Exhibit 8
Comments in response to questionnaire Category No.6 ( f )Question:
Please state any other comments, if any, in regard to the US export controls.

Comments:
1. The extraterritorial application of the U.S. export control regulations, we believe, isapparently an excess of authority; the regulations should be applied only within the U.S.
territory.
Because of the extraterritoriality, our company is increasingly losing businesses chancesand bearing extra costs these years.
We would request the U.S. Government to withdraw the re-export control simply becausedual-use goods and technologies produced in the EU and Asian countries are no lessadvanced than those produced in the United States.
2. Our company is a Japanese subsidiary of a U.S. company of semiconductor manufacturing
equipment. Both design and procurement are done by the U.S. parent company for us;
therefore, the U.S. re-export control barely affects our operations.
3. We would say it’s more than enough as far as U.S. exporters comply with the EAR or ITAR.
In principle, the U.S. Government should abandon the extraterritorial application of the
U.S. export control.
If not, however, it should at least exclude member nations of the multilateral export
control regimes from the countries subject to the control.
4. If the U.S. Government applies its export controls extraterritorially, it must at least takesteps as follows:(1) Translation of the U.S. regulations and other related documents into our language.
(2) Quicker issuance of licenses.
(3) Face-to-face consultation in our language.
(4) To make it mandatory for U.S. exporters to inform ECCNs to foreign importers.
5. We are a Japanese affiliate of a U.S. company, and are regarded as a U.S. person
according to the U.S. regulations. Our company is, therefore, complying with theapplicable U.S. laws and regulations too. But personally, as Japanese nationals, we are
doubtful about the U.S. way of applying its export control regulations to non-U.S.
countries.
6. Since its definition itself is unclear, “U.S.-origin” or “de minimis” should not be used as acondition for the licensing requirements.
7-1. Because of the U.S. re-export control, our company is currently suffering the following
problems.
1(1) Extra management costs that are increasing year by year
(2) Losing business opportunities(3) Losing customers’ trust because of delayed delivery and failed customer services
Our company is consuming considerable amount of manpower for calculating de minimis,
checking ECCNs and responding to the inquiries from other companies. It’s also a big
burden that we must place staff members specialized in the U.S. laws and regulations. In
addition, we are always facing risks of losing business opportunities as well as customers’
trust, especially because the U.S. Government quite strictly controls exports to specificcountries of concern. We have recently had a grave problem, for example, that theoperation of our product exported lawfully to an E1 country stopped all of a sudden for alack of service parts. Actually, we couldn’t supply the parts to the country because thosewere U.S.-origin items.
7-2. Also, we have other problems related materials sourcing. Our company decides
procurement sources based on Quality, Cost and Delivery (QCD), and never decides sourcecompanies based simply on the countries of origin. Due to extra management costs andlosing business opportunities, however, the cases in which we choose non-U.S. sources
tends to increase in the future, if the QCD level is equal between U.S. and non-U.S.
companies. Note that extra costs that incur due to the U.S. re-export control are especiallyhigh in design and production control sections. Of course, we will not elect U.S.-origin
products if those are very sensitive, high-priced and strictly controlled items.
7-3. Therefore, we strongly request the U.S. government to consider:(1) First, excluding member nations of the international export control regimes from thecountries subject to the U.S. re-export control.
(2) Eliminating the control on products for specific applications including medical
equipment, some of which are now not exportable even if they are low-utility items
classified as EAR 99.
(3) Reducing the controls to those within the scope regulated by the international export
control regimes.
(4) Making it mandatory for U.S. exporters to inform ECCNs to foreign importers so thatthe extra burden can be reduced.
8. The U.S. re-export control is absolutely unjustifiable because, we believe, it not only is aviolation of the international law but also imposes dual burden on non-U.S. exporters.
While U.S. exporters are required only to comply with the U.S. export control regulations,non-U.S. exporters are required: (1) to comply with their national regulations, (2) to judge
if the export transaction is subject to the U.S. regulations or not, and (3) to comply with
the U.S. regulations if so judged. Especially in regard to the item (2), we cannot make thejudgment correctly unless there exists an effective system of giving necessary information
like ECCNs and others without failure to the importers.
