From: To: Cc: Subject: Date: Mosier, Michael Smith, John; Gacki, Andrea; Demske, Susan Blackborow, Davin RE: Greetings from Google! Tuesday, November 17, 2015 1:32:49 PM Sounds very interesting.  I’d love to join if possible, but don’t schedule around me.        From: Smith, John Sent: Tuesday, November 17, 2015 1:09 PM To: Gacki, Andrea; Demske, Susan; Mosier, Michael Cc: Blackborow, Davin Subject: RE: Greetings from Google! Fine by me;   (b)(5) Thanks! From: Gacki, Andrea Sent: Tuesday, November 17, 2015 1:02 PM To: Demske, Susan; Smith, John; Mosier, Michael Cc: Blackborow, Davin Subject: RE: Greetings from Google! No objection here.   From: Demske, Susan Sent: Tuesday, November 17, 2015 1:00 PM To: Smith, John; Gacki, Andrea; Mosier, Michael Cc: Blackborow, Davin Subject: FW: Greetings from Google! John, Andrea, and Mike, Google has asked about coming in on Dec 2 to explain further technical issues relating to the possibility of providing peering and caching services in Cuba. State has asked us to incorporate authorizations for peering and caching services in the CACR. In addition, as you know, the Administration has highlighted the importance of enhancing communications in Cuba as one of its highest priorities. Because peering and caching are highly technical (b) (5) matters, (b) (5) (b) (5) Thanks, Susan and Davin (b) (6) From: Sent: Tuesday, November 17, 2015 12:30 PM To: Blackborow, Davin Cc: Demske, Susan Subject: Re: Greetings from Google! 2018-11-133 000001 Hi Davin and Susan, Please let me know if 12/2 (Wednesday) would work best, so that we can book our tickets. Thanks so much! --(b) (6) (b) (6) On Fri, Nov 13, 2015 at 10:54 AM, wrote: It was great speaking with you both today. I checked in with a couple people on our side, and it looks like 12/2 (Wednesday) would work best. If we could do the meeting in the morning or early afternoon, that would work best for everyone to be able to catch evening flights back to the west coast. Please let me know what time works for you. Thanks and regards, (b) (6) On Thu, Nov 12, 2015 at 9:57 PM, (b) (6) wrote: Thanks, Davin. I will call you tomorrow at that number. Best regards, (b) (6) On Thu, Nov 12, 2015 at 6:03 PM, wrote: (b) (6) (b)(6) or alternatively, we could also do Monday at 3pm You can feel free to call eastern, 12pm pacific. Just let us know. Thanks, Davin (b)(6) From: Sent: Thursday, November 12, 2015 5:38 PM To: Blackborow, Davin Cc: Demske, Susan Subject: Re: Greetings from Google! Hi Davin, Please let me know what number to call you on at 7am tomorrow (Friday). Thanks, (b)(6) 2018-11-133 000002 On Wed, Nov 11, 2015 at 2:21 PM, wrote: Hi Davin, (b)(6) Is there any other time that works this week for you? If not, we can stick to the 7am time this Friday. Thanks, (b)(6) On Tue, Nov 10, 2015 at 12:55 PM, wrote: Hi Davin, (b)(6) If there is any other time that works for you this week, that would be great. I have young kids so 7am tends to be "rush hour" at my place, but if that's the only time that works this week for you, I will make it work. Thanks again, (b)(6) On Tue, Nov 10, 2015 at 11:34 AM, wrote: Sorry for being unclear – I meant 10 AM east coast, which I realize is quite earlier for you. If that doesn’t work, we can reschedule for next week. (b)(6) From: Sent: Tuesday, November 10, 2015 2:25 PM To: Blackborow, Davin Cc: Demske, Susan Subject: Re: Greetings from Google! Hi Davin, Did you mean 10am PDT or EDT? If Pacific, 10am definitely works on Friday for me. I will definitely check in internally to see if it makes sense to consolidate the discussion with State. Thanks so much, (b)(6) On Mon, Nov 9, 2015 at 8:23 AM, wrote: (b)(6) We are free on Friday at 10:00 if that works for you. In addition, State informed us that they had been speaking with someone from Google Ideas regarding some Cuba issues. I’m not sure if these are the same issues that you’re interested in discussing but wanted to raise it in case we can consolidate into one discussion. Please let us know if this works. 2018-11-133 000003 Thanks, Davin (b)(6) From: Sent: Friday, November 06, 2015 6:51 PM To: Blackborow, Davin Cc: Demske, Susan Subject: Re: Greetings from Google! Hi Davin, Sorry to pester on this as I know you must be bombarded with requests on Cuba. But, if possible, it would be great if we could do a call early next week and/or set a time for us to meet with you and Susan in DC. As I noted previously, we would love the opportunity to just walk through a presentation on peering and caching in person with you (building much more on what we summarized in our last meeting back in April with you) and discuss some of the steps we'd like to take in this endeavor. With the holidays coming up, I just want to make sure that we have a chance to discuss this project with you before moving down any paths. Thanks so much for your time, and I look forward to chatting with you. Best regards, (b)(6) On Tue, Nov 3, 2015 at 1:24 PM, wrote: Hi Davin, (b)(6) I just realized that I did not give you any available times for this week (past Tuesday). Would anything between 1 and 5pm your time tomorrow (Wednesday) work for you? I also have time between 12 and 5 your time on Thursday. Please let me know what works best for you. Thanks and best regards, (b)(6) On Thu, Oct 29, 2015 at 2:52 PM, wrote: Hi Davin, (b)(6) Thanks so much for getting back to me. I'm sorry for the delay--I was traveling all of last week and got very behind on email. Given the technical nature of the project (details regarding peering and caching), we were thinking that walking through a presentation on the topic might work best which is why we thought an in person meeting might be the most effective. Should we set up a preliminary call just so I can give you a brief description of what we would like to discuss with you, and then, we can see if an in person meeting might be desirable? If that works, some times that 2018-11-133 000004 would work for me would be tomorrow morning (Friday) Pacific time as well as next Tuesday any time between 10 and 12:30 Pacific time. Would either of those windows work for you? Thanks, (b)(6) On Wed, Oct 21, 2015 at 7:09 AM, wrote: (b)(6) Sorry for the delay in responding and thank you for your email. Rather than meet, we think that it would be better to set up a conference call to discuss the project that you reference below. Any written materials that you can send in advance of the call would be helpful and greatly appreciated. Please let us know if there are particular days/times over the next week or two that would work. Thanks again. Regards, Davin (b)(6) From: Sent: Tuesday, October 20, 2015 4:16 AM To: Blackborow, Davin; Demske, Susan Subject: Re: Greetings from Google! Hi Davin and Susan, I just wanted to check in with you both to see if you had had a chance to review my email below. Thanks so much, (b)(6) On Tue, Oct 13, 2015 at 5:02 PM, wrote: Hi Davin and Susan, (b)(6) I hope you both are well! We found our last meeting to be extremely helpful in providing us with guidance on questions we had on the new Cuba regulations. I am writing to see if we might be able to set up some time again with you to meet and discuss in person a specific project we are currently considering in Cuba. Specifically, we would like to have one of our technical experts present a summary of the specific services we are considering and have a short session with you to discuss what authorizations we might need. We can also send you some materials beforehand if that would be helpful. Please let me know if you would be amenable to a meeting and, if so, what dates would work best for you both. Thanks so much and best regards, (b)(6) -2018-11-133 000005 Demske Susan Blackborow Davin RE: Greetings from Gooqle! Wednesday, November 18, 2015 9:36:40 AM Yes. December 2 will work. We will propose 1021111 for the meeting should that work for your folks? Susan Duplicate of Page 2 2018-11-133 000006 2015-10-119 006 Duplicate of page 2 Duplicate of page 3 From: To: Subject: Date: Demske, Susan Blackborow, Davin; (b) (6) RE: Greetings from Google! Monday, November 09, 2015 9:56:23 AM Thanks Davin!  Tomorrow afternoon might be best for me, but I could also do between 12-3 on (b) (6) Thursday, and anytime Friday morning.  I am looping in as it would be great if they could participate.    From: Blackborow, Davin Sent: Saturday, November 07, 2015 9:35 AM To: Demske, Susan Subject: FW: Greetings from Google!   Not sure when you’re free to meet – just let me know and I can respond (or feel free to respond if you’d prefer).  Thanks, Davin   Duplicate of page 4 2018-11-133 000008 From: To: Cc: Subject: Date: Demske, Susan (b)(6) Blackborow, Davin Re: Time for someone to meet with us next week?? Tuesday, April 28, 2015 2:11:34 PM (b)(6) (b)(6) One of us will meet you in the lobby at 330 but please also feel free to call me at when you arrive. Susan (b)(6) From: Demske, Susan Sent: Monday, April 27, 2015 04:21 PM (b)(6) To: (b)(6) Cc: ; Blackborow, Davin Subject: RE: Time for someone to meet with us next week?? Not at all. Thanks very much. Susan (b)(6) From: Sent: Monday, April 27, 2015 4:20 PM To: Demske, Susan (b)(6) Cc: Blackborow, Davin Subject: Re: Time for someone to meet with us next week?? Hi Susan, I apologize for the delay. Please find the information below: (b)(6) Country of Citizenship: USA (b)(6) Country of Citizenship: USA (b)(6) Country of Citizenship: USA Best regards, (b)(6) On Mon, Apr 27, 2015 at 12:47 PM, wrote: (b)(6) I just wanted to check in to see if you might be able to provide the clearance information requested 2018-11-133 000009 today? The Secret Service asks that it be provided a day in advance to ensure there are no delays with clearance into the building. Again, it would be name, date of birth, social security number, and country of citizenship for anyone attending. Thanks, Susan From: Demske, Susan Sent: Monday, April 27, 2015 10:24 AM (b)(6) To: (b)(6) Cc: Blackborow, Davin Subject: RE: Time for someone to meet with us next week?? (b)(6), Apologies for the delay in responding. Yes, we have confirmed that Tuesday at 330 will work. We will need the following information from anyone who will be attending the meeting in order to clear you into the building: name, date of birth, social security number, and country of citizenship. (b)(6) If you prefer, please feel free to give me a call with the information at Thanks, Susan Susan Demske Assistant Director for Regulatory Affairs Office of Foreign Assets Control U.S. Department of the Treasury (b)(6) (o) (b)(6) From: Sent: Thursday, April 23, 2015 4:56 PM To: Demske, Susan (b)(6) Cc: ; Blackborow, Davin Subject: Re: Time for someone to meet with us next week?? Hi Susan, Would you be available at 3:30pm on Tuesday to meet? Best regards, (b)(6) On Wed, Apr 22, 2015 at 11:34 AM, wrote: (b)(6) We would be available to meet with you next week. Tuesday might be preferable for us at 930am, 11am, or 3pm? If those won’t work, we could look at other times Monday morning or later in the week. 2018-11-133 000010 Please let us know what works for you. Susan Susan Demske Assistant Director for Regulatory Affairs Office of Foreign Assets Control U.S. Department of the Treasury (b)(6) (o) (b)(6) From: Sent: Tuesday, April 21, 2015 3:27 PM To: Blackborow, Davin (b)(6) Cc: Demske, Susan; Subject: Re: Time for someone to meet with us next week?? Thanks so much, Davin.    