulations, 31 CFR 515.
(b) Nothing in this license authorizes the transfer of funds through methods which involve debits or credits to
blocked accounts subject to the jurisdiction of the United States.
***************************************************************************************
2003-06-032 000420
,.
ROPES & r,RAY LLP
1/)1 AVENUE OF THE AMERICAS NEW YORK. NY 10020-1104 212 596-9000 F 212 596 9090
BOSTON NEW YORK PALO ALf() SAN FRANCISCO WASHING TON. DC www ropesgray com
DIRECT DIAL
DIRECT FAX
E-MAil
January 5, 2007
I (b)(6) I
Chief, TWEA Licensing Section
Specific License No. CT -8962 in Connection with the Representation of Cubaexport
Dear- I (b)(6) I
We recently received License No. CT-8962 in response to Ropes & Gray LLP's September
29, 2006 application for a specific license in connection with our representation of Empresa Cubana
Exportadora De Alimentos y Productos Varios. S.A., dba Cubaexport ("Cubaexport") in Civil
Action No. 06-1692, pending in the U.S. District Court for the District of Columbia (the "Action").
By this letter, we seek to clarify that License No. CT 8962 includes a specific license allowing
Ropes & Gray LLP to receive payment of our fees and expenses in connection with our
representation of Cubaexport in the Action.
Prior licenses authorized Ropes & Gray LLP and/or it predecessor Fish & Neave to
represent Cubaexport, travel to Cuba and be paid for its representation. (See, e.g., License No. CT
1943(copy attached). We understand that 35 C.F.R. 515.512(a)(3) authorizes Ropes & Gray LLP
to represent Cubaexport in the Action. Ropes & Gray LLP's September 29, 2006 application
expressly requested a specific license to (a) travel to Cuba and (b) solicit and receive payment for
its representation ofCubaexport in the Action (copy attached). License No. CT-8962 authorizes
travel to Cuba, but does not expressly authorize Ropes & Gray LLP to solicit and receive fee
2003-06-032 000421
ROPES & GRAY LLP
January 5, 2007
Page 2
payments and reimbursements for expenses incurred in connection with its representation of
Cubaexport in the Action.
Therefore, Ropes & Gray LLP requests clarification that License No. CT-8962 authorizes
Ropes & Gray LLP to:
11
SOlicit and receive fee payments and reimbursements for expenses incurred in
connection with the legal representation of Cubaexport relating to the above-
discussed action against OF AC, et. al., provided that said fees and expenses are paid
exclusively from fresh funds outside of the United States."
Thank you for your prompt attention to this matter.
Sincerely yours,
- l(b)(6)1
cc: Matthew Tuchband, Esq., Office ofLegal Counsel, OFAC
Liz Farrow, OFAC
2003-06-032 000422
ROPE5 & (,RAy LLP
1211 AVENUL OF THE AMERICAS NCW YORK. NY 10031>-B?O\ 596-9000 r /1;> 591> 9mO
ao; f()N NF.W YORK PALO All 0 sr,N f'RANCISCO I OKYO WAS I llNGTON. DC
DIRECT OW.
DIRECT FAX
EMAll
December 3, 2007
I (b)(6) I
A Licensing Section
Renewal Application For Specific License No. CU-76234 in Connection with the
Representation of Cubaexport
Dear- I (b)(6) I
The law finn of Ropes & Gray is currently the licensee under License No. CU-
76234 pursuant to 31 C.F.R. 515.512, which is set to expire on December 31,2007. License No.
CU-76234 authorizes Ropes & Gray "to receive payment of professional fees" and "reimbursement
of incurred expenses" in connection "with the legal representation of Empresa Cubana Exportadora
De Alimentos y Productos Varios S.A., dba Cubaexport ("Cubaexport") in legal proceedings in the
United States District Court for the District of Columbia against the United States Department of
Treasury, Office of Foreign Assets Control ("OFAC")." For your convenience, a copy of the
license is enclosed.
The aforementioned legal proceeding (Civil Action No. 06-1692) was initiated by
Cubacxport on September 29, 2006 and arises out of certain actions by OFAC, which caused the
U.S. Patent and Trademark Office to refuse to renew a U.S. Trademark Registration owned by
Cubaexport for the HAVANA CLUB & Design. This litigation is still pending in the U.S. District
Court for the District of Columbia (the "Action") and the parties are currently awaiting the Court to
set a briefing schedule for dispositive motions.
2003-06-032 000423
ROPES& GRAY LLP
December 3, 2007
Pagc2
Because Ropes & Gray is continuing to represent Cubaexport in connection with the
Action, Ropes & Gray hereby requests a renewal or extension of License No. CU-76234, or in the
alternative, a new special license serving the purposes mentioned above.
- I (b)(6) I
cc: Matthew Tuchband, Esq., Office of Legal Counsel, OFAC
Liz Farrow, OFAC
{each via facsimile and FcdEx)
2003-06-032 000424
I (b)(6) I
1'-(lv-30--2007 15: 00 US TREASURY

WI-5HINGTON, D.C. 20220
<:uban Assets Control Regula dons
To:
LICENSE
(Granted under the authority of SO U.S.C. App. S(b), 22 U.S.C. 2370{a),
22 U.S.C. 6001 et seq., Proclamation 3447, at1d 31 CPR Parts 501 and 515)
Ropes & Gray LLP (the "'Licensee")
12 51 A venue of the Amercas
New Yo
Attn: I (b)(6) I
1e4004 P.02
I. Pursuant to your application dated SepteJ;nber 29, 2006 (the "Application"), the following transactiom are
hereby licmsed:
* * * * SEE REVERSE * * *
.. )
I ,,'\
I ' ' ' .,' ' r
., .... .;
..
1 ;>I
.:., .. ' ..
. . .....
!
, ; 'I
2. This is granted upon the statements and ,made idn yourbnpplicatbtion, or filed. .: ... .; ...,:...
with or made to lu.o Treasury Department as a supplemont to yo\/.f applicatlon, an is su to e conditions, among' ' .. .
others, that you comply in all respects with lilt reiUiations, rulings, orders and instructions iS$\/.ed by the Secretary oftbo:
Treasury under the authority of cited above and the tel'l'Jl$ of this license.
3. The licensee shall furnish and rnalce available for inspection any relevant information, records or reports
requested by the Secremry of the Treasury or any duly authorized officer or agency of the Secrcwy.
. r
. .
:,,
4. This license expires on December 31, l007, j, not transferable, is subject to the provisions ofTitJe 31, Part$ .. :,. ';
50 I and 515 of the Code of Federal Regulations and any regulations and rulings iss\lcd puxsuant thereto, and may be . : . .
revoked or modified at any time at the discretion of the Secretary of the Treaswy acting directly or'through tbe agouoy. . ..
through which the license was issued, or any other agency de&ignated by the Secretary ofthe Treasury. If this license wia, ... :.
issued as a. tesult of willful misrepresentation on the part of the applicant or his duly authorizod asent, it may, in the .
discretion of the Secretary of the TreaslJ.f)', be declared void from the date of'its issuance, or from any other date.
. ... '
5. This Jicen$C does not excuse compli&llcc with any law or regulation administered by the Office ofFo1-eign : ;, .: } .. :.::;
A.s.!cts Control or anothtr agency (including reporting requirements) applicable to the transac:tions(s) herein llcensed, ..
does it release Licensee(s) or third parties from civil or criminal liability for violation of any law or regulation. . > ...
> : ;:;t
Issued by directio11 and on behalf of the SOt'etary of the Treasury:

