[Federal Register Volume 65, Number 92 (Thursday, May 11, 2000)]
[Notices]
[Pages 30434-30438]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 00-11878]



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INTERNATIONAL TRADE COMMISSION


Summary of Commission Practice Relating to Administrative 
Protective Orders

AGENCY: U.S. International Trade Commission.

ACTION: Summary of Commission practice relating to administrative 
protective orders.

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SUMMARY: Since February 1991, the U.S. International Trade Commission 
(``Commission'') has issued an annual report on the status of its 
practice with respect to violations of its administrative protective 
orders (``APOs'') in investigations under Title VII of the Tariff Act 
of 1930 in response to a direction contained in the Conference Report 
to the Customs and Trade Act of 1990. Over time, the Commission has 
added to its report discussions of APO breaches in Commission 
proceedings other than Title VII and violations of the Commission's 
rule on bracketing business proprietary information (``BPI'') (the 
``24-hour rule''), 19 CFR 207.3(c). This notice provides a summary of 
investigations of breaches in Title VII investigations for the period 
ending December 31, 1999. There were no investigations of breaches for 
other Commission proceedings or for 24-hour rule violations during that 
period. The Commission intends that this report educate representatives 
of parties to Commission proceedings as to some specific types of APO 
breaches encountered by the Commission and the corresponding types of 
actions the Commission has taken.

FOR FURTHER INFORMATION CONTACT: Carol McCue Verratti, Esq., Office of 
the General Counsel, U.S. International Trade Commission, telephone 
(202) 205-3088. Hearing impaired individuals are advised that 
information on this matter can be obtained by contacting the 
Commission's TDD terminal at (202) 205-1810. General information 
concerning the Commission can also be obtained by accessing its 
Internet server (http://www.usitc.gov).

SUPPLEMENTARY INFORMATION: Representatives of parties to investigations 
conducted under Title VII of the Tariff Act of 1930 may enter into APOs 
that permit them, under strict conditions, to obtain access to BPI of 
other parties. See 19 U.S.C. 1677f; 19 CFR 207.7. The discussion below 
describes APO breach investigations that the Commission has completed, 
including a description of actions taken in response to breaches. The 
discussion covers breach investigations completed during calendar year 
1999.
    Since 1991, the Commission has published annually a summary of its 
actions in response to violations of Commission APOs and the 24-hour 
rule. See 56 FR 4846 (Feb. 6, 1991); 57 FR 12,335 (Apr. 9, 1992); 58 FR 
21,991 (Apr. 26, 1993); 59 FR 16,834 (Apr. 8, 1994); 60 FR 24,880 (May 
10, 1995); 61 FR 21,203 (May 9, 1996); 62 FR 13,164 (March 19, 1997); 
63 FR 25064 (May 6, 1998); 64 FR 23355 (April 30, 1999). This report 
does not provide an exclusive list of conduct that will be deemed to be 
a breach of the Commission's APOs. APO breach inquiries are considered 
on a case-by-case basis.
    As part of the effort to educate practitioners about the 
Commission's current APO practice, the Commission Secretary issued in 
April 1996 a revised edition of An Introduction to Administrative 
Protective Order Practice in Antidumping and Countervailing Duty 
Investigations (Pub. No. 2961). This document is available upon request 
from the Office of the Secretary, U.S. International Trade Commission, 
500 E Street, SW, Washington, DC 20436, tel. (202) 205-2000.