Following from my initial discussions with ETECSA, we have a few questions regarding the application of the telco general license for Cuba. We also have a (b) (4) (b) (4) application we are putting together but b/c we have a (b) (4) number of scenarios for how to structures these, especially some of which might not be feasible from your perspective, it would be good to consult a bit before hand.  I'm cc'ing (b)(6) who can add anything I may have missed. In any case, it would be REALLY great if we could meet with you, even for an hour, while we're in town next week. Again, we're happy to work with your schedules. All best, (b)(6) On Tue, Apr 21, 2015 at 12:14 PM, wrote: (b)(6) Thank you for your email regarding a potential meeting with OFAC. OFAC generally seeks a written request detailing the topics/subject matter that you would propose to discuss, so that we can better evaluate whether a meeting would be helpful. If you don’t mind, sending us such information will allow us to better evaluate Google’s meeting request. I will be out of the office later this week, so please copy both Susan Demske and me on any response, and please don’t hesitate to reach out if you have additional questions. Regards, Davin (b)(6) From: Sent: Monday, April 20, 2015 8:05 PM To: Szubin, Adam Cc: Smith, John; Blackborow, Davin; Gacki, Andrea Subject: RE: Time for someone to meet with us next week?? 2018-11-133 000011 Thanks so much, Adam, and congratulations! Not sure how I missed that! John, Andrea and Davin, it's a pleasure to "meet" you. Per my email to Adam, if you'd have time to meet with (b)(6) and me sometime next week we'd be grateful. Please let me know and thanks again! sent via HTC One; please forgive typos On Apr 20, 2015 7:35 PM, wrote: HI (b)(6), I’m sorry that you’ve been having trouble. I’ve taken over David Cohen’s spot on an acting basis, but am copying John and Andrea who are running the show at OFAC now, as well as Davin Blackborow, who’s the head of OFAC’s licensing office. They will be best positioned to direct you as to the best way forward. Many thanks, Adam (b)(6) From: Sent: Monday, April 20, 2015 7:01 PM To: Szubin, Adam Subject: Time for someone to meet with us next week?? Hi Adam, I trust this email finds you well. I've resisted reaching out to you till now but apparently we're having an inordinately difficult time getting anyone to answer the phone, so to speak, related to questions we have on Cuba. (b)(6) I'm going to be in town next Monday and Tuesday and our export compliance counsel, will be in town the whole week.  Is there any way we could find a time to sit down with you or someone on your team to get your feedback on a number of Cuba-focused initiatives we're considering prior to submitting a license application?  In the past such informal consultation has been invaluable to helping us navigate the complexity of the regs.  Please let me know what you think.  If you're available, we'll do whatever we need to do to accommodate your schedule. Thanks and hope to see you soon! (b)(6)   -(b)(6) Director, Free Expression, Google Ideas (b)(6) Follow me on Twitter -2018-11-133 000012 From: To: Cc: Subject: Date: (b)(6) Demske, Susan (b)(6) Blackborow, Davin Re: Time for someone to meet with us next week?? Monday, April 27, 2015 10:54:27 AM Sorry, all.  I hadn't see (b)(6) earlier response.  Let's stick to the original 3:30 timing. (b)(6) Duplicates of pages 010 and 011       2018-11-133 000013 Duplicate of page 001 Duplicate of page 002 From: (6) To: (bll6) Subject: RE: Supplemental Infornia?on Request for Google Application: CT -2014-309634-1 GOOGLE Date: Wednesday, June 25, 2014 5:41:00 PM Attachments: Licensegf License attached for the researchers. A license is not required for ?ight crew who ?y in and drop off travelers and then return to Cuba to pick them up. That falls under a general license of ours related to exports authorized by Commerce. in this case. the aircraft. We don?t issue speci?c licenses to ?ight crew to stay and engage in travel- related transactions in Cuba. On' inal Message-m- From: Sent: Wednesday. June 25. 2014 4:45 PM To: (6) Subject: Re: Supplemental Information Request for Google Application: GOOGLE Thank you. On Jun 25. 2014. at 4:31 PM. (6) wrote: Thank you. Message From: Sex me 25.2014 4:30 PM To: Subject: Fwd: Supplemental Information Request for Google Application: CT-2014-309634-1 GOOGLE (b This is great news. We provided expertise smmnaries for each. but not a full bio or CV. They are attached here for each researcher. Please let me know if you need anything further. Thank you so much for your assistance. We remain hopeful that the trip will be able to take place tomorrow. Best regards. (W6) On Jim 25. 2014. at 4:08 PM. I am conducting the ?nal review of the Google Cuba travel application you submitted. (6) 3 out the rest question so rather than wait for him to provide me the answer so I can move on this now. can you advise whether you included the resumes or or the 4 travelers conducting research? Thanks. Chief. Licensing Division 2018-11-133 000015 2015-10-119 015 >> Office of Foreign Assets Control >> U.S. Department of the Treasury >> (b)(6) >> From: >> Sent: Wednesday, June 25, 2014 11:56 AM (b) (6) >> To: (b)(6) >> Cc: >> Subject: RE: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> Hello again, Mr (b) (6) >> >> I appreciate your call yesterday afternoon.    We are awaiting any update you can provide to, hopefully,  keep (b)(6) as soon as you have this trip on schedule for tomorrow.  Please send us an email or give me a call at something to report. >> >> Again, we appreciate your efforts and hope to hear good news from you soon. >> >> Best regards, >> (b)(6) >> (b)(6) >> From: >> Sent: Tuesday, June 24, 2014 2:26 PM (b) (6) >> To: (b)(6) >> Cc: >> Subject: RE: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> Hi Mr. (b) (6) >> >> Thank you for returning my call yesterday.  We are following up on the status of this license application.  As you know, the trip is scheduled to begin on June 26 (this Thursday), and if it is necessary to cancel the trip due to the lack of a specific license for the travelers, we would need to do so tomorrow.  Please let us know if there is any way to get this license approved today or tomorrow so that the trip can proceed as scheduled. >> >> We understand and appreciate that the OFAC Licensing Division is moving quickly.  Had we know that the Licensing Division did not agree with the use of the General License for the travelers (as we discussed with OFAC's Chief Counsel's Office months ago), we would have certainly submitted the application for specific license earlier.  We sincerely appreciate your willingness to work with us and hope that this trip can move forward as scheduled. >> >> Best regards, >> (b)(6) >> (b)(6) >> From: >> Sent: Friday, June 20, 2014 2:38 PM (b) (6) >> To: (b)(6) >> Cc: >> Subject: RE: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> Thank you very much.  I await your call with a projected timeline as soon as possible.  You may reach me at (b)(6) >> >> Best regards, >> (b)(6) >> >> From: (b) (6) (b) (6) >> Sent: Friday, June 20, 2014 2:09 PM (b)(6) >> To: 2018-11-133 000016 (b)(6) >> Cc: >> Subject: RE: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> Dear Sir/Mam, >> >> Thank you for your response to our request for information.  Your response has been added to the case file CT2014-309634-1 and your application remains in process with OFAC's Licensing Division at this time.  If further information is required you will be contacted. >> >> Thank you for your time and cooperation on this matter.  Please feel free to consult OFAC's various sources of information available electronically (Internet Address: www.treasury.gov/ofac) and contact us by phone: ((202) 622-2480) or email with any further questions. >> >> Best, >> (b) (6) >> >> US Department of the Treasury >> Office of Foreign Assets Control >> Licensing Examining Officer >> (b)(6) >> From: >> Sent: Friday, June 20, 2014 2:05 PM (b) (6) >> To: (b)(6) >> Cc: >> Subject: RE: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> Mr. (b) (6) >> >> Per our discussion, please consider this email as our request to add the four researchers referenced in CR-2014309634-1 to the specific license application under 515.564(b).   The following four travelers will be conducting professional research:  Eric Schmidt, Jared Cohen, Brett Perlmutter, and Daniel Keyserling.  The materials we have provided should supply all of the information required under the regulations.  If you require any additional information, please contact us as quickly as possible. >> >> As we discussed, this group is scheduled to travel next Thursday.  We hope that, given the fact that Google has been in coordination with OFAC for several months regarding this transaction and the change in OFAC's position regarding our use of the professional research General License, OFAC will consider moving forward quickly so that this important trip can move forward. >> >> We look forward to hearing from you soon. >> >> Best regards, >> >> >> >> Partner >> Export Controls and Economic Sanctions Group >> >> Wilson Sonsini Goodrich & Rosati >> Professional Corporation >> >> 1700 K Street, NW  5th Floor >> Washington, DC  20006-3817 (b)(6) >> Direct Tel: >> Fax: (202) 973-8899 (b)(6) >> E-mail: >> www.wsgr.com (b)(6) 2018-11-133 000017 >> >> _____________________________________________ (b)(6) >> From: >> Sent: Tuesday, June 17, 2014 4:35 PM (b) (6) >> To: (b)(6) >> Cc: >> Subject: Supplemental Information Request for Google Application: CR-2014-309634-1 >> >> >> Dear Mr. (b) (6) >> >> Per  your request, we are attaching a letter detailing how the Google employees satisfy the requirements to use the General License for Professional Research and a copy of the itinerary.  As we discussed by phone, we did discuss the use of this General License with the Office of Chief Counsel prior to our submission of the pending application for the flight crew. >> >> We are happy to address any additional questions you may have.  Please do not hesitate to contact us with any questions. >> >> With best regards, >> (b)(6) >> >> << File: 06-17-2014 OFAC CR 2014 309634-1 Suppl Letter.pdf.pdf >>  << File: Google Ideas Itinerary.pdf >> >> (b)(6) >> >> Partner >> Export Controls and Economic Sanctions Group >> >> Wilson Sonsini Goodrich & Rosati >> Professional Corporation >> >> 1700 K Street, NW  5th Floor >> Washington, DC  20006-3817 (b)(6) >> Direct Tel: >> Fax: (202) 973-8899 (b)(6) >> E-mail: >> www.wsgr.com >> >> *       *       * >> This electronic message contains information which may be legally confidential and/or privileged. The information is intended solely for the individual or entity named above and access by anyone else is unauthorized. If you are not the intended recipient, any disclosure, copying, distribution, or use of the contents of this information is prohibited and may be unlawful. If you have received this electronic transmission in error, please reply immediately to the sender that you have received the message in error, and delete it. Thank you. >> >> >> >> >> >> >> This email and any attachments thereto may contain private, confidential, and privileged material for the sole use of the intended recipient.  