ALEMANNO TO SEMBLER: LESS OPEN ON BIOTECH

C O N F I D E N T I A L SECTION 01 OF 03 ROME 002551 SIPDIS STATE FOR SCIENCE ADVISOR NEUREITER, EUR FOR EUR/WE AND EUR/ERA FOR HEN-NIL, EB FOR GADSDEN AND EB/TPP/ATT FOR PEREZ, E FOR SHUB, OES A/S TURNER, STATE PASS USTR FOR STROJE AND NOVELLI, STATE USDA FOR O/S HEGWOOD, FAS/OA TERPSTRA AND SLUTSKY, ITP SHEIK, MACKE, AND EJONES, FAS/FAA/WILSON, AND FAS/OPD BLU, NSC FOR EDSON CONFIDENTIAL PAGE 02 ROME 02551 01 OF 03 241547Z E.O. 12958: DECL: 05/24/2012 TAGS: EAGR ECON IT PREL TBIO ECON IT PREL TBIO ECON IT PREL TBIO WTOEAGR WTOEAGR WTO SUBJECT: ALEMANNO TO SEMBLER: LESS OPEN ON BIOTECH REF: A. ROME 1457 ¶B. ROME 1697 ¶C. ROME 1726 ¶D. ROME 1965 CLASSIFIED BY: AMBASSADOR SEMBLER FOR REASONS 1.5 (B AND D) ¶1. (SBU) SUMMARY. AMBASSADOR MET MAY 17 WITH ITALIAN MINISTER OF AGRICULTURE ALEMANNO TO DELIVER SECRETARY VENEMAN'S LETTER ON ALEMANNO'S BIOTECH WHITE PAPER AND LAY THE GROUNDWORK FOR THE MAY 27 MEETING BETWEEN PRESIDENT BUSH AND PRIME MINISTER BERLUSCONI. ALEMANNO INDICATED THAT HIS POSITION ON AGRICULTURAL BIOTECHNOLOGY IS LESS OPEN TODAY THAN WHEN HE AND THE AMBASSADOR MET LAST JANUARY. THERE APPEARS TO BE A SMALL OPPORTUNITY FOR COLLABORATIVE BIOTECH RESEARCH. THE EMBASSY WILL CONTINUE TO WORK WITH MINAG STAFF TO SECURE ALEMANNO'S SUPPORT FOR AN AGREEMENT ON COLLABORATIVE BIOTECH RESEARCH THAT COULD FREE OTHER MINISTRIES TO WORK MORE ACTIVELY WITH US. ¶2. (C) COMMENT. AS PREVIOUSLY REPORTED, ALEMANNO CONTINUES TO AVOID AN OPEN AND HONEST DEBATE ON THE MERITS OF AGRICULTURAL BIOTECHNOLOGY. HE CONTINUES TO TRY TO SECURE A PRE-DETERMINED OUTCOME BEFORE OTHER COMPETING POINTS OF VIEW WITHIN THE GOI CAN EFFECTIVELY WEIGH-IN. VARIOUS AND CONTRADICTORY MOTIVES ARE ASCRIBED TO ALEMANNO'S POSITION ON BIOTECH, FROM A ROMANTIC VIEW OF CONFIDENTIAL PAGE 03 ROME 02551 01 OF 03 241547Z ITALIAN AGRICULTURE, TO PANDERING TO CONSUMER SENTIMENTS AND POPULIST POLITICS. WHATEVER HIS UNDERLYING CONVICTIONS, WE ARE NOT GOING TO GET ANYWHERE ARGUING THE MERITS OF BIOTECHNOLOGY WITH HIM. RATHER, THE WAY TO ROLL BACK HIS MOMENTUM IS BY CONTINUING TO HELP OTHER VOICES WITHIN THE AN PARTY, BERLUSCONI'S BROADER COALITION, AND ITALIAN SOCIETY WHO WANT TO TALK THROUGH THE ISSUES ON THE MERITS. SUCH A COALITION OF LIKE-MINDED, OR AT LEAST OPEN-MINDED, ADVOCATES OF BIOTECHNOLOGY AND SCIENCE-BASED DECISION MAKING CAN PROVIDE A COUNTERWEIGHT TO THE COALITION OF STRANGE BEDFELLOWS THAT