In reality, however, there’s no such system at all, and we are all forced to make extra
efforts ourselves to get such information from U.S. suppliers, who are sometimes reluctant,or even unable, to respond. Or the information we get from them is sometimes unreliable.
This directly means that the U.S re-export control is an unfair system for non-U.S.
exporters. Therefore, we naturally try to avoid using U.S.-origin items as far as possible2

regardless of their sensitivity.
9. Nobody will doubt that an exporter of a country must comply only with its national export
control laws and regulations, and should not be required to comply with those of any othercountries. The extraterritorial application of the U.S. export control regulations is not
simply a matter of whether we elect U.S.-origin items or not, but is forcing exporters of all
non-U.S. countries to make unnecessary efforts to learn and understand the regulations
themselves. The U.S. Government must be aware that for a non-U.S. company, justpromoting awareness of the U.S. re-export control among its employees incurs
non-negligible costs. Imagine what would happen if every country starts applying its
national export control laws and regulations to all other countries in the world.
10. If the U.S. Government intends to apply its re-export control to other countries, it must,first of all, promote awareness of the control among its own people so that it can be
implemented efficiently and effectively.
Presently, there are few U.S. suppliers who can reply the ECCNs of their own products to
our inquiries. Moreover, the U.S. Government should realize that many of the small- andmedium-sized companies in the U.S. are even not aware of “EAR” or “ECCN.”
Why do we Japanese companies have to teach the U.S. export control laws and regulations
to American companies? As long as the U.S. Government applies its export control laws
and regulations extraterritorially, it must take full responsibility for teaching its own
people how those are regulated, including its instruction to inform relevant ECCNs totheir foreign importers.
11-1. We don’t think the U.S. authority should control short-distance communication
technologies like bluetooth and WLAN that are widely available now in the world. We
believe those should be classified just EAR 99.
11-2. We are sometimes doubtful if U.S. companies themselves are knowledgeable about
their own regulations. They are even uncertain about classification of their own products.
11-3. The extraterritorial application of the U.S. export control laws and regulations areunacceptable, unless implemented within a framework of government-to-government
agreement.
11-4. The unilateral application of the U.S. export control laws and regulations to othercountries is, in a sense, a violation of the international law.
11-5. Should there be any necessity to include an extraterritoriality in the internationalframework of export controls, the items subject to the extraterritorial control should be
limited to arms or other high-tech items, eliminating the condition of whether the items
are U.S-origin or not. (We don’t agree that U.S. products are the most advanced in theworld.) In that sense, we suggest that how such extraterritorial elements of the control
should be dealt with must be decided at the place of the Wassenaar Arrangement (WA).
(We understand such is part of the list control.)
11-6. For us Japanese exporters, it is quite doubtful if the U.S. re-export control is really3effective as a means of preventing any illicit diversions of U.S.-origin items.
11-7. Control on re-exports to the exporter’s overseas affiliates, or intra-company transfers,
should be relaxed.
11-8. The U.S. re-export control should not be applied blindly to the whole world without
considering each country’s security status. At least, member countries of the multilateralexport control regimes should be excluded from the control.
11-9. The biggest burden on non-U.S. companies in complying with the U.S. re-export
control is to get the information of relevant ECCNs from U.S. suppliers. If the U.S.
Government intends to continue its re-export control, it must at least make it mandatory
for U.S. exporters to inform the ECCNs to their foreign importers.
11-10. To comply with the U.S. re-export control, we must also consider the element of the“deemed re-export.” If we reject to employ any person for a reason of his/her nationality
relating it to the U.S. control, then the person would come up with a bad impression about
the country.
11-11. The U.S. export control laws and regulations are too much complicated to understand.
Especially, the de minimis is a daunting rule because we are still struggling to find out
how we should implement it correctly.
12. Having fully owned subsidiary companies for sales and manufacturing in Germany andthe United States, we are operating our businesses globally supplying products to eachother as necessary. Whenever we source abroad carbon fiber products (part of our productrange) we check if they are controlled or not by the applicable export control laws of thecountry, taking it into consideration that such products are basically list controlled inJapan. In addition, we conduct the required classification ourselves referring to thetechnical data we received from the overseas suppliers. Especially, if they are U.S.-origin
items, we inform every customer that the products are controlled by both the Japaneseand the U.S. laws in order to avoid any illicit diversions. However, most customers,
domestic or overseas, are reluctant to buy the U.S.-origin products, or reject to buy them,for a reason of the U.S. re-export control, in which case we must offer products of otherorigin instead. We have some experiences in the past that it took more than six months to
obtain licenses from the BIS, during which our foreign customers cancelled their orders.