Any review, copying, or distribution of this email (or any attachments thereto) by others is strictly prohibited.  If you are not the intended recipient, please contact the sender immediately and permanently delete the original and any copies of this email and any attachments thereto. > 2018-11-133 000018 1700 Street. NW. Fifth Floor Washington. DC. 20006?3817 35:7wa 11301.: 501131111 CY. ?jilf'fii?ll. 1. 20,) 973 8800 I :l . .. we?. 1.54 was I: I: J: ms 202.973.8899 ?v'ur' Vt." . SIT . at June 17,2014 Licensing Division Office of Foreign Assets Control US. Department of the Treasury 1500 Avenue, NW. Washington, DC. 20220 RE: Supplementary Information for Application Number CR-2014-309634-1: Quali?cations for a General License Under 3 515.564(a) Dear Mr. Brodell: On behalf of Google Inc. (??Google? or ?the Company?), we are submitting the requested supplementary information outlining Google?s use of General License As part of a Google Ideas initiative, four Google Employees plan to engage in travel?related transactions in Cuba for the purpose of researching how the Company, individuals, and organizations can better promote positive social change via the internet in Cuba. The research is non-commercial and academic in nature. Google Ideas is a think/do tank that explores how technology can enable people to confront threats in the face of conflict, instability or repression. Again, the goal of the initiative is to understand the ability of the Cuba people to use the Internet as an effect tool for positive social change, and for that reason, there is no commercial purpose for this travel. The researchers attending this trip have carried out similar trips in other countries throughout the world, and these trips have informed Op?Eds and a book on these topics. 1. Organizational Information Google?s mission is to organize the world?s information and make it universally accessible and useful. Google?s website provides information in many different languages and allows a user to check stock quotes, maps, and news headlines; lookup phonebook listings for every city in the United States; search billions of images; and peruse the world?s largest archive of Usenet messages more than 1 billion posts dating back to 1981. Google is not an ordinary company, nor does it intend to become one. Google is dedicated to ?nding ways for technology to help people to confront threats in the face of instability and repression. Google Ideas is a think/do tank that explores how technology can enable people to confront threats in the face of conflict, instability or repression. Google Ideas connects users, experts and engineers to research and seed new technology?driven initiatives. i \l intuit} LIJH 31.1.1 -- 2.2: 1-. 2018-11-133 000019 Licensing Division Office of Foreign Assets Control June 17, 2014 Google Ideas was founded on the principle that the next five billion to come online will face far greater human challenges than the first two billion. Many of these challenges are thorny and difficult to address, and include violent extremism and fragile states, among others. Through events online and of?ine, Google Ideas brings people with a diverse range of expertise and experience together. Google Ideas works to find new ways that connected technologies can offer solutions to people caught in these circumstances, use research to provide fresh insights and develop interactive data visualizations to bring information to life. Google Ideas is not a revenue generating division of Google. Google Ideas does not make products to sell. The work is open?sourced, and is it dedicated to empowering minority rights and enshrining free speech. II. Analysis The use of the General License for professional research outlined in 31 CPR. 515.564(a) requires a full work schedule of noncommercial, academic research that has a substantial likelihood of public dissemination and is in the traveler?s professional area. Google, through its think tank Google Ideas, plans to engage in travel?related transactions in Cuba for the purpose of researching how the Company and individuals can better promote positive social change via the Internet. Additionally, the researchers would like to promote a healthy dialogue between the government, Cuban citizens and organizations with a goal of further opening up Internet communication. After conducting this research, the individuals plan to publish speci?c recommendations and suggested next steps in line with this goal. This research also does not benefit the Government of Cuba or the infrastructure of Cuba in any way. It would simply help support the spread of democratic principles and the availability of more free communications for Cuban citizens. The researchers attending this trip have carried out similar trips in other countries throughout the world, and these trips have informed Op-Eds and a book on these topics. A. Full Work Schedule The team will have a full work schedule during the trip. The trip will be from June 26 June 28. B. Non-Commercial and Academic Research The research is non?commercial and academic in nature. The proposed travel is an initiative of Google Ideas which is a think/do tank that explores how technology can enable people to confront threats in the face of con?ict, instability or repression. A goal of Google Ideas is to connect users, experts and engineers to research and seed new technology-driven initiatives. Google Ideas is not a revenue?generating division of 2018-11-133 000020 licensing Division Of?ce of l?oreign Assets Control June I7. 2014 Google and is not a commercial enterprise. It does not sell any products or services. Instead. it is a group wholly dedicated to helping others use technology to overcome con?ict. instability and repression. During this visit. the researchers are hoping to better assess the technical capabilities of organizations and individuals in Cuba to conduct social change and human rights activities via the Internet. speci?cally democracy. empowerment through speech. freedom of expression, human and civil rights, relicl? aid. promotion ol~ health and peace- inspired themes. Additionally. the researchers would like to promote a healthy dialogue between the government and these individuals and organiyations in order to promote more open Internet communication. ?l?here is no commercial purpose for this travel. and (iooglc has no plans to conduct any business activities while in (?uba 'l?he individuals travelling to Cuba will carry out this research by conducting (4 meetings to: The Internet is a valuable tool that can be used to give a voice to those who may not otherwise have the opportunity to express themselves. 'l?he Internet, as the biggest social interface to-date, is advancing dialogue. debate and consensus through communication making it an effective tool for social change. (ioogle Ideas is not a revenue generating division ol?(ioogle. Google Ideas does not make products to sell. 'l?he work is open-sourced. and is it dedicated to empowering minority rights and enshrining free speech. The ?moonshot? ol?Uoogle Ideas is to end repressive censorship. Nearly a third ol? the world lives under some form of repressive surveillance or outright censorship. In many places. governments control what people can say. who gets punished lor expressing an unpopular opinion, and what political opinions are permissible. 'l?he Googlc Ideas team seeks to end that. \one ot?thesc goals have commercial value. 2018-11-133 000021 2015-10-119 021 Licensing Division Office of Foreign Assets Control June 17, 2014 Google personnel and Google Ideas personnel have made similar trips to Afghanistan, Pakistan, Chad, Ivory Coast, North Korea, and Rwanda. In all of these trips, and in this Cuba trip, the goal is to better understand the state of technology in each country, and to advocate for a free and open internet. Google has little to no presence in each of these countries, and in each case our interest was purely humanitarian and academic. Several of these trips lead to published editorials, and the collective experience of traveling to some of the most repressive and violent places in the world informed the content of Eric and ared?s book, The New Digital Age. The purpose of that book is to better understand how technology is changing the way that people relate to their governments, how their governments wield power, and how businesses can transform the way they operate. The book?s content, and the research that informed it, had no commercial purpose. In this speci?c case of Cuba, Google has no commercial interest. Rather, the interest is in learning more about the state of connectivity on the island (which is grim), how normal people use the internet as they find it, and what the government?s priorities are regarding telecommunications regulation in the near future. The purpose of this trip is to understand this autocratic and ghastly approach to free speechdismantle it. Google asks these questions not because Google has commercial interests in any of the answers, but because they are the most important questions to ask of an autocratic regime, and because Google is among the few institutions in the world equipped to ask them. These questions are important because they help the world to understand that a seemingly global public good, the intemet, is actually a fragile collection of networks around the world that have varying degrees of security and freedom. The interest in this phenomenon security and identity which may be one of the most pressing geopolitical questions ofthis decade, is whether, as a society, we are comfortable with the internet becoming a fractious marketplace whereby certain content is permitted and others banned. None of these goals have any commercial value, but they have massive implications. C. Substantial Likelihood of Public Dissemination The result of the research will be disseminated publicly. After the trip, the researchers plan to publish recommendations on next steps to promote such a dialogue. They intend to jointly author an Op-Ed piece on what they have learned during the trip. As you will see below, each team member will contribute substantively to this written piece. Similar trips resulted in the publication of a book entitled The New Digital Age and other Op-Eds. 2018-11-133 000022 Licensing Division Of?ce ol? Foreign Assets Control June 17. 2014 I). 