Eli ethW:Fa.rrow
Assistant Director for Lie<:nsing
[Attention is directocl to 19 U.S.C. 1592 and 1595a, 18 V.S.C. 545, 18 U.S.C. 1001,
50 U.S.C. App. 16, and 31 CFR .515.701 et seq. fur provisions relating to penalties.J
2003-06-032 000425
. ;., .
t .
. ',. :'
' . ...
" ,._;' . :
I
US TREASURY
P.03
Licensees: Ropes'& Gray LLP
; :i:: <1 ..
Page 2 ::( Y

. . . ...' ']
SECTION 1 - AUTHORIZATION: All transactions are authorized to enablo the Licensee, 1n connection . ! :: . .:.
with the legal representation ofEmpresa Cubana Exportadora de Alimentos y Productos Varios :'::,,''_,.:
in legal proceedings in the United States District Court for the District of Columbia against the United States : ':.>.::;.;
Department of the Treasury, Office of Foreign Assets Control ("OFAC"), descnbed in the Application, to . -::" :.
receive payment of professional fees for such services and reimbursement of incurred expenses related to such .. . -t., ':
services from Cuban nationals through banking channels, provided the funds are routed from Cuba to the i,.
United States via a third-country bank. ., '
,.
''' ,, 'I
.-..
SECTION 1- CONDITION: It is a condition of this license that payments of fees or retainers pursuant to. . : .... . (
,; :
paragr11ph (a) above are made exclusively from freab funds originating from a source not currently within the :' ..
United States or within the possession or control of a United States person, including its overseas branches, . .: :
that such payments are not made form a blocked account or from other blocked property.
.,
SECTION 3- RECORDKEEPING REQUiREMENT: The Licensee shall keep a record of the transactions ; . : .. :, . ., ;
under this license. Such record$ shall be made available foe examination upon demand for at least five years . :. ' ... : ,
from tbe date of eacb transaction, .' ; .: : .. ,:-;
SECTION 4 W ARNJNGS: (a) Except as explicitly authorized in Section l above, nothing in this license
authorizes any person subject to the jurisdiction of tno United States to engage in any transaction or acti-vity
prohibited by the Cuban Assets Control Regulations, 31 CFR S 15.
'. : , \
I ..... ' ...
., I
, :I
' '. J
',I o I :\I' :, "\
(b) Nothini in this license authorizes the transfer of funds through methods wh1ch involve debits or f. : .. y/:lf::
\>locked accounts subject to the jurisdiction of the United States. . .' .
SECTIONS- PRECEDENTIAL EFFECT: The authorization contained in this license is limited to the . . : , .
and circumstances specific to the appUcation. : .: :
. .
,. '
'. :.j_.r:;. ...
.
..
TllTAI P.
2003-06-032 000426
All redactions on this page are made pursuant to FOIA Exemption (b)(6) unless
otherwise indicated
-------------------
From:
Sent:
To:
Cc: , Matthew
Subject: to legal action against OFAC, etc.

Cc: Tuchband, Matthew
Su related to legal action against OFAC, etc.
From:
Sent:
To:
Cc:
Subject:
-I have a renewal request from Ropes & Gray, the firm representing Cubaexport in their legal proceedings against OFAC
and Treasury. Their report indicates the firm's attorneys took two trips under the previous license to gather information
and participate in meetings with Cubaexport in order to oppose Treasury's motion to dismiss Cubaexport's complaint
against us.
You signed the last license. I may have not been here. They state that they will have a continuing need to engage in the
aforementioned transactions in connection with its representation of Cubaexport in this Action. They state that the Court
has reopened this Action and will set a briefing schedule for dispositive motions and expect to have to travel to Cuba.
(b)(5)

2003-06-032 000427
All redactions on this page are made pursuant to FOIA Exemption (b)(6) unless otherwise indicated
Case No. CT-9554
New York, NY 10036-8704
RE: Letter dated March 9, 2007
Dear
This is in response to your letter on behalf of Ropes & Gray LLP, requesting authorization to
engage in travel-related transactions involving Cuba.
The Cuban Assets Control Regulations, 31 C.F.R. Part 515 (the "Regulations"), administered by
the U.S. Department of the Treasury's Office of Foreign Assets Control, prohibit all persons
subject to the jurisdiction of the United States from dealing in property in which Cuba or a
Cuban national has an interest. This prohibition includes all Cuba travel-related transactions
unless such transactions are authorized in accordance with current licensing policy set forth in
515.560(a) and the related sections of the Regulations enumerated in 515.560(a).
We have reviewed your request and determined that you have not addressed a portion of the
relevant criteria listed in our Comprehensive Guidelines for License Applications to Engage in
Travel-Related Transactions Involving Cuba (the "Application Guidelines"), which are available
on our Internet website at www.treas.gov/ofac. Accordingly, your application is hereby denied.
Should you wish to reapply for a license, please review and address the Application Guidelines
for the relevant category of travel in order that we may more favorably consider your request.
Enclosure
Sincerely,
Travel
2003-06-032 000426
I All redactions on this page are made pursuant to FOIA Exemption (b)(6) unless otherwise indicated
~ ~ - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - ~
~ . m ~ . :
~ ~ ~
',' 1789 ./
Case No. CT-9554
. . .

