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Program Materials
James R. Jenkins - Senior Vice President & General Counsel, Deere & Company; Anastasia D. Kelly - Senior Vice President & General Counsel, Sears, Roebuck and Co.; William B. Lytton - Executive Vice President & General Counsel, Tyco International; John H. Ogden - General Counsel, Coperion Corporation
10/01/2002

Discusses the evolving role of corporate counsel, adding and assessing the value of law departments, and communicating that value. Also discusses synchronizing business & legal priorities.

Resource Details
Interest Area: Law Department Management
Source: Meetings
Region: United States
… WAY: TRANSFORMING THE IN-HOUSE PROFESSION This material is protected by copyright. Copyright © 2002 various authors … at ACCA: 202/293-4103, ext. 326; merklinger@acca.com 402 Chair's Choice Best of ACCA '00 & '01 Adding Value to … vice president and general counsel, is chief legal officer for Deere & Company with worldwide executive management …
Program Materials
N. Cornell Boggs III -- americas regional counsel, Intel Corporation; Rhynette N. Hurd -- counsel-information technology, International Paper Company; Eileen Morgan Johnson -- general counsel, National Wildlife Federation; Jessica R. Shawl -- legal web team manager, Intel Corporation
10/01/2002

Discusses benefits of using intranets and what types of information to display on them.

… WAY: TRANSFORMING THE IN-HOUSE PROFESSION This material is protected by copyright. Copyright © 2002 various authors … at ACCA: 202/293-4103, ext. 326; merklinger@acca.com 105 Best Practices Using Intranets & Websites N. Cornell … III N. Cornell Boggs III is the Americas regional counsel for Intel Corporation, based in Folsom, CA. In this capacity, …
Program Materials
Bob Robinson - general counsel and vice president of business development, Renew Data Corporation; Randy S. Segal - senior vice president, general counsel, and secretary, Hughes Network Systems; D.C. Toedt III - vice president, general counsel, and secretary, BindView Corporation
10/01/2002

General information and tips on getting up to speed as a new general counsel, including employment/HR issues, IP issues, and contracts.

Resource Details
Source: Meetings
Region: United States
… WAY: TRANSFORMING THE IN-HOUSE PROFESSION This material is protected by copyright. Copyright © 2002 various authors … at ACCA: 202/293-4103, ext. 326; merklinger@acca.com 809 Best of ACCA '01 Top 10 Things You Should Know Your … must exercise caution in applying existing principles to website content, postings (in general and during an …
Program Materials
Simon McLeod
07/15/2002

Presented at ACCA/GCCA European chapter 2002 Annual Meeting. This presentation was part of the program on buying distressed companies.

Resource Details
Source: Meetings
Region: United States
… Meeting. This presentation was part of the program on buying distressed companies. Author Simon McLeod Primary File … … BUYING DISTRESSED COMPANIES By Simon McLeod 2What is a Distressed Company? • Financial position of the target … – misfeasance – breach of duty – defences available for wrongful trading – reasonable prospect of avoiding …
Program Materials
James R. Jenkins - Senior Vice President & General Counsel, Deere & Company; Anastasia D. Kelly - Executive Vice President & General Counsel, Sears, Roebuck and Co.; William B. Lytton - Senior Vice President & General Counsel, International Paper Company; Marco Pagni - Vice President & General Counsel-International, McDonald’s Corporation
10/01/2001

Program Material: Sample Client Surveys (Deere & Co., Sears, International Paper Law Depts.)

Resource Details
Interest Area: Law Department Management
Source: Meetings
Region: United States
… … ACCA’S 2001 ANNUAL MEETING ADDING VALUE This material is protected by copyright. Copyright © 2001 various authors … at ACCA: 202/293-4103, ext. 326; merklinger@acca.com 010/020 Chair’s Choice: Adding Value to Your Corporations … To complete the survey, log onto Altman Weil’s secure website, using the password “Sears” and your first initial …
Program Materials
ACC
01/01/2000

Presented at ACC's Annual Meeting 2000; Program - Defining the IP Attorney’s Role in the E-Commerce Revolution