I. In General

    The current APO form for antidumping and countervailing duty 
investigations, which the Commission has used since March 1995, 
requires the applicant to swear that he or she will:
    (1) Not divulge any of the BPI obtained under the APO and not 
otherwise available to him, to any person other than--
    (i) personnel of the Commission concerned with the investigation,
    (ii) the person or agency from whom the BPI was obtained,
    (iii) a person whose application for disclosure of BPI under this 
APO has been granted by the Secretary, and
    (iv) other persons, such as paralegals and clerical staff, who (a) 
are employed or supervised by and under the direction and control of 
the authorized applicant or another authorized applicant in the same 
firm whose application has been granted; (b) have a need thereof in 
connection with the investigation; (c) are not involved in competitive 
decisionmaking for the interested party which is a party to the 
investigation; and (d) have submitted to the Secretary a signed 
Acknowledgment for Clerical Personnel in the form attached hereto (the 
authorized applicant shall sign such acknowledgment and will be deemed 
responsible for such persons' compliance with the APO);
    (2) Use such BPI solely for the purposes of the Commission 
investigation [or for binational panel review of such Commission 
investigation or until superceded by a judicial protective order in a 
judicial review of the proceeding];
    (3) Not consult with any person not described in paragraph (1) 
concerning BPI disclosed under this APO without first having received 
the written consent of the Secretary and the party or the 
representative of the party from whom such BPI was obtained;
    (4) Whenever materials (e.g., documents, computer disks, etc.) 
containing such BPI are not being used, store such material in a locked 
file cabinet, vault, safe, or other suitable container (N.B.: storage 
of BPI on so-called hard disk computer media is to be avoided, because 
mere erasure of data from such media may not irrecoverably destroy the 
BPI and may result in violation of paragraph C of the APO);
    (5) Serve all materials containing BPI disclosed under this APO as 
directed by the Secretary and pursuant to section 207.7(f) of the 
Commission's rules;
    (6) Transmit such document containing BPI disclosed under this APO:
    (i) with a cover sheet identifying the document as containing BPI,
    (ii) with all BPI enclosed in brackets and each page warning that 
the document contains BPI,
    (iii) if the document is to be filed by a deadline, with each page 
marked ``Bracketing of BPI not final for one business day after date of 
filing,'' and
    (iv) if by mail, within two envelopes, the inner one sealed and 
marked ``Business Proprietary Information--To be opened only by [name 
of recipient]'', and the outer one sealed and not marked as containing 
BPI;
    (7) Comply with the provision of this APO and section 207.7 of the 
Commission's rules;
    (8) Make true and accurate representations in the authorized 
applicant's application and promptly notify the Secretary of any 
changes that occur after the submission of the application and that 
affect the representations made in the application (e.g., change in 
personnel assigned to the investigation);
    (9) Report promptly and confirm in writing to the Secretary any 
possible breach of the APO; and
    (10) Acknowledge that breach of the APO may subject the authorized 
applicant and other persons to such sanctions or other actions as the 
Commission deems appropriate including the administrative sanctions

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and actions set out in this APO. The APO further provides that breach 
of protective order may subject an applicant to:
    (1) Disbarment from practice in any capacity before the Commission 
along with such person's partners, associates, employer, and employees, 
for up to seven years following publication of a determination that the 
order has been breached;
    (2) Referral to the United States Attorney;
    (3) In the case of an attorney, accountant, or other professional, 
referral to the ethics panel of the appropriate professional 
association;
    (4) Such other administrative sanctions as the Commission 
determines to be appropriate, including public release of or striking 
from the record any information or briefs submitted by, or on behalf 
of, such person or the party he represents; denial of further access to 
business proprietary information in the current or any future 
investigations before the Commission; and issuance of a public or 
private letter of reprimand; and
    (5) Such other actions, including but not limited to, a warning 
letter, as the Commission determines to be appropriate.
    Commission employees are not signatories to the Commission's APOs 
and do not obtain access to BPI through APO procedures. Consequently, 
they are not subject to the requirements of the APO with respect to the 
handling of BPI. However, Commission employees are subject to strict 
statutory and regulatory constraints concerning BPI, and face 
potentially severe penalties for noncompliance. See 18 U.S.C. 1905; 
Title 5, U.S. Code; and Commission personnel policies implementing the 
statutes. Although the Privacy Act (5 U.S.C. 552a) limits the 
Commission's authority to disclose any personnel action against agency 
employees, this should not lead the public to conclude that no such 
actions have been taken.
    An important provision of the Commission's rules relating to BPI is 
the ``24-hour'' rule. This rule provides that parties have one business 
day after the deadline for filing documents containing BPI to file a 
public version of the document. The rule also permits changes to the 
bracketing of information in the proprietary version within this one-
day period. No changes-- other than changes in bracketing--may be made 
to the proprietary version. The rule was intended to reduce the 
incidence of APO breaches caused by inadequate bracketing and improper 
placement of BPI. The Commission urges parties to make use of the rule. 
If a party wishes to make changes to a document other than bracketing, 
such as typographical changes or other corrections, the party must ask 
for an extension of time to file an amendment document pursuant to 
section 201.14(b)(2) of the Commission's rules.