p y
New York, NY 10036-8704
RE: Letter dated March 9, 2007
This is in response to your letter on behalf of Ropes & Gray LLP, requesting authorization to
engage in travel-related transactions involving Cuba.
The Cuban Assets Control Regulations, 31 C.F:R. Part 515 (the "Regulations"), administered by
the U.S. Department of the Treasury's Office of Foreign Assets Control, prohibit all persons
subject to the jurisdiction of the United States from dealing in property in which Cuba or a
Cuban national has an interest. This prohibition includes all Cuba travel-related transactions
unless such transactions are authorized in accordance with current licensing policy set forth in
515.560(a) and the related sections ofthe Regulations enumerated in 515.560(a).
We have reviewed your request and determined that you have not addressed a portion of the
relevant criteria listed in our Comprehensive Guidelines for License Applications to Engage in
Travel-Related Transactions Involving Cuba (the "Application Guidelines"), which are available
on our Internet website at www.treas.gov/ofac. Accordingly, your application is hereby denied.
Should you wish to reapply for a license, please review and address the Application Guidelines
for the relevant category of travel in order that we may more favorably consider your request.
Program Manager, Cuba
Enclosure
2067Mar:22 04:58 PM Ropes & Gray 2125969090

e, :OPAY .LP
. 1 A.
1
1<NUE OF 7hE Ar' EP CAS '! EW YC: i<i(. Y C4 : 21
FAX TRAI\'SMITTAL LF.TTER
PLEASE DELIVER THIS DOCU\1El"T IMMEDIATELY I
:F YOG DO NOT RECE:VE ALL PAGES, PLEASE CALL: 212-596-9070
TOTAL OF PAGES rNCLCD['JG THIS TR.A:..:SlvJ;TTAL LETTER: 3
To: Ms. Elizabeth Fa.now
(OFAC)
Firm/Company
Office of Foreign Assets
Control,
u.S. Department of the

Fax Phone
(202) 622-0447
(b)(6)
Matthew Tuchband, Esq.
(Office of Legal Counsel)
-,T\VEA
Licensing Section
From:
Comn:ents:
PLEASE COMPLETE WHEN TO FAX DEPARTJI.IEST
Date: March 22, 2007
File Symbol: 001214.0001 Personal ID 1\umber:
Submitted By:
I (b)(6) I
Phone: 2! 2-596-9070
THIS FAX HAY CONTAIN INFORJ1AT!ON THAT IS PRIVILEGED, COrlFIDENTIAL AND EXEMPT FR.OI-1 DISCLOSURE.
IT :s :NTENDED FOR USE ONLY B'l' THOSE TO LT !S ADDRESSED. IF THIS FAX !5 NOT ADDR::SSED TO
YOU, OR IF vou RECEIVED IT IN E=<.ROR, YOU t1AY NOT DISCLOSE, DISTR!BL TE, COPY OR USE THIS FAX OR AI IY
INFORMATION IN IT. INSTEAD, PLEASE C/1LL US COLLECT AT 212.5969070 TO ARR.ANGE FOR ITS DESTRUCTION
OR
2003-06-032 000430
1/J
20ri7-Har:22 04:58 PH Ropes & Gray 2125969090
FISH & NEAVE IP GROUP
S.
12': He p.r,\;:11CAS 'lEv' YCRK, rl'f 10J36-8704 F
r<el"< YORK PA'.::J A.".TO SAN FRM:CISCO D: wwhrcpe,gay :-:>'1".
March 22, 2007
BY F ACSI"IILE BY MAIL)
Yfs. Elizabeth Farrow
Associate Director for Licensing
1..J .S. Dep<niment of the Treasury
1500 Pennsylvania Avenue.l\W
Dear Ms. Farrow:
The law :inn of Ropes & Gray currently the licensee under License No. CT-
7571 authorizing "representatives of Ropes & Gray to engage in travel-related transactions
involving Cuba set forth in 31 CPR 515.560( c) of the Cuban Asset Control Regulations (the
"Regulations") and such additior.altransactions as ar:! directly to profess:onal research
and professional meetings relevant tu be legal proceedings in the United States related to the
Trademark Trade and Appeals Board cancellation proceeding munber 24,108 (including appeals
of that proceeding), including but not limited to conducting interviews and depositions, and
creating written and other records.'' License CT-7571 is set to expire on April30, 2007. For
your convenience, a copy of the license is enclosed.
Ropes & Gray representatives have a contimling need to engage in the
aforementioned transactions in connection with its representation oi Cubaexport in legal
proceedings related to the afcrementioncd cancellation proceeding. T:m5, Ropes & Gray hereby
requests a renewal or extension of License No. CT 7571 or, in the altemative, a new license
au1.hor:zing il to continue to e11gage in :he aforementioned licensed trar.sactions.
In as muc:t as t:Us m::mer concerns legal proceedings, we are taking the liberty of
forv,;arding a copy of this application to the Office uf Legal Counsel, Of A C.
2003-06-032 000431
04:58 PM Ropes & Gray 212-5969090
RO:JES & GRAY LLP
Ms. Elizabeth Farrow
March 22, 2007
Page 2
Sincerely,
- l(b)(6)1
Enclosure
cc: Matthew Tuchband, Office of Legal Counsel, OFAC
TWEA Licensing Section
Y tax) I (b)(6) I
2003-06-032 000432
j/j
LICENSE
License No. CT -2664
New Y NY 10020
Attn:
I. Pursuant to your application dated April 27, 2004, and the supplemental letter dated May 7, 2004, the
following is hereby licensed:
4. This license expires on May 31, 2005, is not transferable, is subject to the provisions of 31 C.F.R. Parts 501
and 515, and any regulations and rulings issued pursuant thereto and may be revoked or modified at any time at the
discretion of the Secretary of the Treasury acting directly or through the agency through which the license was issued, or
any other agency designated by the Secretary of the Treasury. If this license was issued as a result of willful
misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the Secretary of the
Treasury, be declared void from the date of its issuance, or from any other date.
l(b)(6)1
50 U .S.C. App. 16, and 31 CFR 515.701 et seq. for provisions relating to penalties.]
2003-06-032 000433
License No. CT-2664
Page 2 Df 3
SECTION 1 -AUTHORIZATION: (a) This license authorizes the representatives of the law firm Fish &
Neave to engage in travel-related transactions involving Cuba set forth in 31 CFR 515. 560( c) and such
additional transactions as are directly incident to professional research and professional meetings relevant to
legal proceedings in connection with all matters relating to Bacardi & Company Limited and Bacardi U.S.A.,
Inc. v. Empressa Cubana Exportadora de Alimentos y Productos Varios d/b/a/ Cubaexport and Havana Club
Holding S.A. d/b/a HCH. S.A. (filed in tl1e District Court for the District of Columbia) and Galleon S.A ..
Bacardi-Martini U.S.A .. Inc .. and Bacardi & Company Limited v. Havana Club Holding, S.A .. d/b/a HCH, S.A ..
and Empresa Cuban Exportadora De Alimentos y Productos Varios. S.A., d/b/a Cubaexport (Trademark Trial
and Appeal Board Cancellation No. 92024108), including but not limited to conducting interviews and
depositions, and creating written and other records, as described in your application, subject to the conditions
set forth in Section 2 below.
SECTION 2- CONDITIONS: (a) The Licensee must provide each traveler with a letter confirming that the
named individual will engage in authorized activities on behalf of the Licensee and cite the number of this
license.
(b) It is a condition of this license that the Licensee infonn each traveler of his/her responsibilities under the
Regulations, by, for example, providing each traveler with OFAC's "Travel Restrictions" brochure or other
document providing information concerning the travel-related transactions authorized by 31 CFR 515.560(c) of
the Regulations prior to travel.
SECTION 3 - WARNINGS: Except as explicitly authorized in Section 1 above, nothing in this license
SECTION 4 - RECORDKEEPING REQUIREMENTS: The Licensee is required to keep a list of
individuals whose travel transactions were authorized under this license and their actual dates of travel. Each
individual traveler must also retain records related to his/her travel transactions. Such records shall be made
available for examination upon demand for at least 5 years from the date of each transaction. A report from the
Licensee is required on activities undertaken pursuant to this license in conjunction with an application to renew
or extend this license.
SECTION 6- PRECEDENCE: The authorization contained in this license is limited to the facts and
circumstances specific to the application.
******************************************************************************************
2003-06-032 000434
LICENSE
License No. CT-7571
22 U.S.C. 600 I et seq., Proclamation 3447, and 31 CFR Parts 50 I and 515)
To: Ropes & Gray LLP (the
1251 A venue of the Am ere as
A
New York, NY 10020
Attn: (b)(6)
I. Pursuant to your application dated February 27, 2006, the following transactions are hereby licensed:
othe'rs, that you comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of the
4. This license expires on April 30, 200f, is not transferable, is subject to the provisions of Title 31, Parts 50 I and
515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may be revoked or
modified at any time at the discretion of the Secretary of the Treasury acting directly or through the agency through which
the I icense was issued, or any other agency designated by the Secretary of the Treasury. If this license was issued as a
result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the
By
______________ _
50 U .S.C. App. 16, and 31 CFR 515.701 et seq. for provisions relating to penalties.]
License No. CT7571
Licensee: Ropes & Gray
Page 2 of2
SECTION 1- AUTHORIZATION: (a) This license authorizes representatives of Ropes & Gray (the
"Licensee") to engage in the travel-related transactions involving Cuba set forth in 31 CFR S 15.560(c) of the
Cuban Assets Control Regulations (the "Regulations") and such additional transactions as are directly incident
to professional research and professional meetings relevant to legal proceedings in the United States related to
Trademark Trade and Appeals Board cancellation proceeding number 24,108 (including appeals of that
proceeding), including but not limited to conducting interviews and depositions, and creating written and other
records, subject to the conditions set forth in Section 2 below.
Authority: 31 CFR 51S.S60(c) and 51S.S64(b).
license.
(b) It is a condition of this license that the Licensee inform each traveler of his/her responsibilities under the
Regulations prior to the travel, by, for e x a ~ p l e , providing each traveler with OFAC's brochure "Cuba: What
You Need to Know about the Embargo" or other document providing information concerning the travel-related
transactions authorized by 31 CFR 515.560(c) of the Regulations.
SECTION 3 - WARNINGS: Except as explicitly authorized In Section 1 above, nothing In this license
SECTION 4- RECORDKEEPING REQUIREMENTS: The Licensee is required to keep a list of
SECTION 6 - PRECEDENCE: The authorization contained in this license is limited to the facts and
******************************************************************************************
2003-06-032 000436