ALEMANNO HAS BEEN RIDING TO THIS POINT. PM BERLUSCONI AND DEPUTY PM FINI CAN ALSO MODERATE ALEMANNO'S INTENTIONS, BUT IF, AND ONLY IF, THEY ARE CONVINCED THEY NEED TO FOCUS THEIR ATTENTION ON THE ISSUE. END COMMENT AND SUMMARY. ¶3. (SBU) AMBASSADOR SEMBLER MET AGMINISTER ALEMANNO ON MAY 17 TO DELIVER SECRETARY OF AGRICULTURE VENEMAN'S LETTER TO ALEMANNO ON THE AGMIN'S PAPER ON BIOTECHNOLOGY ENTITLED "TRANSGENIC ORGANISMS AND AGRICULTURE: A TIME FOR CHOICES:, AND TO SEEK A WAY FORWARD ON BIOTECHNOLOGY IN ADVANCE OF THE MAY 27 MEETING BETWEEN PRESIDENT BUSH AND PRIME MINISTER BERLUSCONI. AMBASSADOR SEMBLER EMPHASIZED THE SECRETARY'S CONCERNS THAT THE ALEMANNO PAPER IS UNBALANCED SIPDIS AND RELIES ON ARGUMENTS WITHOUT SCIENTIFIC FOUNDATION. HE ASKED ALEMANNO FOR HIS SUPPORT OF UNDER SECRETARY GIANNI LETTA'S (SENIOR ADVISOR TO THE PRIME MINISTER) IDEA TO DEVELOP A COOPERATIVE SCIENTIFIC RESEARCH AGREEMENT ON BIOTECHNOLOGY, SIMILAR TO THE BILATERAL AGREEMENT ON CLIMATE CHANGE, AS A WAY FORWARD ON AGRICULTURAL BIOTECHNOLOGY. A BUSH-BERLUSCONI ACKNOWLEDGMENT OF SUCH AN CONFIDENTIAL PAGE 04 ROME 02551 01 OF 03 241547Z AGREEMENT COULD THEN BE A BASIS FOR MINISTER ALEMANNO'S MEETING WITH SECRETARY VENEMAN IN JUNE DURING THE WORLD FOOD SUMMIT AT FAO. (COMMENT: WE UNDERSTAND THE WHITE HOUSE DOES NOT WISH ANY BILATERAL ANNOUNCEMENTS. A QUIET AGREEMENT TO DEVELOP AN ANNEX TO THE EXISTING BILATERAL S&T AGREEMENT MAY BE MORE APPROPRIATE. WE WILL INVESTIGATE THIS POSSIBILITY. END COMMENT.) ¶4. (SBU) ADDRESSING THE TIMING OF THE WHITE PAPER, ALEMANNO INDICATED THAT IT WOULD BE NECESSARY TO CONSULT WITH REGIONAL GOVERNMENTS AND THE TAVOLA AGROALIMENTARE (THE GOVERNMENT'S FOOD INDUSTRY ADVISORY GROUP) PRIOR TO SUBMITTING THE DOCUMENT TO EITHER THE COUNCIL OF MINISTERS OR THE PARLIAMENT FOR DEBATE. THE TAVOLA AGROALIMENTARE IS SCHEDULED TO DISCUSS THE PAPER ON JUNE 4. (COMMENT: WE LEARNED SUBSEQUENTLY THAT ALEMANNO HAD SENT THE THIRD VERSION OF HIS WHITE PAPER TO THE CHAMBER OF DEPUTIES ON MAY 16 AND TO THE SENATE ON MAY 17. BOTH ARE CLOSED THIS WEEK FOR LOCAL ELECTIONS. END COMMENT.) ¶5. (SBU) ON THE SUBSTANCE OF THE WHITE PAPER, ALEMANNO EXPLAINED THAT HIS POSITION ON BIOTECHNOLOGY HAD BECOME LESS OPEN SINCE HE AND THE AMBASSADOR LAST MET (JANUARY 22, 2002) BECAUSE OF SOCIAL AND ECONOMIC EVENTS THAT HAVE SINCE CONFIDENTIAL CONFIDENTIAL PTQ8283 PAGE 01 ROME 02551 02 OF 03 241547Z ACTION EUR-00 INFO LOG-00 NP-00 AGRE-00 