EXTRANCHECK: POST-SHIPMENT VERIFICATION: INNOVATE

UNCLAS NEW DELHI 000667

SIPDIS

SIPDIS

USDOC FOR 532/OEA/M. NICKSON-D/KGAINES/JHATFIELD
USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL
USDOC FOR 4530/MAC/ANESA/OSA
ICE HQ FOR STRATEGIC INVESTIGATIONS
STATE FOR EB/ESP

E.O. 12958: N/A
TAGS: ETTC ETRD BEXP IN
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: INNOVATE
SOFTWARE SOLUTIONS PVT. LTD., BANGALORE

REF: USDOC 08444


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


2. On November 28, 2007, Export Control Officer (ECO) Paul
Cushman and BIS FSN Prem Narayan conducted a Post-shipment
Verification (PSV) at Innovate Software Solutions Pvt. Ltd.
(ISS),Bangalore.


3. BIS requested a PSV at ISS, a private sector company
located at: #333, 18th G. Main Road, 6th Block,
Koramangala, Bangalore 560095, Tel: 91-80-4110-5384, Fax:
91-80-2553-7138, Email: manjup@innovatesolutions.net,
website: www.innovatesolutions.net. ISS was listed as an
ultimate consignee for three MAJIC II JTAG emulators for
ARM and seven MAJIC-LT JTAG emulators for MIPS (CK-EJ52
Cable Kit) The exporter was Embedded Performance, Inc.
(EPI),Milpitas, California. Export License Number:
GBS/NLR. ECCN: 3A992.


4. ECO and FSN Narayan met with P. Manjunath, Managing
Director and T.K. Anil Kumar, Administration-Manager, ISS.


5. ISS representatives were aware of certain BIS
regulations. However, this was the first visit of BIS
officials to ISS.


6. Manjunath stated that ISS is the authorized distributor
in India for Mentor Graphics, Inc. (MGI) based in
Wilsonville, Oregon. MGI acquired EPI in 2004. He stated
that the commodities on check were sold to the following
six Indian companies:

Analog Devices India Pvt. Ltd., Hyderabad, Andhra Pradesh
Four units bearing serial numbers 501GB015, 501GB016,
501GB018, and 501GB019.

LG Soft India Pvt. Ltd., Bangalore, Karnataka
One unit bearing serial number 504GB017.

LVL Systems Pvt. Ltd., Hyderabad, Andhra Pradesh
One unit bearing serial number 501GB020.

Alumnus Software Ltd., Kolkata, West Bengal
One unit bearing serial number 501GB021.

Ramaiah School of Advanced Studies, Bangalore, Karnataka
One unit bearing serial number 501GB022.

HCL Technologies Ltd., Chennai, Tamilnadu
Two units bearing serial numbers 501GB023 and 501GB024.

Manjunath provided a set of documents reflecting the sale
of all ten units on check. The documents included ISS
Purchase Order, EPI Invoice, Indian Customs Authority EDI
(Electronic Data Interchange),Service Centre Notice for
all ten units, Delivery Challans reflecting that all ten
units were delivered to the companies mentioned above.


7. Manjunath stated that ISS primarily supplies emulators
to computer hardware, telecom equipment, and consumer
electronics manufacturers. The emulators serve as a non-
intrusive tool for inspecting hardware and debugging
software in embedded systems. He stated that they exercise
due diligence to ?know their customer? prior to selling
these products.


8. Established, 2001, ISS is a small company that serves as
agent/distributor for foreign firms. It develops, markets,
and supports engineering solutions for multi-physics
modeling and embedded applications. In addition to the
customers listed above, ISS renders information technology
consulting services for various technology platforms. ISS
also undertakes software projects for the GOI?s Defence
Research and Development Organization (DRDO) laboratories.
ISS? sales turnover for FY 2007 was approximately $895,000.
It has 18 employees.


9. Recommendation: The ten items on check were not
available for inspection, as they had been sold to six
different Indian companies. Based on the interview of the
corporate officers and the documents they provided,
Innovate Software Solutions Pvt. Ltd. appears to be a

reliable recipient of controlled U.S.-origin commodities.
However, because physical verification could not be
accomplished, this check remains inconclusive.
MULFORD