!
!
..
' .,.
'"-. 1no,./

LICENSE
License No. CT-7571
12 51 A venue of the Americas
New Y NY 10020
Attn: (b )(6)
1. Pursuant to your application dated February 27, 2006, the following transactions are hereby licensed:
4. This license expires on April 30, 2007, is not transferable, is subject to the provisions of Title 31, Parts 501 and
515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may be revoked or
the license was issued, or any other agency designated by the Secretary of the Treasury. If this license was issued as a
result of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the
I (b)(6) I
arrow
2003-06-032 000437
..
License No. CT-7571
Licensee: Ropes & Gray
Page 2 of 2
SECTION l- AUTHORIZATION: (a) This license authorizes representatives of Ropes & Gray (the
"Licensee") to engage in the travel-related transactions involving Cuba set forth in 31 CFR 515.560(c) ofthe
Cuban Assets Control Regulations (the "Regulations") and such additional transactions as are directly incident
to professional research and professional meetings elevant to legal proceedings in the United , 'ncluding.
but not limited to conducting interviews and depo ions, and creating written and other records, su ect to the
conditions set forth in Section 2 below. .. . . - ------- _
-J!x / di..ld frc tl 1. >'i7<J )
(b) This license authorizes multiple trips during the validity period of the license. / - t /a
1
f"9"':" /
__ ;, 1/ .. f
Authority: 31 CFR 515.560(c) and 515.564(b). ; //,.c--1 ;3<-!
t ....:: .... .......... ,',\...) ,'
SECTION 2- CONDITIONS: (a) The Licensee must provide each traveler
named individual will engage in authorized activities on behalf of the Licensee and cite t . . -----... _
1
- / "
tcense. ")-'/"--'-' vf- (7.._.1 -' '
!'