'l?ravelers? Professional Quali?cations This research falls squarely within each traveler?s professional specialties. The individuals traveling will be: Eric Schmidt, Jared Cohen, Brett l?erlmutter. and Daniel Keyserling. Mr. Schmidt and Mr. Cohen wrote a related book entitled The New Digital Age that addresses very similar topics. Mr. Schmidt and Mr. Cohen have been on various trips to other countries to promote freedom and free communications and other related topics. Mr. l?erlmutter is an expert in Latin American studies, having obtained his Masters of Philosophy from the University ol? Cambridge. in Latin American Political Economy and has spoken at international conferences in this area. He also Mr. Keyserling was the Deputy Communications Director for a non-partisan think tank, provided regular contributions to Larry Sabato?s Ball, political analysis blog, edited books. and wrote press released and daily memos for the New York Times. He will be key in the dissemination ot'the results of the academic research arising from this trip. If you have any questions. please feel free to contact the undersigned at 202-973- Counsel for Google, Inc. 8800. 2018-11-133 000023 2015-10-119 023 PROGRAMA GENERAL DE LA VISITA Jueves 26 10:45 Llegada al Aeropuerto Internacional José Martí. Recibimiento en el aeropuerto por funcionarios de ETECSA.  Arrival at José Martí International; Reception by representatives from ETECSA (Note: this is the Cuban telecom) 12:00 Alojamiento en el hotel Nacional.  Accommodation in the Hotel Nacional 13:00 Almuerzo de cortesía ofrecido por ETECSA.  Lunch offered by ETECSA 15:00 Reunión de trabajo con ETECSA.  Work meeting with ETECSA 16:30 Presentación e intercambios en la empresa de Tecnologías de la Información y Servicios Telemáticos Avanzados (CITMATEL).  Presentation and exchange at CIMATEL (Information Technologies and Advanced Telematic Services) [Note: this is the Cuban ISP] 18:00 Regreso al hotel.  Return to the hotel 20:00 Cena en el complejo Morro Cabaña.  Dinner at the Morro Cabaña Complex (Note: this is the Spanish fortress that was seized by the Cuban Revolution, marking their taking of Havana; it served as a temporary HQ for the Revolution and military prison) Viernes 27 08:30 Visita al Centro de Datos Públicos de ETECSA.  Visit to the ETECSA Public Data Center 10:00 Visita al Centro de Investigaciones Tecnológicas del Instituto Superior Politécnico “Jose Antonio Echeverría”.  Visit to the Center of Technologic Reporting of the Superior Polytechnic Institute “José Antonio Echeverría” [NOTE: This is an engineering and technology university in Havana] 12:30 Almuerzo.  Lunch 14:30 Presentación e intercambios en el Centro Nacional de Información de Ciencias Médicas (INFOMED). 2018-11-133 000024 Presentation and exchange at the National Center of Information of Medical Sciences (INFOMED) [NOTE: This is their online medical database service] 16:30 Presentación e intercambios en el Proyecto Comunitario Joven Club.  Presentation and exchange at Community Project Youth Club [NOTE: This is the body that manages the public “internet cafes”] 18:00 Regreso al hotel. Cena.  Return to the hotel. Dinner.  Sábado 28 09:00 Visita a la Universidad de las Ciencias Informáticas (UCI)  Visit to the University of Information Sciences (UCI) [Note: this is the technology university, just outside of Havana. It played an important role in the attempt to create a domestic Linux-based OS that never really took off.] 12:30 Despedida en el Aeropuerto José Martí por funcionarios de ETECSA.  Goodbye at José Martí International by representatives of ETECSA 13:00 Regreso a Estados Unidos  Return to the US 2018-11-133 000025 From: To: Subject: Date: (b)(6) Gacki, Andrea; Sens, Andrew; Google Cuba travel request Wednesday, May 21, 2014 11:49:39 AM (b) (6) Just an fyi in case we get any calls about this, not that I have information we will, but I am assigning this Google travel request to (b) (6) They want a license to take their own flight crew to Cuba to do research.  We don’t license flight crew. They can’t stay in Cuba. 533 GL incident to Commerce license for aircraft allows plane to go in and come out but we do not license the crew to engage in extra travel-related transactions to stay overnight, for example. The real issue may be that we have to determine whether their research falls under the gl or needs a specific license.    (b) (6) process in turn.   Just an fyi. (b)(6) Case ID: Primary Owner: CT-2014-309634-1 (b) (6) Status: Assigned Actual Party: Google Inc. 05/13/2014 Case Type: License Application Request Date Received: Program: Cuba Travel Case Open Date: 05/21/2014 Category: Cuba Travel Case Close Date: Subcategory: 564 Professional Research/Meetings Determination: Expiration Date: Notes: 05/21/2014 - On behalf of Google Inc. (“Google” or “the Company”), we request a specific license under 31 CFR § 515.564(b) for members of a flight crew to engage in travel-related transactions in Cuba by transporting three Google employees traveling to Cuba on a General License under 31 CFR § 515.564(a). The three Google employees traveling under the General License will be researching how the Company and individuals and organizations can better promote positive social change via the Internet. An editorial will be published after the trip. For security reasons, Google prefers to use its own flight crew instead of those of an authorized Carrier Service Provider (“CSP”). The flight crew   2018-11-133 000026 DEPARTMENT OF THE TREASURY WASHINGTON, D.C. 20220 17m Cuban Assets Control Regulations License No. CU-2013-301218-2 AMENDED LICENSE (Granted under the authority of 50 U.S.C. App. 22 U.S.C. 2370(a). 22 U.S.C. 6001 et seq.. Proclamation 3447. and 31 C.F.R. Parts 501 and 515) To: Google Inc. c/o Wilson Sonsini Goodrich Rosati 1700 Street, NW Fifth Floor Washin ton DC 20006-3817 m: him? 1. Pursuant to your letter dated January 9, 2015, on behalf of Google Inc.. to the Of?ce of Foreign Assets Control (the ?Application?), the transactions and activities delineated herein are hereby authorized. This license supersedes License in all respects. SEE PAGE 2 2. This license is granted upon the statements and representations made in the Application. or otherwise ?led with or made to the Treasury Department as a supplement to the Application. and is subject to the conditions. among others. that the Licensee comply in all respects with all regulations. rulings. orders and instructions issued by the Secretary of the Treasury or his designees 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 of?cer or agency of the Secretary. 4. This license expires on May 31, 2017. 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?ed at any time at the discretion of the Secretary of the Treasmy 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 authonzed agent. it may. in the discretion of the Secretary of the Treasury or his designees. 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 (including reporting requirements) administered by the Of?ce of Foreign Assets Control or another agency applicable to the transactions(s) herein licensed. nor does it release Licensee or third parties ?om civil or criminal liability for violation of any law or regulation. Issued on behalf of the Secretary of the Treasury: OFFICE OF FOREIGN ASSETS CONTROL (6) M01 015 Andrew Sens Chief. Licensing Division [Attention is directed to 18 U.S.C. 1001. 50 U.S.C. App. 16. 31 .F.R. 501.701 et seq. and 31 .F.R. 515.701 et seq. for provisions relating to penalties] 2018-11-133 000027 2015-10-119 027 License No. CU-2013-301218-2 Licensee: Google Inc. Page 2 of 2 SECTION 1 – AUTHORIZATION: (a) Subject to the conditions and limitations stated herein, Google Inc. (the “Licensee”) is hereby authorized to engage in those transactions otherwise prohibited by the Cuban Assets Control Regulations, 31 CFR Part 515, that involve the participation of a citizen, national, or permanent resident of Cuba who is neither a prohibited official of the Government of Cuba nor a prohibited member of the Cuban Communist Party, as such terms are defined, respectively, in 31 C.F.R. 515.337 and 515.338, in international software coding contests sponsored by the Licensee, including: • • • awarding cash prizes of up to USD 25,000 and remitting the cash prize(s) to the national of Cuba in Cuba; paying for travel and accommodations to participate in onsite events at a regional Google office in thirdparty countries; and, (b) (4) providing to successful participants, as described in the Application. (b) Any transfer of funds through the U.S. financial system pursuant to the authorization set forth in paragraph (a) hereof should reference the number of this license to avoid the blocking or rejection of the transfer. Authority: 31 C.F.R. § 515.801. SECTION 2 – CONDITIONS: It is a condition of this license that any payment of travel expenses from Cuba to the United States on behalf of a successful participant arranged by the Licensee in conjunction with the Authorization in Section 1 above must be effected in a manner consistent with 31 C.F.R. § 515.571. SECTION 3 – WARNINGS: (a) Except as authorized in Section 1 above, nothing in this license authorizes any 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. (b) This license does not authorize the export of any goods, technology, or commodities to Cuba. An export license or other authorization issued by the U.S. Department of Commerce pursuant to the Export Administration Regulations (15 C.F.R. Parts. 730 et seq.) is required for this purpose. For questions relating to the licensing requirements for the exportation of items from the United States to Cuba, please contact the U.S. Department of Commerce’s Bureau of Industry and Security at (202) 482-4811. SECTION 4 – RECORDKEEPING AND REPORTING REQUIREMENT: The Licensee shall keep a record of all transactions entered into pursuant to this license. Such records shall be made available for examination upon demand for at least five years from the date of each transaction. Such records shall clearly demonstrate the applicability of the authorization set forth in Section 1 hereof. (See 31 C.F.R. §§ 501.601 and 501.602). SECTION 5 – PRECEDENTIAL EFFECT: The authorization contained in this license is limited to the facts and circumstances specific to the application. ***************************************************************************************** 2018-11-133 000028 NW, Fifth Floor- Washington, DC. 20006-3817 Wilson Sonsml Goodrich 8L Rosatr mm 202.973.8800 PROFESSIONAL CORPORATION FAX202973.8899 ww.wsgr.mm Internet: Direct Dia January 9, 2015 PRIVILEGED AND CONFIDENTIAL CONTAINS BUSINESS PROPRIETARY INFORMATION NOT SUBJECT TO RELEASE UNDER FOIA BY HAND AND VIA EMAIL Attention: Licensing Division Of?ce of Foreign Assets Control US. Department of the Treasury 1500 Avenue, NW. Washington, DC. 20220 Re: Application for a Renewal License to Allow Google Inc. to Award Prizes of Cash and Certain Low Cost Logoed Products (?Sch wag?) to Contest Winners from Cuba To Whom It May Concern: On behalf of our client, Google Inc. (?Google?), a Delaware corporation headquartered in California, and pursuant to the Cuban Asset Control Regulations, 31 CF Part 515 we submit this application for a license from the Of?ce of Foreign Assets Control authorizing Google to award prizes? of cash and certain low cost logoed products (?schwag?) to software coding contest winners from Cuba. As described in further detail below, in this application, Google sponsors intemet-based software 'code writing contests, among other contests, for educational and