… … Page 1AM2KProgram 1/10/2009 10:23:43 AMhttp://www2.acc.com/education2000/am/cm00/html/autofinance.html DELIVERING … (USPTO), and specifically, the workgroup responsible for examining patent applications in automated business data … business data processing, the transition this technology is beginning, and the initiatives the USPTO is engaged in to …
Program Materials
ACC; The Affiliates
10/01/2000

Program - Career Development: Marketing for the Mature Job Seeke Presented at ACCA’s Annual Meeting 2000

… Program - Career Development: Marketing for the Mature Job Seeke Presented at ACCA’s Annual Meeting … … Page 1AM2KProgram 1/10/2009 11:38:40 AMhttp://www2.acc.com/education2000/am/cm00/html/careeropt.html DELIVERING … of ACCA or any of its lawyers, unless so stated. This is not intended as definitive statement on the subject but a …
Program Materials
ACC
01/01/2000

Presented at ACC’s Annual Meeting 2000; Program - A Comparative Analysis between U.S. and European Competition Laws

Resource Details
Interest Area: Compliance and Ethics
Source: Meetings
Region: United States
… … Page 1AM2KProgram 1/10/2009 11:39:22 AMhttp://www2.acc.com/education2000/am/cm00/html/comnotice.html DELIVERING … ACCA'S 2000 ANNUAL MEETING (Only the published text is authentic. Published in the OJ C 207 of 18.07.1996) … ultimately result in increased prices and reduced choice for the consumer. Furthermore, they not only prejudice the …
Program Materials
Michael Butler -- attorney, UPS; Mary Mack -- corporate technology counsel, Fios, Inc.; Kenneth Rashbaum -- consultant, Fios, Inc.; Marc Vockell -- senior counsel, litigation, Dell, Inc.
10/19/2009

With the increase of corporate globalization, potentially relevant evidence can reside in many countries. From foreign language and computer language barriers, to privacy laws and safe harbor issues, counsel encounter numerous challenges when litigation is anticipated. It’s critical to understand the rules and regulations that govern the access to and the use of foreign data. This session will examine ethical issues and practical solutions for cross-border e-discovery, including e-discovery vs. e-disclosure — managing conflicts between US and foreign laws and procedures, cross-border, multi-language e-discovery requirements — managing data from collection and translation through review and production, and cost containment — managing the costs of e-discovery while data volumes and legal complexities explode.

Resource Details
Source: Meetings
Region: Australia, Belgium, Brazil, Canada, China, Colombia, Czech Republic, Ecuador, European Union, France, Germany, Hungary, Italy, Japan, Paraguay, Peru, Poland, Romania, Singapore, South Africa, South Korea, Spain, United Kingdom, United States
… counsel encounter numerous challenges when litigation is anticipated. It’s critical to understand the rules and … requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC … 20. Information on all of these can be found on Fios’ website at www.fiosinc.com. Mary Mack “I continue to think …
Program Materials
Brennan Holland -- counsel, Litton Loan Servicing; Joseph Napoli -- senior general attorney-corporate, United States Steel Corporation; Mark Sessions -- general counsel, NovaTel Ltd.; Ronald Vaske -- attorney, Lindquist & Vennum
10/19/2009

This program will discuss legal issues that arise in a tight credit market. Negotiating security arrangements, factoring defaults arising from failures of guarantors and back up credit arrangements, reductions in credit limits, are among the topics to be examined.

Resource Details
Interest Area: Financial Services
Source: Meetings
Region: United States
… requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC … sponsors, and/or the ACC. This ACC Annual Meeting material is not intended as a definitive statement on the subject … Agent that such information has been posted on Borrowe r’s website on the Internet at www.??? ? ? ?.com , at …
Program Materials
Jane Freedman -- secretary and associate general counsel, One Beacon Insurance Company Ltd.; Richard J. Morrison -- associate general counsel and secretary, Nstar Electric & Gas Corporation; Nicolas J. Pace -- senior vice president and deputy general counsel, Amerigroup Corporation; Michael Wu -- general counsel, Rosetta Stone
10/19/2009


Have you ever wondered what are the roles and responsibilities of a corporate secretary? Experienced corporate secretaries and board counsel will offer tips and views, with a significant portion of the session devoted to Q&A. This session will be a great opportunity to get your questions answered and benchmark with your peers.