/ / /
(b) It is a condition of this license that the Licensee inform each traveler of his/her responsibilities unCTef'--Qlje...
Regulations prior to the travel, by, for example, providing each traveler with OFAC's brochure "Cuba: What
You Need to Know about the Embargo" or other document providing information concerning the travel-related
transactions authorized by 31 CFR 515.560(c) of the Regulations.
abridged version of consular information sheets can be heard by calling (202) 64 7-5225.
******************************************************************************************
2003-06-032 000438
POPES?, GRAY Lo_P
1151 AVENUE OF T'1E AMERICAS NEW YOR<. NY 10020-1104 212-5% ''000 F 212 596-9090
BOSTON NEW YORK PALO ALTO ';AN FRANCISCO 'NASHINGTON DC www ropesgray com
DIRECT DIAL
DIRECT FAX
E-MAIL
(b )(6)
February 27, 2006
Ms. Barbara Hemmerslee
Dear Ms. Hemmerslee:
The law firm of Ropes & Gray is currently the licensee under License
No. CU-74488. License No. CU-74488 is set to expire on March 31, 2006. A copy of this license
is enclosed.
That license was granted in response to an application to renew License No.
CT -1943 authorizing (a) " ... Licensee to engage in travel-related transactions involving Cuba set
forth in 31 CFR 515.560(c) of the Cuban Assets Control Regulations (the 'Regulations') and such
additional transactions as are directly incident to professional research relevant to legal proceedings
in the United States, including but not limited to conducting interviews and depositions, and
creating written and other records, as described in your application, subject to the conditions set
forth in Section 2 below; (b)" ... Licensee to provide legal services to, and receive payment for such
services from Empresa Cubana Exportadora De Alimentos y Productos Varios ('Cubaexport'), a
Cuban national; (c) multiple trips during the validity period ofthe license."
On January 29,2004, the Trademark Trial and Appeal Board of the United States
Patent and Trademark Office dismissed cancellation proceeding number 24,108. On March 29,
2004, Bacardi & Company Ltd. (the parent company of Galleon S.A.) and Bacardi U.S.A., Inc.
filed a complaint against Havana Club Holding S.A. and Cubaexport, which was joined by the
Trademark Trial and Appeal Board to the cancellation proceeding. The complaint appeals the
decision of the Trademark Trial and Appeal Board and asserts additional claims against the
defendants. Ropes & Gray has continued to represent Cubaexport in these proceedings.
2003-06-032 000439
ROPES & GRAY LLP
Ms. Barbara Hemmerslee
February 27, 2006
Page 2
Ropes & Gray hereby requests a renewal of License No. CU-74488, authorizing
Ropes & Gray to continue to represent Cubaexport and to receive payment and engage in
authorized travel in connection with that representation.
Thank you f o ~ to this matter. If we can be of further assistance, please
do not hesitate to call me at-- I (b)(S) I
Sincerely,
- j(b)(6)j
Enclosures
cc: Mr. Matthew Tuchband, Office ofLegal Counsel, OFAC
1 (b)(6) 1 Licensing Division, OFAC
2003-06-032 000440