II. Investigations of Alleged APO Breaches

    Upon finding evidence of a breach or receiving information that 
there is a reason to believe one has occurred, the Commission Secretary 
notifies relevant offices in the agency that an APO breach 
investigation file has been opened. Upon receiving notification from 
the Secretary, the Office of General Counsel (OGC) begins to 
investigate the matter. The OGC prepares a letter of inquiry to be sent 
to the alleged breacher over the Secretary's signature to ascertain the 
alleged breacher's views on whether a breach has occurred. If, after 
reviewing the response and other relevant information, the Commission 
determines that a breach has occurred, the Commission often issues a 
second letter asking the breacher to address the questions of 
mitigating or aggravating circumstances and possible sanctions or other 
actions. The Commission then determines what action to take in response 
to the breach. In some cases, the Commission has determined that 
although a breach has occurred, sanctions are not warranted, and 
therefore has found it unnecessary to issue a second letter concerning 
what sanctions might be appropriate. Instead, it issues a warning 
letter to the individual. The Commission retains sole authority to 
determine whether a breach has occurred and, if so, the appropriate 
action to be taken.
    The records of Commission investigations of alleged APO breaches in 
antidumping and countervailing duty cases are not publicly available 
and are exempt from disclosure under the Freedom of Information Act, 5 
U.S.C. 552, section 135(b) of the Customs and Trade Act of 1990, and 19 
U.S.C. 1677f(g).
    The breach most frequently investigated by the Commission involves 
the APO's prohibition on the dissemination of BPI to unauthorized 
persons. Such dissemination usually occurs as the result of failure to 
delete BPI from public versions of documents filed with the Commission 
or transmission of proprietary versions of documents to unauthorized 
recipients. Other breaches have included: the failure to bracket 
properly BPI in proprietary documents filed with the Commission; the 
failure to report immediately known violations of an APO; and the 
failure to supervise adequately non-legal personnel in the handling of 
BPI.
    Counsel participating in Title VII investigations have recently 
reported to the Commission two potential breaches involving the 
electronic transmission of public versions of documents. In both cases, 
the document transmitted appears to be a public document with BPI 
omitted from brackets. However, the BPI is actually retrievable by 
manipulating codes in the computer software programs. The Commission is 
currently conducting investigations of these potential breaches and has 
not made any determination at this time.
    The Commission advised in the preamble to the notice of proposed 
rulemaking in 1990 that it will permit authorized applicants a certain 
amount of discretion in choosing the most appropriate method of 
safeguarding the confidentiality of the information. However, the 
Commission cautioned authorized applicants that they would be held 
responsible for safeguarding the confidentiality of all BPI to which 
they are granted access and warned applicants about the potential 
hazards of storage on hard disk. The caution in that preamble is 
restated here:

    [T]he Commission suggests that certain safeguards would seem to 
be particularly useful. When storing business proprietary 
information on computer disks, for example, storage on floppy disks 
rather than hard disks is recommended, because deletion of 
information from a hard disk does not necessarily erase the 
information, which can often be retrieved using a utilities program. 
Further, use of business proprietary information on a computer with 
the capability to communicate with users outside the authorized 
applicant's office incurs the risk of unauthorized access to the 
information through such communication. If a computer malfunctions, 
all business proprietary information should be erased from the 
machine before it is removed from the authorized applicant's office 
for repair. While no safeguard program will insulate an authorized 
applicant from sanctions in the event of a breach of the 
administrative protective order, such a program may be a mitigating 
factor. Preamble to notice of proposed rulemaking, 55 Fed. Reg. 
24,100, 21,103 (June 14, 1990).

    Sanctions for APO violations serve two basic interests: (a) 
preserving the confidence of submitters of BPI in the Commission as a 
reliable protector of BPI; and (b) disciplining breachers and deterring 
future violations. As the Conference Report to the Omnibus Trade and 
Competitiveness Act of 1988 observed, ``the effective enforcement of 
limited disclosure under administrative protective order depends in 
part on the extent to which private parties have