Resource Details
Source: Meetings
Region: United States
… requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC … sponsors, and/or the ACC. This ACC Annual Meeting material is not intended as a definitive statement on the subject … Scholl Executive Education Program Telephone: 800-HBS-5577 Website: www.exed.hbs.edu/programs/finder.ht …
Program Materials
Joseph J. Catalano -- senior vice president and chief litigation counsel, Union Bank, N.A.; Mark Diamond -- chief executive officer, Contoural; Patrick Oot -- director of electronic discovery and senior litigation counsel, Verizon
10/20/2009

Part one of this two-part program will guide you through the steps you must take regarding records before litigation is foreseeable and once it has commenced in order to be prepared. The panel will describe effective practices in collection and production that will prepare your counsel for mandatory discovery conferences. During the program, you will grasp the details about some of the tools currently available to in-house practitioners and hear about some of the emerging technologies that may soon be available to help manage this process. Learn the tricks to managing discovery and combining the talents of your law firms and vendors to achieve better results and greater cost savings.

… steps you must take regarding records before litigation is foreseeable and once it has commenced in order to be … collection and production that will prepare your counsel for mandatory discovery conferences. During the program, you … requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC …
Program Materials
Arleigh Closser -- director of legal affairs, assistant general counsel, Juniper Networks; Douglas Cole -- vice president and general counsel, ECS, Ltd.; Lydia Tallent -- in-house counsel, SC Solutions
10/20/2009

It's not possible to keep up with it all, but this session will help you stay up-to-date with changes that effect E-Verify, business ethics programs and mandatory disclosure requirements in 2009. Don't get caught off guard! This course will provide a summary of the new requirements for prime contractors and subcontractors as well as an up-to-date assessment of where things are headed after the first nine months.

Resource Details
Source: Meetings
Region: United States
… requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC … sponsors, and/or the ACC. This ACC Annual Meeting material is not intended as a definitive statement on the subject … a violation of federal criminal law (See GSA OIG reporting website) !! Fully cooperate in government audits, …
Program Materials
Joe Beck -- partner, consumer product safety, Kilpatrick Stockton LLP; Christopher Fox -- vice president, corporate social responsibility, Hanesbrands Inc.; Alan Schoem -- senior vice president, Marsh Risk Consulting Global Product Risk Practice; Joel Tennenberg -- litigation & regulatory counsel, Toys “R” Us, Inc.
10/21/2009

Congress recently passed the most significant amendments to the federal consumer product safety laws in 30 years. These changes affect not just manufacturers of consumer products, but also importers, private labelers, distributors and retailers. This session will address how these sweeping changes impact consumer product companies, new legal risks, and new burdens that have been placed on sellers and manufacturers. Developments in consumer product safety, including recent Consumer Product Safety Commission regulations, federal, private, and international efforts to bolster import safety, and related best practices in the face of heightened visibility and enforcement of product safety matters, will also be addressed.

Resource Details
Source: Meetings
Region: United States
… requests should be directed to legalresources@acc.com or +1 202.293.4103, ext. 342. The information in this ACC … sponsors, and/or the ACC. This ACC Annual Meeting material is not intended as a definitive statement on the subject … ENTITIES.—The Commission shall maintain on its Internet website an up- to-date list of entities that have been …
Program Materials
Alexander Duisberg
06/08/2009

This material discusses the legal framework for managing the challenges of a security breach.

… This material discusses the legal framework for managing the challenges of a security breach. (hidden) … than 780 fee earners •  One of the strongest growing firms in Europe •  Awards and accolades About Bird & Bird – Sector … Parliament legislative resolution of 6 May 2009 –  Debate is ongoing in these days Data Protection Directive 95/46/EC …
Program Materials
Baker McKenzie
09/10/2009

Developments in EU Verticals:
BER reform and online sales

Resource Details
Source: Meetings
Region: European Union, Germany, Switzerland, United Kingdom, United States
… 2009, Zurich 3 BER Reform Market share threshold(s): is more really better? Territorial restrictions: a missed … sales: the single European market? Agents: more room for agency agreements? European Competition Law Update 2009, … as passive sales No circumventions: Prevention access to website from abroad Automatic transfer to local website Split …
Program Materials
Erik van Dijk, Misha lutje Beerenbroek, Emma C. Runia
05/29/2008

A very comprehensive presentation on The Dutch Competition Act.