a

d
'$,J

Cuban ssets Control Regulations
LICENSE
700 12th Street, NW, Suite 900
W DC 20005-3948
(b)(6)
1. Pursuant to an application dated January 26, 2005, the following transactions are hereby licensed:
requested by the Secretary of the Treasury or any duly authorized officer or agency of the Secretary .
. ,
515 of the Code ofF ederal Regulations, and any regulations and rulings issued pursuant thereto and may be revoked or
modified at any time at the discretion of the Secretary of the Treasury acting directly or through the agency through
which the license was issued, or any other agency designated by the Secretary of the Treasury. If this license was issued
as a result ofwillful on the part of the applicant or his duly authorized agent, it may, in the discretion
of the Secretary of the Treasury, be declared void. from the date of its issuance, or from any other date.
l(b)(6)1
2003-06-032 000441
' '
Page 2 of2
SECTION 1- AUTHORIZATION: (a) All transactions are authorized to enable the Licensee, in connection
the legal representation ofEmpresa Cubana Exportadora de Alimentos y Productos V arios ("Cubaexport"), and
Havana Club Holdings S.A. in legal proceedings in the United States related to the HAVANA CLUB trademark,
as described in the application, to receive payment for such services and reimbursement for expenses related to
such services from Cuban nationals through banking channels, provided the funds are routed from Cuba to the
United States via a third-country bank.
Authority: 31 C.F.R. 515.801.
SECTION 2 -RECORDKEEPING REQUIREMENTS: The Licensee is required to keep a record of all
transactions engaged in pursuant to the authorization (Section I) of this license. Such records shall be made
available for examination, upon demand, by the Office of Foreign Assets Control for at least five years from the
date of each transaction.
SECTION 3- WARNINGS: (a) Except as authorized above, nothing in this license authorizes persons subject
to the jurisdiction of the United States to engage in any transaction or activity prohibited by the Cuban Assets
Control Regulations, 31 C.F.R. Part 515, as amended.
(b) Nothing in this license authorizes the transfer of funds through methods which involves debits or credits to
blocked accounts subject to the jurisdiction of the United States.
SECTION 4 - PRECEDENCE: The authorization contained in this license is limited to the facts and
*******************************************************************************************
2003-06-032 000442
ssets Control Regulations
LICENSE
12 51 A venue of the American
New York, NY 10020
Attn: I (b )(6) I
1. Pursuant to your application dated September 29, 2006, the following transactions are hereby licensed:
others, that you comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of
the Treasury under the authority of cited above and the terms of this license.
3. The licensee shall furnish and make available for inspection any relevant information, records or reports
4. This license expires on December 31, 2007, is not transferable, is subject to the provisions of Title 31,
Parts 50 l and 515 of the Code of Federal Regulations and any regulations and rulings issued pursuant thereto, and may
be revoked or modified at any time at the discretion of the Secretary of the Treasury acting directly or through the
agency through which the license was issued, or any other agency designated by the Secretary of the Treasury. If this
license was issued as a result of willful misrepresentation on the part of the applicant or his duly authorized agent, it
may, in the discretion of the Secretary of the Treasury, be declared void from the date of its issuance, or from any other
date.
I (b)(6) I
[Attention is directed to 19 U.S.C. 1592 and l595a, 18 U.S.C. 545, 18 U.S.C. l 001,
2003-06-032 000443
Page 2 of2
SECTION 1- AUTHORIZATION: (a) This license authorizes the representatives of Ropes & Gray LLP
to engage in travel-related transactions involving Cuba set forth in 31 CFR 515 .560(c) of the Cuban Assets
Control Regulations (the "Regulations") and such additional transactions as are directly incident to
professional research and professional meetings, including but not limited to conducting interviews and
depositions, and creating written and other records, incident to the representation of Empresa Cubana
Exportadora de Alimentos y Productos Varios ("Cubaexport") in legal proceedings in the United States
District Court for the District of Columbia against the United States Department of the Treasury, Office of
Foreign Assets Control, described in the application, subject to the conditions set forth in Section 2 below.
SECTION 2- CONDITION: It is a condition of this license that the Licensee engage in a full-time
schedule of professional research activities consistent with 31 CFR 515.564(b) and described in the license
application.
activity prohibited by the Regulations. This license only authorizes travel-related transactions
consistent with a full-time schedule of activities authorized by this license.
SECTION 4- RECORDKEEPING REQUIREMENT: The Licensee shall keep a record of the
transactions under this license. Such records shall be made available for examination upon demand for at
least five years from the date of each transaction. The Office of Foreign Assets Control may require the
submission of a report from the Licensee or any individual traveler concerning the activities undertaken
pursuant to the license. A report from the Licensee is required on activities undertaken pursuant to this
license in conjunction with an application to renew or extend this license.
SECTION 5- INFORMATION: (a) For information concerning the categories of travel for which
licenses may be issued, please refer to our Comprehensive Guidelines for License Applications to Engage in
Travel-Related Transactions Involving Cuba on our Internet website at www.treas.gov/ofac (Sanctions
Programs & Country Summaries -Cuba, Guidelines and Information).
SECTION 6- PRECEDENTIAL EFFECT: The authorization contained in this license is limited to the
facts and circumstances specific to the application.
* * * * * * * * * * * * * * * * * * * * * * * * * * * * ~ * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * * *
2003-06-032 000444
Sap-;-Z9-lC06 OZ :4,9pm From-ROPES AND GRAY
+ T-165 P 001/003 F-679
ROPES & GRAY LLP
1251 AVENuE Or'THE AMERICAS NCW YORK, NY 100201 104 21 259e9000 F 212596-9090
90STON NEW PALO ALTO SAN FRANC<SCO WASI-11NGTON. DC com
FAX TRA.NSMJn' . .t.L LETTER
IMPORTANT: PLEASE DELIVER THIS DOCUMEN'f IMMEDIATELY!
IF YOU DO NOT RECEIVE ALL PAGES, PLEASE CALL: 212-596-9070
TOTAL NUMBER OF PAGES INCLUDING THIS TRANSMITTAL LETTER: 3
To:
From:
Tuchband, Esq.
(Office of Legal Counsel)
Ms. Liz Farrow (OFAC)
Comments:
Firm/Company
Office of Foreign Assets
Control,
U.S. Department of the
Treasury
(b)(6)
Fax Number Phone Number
(202) 622-044 7
PLEASE COMPLETE WHEN Su BMITIING TO FAX DEPARTMENT
Date: September 29, 2006
File Symbol: 001214.0001
Submitted
I (b)(6) I
Time: 2:45 PM
Personal ID Number:
Phone: 212-596-9070
iHIS FAX MAY CONTAIN INFORMATION THAT IS PR!V1LEGED, CONFIDENTIAL AND !;XEMPT FROM DISCt.OSVRE.
IT IS INTENDED FOR USE ONLY BY THOSE TO WHOM IT IS ADDRESSED. IF THIS FAX IS NOT ADDRESSED TO
YOU, OR IF YOU RECEIVED IT IN ERROR., YOU MAY NOT DISCLOSE, DISiRIBUTE, COPY OR USE THIS FAX OR ANY
INFORMATION IN IT. INSTEAD, PLEASE CALL US COLLECT AT 212-596-9070 TO ARRANGE FOR ITS DESTRUCTION
OR RETURN.
2003-06-032 000445
From-ROPES AND GRAY +
T-165 P 002/003 F-679
&. Gl!to.Y Li.l'
12:01 !\VENUE OF THE AMER,CAS NEW YORK, NY 1002011()11 2125969000 r
BOSTON NEVV YORK. PAi.O ALTO SAN FRANCISCO DC
DIRE CO 01.'1.
(b)(6)
DIRECT FAX
Sepember 29, 2006
Application for Specific License in Connection with the Representation of Cubacxport
Dear Sir/Madam:
As counsel for Empresa Cubana Exportadora De Alimentos y Productos Varies. S.A., dba
Cubaexport ("Cubaexport"), the law firm of Ropes & Gray LLP is concurrently filing an action in
the United States District Coun for the District of Columbia against the United States Department
ofTreasury, Office of Foreign Asset Control ("OFAC"), Henry M. Paulson, Jr., as Secretary of
Treasllry, Adam .T. Szubin, as Director ofOFAC, and the United Stares. This lawsuit Diises out of
certain actions by OF AC, which caused the United States Patent and Trademark Office ("PTO") to
refuse to renew a United States trademark registration owned by Cubaexport for the trademark
HAVANA CLUB & Design (the "HAVANA CLUB Registration"). As a result ofOFAC's actions,
t11e PTO has notified Cubaexport that the HAVANA CLUB Registration will be cancelled/expired.
This cancellation will result in Cubaexpon's loss of valuable property rights.
Pursuant to the general license provision set forth in 35 C.F.R. 515 .512(a)(3), Ropes & Gray
LLP submits thnt it is authorized to represent Cubaexport in this legal proceeding. Ropes & Gray
LLP hereby applies for a specific license to provide and receive payment for such representation of
Cubaexpon in connection with the above-discussed action against OFAC, et. al.
2003-06-032 000446
ROPES & GRAY LLP
Office of foreign Assets Control
September 29, 2006
Page 2
+
T-165 P 003/003 F-679
We specifically request that a specific license issue authorizing all necessary transactions
associated with the legal representation by Ropes & Gray LLP of Cubaexport, a Cuban national, for
the following purposes:
(i) to solicit and receive fee payments and reimbursements for expenses incurred in
connection with the legal representation of Cubaexport relating to the above-discussed action
against OFAC, et. al., provided that said fees and expenses are paid exclusively from fresh funds
outside of the United States; and
(ii) for travel to Cuba by attorneys at this firm and otl1ers acting under their supervision and
control, for the purposes of communicating with our client in connection with the above.
Inasmuch as this matter concerns legal proceedings, we are taking the liberty of forwarding
a copy ofthis application to the Office ofChiefCoumel, OFAC.
Sincerely yours,
- l(b)(6)1
cc: Matthew Tuchband, Esq., Office of Legal Counsel, OFAC
Liz Farrow, OF AC
2003-06-032 00044 7
I (b)(6) I
. . '
. t"
. '
'r
,y
'
LICENSE
(Granted under the authority of 50 U.S.C. App. S(b), 22 U.S.C. 2370(a),
22 U .S.C. 6001 et seq., Proclamation 344 7, and 3 l CFR Parts 50 l and 515)
700 12th Street, NW, Suite 900
W a s h i ~ 8
Attn: - l,.......,(,...,.b)..,.,..,(6)--.l
License No. CT-4558
I. Pursuant to an application dated January 26, 2005, the following transactions are hereby licensed:
2. This license is granted upon the statements and representations made in your application, or otherwise filed with
or made to the Treasury Department as a supplement to your application, and is subject to the conditions, among others,
that you comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of the Treasury
515 of the Code of Federal Regulations, and any regulations and rulings issued pursuant thereto and may be revoked or
the license was issued, or any other agency designated by the Secretary of the Treasury. If this license was issued as a result
of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the
does it release Licensee(s) or third parties from civil or criminal liability for violation of any law or regulation.
[Attention is directed to 19 U.S.C. 1592 and l595a, 18 U.S.C. 545, 18 U.S.C. 1001,
2003-06-032 000448
License No. CT-4558
Page 2 of2
SECTION 1- AUTHORIZATION: (a) This license authorizes the Licensee to engage in travel-related
transactions involving Cuba set forth in 31 CFR 515.560(c) of the Cuban Assets Control Regulations (the
"Regulations") and such additional transactions as are directly incident to professional research in connection
the legal representation ofEmpresa Cubana Exportadora de Alimentos y Productos Varios ("Cubaexport"), and
Havana Club Holdings S.A. in legal proceedings in the United States related to the HAVANA CLUB
trademark, including but not limited to conducting interviews and depositions, and creating written and other
records, as described in your application, subject to the conditions set forth in Section 2 below.
license.
Regulations, by, for example, providing each traveler with OFAC's "Travel Restrictions" brochure or other
document providing information concerning the travel-related transactions authorized by 31 CFR 515 .560( c) of
******************************************************************************************
2003-06-032 000449
LICENSE
22 U.S.C. 6001 et seq., Proclamation 3447, and 31 CFRParts 501 and 515)
700 Ith Street, NW, Suite 900
Washi DC 20005-3948
Attn: (b)(6)
License No. CT-4558
l. Pursuant to an application dated January 26, 2005, the following transactions are hereby licensed:
2. This license is granted upon the statements and representations made in your application, or otherwise filed with
or made to the Treasury Department as a supplement to your application, and is subject to the conditions, among others,
that you comply in all respects with all regulations, rulings, orders and instructions issued by the Secretary of the Treasury
4. This license expires on March 31, 2006, and is not transferable, is subject to the provisions ofTitle 31, Part
515 of the Code of Federal Regulations, and any regulations and rulings issued pursuant thereto and may be revoked or
the license was issued, or any other agency designated by the Secretary of the Treasury. If this license was issued as a result
of willful misrepresentation on the part of the applicant or his duly authorized agent, it may, in the discretion of the
5. This license does not excuse compliance with any Jaw or regulation administered by the Office of Foreign
does it release Licensee(s) or third parties from civil or crimina11iability for violation of any law or regulation.
By __________________________ __
David W. Mills
Chief of Licensing
I (b)(
6
) I [Attention is directed to 19 U.S.C. 1592 and l595a, 18 U.S.C. 545, 18 U.S.C. 1001,