Also, it’s a big problem when we are required by the U.S. authority to obtain certification
documents from our importers, because it usually takes quite a long time, and they evenreject our requests some times. For those reasons, we are now considering to downgrade
the specifications of the U.S.-origin products to cross them out in our list of controlled
items.
13. Since we are a trading firm, it is basically not possible to change the products’ source
country from the United Stets to other countries once specified by our customers.
It is natural, however, that our foreign customers will have wider choices if the U.S.
re-export control disappears. Similarly, our sales staff will become more positive to sell
U.S.-origin products to our customers, domestic and overseas.
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14. Honestly, it is quite difficult for us to understand a country’s unilateral regulations
written in English.
15-1. Most of the Japanese exporters are faithfully complying with the U.S. re-export control
regulations, and are confirming even with domestic suppliers whether the product is
U.S.-origin or not, or if it is a direct product of any U.S. technology.
15-2. The additional burden of complying with the U.S. re-export control should be
eliminated since Japan is already implementing its national export controls as strictly as
the country.
16. We have no options of source countries for parts and components when developing ourleading edge products, in which case the applicable technology, not country of origin,comes to the top of the priority list. In our opinion, it is meaningless to apply the U.S.
re-export control to those countries in which export controls are poorly implemented. To
the contrary, however, it is also meaningless to apply them to those countries like Japanthat are already advanced in establishing own export control systems. However, if the U.S.
Government still insists on maintaining the extraterritorial application of its export
control laws and regulations, it should at least simplify and streamline the regulations sothat everybody can understand them without any difficulties.
17. In addition to do it based on the Japanese law, we conduct classification on all our
products based on the EAR, which is a dual burden on our company.
18. So far we have had no particular troubles in exporting our products that are U.S.-origin
or include U.S. contents. Rather, we sometimes have difficulties in classifying those thatare direct products of U.S. technology.
19. Countries that are members of the international export control regimes should be
excluded from the U.S. re-export control.
20. For our company, it’s a time and cost consuming task to implement the extra controls on
exports or procurement of products that contain U.S.-origin items or those that are direct
products of U.S. technology. What is most problematic in such transactions is that U.S.
suppliers sometimes have no ability to classify their own products, or the ECCNs given bythem are unreliable or incorrect. It is strongly requested, therefore, that the U.S.
authority establish an effective system to provide relevant ECCNs or USML category
numbers from American suppliers to foreign importers.
21. If the U.S. Government really wishes to push through its own export control laws andregulations to other countries, it must at least simplify and streamline the regulations
and provide useful services to help non-U.S. exporters implement them easily.
22. The U.S. Government should spend its energy not to apply its own re-export control toother countries, but to build up an appropriate international framework of export controlsthat must be implemented equally by all countries in the world, where the level of export
controls still varies from country to country.
523. Japan already has its national export control law and regulations, and no additional
control, whether it is U.S. re-export control, is necessary. However, suppose the U.S.
Government still wants to maintain the re-export control for any reasons, it should makeit simple enough for everybody to comply with. The present U.S. regulations are tootangled and complicated to understand.
24. Once imported to Japan, the goods, technology, or software comes under the jurisdictionof Japan, not of any third countries. It’s pure and simple.
25. Our company has just started implementing our controls to comply with the U.S.
re-export control. At this moment we are just responding to the requests from ourbusiness partners to issue a Letter of Assurance in relation to the U.S. control.
26. Some of our products include U.S. contents. The largest problem for us in complying with
the U.S. re-export control is the de minimis calculations. To identify U.S.-origin items outof thousand of parts and components contained in our product requires countless time andmoney. It’s our strong desire that countries that are excellent in export control compliance
be excluded from the U.S. re-export control. Moreover, we are now receiving increased
number of inquiries related to the EAR from our business partners, and they make suchinquiries not only associated with actual exports but also for their internal control purpose
only, which is adding rather meaningless costs to our company. Also, the U.S. Government
should realize the fact that we frequently get into troubles that our suppliers can’t answer
whether their parts and components are U.S.-origin items or not, or answer relevant
ECCNs themselves.