Resource Details
Source: Meetings
Region: Netherlands
… Concentrations (continued) – Penalties have been increased for violations of the merger control regime: maximum fine for non- notification is now €450,000 or, if more, 10 % of the company’s (group) … CRA International Amsterdam + 31 20 521 9321 edroste@crai.com www.crai.com/ecp Abuse of Dominance - Article 82 Update …
Program Materials
Nina Niejahr
09/18/2008

This material covers the 'abuse of dominance' in recent EC developments.

Resource Details
Source: Meetings
Region: European Union
… EC developments. Source Meetings … Baker & McKenzie LLP is a limited liability partnership registered in England and … regulatory position is available at http://www.bakernet.com/London/Regulation. EC and UK Competition Law Update 2008 … >40% possible, >50% presumed – Competitors’ size, barriers for new entrants • Abuse – Exclusionary, e.g. bundling, …
Program Materials
Ross Denton
Grant Murray
03/10/2010

This material gives an update on regulations surrounding cartels in Europe.

… Dutch beer cartel cases (only 6 years apart): €46 million for Interbrew in 2001; €219 million for Heineken in 2007. – … have made leniency applications –Evidence against all is, on balance, strong 7Does this typical case looks right … submission by defendant – Case team gets provisional “buy in” from College, including sum – Third meeting, delivery …
Program Materials
Helen Bardell
03/10/2010

Coverage of the currant regime and the new regime which is set to take the lead in June 2010.

Resource Details
Source: Meetings
Region: European Union
… Coverage of the currant regime and the new regime which is set to take the lead in June 2010. (hidden) Interest Area … market will likely be wider than the relevant market for resale) 6Exclusive Distribution – Current Position: – … a search engine/search engine optimiser to have website found more easily in a particular territory/by a …
Program Materials
Stuart Dutson <br />Partner <br />Eversheds LLP <br />Nathan Nelson <br />General Counsel <br />Albion Laboratories, Inc. <br />Nick Sayeedi <br />Vice President & Associate General Counsel <br />Dish Network, L.L.C. <br />James Shannon <br />Senior Vice President and Deputy General Counsel <br />Bechtel Group, Inc. <br />Vijayendra Pratap Singh <br />Partner <br />Lex Mundi<br />
10/25/2010

This panel will examine how companies can best handle issues surrounding international dispute resolution, including how to leverage bilateral investment treaties in jurisdictions that have a tendency to favor local businesses and investors, and enforcing arbitration in difficult jurisdictions.

… … ACC’s 2010 Annual Meeting Be the Solution. This material is protected by copyright. Copyright © 2010 various authors … at ACC: +1 202.293.4103, x338; legalresources@acc.com Monday, October 25 4:30pm-6:00pm 404 - Effectively … U.S. and Europe, overseeing all transactional legal work for both Dish Network and its recently spun off affiliate …
Program Materials
Panagiotis Bayz
Of Counsel
Morrison & Foerster LLP
Mark Ehrlich
Managing Director, Ethics and Compliance
The AES Corporation
Nancy Heafey
Vice President, Deputy General Counsel and Chief Compliance Officer
Con-way Inc.
Kimberly White
Director, Business Ethics & Senior Corporate Counsel
Underwriters Laboratories Inc.
10/26/2010

Given the compliance expectations of regulators and the increase in enforcement actions by BIS, DDTC and OFAC, it can be a challenge to stay safe in a global business environment. Should you monitor your international charitable grantees? Does your due diligence of business partners consider risks of trade sanctions or anti-terrorism laws? This program on legal compliance with the FCPA's under-recognized cousins seeks to provide an overview and general primer into trade sanctions, import-export and anti-boycott compliance -- for large and small companies. The program will explore the critical elements of a global compliance program -- including identifying your vulnerabilities, and monitoring the compliance of third parties -- and offer insight into recent enforcement actions.