entertainment reasons and Google is seeking authorization to award prizes to any winners of these contests from Cuba.1 These activities were most recently authorized in Export License which expires on May 31, 2015. Please see Attachment A. Google seeks renewal because it would like to continue these contests. None of the characteristics of the contests have changed since the export license listed above was issued except that the ?nals are streamed live. . (4) AUSTIN BEIJING BRUSSELS HONG KONG NEWYORK ?1.0 ALTO SAN DIEGO SANFRANCISCO SEATTLE SHANGHAI WASHINGTON, DC 2018-11-133 000029 2015-10-119 029 I 1 Wilson Sonsini Goodrich 8L Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division U.S. Department of the Treasury January 9, 2015 Page 2 We believe that the approval of this license application would still be consistent with US. policies toward Cuba. We believe that this license application should be approved because the transactions at issue are educational in nature and would be consistent with policy and practice to issue speci?c licenses authorizing money to be sent to independent non-governmental entities in Cuba, including pro-democracy, civil rights, and educational groups. The approval would not bene?t the Government of Cuba or the infrastructure of Cuba in any way. We also do not believe that the contests involve the importing of a service from Cuba as prohibited in Section 515.206. A. APPLICANT INFORMATION Google-?s mission is to organize the world?s information and make it universally accessible and useful. Google?s website provides information in many different languages and allows a user to check stock quotes, maps, andnews headlines; lookup phonebook listings for every city in the United States; search billions of images; and peruse the world?s largest archive of Usenet messages more than 1 billion posts dating back to 1981. Google is based at: Google Inc. 1600 Amphitheatre Parkway Mountain View, CA 94043 'The individual responsible for this application and the related transactions is: Export Compliance Counsel Google Inc. . 1600 Amphitheatre Parkway Mountain View, CA 94043 Telephone Number: Fax NUmber: (650) 253-0001 Email: 1. Contest Background Information Google conduCts a variety of contests, most notably software coding contests, over the internet that are designed to identify the rising stars of the technology world, particularly potential software developers. Over half of the participants are university students the majority of which are enrolled in computer science and computer engineering programs. The other participants are predominantly working professionals in the computer science and computer engineering ?elds. 2018-11-133 000030 2015-10-119 030 Wilson Sonsini Goodrich 8t Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 3 Google began running these types of contests about twelve years ago and has had registrants from many foreign countries. As an example, in 2014, the Code Jam contest, one of the coding contests that Google runs which consists of intense algorithmic puzzles held over multiple online rounds, had nearly 50,000 registrants from approximately 120 countries and territories. lt culminated in an on-site ?nal round with the top 26 contestants and Google?s ?rst- ever live stream ?nals. There is no fee to enter the contests and the contestants only interact at a very basic level with the US. website on which it is hosted. Each contestant reviews information posted on the website, and then indicates when he or she is ready to submit a solution. The contestant then downloads an input used to test his or her solution, tests it, then submits information to Google which Google then judges as correct or incorrect. The inputs are simply data that will test whether the contestants? programs worked correctly and do not contain any or We provide below an example of how such contests work: Round 1: Contestants conduct a code writing challenge in their home country based upon the terms of the Google contests. The submission is then sent to Google in the United States for judging. Google then noti?es the winners of Round 1 and they advance to the closest regional Google of?ce for Round 2. Round 2: The winners from Round 1 conduct another code-writing challenge based upon the contest criteria. These submissions also are submitted to Google in the United States for judging. Google then noti?es the winner and the winner is invited for a ?nal round in a location that changes annually. The 2015 ?nals will be held in Seattle, Washington. (D) (4) (4) Im- The predominant reasons that Google offers and runs these contests is to encourage and rt er develop interest in computer science and computer engineering, the ?elds on which Google is based, and to become further involved in the computer science community. The contests also allow Google the opportunity to recognize excellent software engineers and increase its recruiting presence worldwide. A sample of software coding contest rules and requirements is attached as Attachment B. Again, these activities were already authorized in Export License CU-2013-301218-1, and we seek renewal because Google would like to continue the contests. None of the characteristics of the key characteristics of the Contests have changed since the export license listed above was issued. 2018-11-133 000031 2015-10-119 031 Wilson Sonsini Goodrich 8L Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 4 B. DESCRIPTION OF THE PRODUCTS TO BE EXPORTED AND INTENDED USE Google awards the winners ?schwag? low?cost logoed materials, monetary prizes, and expense-paid visits to Google?s regional and, possibly, U.S. of?ces. The prizes of schwag may include a variety of items ranging from desk or work supplies to toys and personal accessories. Examples of schwag prizes include but are not limited to t- shirts, hats, blankets, mugs, travel mugs, tote bags, lap top bags, picture frames and similar items. These prizes are nominal in value, claSsi?ed as EAR99 and would be limited to an individual?s personal use. With respect to cash prizes, Google would like continued authorization to award cash prizes up to $25,000 to a contest winner. The cash prizes will be awarded through of issuance of a check, money order, or electronic payment card to the winner, and Google will advise any winner from Cuba that any cash awarded must be paid into a bloCked, interest-bearing account in a domestic bank. C. ULTIMATE USERS As stated ab'Ove, the Google software Coding contests are designed to identify the rising stars of the technology world, particularly potential software developers. Over half of the participants are university students the majority of which are enrolled in computer science and computer engineering programs. The rest of the participants are working professionals of which many are in the computer science and computer engineering ?elds. Google has had registrants from many foreign countries. As an example, in 2014, the Code Jam contest, one of the coding contests that Google runs which consists of intense algorithmic puzzles held over multiple online rounds, had nearly 50,000 registrants from approximately 120 countries and territories. It culminated in an on-site ?nal round with the top 26 contestants and Google?s ?rst-ever live stream ?nals. The 2012 contests were opened to Cuba under Export License The license was then renewed in Export License which expires on May 31, 2015. Google would like to request the renewal of the license because Google would like to continue the contests. As discussed in detail below, Google ?rmly believes that the contests can only be properly run if all contestants are eligible to receive prizes. None of the characteristics of the contests have changed since the export license listed above was issued. Google is seeking renewed OFAC authorization for approval to award prizes of cash and schwag to a class of individuals individuals in Cuba who win the Google contests and are not listed on the SDN List or List of Denied Persons or any other relevant US. Government 2018-11-133 000032 I Wilson Sonsini Goodrich 8L Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 5 List of prohibited persons. Google needs approval for this category of end users because Google does not know who the contest winners will be until the conclusion of each round. It is not feasible for Google to apply for a license after the winner is known, due to the length of time it - takes to obtain authorization. .If Google had to wait and apply for a license to award a cash or schwag prize, Google would have to delay the start of the contests at least six months after registration (which is an unreasonably long delay) and would also have to wait an additional six months or longer between the running of the ?nal online round and the onsite round. Google ?rmly believes that these types of delays would not allow the contests to operate in a reasonable or feasible manner as the contests can only truly be effective if all contestants are allowed to compete, to proceed to the on-site rounds and to win prizes. Currently, most contests are completed in several months with each round running for several weeks. Further, Google strongly believes that that it would be both unfair to the individual and contrary to the Google philosophies that the world?s information should be universally accessible and that information needs to cross borders if Google allowed a contestant to compete and proceed to a Google of?ce to compete in Round 2 of the contest when there would be no certainty that the contestant could receive a prize of schwag or cash. (4) As described in more detail below, given the educational nature of the contests, the participation by Cubans and the awarding of cash or schwag prizes to them would not con?ict with US. interests or foreign policy concerns and Google does not believe that the CACR prohibit the participation of the contestants in the contests or the reimbursement of travel expenses. D. ANALYSIS (4) 2018-11-133 000033 2015-10-119 033 Wilson Sonsini Goodrich 8c Rosati PROFESSIONAL Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 6 (4) 2. Request for license for travel reimbursement for Cuban participants With regards to reimbursement of travel expenses for Cuba participants, Google believes that reimbursement not involving travel to the United States would be covered under the award of cash prizes mentioned above. (43) (4) Google understands that winners would need to apply to the US. State Department for visas to travel to the United States. To arrange any travel between the United States and Cuba for a Cuban contest winner, Google will use one of the providers included on List of Authorized Providers of Air, Travel and Remittance Forwarding Services to Cuba. By using one of the authorized providers, Google believes that no further authorization is required from OF AC for the awarding of travel between Cubavand the United States for a Cuban contest winner. Again, Google believes that approval of the license is appropriate as the Google contests provide educational exchange opportunities for persons in Cuba who would otherwise not have this chance and would be also