27-1. Recent revisions to the EAR make us feel that the regulations are becoming worse. The
long-awaited change in the de minimis rule dated on October 1, 2008, for example, turned
out to be undigested, and the introduction of the new concept of “bundled software” hasmade us foreign exporters even confused. We dare say that it would have been muchbetter if the BIS had done nothing in this respect.
27-2. Another example is the revision announced in the Federal Register, 74FR770, ofJanuary 8, 2009. With this revision, a new Note was added in respect to the end-user
based control related to Burma in Section 744.22 of the EAR, saying, “Entities owned
more than 50% by SDNs are themselves SDNs, even if not listed.” BIS referred to the
OFAC Guidance dated February 14, 2008 as a ground for this addition. But it is
impossible for us non-U.S. persons to reach the Guidance itself unless we go throughcumbersome steps of net searching. If the authority refers to any “Guidance,” it must, ofcourse, be publicly accessible without any difficulties. In addition, before saying “even if
not listed,” the BIS should publish “Entities owned more than 50% by SDNs” as “SDN
(BURMA).”
27-3. Whether the items are Japanese- or U.S.-origin, we will stop any exports if we havecome up with any concerns about their end-uses or end-users. But we must point to thefact—an essential part of security export control—that the circumstances of our customers,
who are third parties in third countries, will change as time passes. We, in the Export
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Control Division of our company, are responsible not only for preventing our products fromgoing to any evil hands but also for preventing ourselves getting involved in any legal
troubles. Besides conducting necessary screening on each export transaction, we must,
therefore, have a proper program for making ourselves ready to cope with any
emergencies. In this regard, while we may consult with the Japanese authority METI,
nobody in Japan wants to face any emergency issue that involves himself/herself in asituation of consulting with the U.S. Government. Therefore, as a simple mechanism, anincreasing number of Japanese companies will try to avoid using U.S.-origin products.
28-1 Countries that are implementing rigorous export controls based on national laws andregulations should be excluded from the U.S. re-export control.
28-2. If the U.S. Government really wants to prevent non-U.S. companies from illicitly
diverting U.S.-origin goods and technologies, it should implement the required control not
extraterritorially but within the framework of the agreements made in the international
export control regimes.
28-3. At least the U.S. Government should simplify its regulations and provide usefulservices to help non-U.S. companies comply with them easily.
29. Our company has so far had no cases of electing non-U.S. products for a reason of the U.S.
re-export control. But from now on, we will consider it as an important factor in selecting
foreign parts and components, because our company is now consuming increasing amountof time and money for dealing with the U.S. regulations.
30. If the U.S. Government forces other countries to comply with its export control laws andregulations extraterritorially, it must at least provide useful written guidance andface-to-face consulting services, both in each country’s language. The U.S. authority must
realize that in Japan CISTEC holds the U.S. re-export control seminar at least five times
each year. At each seminar an audience of several hundred people gets together at theplace. That involves quite a big money.
31. Most of the advanced countries are implementing export controls in accordance with theagreements made in the international export control regimes. Each country’s export
control regulations, therefore, should be decided within the international control
framework. However, if the U.S. Government wants to apply its own regulations to othercountries, it must first reform the complicated multi-agency regulatory system, where
different sets of regulations are involved, into one single set of regulations that should be
administered under one single authority. Further, the U.S. authority should provide
useful guidance written in Japanese if it forces us Japanese companies to comply with theregulations. Also, the U.S. government’s administration within the own country seems
very weak contrary to its strong outreach activities promoting foreign exporters’
awareness. Suffice it to say as evidence that U.S. suppliers, in many cases, can’t answer
relevant ECCNs of their own products to our inquiries. Therefore, under thesecircumstances, we’d better keep ourselves away from the U.S. re-export control by notusing U.S.-origin products, nor exporting any products that include U.S. contents.
Otherwise we can’t be hundred percent clean under the U.S. regulations.
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