Resource Details
Interest Area: Compliance and Ethics
Source: Meetings
Region: United States
… sanctions, import-export and anti-boycott compliance -- for large and small companies. The program will explore the … … ACC’s 2010 Annual Meeting Be the Solution. This material is protected by copyright. Copyright © 2010 various authors … at ACC: +1 202.293.4103, x338; legalresources@acc.com Tuesday, October 26 11:00am-12:30pm 604 - Effective …
Program Materials
Keith Agisim <br />Associate General Counsel, Global Intellectual Property <br />Bank of America <br />Stephen Koch <br />Assistant Chief Attorney <br />ExxonMobil Upstream Research Company <br />BJ Watrous <br />VP and Deputy General Counsel, Intellectual Property and IP Licensing <br />Hewlett-Packard<br />
10/26/2010

Whether you already own ‘em or want to buy ‘em, what it the actual business value of a patent? This session will discuss how to value a particular patent, cost effective patent mining, and portfolio mapping strategies, techniques and tips.

… … ACC’s 2010 Annual Meeting Be the Solution. This material is protected by copyright. Copyright © 2010 various authors … at ACC: +1 202.293.4103, x338; legalresources@acc.com Tuesday, October 26 11:00am-12:30pm 609 - Evolution of … Keith Agisim Keith Agisim is associate general counsel for global technology & operations and global intellectual …
Program Materials
John Angelo <br />Vice President, Federal Government Services Counsel <br />AECOM Technology Corporation <br />Melanie Brown <br />Director, Global Trade Compliance <br />Silicon Image, Inc. <br />Charles Duross <br />Deputy Chief - Foreign Corrupt Practices Act Unit <br />U.S. Department of Justice <br />Carolyn Lindsey <br />Director, Member Services <br />TRACE International, Inc. <br />
10/26/2010

This panel will review new trends in FCPA enforcement and how global organizations are handling anti-bribery compliance in an increasingly complex world. Our panel features diverse participation by in-house counsel, representatives from enforcement agencies and global organizations that deal with anti-bribery compliance. What lessons are emerging from the increasing aggressive enforcement of the FCPA? What are the emerging “best practices” in policy, due diligence, and training initiatives? What are the traps to avoid?

Resource Details
Interest Area: Compliance and Ethics
Source: Meetings
Region: United States
… … ACC’s 2010 Annual Meeting Be the Solution. This material is protected by copyright. Copyright © 2010 various authors … at ACC: +1 202.293.4103, x338; legalresources@acc.com Tuesday, October 26 2:30pm-4:00pm 704 - Developments inin-house counsel and director of global trade compliance for Silicon Image Inc., in Sunnyvale, CA. Her …
Program Materials
Dani Gleason <br />Staff Attorney <br />BMC Software, Inc. <br />William Harn <br />Senior Attorney <br />Southern California Edison Company <br />Kevin Mencke <br />Chief Counsel – Employment & Labor <br />International Paper Company <br />
10/27/2010

Join this session and learn the most recent employment law updates. Important employment-related case law and legislation will be discussed.

Resource Details
Interest Area: Employment and Labor
Source: Meetings
Region: United States
… … ACC’s 2010 Annual Meeting Be the Solution. This material is protected by copyright. Copyright © 2010 various authors … at ACC: +1 202.293.4103, x338; legalresources@acc.com Wednesday, October 27 11:00am-12:30pm 1005 - Employment … it has at least three sitting members •  NRLB added to its website (http://www.nlrb.gov) a database of information and …
Program Materials
Edward Chansky
Of Counsel
Greenberg Traurig, LLP
Lesley Lurie
Associate General Counsel
Susan G. Komen Breast Cancer Foundation, Inc.
Po Yi
VP & Chief Advertising Counsel
American Express Travel Related Services Company, Inc.
10/27/2010

New economic realities demand that companies and brands act as good corporate citizens to connect with consumers. Traditional corporate philanthropy is increasingly eclipsed by “cause marketing” techniques, such as green marketing, donation-with-purchase, collecting contributions at checkout, online “voting” for charities, sale of donation cards and a myriad of others. Special charitable initiatives like Project Red have become global brands, themselves. In striving to do good while doing well, companies and brands need to be aware of the broad array of federal and state laws that can affect cause marketing efforts. These include commercial coventurer laws, professional fundraising regulation, IRS sponsorship and self-dealing guidelines, and general consumer protection laws prohibiting false or deceptive advertising. International campaigns introduce additional complications. This program will provide a structured overview and analytical framework for legal regulation of cause marketing programs, along with practical advice for compliance and best practices in this fast-growing field.