consistent with policy and practice to license certain non- commercial personal remittances to persons in Cuba such as pro-democracy groups, civil rights organizations and educational groups. (4) 2018-11-133 000034 2015-10-119 034 Wilson Sonsini Goodrich 8L Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 7 3. Request for license for schwag and cash prizes Google seeks authorization from OFAC to continue to award schwag and/or cash prizes to winners from Cuba or to Cuban nationals. The award of these prizes was already authorized by OF AC in Export Licenses CU-82203 and CU-2013-301218-1. This license seeks to renew . the existing license. None of the key characteristics of the contests have changed since the export license listed above was issued. Thus, Google believes that the approval of this license is still consistent with US. policy toward Cuba. The Google contests provide educational exchange opportunities for Cubans who would otherwise not have this chance. The code writers identi?ed through these contests often go on to work in the United States at technology and intemet companies. We believe that approval of the license is appropriate as the Google contests provide educational exchange opportunities for persons in Cuba who would otherwise not have this chance and would be also consistent with policy and practice to-license certain non- commercial personal remittances to persons in Cuba such as pro-democracy groups, civil rights organizations andeducational groups. Additionally, Google does not provide the answer to these challenges but instead it simply provides an opportunity to compete against other code writers. Thus, the contests are not in furtherance of technological infrastructure or potential in Cuba. The code writers are not taught how to write code but merely allowed to apply their skills in competition with other code writers. E. CONCLUSION We respectfully request that OFAC re-issue a license permitting Google to award schwag in the form of low-cost lo orizes u- to $25 000 to Cuban contest winners. Please be advised that this letter (including all attachments) contains sensitive information about Google and its business and commercial activities that is con?dential, and not customarily released publicly, and which is, therefore, exempt from the public access provisions of the Freedom of Information Act, 5 U.S.C. 552. Such information, if disclosed, could adversely affect the ?nancial and competitive position of Google and the normal conduct of its 2018-11-133 000035 2015?10?119 035 Wilson Sonsini Goodrich 8L Rosati PROFESSIONAL CORPORATION Of?ce of Foreign Assets Control, Licensing Division US. Department of the Treasury January 9, 2015 Page 8 business operations. Accordingly, Google requests that this letter be withheld in the event of a demand for its disclosure. Google understands that in the event of such a demand, your of?ce will give Google prompt notice and an opportunity to be heard prior to taking any action to disclose. If you have any additional questions about this application, please do not hesitate to contact us at 202 973-8800. We would appreciate a of any such approval be sent to Thank you for your consideration of this request. Sincerely, b)(6 Counsel for Google Inc. Attachments Export License CU-201 3-301218-1 Sample Coding Terms and FAQ 2018-11-133 000036 2015-10-119 036 DEPARTMENT OF THE TREASURY WASHINGTON, DC. 202-20 . . ?Jinx Cuban Assets Control Regulations License No. CU-2013-3012l8-l LICENSE (Granted under the authority 01'50 App. 22 U.S.C: 2370(3). 22 U.S.C. 600! et seq. Proclamation .3447. and 3 C.F.R. Parts 501 and 5 l5) To: Googlc Inc. c/o Wilson Sonsini Goodrich Rosati 1700 Street, NW Fifth Floor Wushin ton DC 20006-3817 l. Pursuant to yOur letter dated March 19, 2013, on behalf of Google lnc., to the Of?ce of?Forei'g?n Assets Control (the ?Application?), the transactions and activities delineated herein are hereby authorized. This license supersedes License CU- 82203 In all respects. . 2. This license is granted upon the statements and representations made in the Application, or otherwise ?led with or made to the Treasury Department as a supplement to the Application, and is subject to the conditions, among others, that the Licensee comply in all respects with all regulations, rulings, orders and instructions issued by the.Secr_etary of the Treasury or his dcsignee?s 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 of?cer or agency of the Secretary. 4. This license expires on May 31,2015, is not transferable, is subject to the provisions of Title Par-Is 50! and 5 5 ofthe Code of Federal Regulations and any Iegulations and rulings issued pursuant thereto, and may be revoked or modi?ed at any time at the discretion ofthe SeCIetary ofthe 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 ofthe applicant or his duly authorized agent, it may, in the discretion of the Secretary of the Treasury or his designees, 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 (including reporting requirements) administered by the Office of Foreign Assets Control or another agency applicable to the trans?actions(s) herein licensed, nor does it release 1 icensee. or third parties from civil or criminal liability fer violation of. any law or. regulation. Issued on behalfofthe Secretary ofthe Treasury: OFFICE OF FOREIGN ASSETS CONTROL Mag 20, 2201.3 By An rea ?aC'l Assistant Directbr for Licensing is directed to mm. 50 U.S.C. App. 16. 3l C.F.R. 50l.70l ct seq. and 3 C.F.R. 5l5.70l et seq. l'or provisions relating to penalties] 2018-1171330o0037 2015-10.-119 037 License No. CU-2013-301218-I Page 2 of2 Licensee: Google Inc. SECTION I - AUTHORIZATION. Subject to the conditions and limitations stated herein, Googlc Inc. (the ?Licensee? 1s hereby authorized to engage in those transactions otherwise prohibited by the Cuban Assets Control Regulations, 3] CFR Part 515, that involve the participation of a citizen, national, or permanent resident of Cuba who is neither a prohibited of?cial of the Government of Cuba nor a prohibited member of the-Cuban Communist. Party, as such terms are de?ned, respectively, in '31 C.F.R. 515.337 and 515.338, in international software coding contests sponsored by the Licensee, including: awarding cash prizes of up to USD 25, 000; paying for travel and accommodations to participate in onsite events at a regional Googlc of?ce 1n third- party countries; and 0 providing ?to successful participants, as described in the Application. Any transfer of funds through the US. financial system pursuant to the authOrization set forth in paragraph hereof should reference the number of this license to avoid the blocking or rejection of the transfer. Authority: 31 C.F.R-. 515.801. SECTION 2- CONDITIONS: It is a condition of' this license that any payment of travel expenses from Cuba to the United States on behalf of a successful participant arranged by the Licensee in conjunction with the. Authorization 1n Section 1 above must be effected 111 a manner consistent with 31 C. F. R. 515.571. SECTION 3 WARNINGS: Except as expressly authorized in Section 1 above, nothing in this license authorizes any persons subject to the jurisdiction of the United States to engage in any transaction or activity prohibited by the Cuban Assets Control Regulations, 31 CPR. Part 515. This license does not authorize the export of any goods, technology, or commodities to Cuba. An export- license or other authorization issued by the US. Department of Commerce'pursuant to the Export Administration Regulations (15 CPR. Parts. 730 et seq.) is required for this purpose. For questions relating to the licensing requirements for the exportation of items from the United StatestoCuba, please contact the U.S.. Department of Commerce?s Bureau of Industry and Security at (202) 482-4811. SECTION 4 AND REPORTING REQUIREMENT: The Licensee shall keep a record 01 all transactibns entered into pursuant to this license. Such records shall be made available for examination upon demand for at least ?ve years from the date of each transaction records shall clearly [demonstrate the applicability of the authorization set forth 1n Section 1 hereof. (See 31 C. R. 501.601 and 5016.02) SECTION 5 EFFECT: The authorizatibn contained in this license is limited to the facts and circumstances speci?c to the application. 2018-11-153 000038 2015-10-119 038 code jam Code Jam 2015 Code Jam Home Schedule Terms and Conditions WEE Quick?tart Gulde Archive Code Jam History Terms and Conditions GOOGLE CODE JAM TERMS AND CONDITIONS Welcome to Google Code Jaml These Terms and Conditions (?Terms?) apply to Google Code Jam and all related Code Jam contests sponsored by Google Inc. (each referred to as a ?Contest? Please read these Terms carefully as they form a binding legal agreement between you and Google Inc.. located at 1600 Amphitheatre Parkway. Mountain View. CA 94043. United States ('Google" )with respect to the Contest. Our Code Jam Contests vary and we may post additional terms and conditions on the Contest website. which become part of these Terms and your agreement with 'us with respect to the Contest. YOU MAY NOT SUBMIT AN ENTRY TO A CONTEST AND ARE NOT ELIGIBLE TO RECEIVE PRIZES UNDER A CONTEST UNLESS YOU AGREE TO THESE TERMS. YOUR SUBMISSION OF AN ENTRY IN A CONTEST CONSTITUTES YOUR AGREEMENT TO THESE TERMS. The words ?include" and 'including? as used in these Terms mean ?including but not ?mited to.? 1. Eligibility. 1.1 . The Contest is void in Cuba. North Korea, Sudan, Syria. Quebec. and where prohibited by law. HASE . You do not need to purchase any Google product or service to enter or win the Contest. 1.3 ne igib ? ndividga s. You cannot participate in the Contest if: You are a resident of Cuba. North Korea. Sudan, Syria, or Quebec or anywhere that the Contest is prohibited by (ii) You arerestricted by applicable export controls and sanctions programs; You are a current employee ancluding intern). contractor. of?cer..or director. of Google or its af?liates; or (iv) You are an immediate family member Gncluding a parent. sibling. child, spouse, or life partner regardless of'where you live) of one of the individuals listed in subsection above or you are a member of their household (whether related or not). However. Sectim above does not apply if you are a Google Student Ambassador (whether paid or not) and you may participate in the Contest. If you gained information on a problem while working as an employee. intern, contractor. or of?cial of?ce-holder of Google. 0) you may be disquali?ed if you attempt to gain points on that problem in the Qualification Round; and (ii) you may not participate in the Contest if that problem Is usedin any later rounds. 1.4 Rmuirements to Enter and Begeive E?'ze. in order to enter the Contest. you must have access to the lntemet. and (ii) a valid email address. In order to receive a prize. you must provide your name, phone number. a valid postal address. and any other information Google may need to avard or send you a prize. 