EXTRANCHECK: PRE-LICENSE CHECK: REMARKABLE MASK TECHNOLOGY

UNCLAS HONG KONG 000336

SIPDIS

USDOC FOR 532/OEA/LHINES/ADYSON
USDOC FOR 3132 FOR FCS/OIO REGIONAL DIRECTOR WILLIAM ZARIT
BICE FOR OFFICE OF STRATEGIC INVESTIGATIONS

SIPDIS

E.O. 12958: N/A
TAGS: BMGT BEXP HK ETRD ETTC
SUBJECT: EXTRANCHECK: PRE-LICENSE CHECK: REMARKABLE MASK TECHNOLOGY
COMPANY

REF: A) USDOC 00635 B) D389165


1. Unauthorized disclosure of the information provided below is
prohibited by Section 12C of the Export Administration Act.


2. As per reftel A request and at the direction of the Office of
Enforcement Analysis (OEA) of the USDOC Bureau of Industry and
Security (BIS),Export Control Officer Philip Ankel (ECO),conducted
a pre-license check at Remarkable Mask Technology Company, 7 Dai
Shun Street, Tai Po Industrial Estate, Tai Po, N.T., Hong Kong
(Remarkable Mask). The purpose of the visit was to determine the
suitability of Remarkable Mask to be a recipient of two White Knight
Atloo Pumps that are the subject of export license application
D389165. The items (ECCN 2B350) are valued at USD $15,340 and are
controlled for chemical and biological weapons reasons (CB). The
license applicant is Akrion Inc. of Allentown, Pennsylvania.


3. A Hong Kong Companies Registry check of Remarkable Mask reveals
that the company is registered in 2003 in the Cayman Islands. Hong
Kong residents Cao, Zhong, Chau, Chit and Leung, Shun San Tony are
listed as directors as is Taiwan national Tzu, San Te and mainland
Chinese national Wang, Ning. A review of the Remarkable Mask web
site (www.remarkable.com) reveals that the company was established
with an initial investment of USD 60 million. Remarkable Mask's
parent company, Shougang Concord Technology Holdings Limited was
established in 1983 and is listed on the Hong Kong Stock Exchange.
The company produces photomasks used in semiconductor production.


4. On February 5, 2008, the ECO, accompanied by Commercial
Assistant, Carrie Chan, visited Remarkable Mask at the address
listed above and met with Mr. Tom Chen, Procurement Manager. Mr.
Chen provided a general overview of the company. He stated that the
company's customers are foundries in mainland China, Malaysia,
Taiwan and elsewhere in Asia. Customers include GSMC, HHNEC, ASMC,
X-FAB and PSC.


5. As to the specific items in question, Mr. Chen stated that the
pumps would be used in a cleaning tool used to clear masks after
production. They will be used to replace existing pumps (there are
four total on the cleaning tool). Chen stated that Remarkable Mask
had already received three pumps (pursuant to license) and had
ordered one additional pump. He provided, by subsequent e-mail,
documentation concerning the three pumps already received.


6. Mr. Chen then provided the ECO with a tour of the clean room
where the Akrion Gama Wet Cleaning Tool is located. ECO saw an
Akrion cleaning unit as well as four pumps in operation on the unit.



7. The ECO found Mr. Chen's explanations credible and generally
consistent with information independently obtained by the ECO. ECO
recommends that OEA independently verify that the prior three units
already shipped to Remarkable Mask were all appropriately shipped
under existing licenses.

Cunningham