Resource Details
Source: Meetings
… connect with consumers. Traditional corporate philanthropy is increasingly eclipsed by “cause marketing” techniques, … at ACC: +1 202.293.4103, x338; legalresources@acc.com Wednesday, October 27 11:00am-12:30pm 1007 - Doing … rather than business opportunities? C. Example 3: Website telling the consumer that, every time he or she makes …
Program Materials
ACC & WeComply
12/21/2010

This EU Competition Law training course provides an overview of EU competition law and helps you recognize and deal with "red flags" — situations that present a risk of competition-law violations and legal liability.

After a summary of the most important laws and legal principles and a discussion of some situations that should trigger red flags, you'll play a game that presents situations for you to analyze. If you respond correctly, you will move through the game and earn a Certificate of Completion.

To access the EU Competition Law Training Course, visit <a href=http://www.ethicsxchange.com/topic/37382-eu-competition-law>www.acc.com/compliance</a>.

Resource Details
Source: Meetings
Region: European Union
… red flags, you'll play a game that presents situations for you to analyze. If you respond correctly, you will move … Training Course, visit <a href= http://www.ethicsxchange.com/topic/37382-eu-competition-law>www.acc.com… ;. (hidden) … • Classroom Training: A PowerPoint version of this course is available free to ACC members through the ACC Compliance …
Program Materials
ACC & WeComply
12/21/2010

This Fair Labor Standards Act (FLSA) training course will help you understand issues involving overtime, how "exempt" employees are classified, independent contractors, and FLSA record-keeping requirements, among other things.

To access the Fair Labor Standards Act Training Course, visit, <a href=http://www.ethicsxchange.com/topic/35553-fair-labor-standards-act>www.acc.com/compliance</a>.

Resource Details
Source: Meetings
Region: United States
… Training Course, visit, <a href= http://www.ethicsxchange.com/topic/35553-fair-labor-standards-act>www.a… ;. Author ACC … • Classroom Training: A PowerPoint version of this course is available free to ACC members through the ACC Compliance … version of this course is available at a discounted rate for ACC members through WeComply. For more information, …
Program Materials
ACC & WeComply
12/22/2010

The U.S. Government, through the Office of Foreign Assets Control (OFAC), uses economic sanctions and trade embargoes to protect the country's economy and enhance its security. Your Company must comply with all applicable sanction and embargo regulations or you — and in some cases the individual employees involved — will face substantial penalties. This 30-minute training course provides an overview of OFAC sanctions and their key provisions. It will help you recognize situations presenting a risk of legal violations and deal with them properly.

To access the Economic Sanctions and Trade Embargoes Training Course, visit <a href=http://www.ethicsxchange.com/topic/37383-ofac-sanctions-and-embargoes>www.acc.com/compliance</a>.

Resource Details
Source: Meetings
Region: United States
… Training Course, visit <a href= http://www.ethicsxchange.com/topic/37383-ofac-sanctions-and-embargoes>w… ;. Author ACC … • Classroom Training: A PowerPoint version of this course is available free to ACC members through the ACC Compliance … version of this course is available at a discounted rate for ACC members through WeComply. For more information, …
Program Materials
Jack O'Neil - General Counsel, Western Construction Group, Inc.; Todd Silberman - Vice President & General Counsel, Express Carriers; Susan Zoch - Associate General Counsel, Vertis, Inc.
10/01/2005

Every in-house practitioner has negotiated between one and a million contracts in his career. But do you excel in this element of your job or cringe when the occasion presents itself? Here is your chance to refresh everything you learned in contract law and forgot. Unlike law school though, in addition to the law, we'll send you home with a set of practical tools to manage the contract process including those that are difficult to negotiate. Topics will include tips on managing the battle of the forms, responding to overreaching and inapplicable terms and conditions, and setting up internal contract management processes and controls.

… your job or cringe when the occasion presents itself? Here is your chance to refresh everything you learned in contract … Bramesco at ACC: 202/293-4103, ext. 338; bramesco@acca.com 602 Practical Tools for Managing & Negotiating Today's … contract s with its custo m e r s (check the other side’s website; check EDGAR) Re q u i r e appropri a t e level …
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