1.5 Veg?' ing Eligibility. Google reserves the right to verify your eligibility and to adjudicate on any dispute at any time. You agree to provide Google with any proof of eligibi?ty requested by Google and your refusal or failure to provide such proof within 10 days of Google's request will result in your disquali?cation from the Contest and forfeiture of any prizes. 1.6 All communications between Google and you. including the Contest website and email communications. will be in English. 2W 2.1 Rgistration. To enter the Contest. you must register at the Contest website and provide the required information about yourseif. . Registration times are listed on the Contest website. YOU ARE RESPONSIBLE FOR DETERMINING THE CORRESPONDING TIME IN YOUR TIME ZONE. You must register for each Contest before you can participate in that Contest. For example. if you 2018-11-133 000039 9? .5 6. registered for Code Jam 2014, you would still need to register for any other contests. You may only register for the Contest with one valid email address. If you compete in the same Contest with multiple email addresses. you will be disquali?ed. 2.2 W. Google reserves the right to change or omit contestant screen names or nicknames for purposes of-publication on Google websites or listserv. particularly if they are. in Google's sole opinion. obscene or violate the intellectual property rights of others. Contest Structure. 3.1 Overview. The Contest consists of one or more rounds as may be more fully described in additional terms and conditions posted on the Contest website. Each round consists of one or more problems. In each round. you witl receive a score based on the answers you provide to the problem(s). it the Contest has more than one round. you will advance to the next round if your. score exceeds a speci?ed. threshold or is one of a specified number of highest scores in that round. 3.2 Modifying the Contest. Google may cancel or modify the and location of the Contest if technical difficulties prevent or make it unfair to run the Contest in accordance with these Terms. . Environment. 4.1 W. You may use any programming language to solve the problems, using any development environment or text editor. However. for any round after the quali?cation round, the Compiler 'or interpreter you use must be available such that anyone else can use it for free without a time limitation and without violating any rights of any person or entity. 4.2 Exceptions. Visual Studio. Microsoft Excel. and MATLAB are acceptable. Compilers and interpreters that require Microsoft Windows or Mac OS are acceptable. as long as the compiier or interpreter itself is free. as described in Section 4.1 above. Google may make further exceptions on a case-by-case basis which Google will communicate to you by email. Problems. 5.1 m. Each probtem set consists of a series of algorithmic problems. which may include one or more small inputs. large inputs, or other inputs described in the problem statement. These Terms describe the rules for small and large inputs. A problem may describe special rules for inputs other than small or large. You will be able to access the problems on the Contest website and download the retevant input ?les once the round begins. 5.2 Time Limit. When you attempt to solve a particular input. a timer will start as soon as you begin downloading the ?le. You must submit (1) a conect output ?le and (2) the source code used in its generation or a written explanation explaining how you solved the problem within: 4 minutes for a small input, (ii) 8 minutes fora large input. or some other time as speci?ed in the problem for other inputs. but in each case no later than the end of the Contest. 5.3 Small inputs. Google will judge your submissions for small Inputs immediately and notify youif your submission is corrector inconect. If the output ?le and source code ?le are not received by the end of the 4 minute period or if the output you submit is judged incorrect, you may choose to attempt to solve that problem again within the time remaining in the round, but will have to download a new small input. 5.4 Mauls. You can only attempt to solve each large input once. For each large input, you canmake multiple output submissions within the 8 minute period. but only your last submission will be judged. Google will notify you whether your submission was con'ect or inconect after the round ends by posting the results on the Contest website. 5.5 Submission Rguirements. You must submit output fiies in the format speci?ed by the problem and these Terms (with precedence givenin that order). Google may ignore certain incorrect submissions and notify you that the submission was malformed and that you may submit again in whatever time remains in the period. . You may submit source code as one or more plaintext or zipped plain text files. The size of each source code ?le may not exceed 100KB, and the total size of your source code for an output after being unzipped may not exceed 1MB. If you use a standard library that is freely availabie on the lntemet that is too large to include in your submission. you may exclude it as long as you put a comment in your source code explaining where the library is available. Deliberately obfuscated source code is not allowed. (CD You should submit your output: ?les and source code within enough time remaining in the time period to avoid latency issues between your computer and Google servers. (9) You may not submit source code for any round after it ends. During a round. if you think you submitted the wrong source code for an output. you may notify the judges using the "Ask a Question" link on theContest website. For inputs other than large inputs. the judges may mark the submission as incorrectso that you can attempt the problem again. For a large input for onsite rounds only. the judges may permit resubmission of the source code. W9. The outputr ?les you submit will be judged as follows. 6.1 Points. Each problem is worth a certain value of points. For example, for a problem with a small input and a large input, the solution to the small input may be worth 10 points. while the solution to the large input may be worth 15 points. Your total score for a round will be the sum of the points you earned for 2018-11-133 000040 'Hl inputs in that round. 6.2 133W. Contestants will be ranked in order of the highest score ?rst and lowest score last. In the event of a tie between cantestants. the one with the lcnveet penalty time will be ranked ?rst IIrri'rilrar the one with the highest penalty time will be ranked last. Your penalty time for a round is equal to the time it took you to submit your last correct output file measured from the start of the round plus 4 minutes for each incorrect submission you made for small inputs you eventually solved. Problems with inputs other than small or large may specify nlos for penalty time in their problem statements. 6.3 W. After the end of a rovnd. if a discrepanCy is discovered between the output file you submitted that was judged correct and the corresponding source code that you submitted. then a panel of two or more judges consisting of employees of Garage will examine the source code for you submissions. The judges will determine whether a discrepancy exists. and if so will decide in their sole opinion whether the discrepancy is trivial or non-trivial. For a trivial discrepancy, you will be assessed a Minna penalty tor that input. For a non-trivial discrepariCy. you will be assessed a 4-minute penalty in a quali?cation round and you will forfeit al points for that input in all other rounds. Advancement and Notice of Winners. 7.1 MW. You will be noti?ed by email at least one day before the following round whether you have advanced to the next round. 3".2 mm. The results of each round of the Contest will be announced on the Contest website at least one day prior to the next round. The results of the ?nd round at the Contest will be posted within 7 business days of its completion. Posted will include a list of the contests' names or nickname-s in ranked order based on their scores. 3- BIBLE- B.1 Money Prizes. Money prizes will be awarded in U.S. dollars and may be delivered in the form of cash. check. gift card. or other cash equivalent. 8. 2 Google may either ship your prize to you or request that you come to a Google of?ce to collect your prize. If Google informed you that it will ship your prize to you and you have not received your prize within 6 months after the and of the Contest. please email W. Boogie will not award any prizes beyond 12 months from the and of the Contest. 8.3 Form-item. YOU will forfeit your prize and an alternative winner may be selected. it: You fail to provide a phone number during registration or any other information requested by Google within 15 days of Google's request; You fail to respond to Googe's email noti?cation within 15 days: You fail to follow directions provided by Google for receiving the prize; Your prize or prize noti?cation is returned to Googlo; or to] You tail to pay applicable taxes or timely submit applicable documentation to Google or the relevant tax authority. Bat W. Google may provide a substitute prize of equal or greater value at Google?s discretion, or where required by law. or in the event all or part of a prize becomes unavailable. 8.5 lasso- You are solely responsible for complying with all applicable tax laws and ?ling requirements. To remain eigible for a prize. you must submit to Google or the relevant tax authority 3! documentation requested by Google or required by applicable law within 7' days all Google?s request or earlier it required by law. are solely responsible for paying al taxes imposed on prizes awarded to you. All prizes will be not of any taxes Goods is required by law to withhold. 8.6 Maggie; Except as required by law. Google makes no warranties. express or implied. for prizes. 9. museum. 9.1 You may be disquali?ed from the Contest and torleit any prizes you may be eligible to mceive it Google reasonably believes that you have attempted to ?admins the legitimate operation of the Contest. including: Providng talse intonnation about yourself during registration or concerning your eligibility: Breaching or refusing to compiy with these Terms: to) Tampering or interfering with administration of the Codes: (including monitoring at onsite rounds) or with the ability of other contestants to participate in the Contest; Sharing or using from others any information about a problem (including its content or solution] before the and of a round unless expressly permitted by these Terms; to] Submitting content that: {it violates the rights of a third party. {ii} is lewd obscene. pomogI-aphic. racist. sexist. or otherwise Inappropriate to the Contest. or violates any applicable law. or it) Threatening or harassing other cornerstanls or Goo-go. inducing its employees and representatives. Harassing behavior includes. offensive. tlveatening. andror hateful comments directed toward an individualor protected class [gender sexual orientation. disability. gerider identity. age. race. religion. ethnicity. veteran status]. the use or display of sexual' Images in orbit: spaces. deliberate intimidation. 