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confidence that there are effective sanctions against violation.'' H.R. 
Conf. Rep. No. 576, 100th Cong., 1st Sess. 623 (1988).
    The Commission has worked to develop consistent jurisprudence, not 
only in determining whether a breach has occurred, but also in 
selecting an appropriate response. In determining the appropriate 
response, the Commission generally considers mitigating factors such as 
the unintentional nature of the breach, the lack of prior breaches 
committed by the breaching party, the corrective measures taken by the 
breaching party, and the promptness with which the breaching party 
reported the violation to the Commission. The Commission also considers 
aggravating circumstances, especially whether persons not under the APO 
actually read the BPI. The Commission considers whether there are prior 
breaches by the same person or persons in other investigations and 
multiple breaches by the same person or persons in the same 
investigation.
    The Commission's rules permit economists or consultants to obtain 
access to BPI under the APO if the economist or consultant is under the 
direction and control of an attorney under the APO, or if the economist 
or consultant appears regularly before the Commission and represents an 
interested party who is a party to the investigation. 19 CFR 
207.7(a)(3)(B) and (C). Economists and consultants who obtain access to 
BPI under the APO under the direction and control of an attorney 
nonetheless remain individually responsible for complying with the APO. 
In appropriate circumstances, for example, an economist under the 
direction and control of an attorney may be held responsible for a 
breach of the APO by failing to redact APO information from a document 
that is subsequently filed with the Commission and served as a public 
document. This is so even though the attorney exercising direction or 
control over the economist or consultant may also be held responsible 
for the breach of the APO.

III. Specific Investigations in Which Breaches Were Found

    The Commission presents the following case studies to educate users 
about the types of APO breaches found by the Commission. The case 
studies provide the factual background, the actions taken by the 
Commission, and the factors considered by the Commission in determining 
the appropriate actions. The Commission has not included some of the 
specific facts in the descriptions of investigations where disclosure 
of such facts could reveal the identity of a particular breacher. Thus, 
in some cases, apparent inconsistencies in the facts set forth in this 
notice result from the Commission's inability to disclose particular 
facts more fully.
    Case 1. At the direction of the lead attorney in an investigation, 
a law firm secretary sent copies of a hearing transcript to three of 
the law firm's clients who were nonsignatories to the APO. The lead 
attorney became aware of a potential breach of the APO when one of the 
clients advised him that he had received the in camera version of the 
hearing transcript. The attorney made arrangements to have one 
transcript returned without being reviewed and a second returned 
without the envelope being opened. The attorney had Federal Express 
intercept the third copy before it was delivered; it was returned 
unopened. The attorney informed the Commission's Secretary ten days 
after becoming aware of the potential breach. The Commission determined 
that the lead attorney and a secretary had breached the APO by 
transmitting the in camera transcript of the Commission hearing to 
persons who were not signatories of the APO. In reaching its decision 
to issue warning letters to the attorney and the secretary, the 
Commission considered that this was the only breach in which they had 
been involved, the breach was unintentional, prompt action was taken to 
remedy the breach, and there was no information available to suggest 
that the BPI disclosed was actually reviewed by persons not already on 
the APO. In addition, the Commission noted in the warning letter to the 
secretary that she had been acting under the direction of an attorney. 
The 10-day delay in advising the Commission of the breach was mitigated 
by the fact that the attorney had been out of the country and prompt 
action had been taken to retrieve the documents. Noting that the breach 
arose from a systematic omission of procedures at the law firm for 
checking Commission documents for BPI, the Commission recommended that 
the attorney and the firm review their practices for handling 
Commission documents under the Commission's administrative protective 
order procedures in order to prevent a recurrence of this type of 
incident. The Commission determined that the other attorney in the law 
firm who was a signatory of the APO did not breach the APO.
    Case 2. An attorney for a party to a Commission investigation 
informed the Commission by letter that a lead attorney representing 
another party to the investigation failed to comply with the return or 
destruction requirements of the APO. Specifically, the lead attorney 
failed to destroy the APO documents within 60 days after completion of 
the investigation; he failed to provide certification of destruction 
from all attorneys in his firm on the APO; and he provided a 
certificate for an attorney who was not on the APO. The lead attorney 
did file a certificate of destruction more than two years later than 
required by the APO.
    In responding to the Commission's letter of inquiry, the attorney 
admitted that there had been a technical violation of the APO, but he 
explained that the material had been mistakenly retained during the 
period that the Department of Commerce investigation was under appeal. 
During that time the material had been secured in a locked file 
cabinet, no unauthorized persons viewed the material, and it was 
destroyed promptly at the conclusion of the Commerce appeal process. He 
also explained that one attorney had left the firm and was unavailable 
to provide a certificate of destruction. The non-APO attorney who had 
signed a certificate of destruction actually had no access to the APO 
materials.
    The Commission determined that a breach had occurred for failing to 
meet the deadlines in the APO to return or destroy and for failing to 
certify to the destruction of the materials issued to him under the 
APO. The Commission noted that the deadlines in the APO are clearly 
stated and the waiver of the 60-day destruction or return deadline is 
provided for only in the case of an appeal of the Commission 
determination, not for an appeal of a Commerce determination. The 
Commission issued a private letter of reprimand to the attorney. The 
letter dictated additional restrictions and requirements with which the 
lead attorney must comply until the record of the breach is expunged, 
two years from the date of the private letter of reprimand. In reaching 
its decision on the sanction, the Commission considered that this was 
the third APO breach by this attorney within a short period of time and 
that this attorney appears before the Commission on a regular basis. 
Noting that the breach did not appear to have involved willful 
misbehavior or gross negligence, it was decided that a public letter of 
reprimand was not called for in that instance. The attorney was warned, 
however, that if he is found to have committed another APO breach 
before his prior breaches are expunged, the Commission would consider a 
more public form of sanction.