AID-00 AIT-03 AMAD-00 ACQ-00 CEA-01 CIAE-00 COME-00 CTME-00 DODE-00 DOTE-00 PERC-00 SRPP-00 DS-00 EB-00 EXIM-01 E-00 FAAE-00 VC-00 FRB-00 HHS-01 H-01 TEDE-00 INR-00 ITC-01 L-00 VCE-00 AC-01 NSAE-00 OES-01 OMB-01 OPIC-01 PA-00 PM-00 PRS-00 ACE-00 P-00 SP-00 SSO-00 SS-00 STR-00 TRSE-00 T-00 USIE-00 EPAE-00 PMB-00 DSCC-00 DRL-02 G-00 NFAT-00 SAS-00 /014W -------------- B38537 241547Z /38 P 241528Z MAY 02 FM AMEMBASSY ROME TO SECSTATE WASHDC PRIORITY 3906 NSC WASHDC PRIORITY INFO EU MEMBER STATES COLLECTIVE AMEMBASSY VATICAN AMCONSUL FLORENCE AMCONSUL MILAN AMCONSUL NAPLES C O N F I D E N T I A L SECTION 02 OF 03 ROME 002551 SIPDIS STATE FOR SCIENCE ADVISOR NEUREITER, EUR FOR EUR/WE AND EUR/ERA FOR HEN-NIL, EB FOR GADSDEN AND EB/TPP/ATT FOR PEREZ, E FOR SHUB, OES A/S TURNER, STATE PASS USTR FOR STROJE AND NOVELLI, STATE USDA FOR O/S HEGWOOD, FAS/OA TERPSTRA AND SLUTSKY, ITP SHEIK, MACKE, AND EJONES, FAS/FAA/WILSON, AND FAS/OPD BLU, NSC FOR EDSON CONFIDENTIAL PAGE 02 ROME 02551 02 OF 03 241547Z E.O. 12958: DECL: 05/24/2012 TAGS: EAGR ECON IT PREL TBIO ECON IT PREL TBIO ECON IT PREL TBIO WTOEAGR WTOEAGR WTO SUBJECT: ALEMANNO TO SEMBLER: LESS OPEN ON BIOTECH TAKEN PLACE IN ITALY. HE EXPLAINED THAT ITALY'S LARGEST AND STRONGEST FARMERS' ORGANIZATION, COLDIRETTI, HAS MADE CLEAR ITS OPPOSITION TO BIOTECHNOLOGY AND HAS "CEMENTED A STRONG FRONT WITH ALL OF ITALY'S CONSUMER ORGANIZATIONS AND ENVIRONMENTAL GROUPS". THEIR STRENGTH WAS "CLEARLY SHOWN" IN THE DEMONSTRATION THEY HELD IN FRONT OF MONSANTO'S FACILITY IN LODI ON APRIL 20, ALEMANNO ASSERTED. ACCORDING TO ALEMANNO, COLDIRETTI HAS ALSO ACCUSED THE MINAG OF BEING TOO SOFT ON GMO-USE IN ITALY. ¶6. (C) COMMENT. ALEMANNO'S ANALYSIS IS CLEARLY SELF-SERVING. FIRST, ACCORDING TO MONSANTO, THE DEMONSTRATION WAS PEACEFUL WITH A FEW TRACTORS AND PERHAPS 30-40 PEOPLE. BY ALL ACCOUNTS, THE PRESS COVERAGE WAS FAR MORE DAMAGING TO MONSANTO THAN THE PROTEST ITSELF. SECOND, WE STILL NEED TO BE CONVINCED THAT ALEMANNO AND COLDIRETTI HAVE ALL ITALIAN CONSUMER GROUPS IN THEIR CORNER. THOSE THAT ATTENDED THE EMBASSY'S FEBRUARY 14 PROGRAM WITH TUSKEGEE UNIVERSITY PROFESSOR C.S. PRAKASH DEMONSTRATED OPEN-MINDEDNESS AND EVEN WARMED TO THE SUBJECT OF BIOTECHNOLOGY. END COMMENT. ¶7. (SBU) ACKNOWLEDGING THAT THERE IS NO SCIENTIFIC EVIDENCE WHICH INDICATES THAT BIOTECH PRODUCTS ON THE MARKET ARE HARMFUL TO HUMAN HEALTH, ALEMANNO EXPLAINED THAT ITALIAN CONSUMERS BELIEVE BIOTECHNOLOGY IS