l<b><e>l
rt+
"J.Jv-f
2003-06-032 000450
;,.. '"""'e.c.t:u . r-< \
ft.; .. l
---------- , .. c ... , ...... /}
a. ... "'"}. of /; ....,.,.,. t ... Jo"'"' f/C'
tLt Page {;(1.' ;41;-c-.tJ 7
y-t.J,teJ .. L) v ...... :o-J I
fi,A
f""' .. 4,.. ..... J
(""'"' '";t:: (_/.,.!.
SECTION 1- AUTHORIZATIO : (a) This license authorizes the Licensee to engage in a -; ated ).,A. '"'
transactions involving Cuba set fo h in 31 CFR 515.560(c) of the Cuban Assets Control Regu tions (the
J "Regulations") and such addition transactions as are directly incident to professional research relevaHftfllegal
/ proceedings in.the United State including but not limited to conducting interviews and depositions, and
creating written and other records, as described in your application, subject to the conditions set forth in Section
2 below.
SECTION 2 -CONDITIONS: (a) The Licensee must provide each traveler with a letter confirming that the
license.
Regulations, by, for example, providing each traveler with OF AC's "Travel Restrictions" brochure or other
document providing information concerning the travel-related transactions authorized by 31 CFR 515 .560( c) of
http://travel.state.gov, or through the State Department's service at (202) 647-3000. An

2003-06-032 000451
I .
ROPES & GRAY LLP
ONE METRO CENTER 700 12TH STREET, NW SUITE 900 WASHINGTON, DC 200J53948 202-500-4600 F 202-500-4650
BOSTON NEW YORK PALO ALTO SAN FRANCISCO WASHINGTON, DC www.ropesgray.com
January 26, 2005
VIA FACSIMILE (CONF. BY FEDEXl
- I (b)(6) I
Licensing Department
- l(b)(6)1
Pursuant to your request made during our January 25 telephone conversation, I
am providing you with additional information regarding the renewal of License No. CT -1943. I
requested renewal of this license in my January 5, 2005 letter to David Mills (the
-letter''). 1 (b)(6) 1
Referring you to the second paragraph ofthe-letter, I explained that a
complaint is currently pending in the U.S. District Court for the District of Columbia against our
clients Cubaexport and Havana Club Holdings S.A. (the "District Court case"). On behalf of our
clients, Ropes & Gray has filed a motion to dismiss that complaint, and we are currently awaiting
a decision from the Court on that motion.
In the past year, we have not had the opportunity to travel to Cuba despite the
authorization given to us by OFAC in License No. CT-1943. We have not traveled to Cuba
because we have not started to conduct discovery in the District Court case. Once the Court
rules on our clients' motion to dismiss, we will know whether we need to proceed with
discovery, which undoubtedly will require travel to Cuba to, among other things, conduct
depositions and collect documents. 1 (b)(6) I
For your convenience, I have attached the .. letter which included License
No. CT-1943. In addition, I have attached OFAC's January llletter in response to the- I (b)(6) I
letter.
2003-06-032 000452
ROPES & GRAY LLP
- J(b)(6)J
- 2- January 26, 2005
I hope this letter provides you with the information you need in order to renew
Ropes &Gray's license. Thank you for your attention to this matter. Ifi can be of further
assistance, please do not hesitate to call me at J (b)(
6
) 1
cc: Office of Legal Counsel, OF AC
Division, OF AC
2003-06-032 000453
MEMCRY TRANSMISSION STRRT=JUL-28 13:33 END=JUL-28 13=34
FILE N0.=148
STN NO.. COMM. ABBR NO. STATION NAME/TEL NO. PAGES DURATION
OK 86467282671
-us .TREASURY
... ; ,. - ***** - ' . . . 104815- *********
UNITED STATES DEPARTMENT OF THE TREASURY
FACSIMILE TRANSMITTAL COVER SHEET
DAT:O:: 7/28/06
NUMBER OY PAGES COVER SHIIT:
I (b)(6) I
FROM:
COMMENTS:
Phone:
Fax:
Liz Farrow
Esquire
(212) 596-9070
(646) 728-2671
Assistant.Direc:tor fo:1:" Licensing
Phone:
Fax:
(202) 622-2480
po2) 622-0447
2003-06-032 000454
CLEARANCE SHEET
DATE: 7-26-2006 FAC No. CU-75835
ME_MdR4NDl]Nl- FORi. DIRECTOR D
. . . . . . -
Associate-DirectoY(Resource Management) 0
Asso-ciate Directof (investigations & Enforcement) D
Associate Director (Program Policy & ImplementatiQn) [J
SUBJECT: Ropes & Gray-HAVANA CLUB trademark
DENIAL pased on guidance from STATE
REVIEW OFFICES (Please circle appropriate office)
Records
Personnel
Budget
Information Technology
OFAC ChiefCounseiD
Referrals: State
International Programs
Enforcement
Special Investigations
Civil Penalties
Advisor: ______ _
Other
----- ------
Licensing
Policy
Compliance
Blocked Assets
Name (Please Type/Print) Initial Date Division
REVIEWER(S)
L I 2.. F t1 r r r/V'vf/
r
THoRNTON
/ f' r