[[Page 30437]]

    Case 3. Counsel in an investigation filed the public version of a 
document which contained BPI. The BPI had not been bracketed in the 
confidential version of the brief, and, therefore, was not redacted 
from the public version of the document. Once counsel became aware of 
the potential breach, they immediately contacted counsel identified on 
both the public and APO service lists and instructed them to destroy 
the pages containing the unredacted BPI. On the next business day, 
counsel notified the Commission's Secretary of the possible breach and 
filed corrected pages with the parties and with the Commission.
    The Commission determined that two of the three attorneys who 
signed the document breached the APO by failing to redact BPI from a 
public version of the document. In making its determination to issue a 
private letter of reprimand to the lead attorney, the Commission 
considered that, although the breaches appeared to have been 
inadvertent and the attorney made prompt efforts to limit the 
possibility of disclosure to persons not already under the APO, the 
attorney was involved in multiple breaches over a relatively short 
period.
    In determining not to sanction the second attorney, but instead to 
issue a letter of warning to that attorney, the Commission considered 
that this was the only breach in which this attorney had been involved, 
the breach was unintentional, and that prompt action was taken to 
remedy the breach.
    The Commission determined that the third attorney whose name 
appeared on the document did not breach the APO because he did not have 
any responsibility in the preparation or filing of the document.
    Case 4. Counsel representing a party to an investigation filed a 
public document which contained a page from which bracketed information 
had not been redacted. Counsel discovered the error, contacted the 
Commission's Office of the Secretary the morning after the filing, and 
corrected the public version of the document before it was placed on 
file for public inspection. Counsel stated in their affidavits that the 
error was discovered and corrected prior to service of the public 
version on the other parties to the investigation, so that no 
unauthorized person actually saw business proprietary information. In 
their response to the Commission inquiry, counsel contended that no 
breach occurred because, although the information in question was 
bracketed in the documents they cited, it was publicly available from 
other sources.
    The Commission determined that three attorneys breached the APO. 
Two of the attorneys failed to redact certain bracketed information 
which contained specific statements not publicly available. They did 
not breach the APO with regard to their failure to redact information 
which was in the public domain at the time they filed their document 
with the Commission. The Commission determined that the third attorney, 
the lead attorney, breached the APO by failing to provide adequate 
supervision over the handling of BPI or to delegate supervisory 
authority in a reasonable manner. In determining to issue private 
letters of reprimand to the three attorneys, the Commission considered 
that the one of the attorneys was involved in three separate breaches 
and two of the attorneys were involved in two separate breaches of 
Commission APOs within a short period of time. Mitigating factors were 
that they reported and corrected the breach promptly and that the firm 
strengthened its APO procedures subsequent to the breaches. With regard 
to the lead attorney, the Commission considered that delegating final 
authority for APO compliance to an attorney who had committed two 
breaches over a short period of time and a junior attorney who had 
recently committed an APO breach was not reasonable when there was 
another experienced attorney available who could have overseen their 
work. Because one of the attorneys had been involved in three separate 
breaches over a short period of time and other attorneys in his firm 
had also been involved in multiple breaches during the same period, the 
Commission required that the attorney, prior to his next appearance in 
a Commission investigation, prepare and conduct an APO compliance class 
for all firm attorneys and staff, and submit to the Commission any 
materials used in the class and certifications that the class occurred 
and that all such attorneys and staff attended. The Commission 
determined that an attorney and a law clerk who were not involved in 
the preparation of the document did not breach the APO.
    Case 5. An attorney and an economic consultant representing a party 
in a Commission investigation filed a public document which contained 
unbracketed and undeleted BPI. The potential breach was discovered by 
both the Commission staff and the counsel on the day the document was 
filed, and counsel took immediate action to retrieve all of the service 
copies of the unbracketed document and destroy them. The error was 
discovered and remedial action was taken quickly enough that the 
document filed with the Commission was not made available to the public 
either as hard copy or through the electronic system.
    The Commission determined that the attorney and the economic 
consultant employed by the law firm had breached the APO by not 
protecting BPI. They mislabeled the document containing BPI as public; 
they failed to place a warning on each page of the document that 
contained BPI; and they failed to bracket the BPI and remove it from a 
public version of the document. In reaching its breach determination, 
the Commission considered that failure to follow the APO rules and 
thereby leaving BPI unprotected and potentially available to be 
disclosed is sufficient to constitute a breach.
    The Commission did not issue a sanction but instead issued warning 
letters to the attorney and economic consultant. In reaching its 
decision on sanctions, the Commission considered that the breach was 
unintentional, neither the attorney nor the economist had previously 
breached a Commission APO, and the law firm acted quickly to mitigate 
any harmful effects of the breach. The Commission determined that two 
attorneys, one of whom was the lead attorney, did not breach the APO 
because they were not involved in the preparation, review, signing or 
filing of the document. In its letter to the lead attorney, the 
Commission acknowledged his immediate action to mitigate the effects of 
the errors which led to the breach.
    Case 6. An associate with a law firm representing a party to an 
investigation prepared an outline of testimony for a client/witness who 
was a nonsignatory to the APO and, although he had been advised earlier 
in the day by the lead attorney that the information was BPI, he 
included the BPI covered under the APO in the outline. The associate 
then sent an e-mail message to the client with the outline as an 
attachment. The potential breach was discovered by the lead attorney 
when he reviewed the outline the next day, and he immediately took 
steps to retrieve and replace the outline containing the BPI before it 
was read by the nonsignatory and to inform the Commission Secretary of 
the potential breach.
    The Commission determined that the associate attorney breached the 
APO by transmitting to a client who was not a signatory to the APO a 
document which he prepared that contained BPI. In reaching its decision 
to issue a warning letter, the Commission considered that this was the 
only breach in which the attorney was involved, that the breach