INCOMPATIBLE WITH QUALITY FOOD. IN ITALY, WHERE THE REPUTATION OF CONFIDENTIAL PAGE 03 ROME 02551 02 OF 03 241547Z ITALIAN PRODUCTS FOR QUALITY IS OF PARAMOUNT IMPORTANCE, IT WOULD NOT BE COMMERCIALLY VIABLE TO DEVELOP BIOTECH CROPS. ALEMANNO ADDED THAT BECAUSE OF THE LIMITED QUANTITY OF LAND AVAILABLE FOR AGRICULTURAL PRODUCTION, IT WOULD BE IMPOSSIBLE TO GUARANTEE THE SEPARATION OF GMO-FREE PRODUCTION, IF PLANTED ALONGSIDE GMO CROPS. THE LATTER CONCERN IS THE BASIS FOR ITALY'S ESPECIALLY CAUTIOUS APPROACH TO BIOTECHNOLOGY. HE REPEATED THAT ITALY'S CONCERN WITH BIOTECHNOLOGY WAS BASED ON COMMERCIAL, NOT HEALTH, FACTORS. IN CONCLUSION, ALEMANNO STATED THAT THE PURPOSE OF THE WHITE PAPER IS TO IDENTIFY THE PROBLEMS SURROUNDING BIOTECHNOLOGY IN ORDER THAT THE COUNCIL OF MINISTERS OR THE PARLIAMENT COULD HAVE AN OPEN AND FAIR DEBATE ON THE ISSUE. HE PROCLAIMED THAT IF THE WHITE PAPER IS PERCEIVED AS BIASED, HE IS PREPARED TO MODIFY IT. ¶8. (SBU) THE U.S. SIDE EXPLAINED THAT THERE IS NO CONCLUSIVE STUDY WHICH SUPPORTS THE ASSUMPTION THAT THE CULTIVATION OF BIOTECH CROPS CANNOT CO-EXIST WITH CONVENTIONAL CROPS. TO THE CONTRARY, SIMILAR CHALLENGES HAVE BEEN OVERCOME IN ORDER TO ENSURE THE PURITY OF PLANTING SEEDS. THE ANSWER TO ALEMANNO'S QUESTION LIES IN RESEARCH, SOMETHING THE UNITED STATES AND ITALY MIGHT WORK ON TOGETHER. THE U.S. SIDE ALSO CHALLENGED ALEMANNO'S ASSERTION THAT BIOTECHNOLOGY IS INCOMPATIBLE WITH QUALITY AGRICULTURE. ITALIAN SCIENTISTS HAVE ALREADY DEVELOPED NEW PLANT VARIETIES WHICH DEMONSTRATE THE POTENTIAL FOR BIOTECHNOLOGY TO IMPROVE THE PRODUCTION, QUALITY, AND SUSTAINABILITY OF TRADITIONAL CROPS SUCH AS THE SAN MARZANO TOMATO AND CARNAROLI RICE. CONFIDENTIAL PAGE 04 ROME 02551 02 OF 03 241547Z ¶9. (SBU) ALEMANNO WAS QUICK TO DENY THAT HE PERSONALLY BELIEVES GMO'S ARE INCONSISTENT WITH QUALITY ITALIAN AGRICULTURE. RATHER, THIS WAS THE PREVAILING PERCEPTION AMONG ITALIAN CONSUMERS. RETURNING TO THE IDEA OF A COOPERATIVE AGREEMENT ON BIOTECHNOLOGY RESEARCH, ALEMANNO ENCOURAGED THE EMBASSY TO WORK WITH PROF. FERNANADO ROMANO, THE NEWLY APPOINTED CHAIR OF THE MINISTER'S BIOTECH COMMITTEE. ROMANO IS ALSO CHAIR OF THE NATIONAL INSTITUTE ON NUTRITION. ALEMANNO SAID HE WOULD ASK ROMANO TO CONTACT THE EMBASSY EARLY THE WEEK OF MAY 20. ¶10. (SBU) AMBASSADOR SEMBLER REPEATED THE INTEREST OF THE UNITED STATES TO MOVE QUICKLY IN ADVANCE OF PRESIDENT BUSH'S VISIT. ALEMANNO IN RESPONSE CONFIRMED THAT PM BERLUSCONI, DEPUTY PM FINI, AND HE ALL WANTED TO AVOID A DISPUTE OVER BIOTECH THAT IMPINGES ON U.S.