2018- 11- 133 000041 stalking. following. taking unwelcome photoslvideos, sustained dismption of talks or other events. inappropriate physical contact. unwelcome sexual attention. and developing and/or promoting any applications designed to encourage any of these behaviors. 9.2 You may report to Google at codeiam@google.com any harassment. cheating. or violati0n of these Terms by another contestant. Google may investigate any such allegations and all decisions by Google in these matters are ?nal and binding. If youare asked to stop any harassing behavior. you are expected to comply immediately. 10. Rights in Your Submissions; Privacy. 10.1 W.YDU retain all rights to your submissions of output ?les and source code that you had before submitting them to the Contest. 10.2 License to?ubmissions. For any submissionyou make to the Contest, you grant Google a non- exclusive. worldwide. perpetual. irrevocable, free license (with the right to sublicense) to reproduce. prepare derivative works of, distribute. publicly perform. publicly display. and otherwise use such submission for the purpose of administering and promoting the Contest. Your submitted source code may be made available for anyone to view on the Internet and download at the end of?the Contest. 10.3 littlest. How Goocrle Mav Use Your Information. Google will use the information you provide during registration-and in any subsequent communications to administer the Contest (including verifying your eligibility to participate in the Contest and delivering prizes). This data may be transfened into the United States and will be maintained in accordance with Google's Privacy Policy. (ii) By accepting a prize, you agree that Google and its agents may use your name. Iik'eness. and statements without Compensation to prompts the Contest. including displaying it on the Contest website. Sharing Your Information. Your name and usemame you create during registration may be displayed publicly on the Contest website. If you win a prize. Google may share your name and address with third parties to ful?ll awarding a prize to you. - Accessing Your Information. You may access. review. and update any of your personal data held by Google in connection with the Contest by emailing or writing to Google (Attention: Code Jam) at the address listed above. Permission to Record You. If you participate in? an onsite round of the Contest. you give permission to Google to make and have made audio. visual. and audiovisual recordings (in any format or media) of you and your activity on a computer while you are participating in the Contest (the 'Recordings') and grant Google an unrestricted. sublicensable, transferable. perpetual. irrevocable. worldwide. free license to use the Recordings to promote the Contest. You waive all rights. including any right of prior approval. and release Google and its agents from. and will neither sue nor bring any proceeding against Google or its agents for, any claim or cause of action. whether now known or unknown. for defamation. copyright Infringement, and invasion of the rights to privacy. publicity. or personality or any similar matter. or based upon or relating to the use and exploitation of the Recordings. 11. Icy: Beamsenglons, ?amgg ties. 11.1 Repgsentations and You represent and warrant that: the information you provide about yourself while registering or in subsequent communications with Google is truthful and accurate; your submissions to the Contest are original and. unless expressly permitted by these Terms. not created with the assistance of any information about the problems not provided by Google; you own all rights in your submissions or otherwise have the right to submit your submissions to Google and grant to Google the licenses granted in these Terms without violating any rights of any other person or entity or any obligation you may have with them; and your submissions do not violate any applicable laws. 11.2 Indemnities. You will indemnify Google and its affiliates, directors, officers, employees against all liabilities. damages. losses, costs. fees ancluding legal fees). and expenses relating?to any allegation or third-party legal proceeding to the-extent arising from: your acts or omissions in relation to the Contest (including-your use or acceptance of any prize and your breach of these Terms); and your submissions violating any rights of any other person or entity or any obligation yOu may have with them. 12. Disclaimers. THE CONTEST WEBSITE AND ALL CONTENT (INCLUDING SOURCE CODE) ON AN AND BASIS. GOOGLE DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES (EXPRESS OR IMPLIED). INCLUDING ANY WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE. GOOGLE IS NOT RESPONSIBLE FOR ANY INCOMPLETE. FAILED. OR DELAYED TRANSMISSION OF YOUR APPLICATION INFORMATION OR SUBMISSIONS DUE TO THE INTERNET. INCLUDING INT ERRUPTION OR DELAYS CAUSED BY EQUIPMENT OR SOFTWARE MALFUNCTION OR OTHER TECHNICAL PROBLEMS. YOU USE ALL SOURCE CODE AVAILABLE ON THE CONTEST WEBSITE AT YOUR OWN RISK. 13- 9mm!- 2018-11-133 000042 13.1 Not an Offer or Contract?OI Emmoyment. You acknowledge that your participation ?is voluntary. You acknourledge that no con?dential, ?duciary. agency or other reiationship or implied-in-fact contract now exists between you and Google and that wrote: Hi (b)(6) we just tried you - could you please just call us back at 3? Sent from my BlackBerry 10 smartphone. (b)(6) From: Sent: Thursday, March 3, 2016 1:50 PM To: Demske, Susan Subject: Re: a way to reach you around 3? Hi Susan, That works fine for me.  My number is (b)(6) Thanks, (b)(6) On Thu, Mar 3, 2016 at 10:18 AM, wrote: (b)(6) ‎Is there a way to reach you around 3 our time? We will be getting off a conference call then so it may be a little after 3 so it might be best if we could call you.  Thanks Susan Sent from my BlackBerry 10 smartphone. (b)(6) From: Sent: Wednesday, March 2, 2016 1:58 PM To: Demske, Susan Subject: Re: Are you available at 4pm my time today for a call? Yes, definitely!  I will call you then. Thanks, (b)(6) On Wed, Mar 2, 2016 at 10:45 AM, wrote: You could reach us at (b)(6) 2018-11-133 000045 From: To: Subject: Date: (b)(6) Demske, Susan Re: Are you available at 4pm my time today for a call? Wednesday, March 02, 2016 1:58:55 PM Yes, definitely!  I will call you then. Thanks, (b)(6) On Wed, Mar 2, 2016 at 10:45 AM, wrote: You could reach us at (b)(6)   Thanks, Susan -- (b)(6) Export Compliance Counsel (b)(6) Tel: Email: (b)(6) This email constitutes an attorney-client communication and/or is attorney work product.  Please do not forward without permission. Check out go/export for useful information on export law! 2018-11-133 000046 From: To: Subject: Date: (b)(6) Demske, Susan Re: Phone Discussion Request Tuesday, March 01, 2016 3:32:17 PM Will do.  Thanks, Susan! -- (b)(6) On Tue, Mar 1, 2016 at 11:59 AM, wrote: Hi (b)(6)   Please call (b) (6) Thanks.   (b)(6) From: Sent: Tuesday, March 01, 2016 2:30 AM To: Demske, Susan Subject: Re: Phone Discussion Request   Hi Susan,   I'll be in a phone room so it would probably be easiest if I ring you.  Can you let me know the best number to reach you?   Thanks, (b)(6)   On Mon, Feb 29, 2016 at 5:37 PM, wrote: That should work.  Shall I call you?    (b)(6) From: Sent: Monday, February 29, 2016 8:09 PM To: Demske, Susan Subject: Re: Phone Discussion Request   2018-11-133 000047 Thanks so much, Susan.  Would 5pm work for you?   --(b)(6)   On Mon, Feb 29, 2016 at 5:02 PM, wrote: Hi (b)(6)   Yes, I could do anytime after 430 tomorrow my time if that would work for you.   Susan   (b)(6) From: Sent: Monday, February 29, 2016 6:20 PM To: Demske, Susan Subject: Phone Discussion Request   Hi Susan,   I hope you are well!  I have a couple urgent matters that have recently come up that I would love to run by you and get your informal read on.  Are you available, by any chance, to have a call with me tomorrow (Tuesday) or Wednesday to discuss?   Thanks and best regards, (b)(6)   -- (b)(6) Export Compliance Counsel (b)(6) Tel: (b)(6) Email: This email constitutes an attorney-client communication and/or is attorney work product.  2018-11-133 000048 From: To: Subject: Date: (b)(6) Demske, Susan Follow Up Tuesday, December 15, 2015 2:25:54 PM Dear Susan, I hope you are well!  I just wanted to check back in with you in follow up to our meeting a couple of weeks ago.  I know that you had wanted to confer a bit more internally on the applicability of 515.578 to peering and caching in Cuba.  Recognizing, of course, that anything you provide would be completely informal at this point, is your general sense that sec. 578 would work for peering and caching, as we described them in our meeting? Thanks so much and best regards, (b)(6) -- (b)(6) Export Compliance Counsel (b)(6) Tel: Email: (b)(6) This email constitutes an attorney-client communication and/or is attorney work product.  Please do not forward without permission. Check out go/export for useful information on export law! 2018-11-133 000049 From: To: Subject: Date: (b)(6) Demske, Susan Fwd: info for OFAC Wednesday, December 02, 2015 9:58:08 AM Hi Susan, Here is the information for (b)(6) Thanks, (b)(6) ---------- Forwarded message ---------(b)(6) From: Date: Dec 2, 2015 9:20 AM Subject: info for OFAC (b)(6) To: Cc: Hi (b)(6)   Can you send my info to your OFAC contact for this AM? (b)(6) US citizen See you soon! 2018-11-133 000050 From: To: Cc: Subject: Date: (b)(6) Demske, Susan Blackborow, Davin Re: Greetings from Google! Monday, November 30, 2015 12:19:39 PM Hi Susan, We are also looking forward to meeting with you.  The attendees' titles are as follows: Global Trade Compliance Access Associate (b)(6) Network Content Distribution LATAM and Caribbean (b)(6) Export Compliance (b)(6) (b)(6) Thanks, (b)(6) On Mon, Nov 30, 2015 at 7:38 AM, wrote: Hi (b)(6)   We are looking forward to our meeting this Wednesday.  Might you please also send titles/position for each attendee?   Thanks, Susan     Susan Demske Assistant Director for Regulatory Affairs Office of Foreign Assets Control U.S. Department of the Treasury (b)(6) (o)       2018-11-133 000051 From: To: Cc: Subject: Date: (b)(6) Demske, Susan Blackborow, Davin Re: Greetings from Google! Thursday, November 19, 2015 2:10:29 PM Hi Susan, Here is the information you requested for the attendees: (b)(6) Citizenship: Mexico.  (b)(6) US citizen. Security clearance of "secret" through the ISTAC/BIS. (b)(6) Country of Citizenship: USA (b)(6) Country of Citizenship: USA Please let me know if there is anything else you need.  Otherwise, we will see you at 10am in the lobby on December 2nd. Thanks! (b)(6) On Wed, Nov 18, 2015 at 9:20 AM, wrote: Yes, actually to clear through the Secret Service into the building, we will need for each attendee:  name, date of birth, social security number, and whether the attendee is a US citizen (and if not, country of citizenship).   2018-11-133 000052 Thanks, Susan   (b)(6) From: Sent: Wednesday, November 18, 2015 12:18 PM To: Demske, Susan Cc: Blackborow, Davin Subject: RE: Greetings from Google!   Thanks, Susan! That time works perfectly. Do you need the names of the attendees in advance to clear them to enter the building? - (b)(6) Duplicate of page 6 2018-11-133 000053