(.; (-
VILL 7/tif6
fJPJ
+jJ.Y:
UJv tJSe l
2003-06-032 000455
I
r
I (b)(6) I
I (b)(6) I
CLEARANCE SHEET
FAC No.: CU-75835 DATE: 5/9/2006
MEMORANDUM FOR: DIRECTOR 0 DEPUTY DIRECTOR 0
Associate Director (Resource Management) 0
Associate Director (Investigations & Enforcement) 0
Associate (Program Policy & Implementation) D
r .
SUBJECT: Referral to State on Ropes & Gray's request to register the ijavanat
Clup tradematl{ at PTO in order to maintain status quo while other issues
(cancellation proceeding) are being sorted out.
REVIEW OFFICES (Please circle appropriate office)
Records
Personnel
Budget
Information Technology
OFAC Chief Counsel [I
Referrals: State
Print}
INITIATOR(S)
REVIEWER(S)
Tuchband, M.
Farrow, L.
International Programs
Enforcement
Special Investigations
Civil Penalties
Licensing
Policy
Compliance
Blocked Assets
Advisor: TUCHBAND/
I (b)(6) I
Other
------
Initial Date Division
slr/o
Licensing
,...--
;At/
. )j;lj.fo .
occ
I
r-:-
I J '
;,_.., s; 7/cr.-
Licensing
PP& I

o FltL--
2003-06-032 000456
Tel. No.
I (b)(6) I
Canter, Virginia .
From:
Sent:
To:
Cc:
St1bject:
otherwise indicated
Thornton, Sean
Thursday, July 27, 2006 2:14PM
Molly; Canter, Virginia; McBrien, Bob;-Szubin, Adam;-
HC
Sorry, I nave'a "second reminder frotn.
' ; ; .;, I ' ' ' 1 I ,' '
The Cubans confisca_te in 1.960 -c theyc6ilfisated using the in Cuba
C!lld if) trird .countries, but the U .9. registratiori" w,as of the Ar"rechaba_la f<hnily imtil the early 1970s, when they
allowed it to expire. The Cuba.n_ government then registered the U.S. mark.in its own name in 1976.
Thanks,
Sean
----Original Message-
From: Millerwise, Molly
Sent: Thursday, Ju'l 27, 2006 12:43 iiPM
To: II
1
McBnen, Bob; Szubin, Adam Farrow, tiz;
Subject: Press pomts or HC
All - I have cleared the following points with Sean. Please let me know any last tweaks. I plan to
give these to press on the record that call about the issue.
Thanks,
Molly
2003-06-032 000457
Farrow, Liz
From:
. Sent:
To:
Subject:
otherwise indicated
Szubin, Adam;-
All- I have cleared the following points with SearL Please 'let me kil'p:w:any last tweaks; .I phm to give
these to press on the record thatcall about the i s s u ~ ..
Thanks,
Molly
2003-06-032 000458
I (b)(6) I
Enf()rceri1ent #:
Other No:
_(l'johe)
(No'ne)
Legislative A(fair No: (None)
FOIA No: (None)
Remarks
Date Ou(:;
Date c;lQs_ed:
Supplemental dtd 6/14/06 sent 6/16/06.

(b)(5)
http://ofacoraprod.do. treas.gov /pls/fac/OF ACRprts.H is
2003-06-032 000459
/(.
Other No: (Nohe)
Legislative Affair No: . (Norte)
FOIA No: (None)

Date .
- _ .
lstaffAssignment IIAssignment Date IIAction !ISti:JtUS
I (b)(6) I
..
1107-APR-06 llcreate this F AC#
I
lxxx 1107-APR -06 . IIsee also F ACNO 11238413
luc 1107-APR-06 lias sign
I
lxxx
Y -06 IIsee also F ACNO 11273712
I (b)(6)l
-
1109-MAY-06 llassign
I
lxxx 1!09-MAY-06 llassociated license recordllcU-75835
Remarks
I (b)(6) I
I (b)(6) I
Page l of 1
I
I
I
I
Supplemental dtd 6/14/06 sent to-Licensing 6/16/06; fax dtd 06/27/06, sent tollltlic and CC to
I (b)(6) I
http:/ /ofacoraprod.do.treas.gov/pls/fac/OF ACRprts.HistoryRpt?p _ docid=2 73201
2003-06-032 000460
7/6/2006
,,._..
Page l of 1

:::: .. t:- .> .. ... ; __ .. .::::- . 1.... .-_:. . .>(..:' .... .' ... .. :.:
. ::::<fhAI>R-66 ,. . - ..
Exec. #: . . at OFAC: 07-APR-06 ....... .
#:
Otlier No:
(None)
(None)
Legislative Affair No: (None)
FOIA No: (None)
Date Out:
Date Closed:
I (b)(6) I
upplemental dtd 6/14/06 sent to-Licensing 6116/06.
http:/ /o facoraprod.do. treas. gov/pls/fac/OF ACRprts.HistoryRpt?p _ docid=2 7320.1
2003-06-032 000461
6/16/2006

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