-ITALIAN RELATIONS. HE SUGGESTED THAT IF GMO-FREE PRODUCTION COULD TAKE PLACE ALONGSIDE BIOTECH CROPS "WITHOUT CONTAMINATION" THE ISSUE COULD BE EASILY RESOLVED. ¶11. (C) ANALYSIS AND COMMENT. ALEMANNO WAS OBVIOUSLY UNCOMFORTABLE WITH SCIENCE AND BACKED DOWN QUICKLY TO EMBRACE THE CAUSE OF FURTHER RESEARCH WHEN THE FOUNDATIONS OF HIS POLICY PAPER WERE SCRUTINIZED. HE AGREED UNDER FIRE CONFIDENTIAL CONFIDENTIAL PTQ8285 PAGE 01 ROME 02551 03 OF 03 241547Z ACTION EUR-00 INFO LOG-00 NP-00 AGRE-00 AID-00 AIT-03 AMAD-00 ACQ-00 CEA-01 CIAE-00 COME-00 CTME-00 DODE-00 DOTE-00 PERC-00 SRPP-00 DS-00 EB-00 EXIM-01 E-00 FAAE-00 VC-00 FRB-00 HHS-01 H-01 TEDE-00 INR-00 ITC-01 L-00 VCE-00 AC-01 NSAE-00 OES-01 OMB-01 OPIC-01 PA-00 PM-00 PRS-00 ACE-00 P-00 SP-00 SSO-00 SS-00 STR-00 TRSE-00 T-00 USIE-00 EPAE-00 PMB-00 DSCC-00 DRL-02 G-00 NFAT-00 SAS-00 /014W -------------- B38541 241548Z /38 P 241528Z MAY 02 FM AMEMBASSY ROME TO SECSTATE WASHDC PRIORITY 3907 NSC WASHDC PRIORITY INFO EU MEMBER STATES COLLECTIVE AMEMBASSY VATICAN AMCONSUL FLORENCE AMCONSUL MILAN AMCONSUL NAPLES C O N F I D E N T I A L SECTION 03 OF 03 ROME 002551 SIPDIS STATE FOR SCIENCE ADVISOR NEUREITER, EUR FOR EUR/WE AND EUR/ERA FOR HEN-NIL, EB FOR GADSDEN AND EB/TPP/ATT FOR PEREZ, E FOR SHUB, OES A/S TURNER, STATE PASS USTR FOR STROJE AND NOVELLI, STATE USDA FOR O/S HEGWOOD, FAS/OA TERPSTRA AND SLUTSKY, ITP SHEIK, MACKE, AND EJONES, FAS/FAA/WILSON, AND FAS/OPD BLU, NSC FOR EDSON CONFIDENTIAL PAGE 02 ROME 02551 03 OF 03 241547Z E.O. 12958: DECL: 05/24/2012 TAGS: EAGR ECON IT PREL TBIO ECON IT PREL TBIO ECON IT PREL TBIO WTOEAGR WTOEAGR WTO SUBJECT: ALEMANNO TO SEMBLER: LESS OPEN ON BIOTECH THAT RESEARCH COOPERATION WITH THE U.S. COULD BE A GOOD THING AND COULD HELP CLARIFY SOME OF THE QUESTIONS HIS PAPER RAISES WITHOUT REFERENCE OR CITATION. NO PROGRESSIVE THINKER HERE, BUT WE MAY BE ABLE TO PIN HIM DOWN BY HIS OWN WORDS INTO COOPERATIVE RESEARCH THAT WILL OPEN THE DOORS FOR ITALY'S UNIVERSITY RESEARCHERS AND ORGANIZATIONS, SUCH AS ENEA AND ISS. WE WILL SOON KNOW WHERE ALEMANNO STANDS BY WHETHER HIS BIOTECH RESEARCH ADVISOR CONTACTS US AS PROMISED. ¶12. (C) ALEMANNO IS NOT NEARLY SO OPEN-MINDED TO BIOTECHNOLOGY AS HE ATTEMPTED TO PORTRAY HIMSELF TO THE AMBASSADOR. HIS PUBLIC STATEMENTS AND SPEECHES MORE CLEARLY REFLECT HIS VIEWS ON THE SUBJECT. THE