[[Page 30438]]

was unintentional, that prompt action was taken to remedy the breach, 
and that neither the client nor any other non-signatory of the APO 
actually read the document. The Commission determined that the other 
attorneys on the APO, including the lead attorney, did not breach the 
APO because they did not participate in the breach.

IV. Investigations in Which No Breach Was Found

    During 1999, the Commission completed two investigations in which 
no breach was found.
    Case 1. An attorney in an investigation filed a public version of a 
document which contained bracketed but unredacted information. The 
bracketed information consisted of citations to submissions by two 
parties to the investigation which were contained in a footnote of the 
document. The Commission determined that the attorney did not breach 
the APO by failing to redact the information because the information 
revealed was publicly available, and the only information which could 
be inferred from the citations was otherwise publicly available.
    Case 2. An attorney in an investigation obtained under an APO 
release of documents a copy of a telephone note containing a summary of 
a conversation between a Commission employee and an employee of the 
Department of Commerce (Commerce). The attorney called the Commerce 
employee and discussed the contents of the note with him. The Commerce 
employee advised the Commission employee of his concern that the 
attorney's call involved a possible breach of the APO. The Commission 
determined that the attorney did not breach the APO because the 
Commerce employee was the person who provided the BPI to the 
Commission, and an attorney's discussion of information released under 
the APO with the person or agency from whom the BPI was obtained is 
permissible.

    Issued: May 5, 2000.

    By order of the Commission.
Donna R. Koehnke,
Secretary.
[FR Doc. 00-11878 Filed 5-10-00; 8:45 am]
BILLING CODE 7020-02-P