LATEST EXAMPLE WAS ON MAY 21 WHEN ALEMANNO, SPEAKING TO A NAPLES CONFERENCE ON WINE, SAID THAT HE WAS PERSONALLY CONVINCED THAT IT IS A GOOD IDEA TO WED "GMO-FREE" TO QUALITY FOOD. WHAT IS ALSO CLEAR IS THAT HE'S RIDING A WAVE OF SUPPORT FROM THE MARRIAGE OF CONVENIENCE BETWEEN COLDIRETTI (FORMERLY ASSOCIATED WITH THE CHRISTIAN DEMOCRATS),THE GREENS, ANTI-GLOBAL GROUPS, AND SOME CONSUMER ORGANIZATIONS. ARE THEY AS FORMIDABLE AS HE SAYS? WE THINK NOT, BUT THEY CAST A MENACING SHADOW. THEY'VE HAD SUCCESS SIMPLY BY VIRTUE OF THE LACK OF ANY REAL COMPETING VISION ON BIOTECHNOLOGY, ESPECIALLY FROM POLITICAL LEADERS. 13.(C) WE SHOULD NOT UNDERESTIMATE ALEMANNO AND HIS CONFIDENTIAL PAGE 03 ROME 02551 03 OF 03 241547Z DETERMINATION TO ADVANCE HIS POLITICAL CAREER. ALTHOUGH HE KNOWS NEITHER AGRICULTURE NOR SCIENCE (HIS SPECIALTY AND POLITICAL HOBBY HORSE IN THE PAST HAS BEEN LABOR),HE KNOWS POLITICS FROM THE GRASSROOTS TO THE CONSIGLIO. HE HAS USED HIS HOME TIES TO THE PUGLIA REGION AND PARTY CONNECTIONS TO LINE UP SUPPORT FOR HIS WHITE PAPER AMONG REGIONAL AGRICULTURE COMMISSIONERS, AND TO CUT A DEAL WITH SOME NATIONAL ALLIANCE (AN) MEMBERS AND FORMER COMMUNIST REGIONS TO SUPPORT HIS NO-GMO VIEWS (WITH ONLY THE REGION OF LOMBARDIA DISSENTING, AND STRONGLY). HE RECENTLY DISPLAYED HIS AMPLE POLITICAL SKILLS AT THE AN CONGRESS IN BOLOGNA; HIS ONE HOUR SPEECH IN A FIFTEEN MINUTE SLOT GALVANIZED THE PARTY FAITHFUL. HIS MOST TRUSTED STAFF AT MINAG FEEL AT LIBERTY TO ROUTINELY ENGAGE IN VERBAL ATTACKS ON OPPONENTS WITHIN THE GOI'S NATIONAL BIOTECH COMMITTEES WHO DARE TO CRITICIZE THE WHITE PAPER. ¶14. (C) WE SUSPECT THAT BEHIND CLOSED DOORS ALEMANNO SEEKS TO SWAY GOVERNMENT POLICY WITH THE SPECTER OF POPULAR PROTESTS. WE QUESTION THE VIABILITY OF SUCH A STRATEGY, BUT NONETHELESS WE CAN'T AFFORD TO LET HIM PROCEED UNIMPEDED. AT PRESENT THE ONLY COUNTERWEIGHT WE SEE TO ALEMANNO'S STRATEGY IS TO CONVINCE PM BERLUSCONI AND DEPUTY PM FINI THAT ADOPTING ALEMANNO'S PAPER UNCHANGED (WHETHER OUT OF FEAR OF POTENTIAL DEMONSTRATION OR A DESIRE TO AVOID INTERNAL CONFLICT ON THE ISSUE) WOULD CREATE A SUBSTANTIAL IMPEDIMENT TO U.S.-ITALIAN RELATIONS. THE UPCOMING VISITS OF THE PRESIDENT, SECRETARY VENEMAN, U/S LARSON AND OTHERS TO ROME PROVIDE PERFECT OPPORTUNITIES TO ADVANCE OUR INTERESTS. END ANALYSIS AND COMMENT. SEMBLER CONFIDENTIAL PAGE 04 ROME 02551 03 OF 03 241547Z CONFIDENTIAL > 2002ROME02551 - Classification: CONFIDENTIAL