Contract analysis

1. All information provided in this CJ request, including the technical descriptions, product specifications, development history, funding sources, proposed classifications, and contemplated export transaction details, is true, accurate, and complete to the best of my knowledge and belief, based upon reasonable inquiry.

2. Whitmore Aerospace LLC is currently registered with the Directorate of Defense Trade Controls under DDTC Registration Code M07-2019-43521. WAL's ITAR registration is current and in good standing, having been most recently renewed on January 15, 2025, with a current expiration date of January 15, 2027.

3. The WPX-4200 Meridian Electro-Optical/Infrared Multi-Spectral Targeting Pod and the WPX-4200-SC07 Digital Signal Processing Module have been accurately described in this CJ request with respect to their technical parameters, design purpose, development history, and intended end-use. No material information regarding these articles has been omitted or misrepresented.

4. Whitmore Aerospace LLC will promptly supplement or amend this CJ request if any material information contained herein changes prior to DDTC's issuance of a jurisdictional determination, or if WAL becomes aware of any additional facts or circumstances that are material to the jurisdictional analysis.

5. I am duly authorized by Whitmore Aerospace LLC to execute and submit this CJ request on behalf of the company, and I have been designated as WAL's Empowered Official in accordance with 22 C.F.R. § 120.67. 10.2 Signature block WHITMORE AEROSPACE LLC By: ________ Name: David Sung Title: Director, Export Controls & Trade Compliance; Empowered Official DDTC Registration Code: M07-2019-43521 CAGE Code: 7H2K9 Date: ____

1. General Status. This draft CJ request has been prepared by Calderwood & Harkness LLP for Whitmore Aerospace LLC's review and approval prior to submission to the Directorate of Defense Trade Controls. The target filing date remains June 20, 2025. We request that WAL's internal review be completed no later than June 10, 2025 to allow adequate time for revisions and finalization.

2. Exhibit F — Program Manager Technical Declaration. Counsel recommends that Lt. Col. (Ret.) Brian Halstead prepare and execute the technical declaration (Exhibit F) no later than June 13, 2025 to allow sufficient time for review by both WAL's legal department and outside counsel. We have prepared a draft declaration template, which will be circulated separately. The declaration should address the exclusively milita

3. SC07 Subcomponent Strategy. The CJ request for the WPX-4200-SC07 Digital Signal Processing Module is included in this filing in order to obtain a unified determination from DDTC covering both the system-level article and the subcomponent. If DDTC determines that the SC07 Module falls within EAR jurisdiction and refers the SC07 determination to BIS, counsel will prepare a separate ECCN classification request for su

4. Estimated DDTC Processing Time. Based on current DDTC processing timelines for Commodity Jurisdiction determinations, counsel estimates a processing time of approximately 45 to 60 business days from the date of filing. Assuming a June 20, 2025 filing date, this yields an anticipated response window of approximately August 25 through September 15, 2025. Counsel notes that processing times may vary and that DDTC may

5. DSP-5 and TAA Preparation. Upon receipt of the CJ determination from DDTC, Calderwood & Harkness will proceed immediately to prepare the DSP-5 permanent export license application and the Technical Assistance Agreement for the Kantara MoND transaction. The target filing date for the DSP-5 and TAA is September 22, 2025, which provides approximately one week of preparation time following the latest anticipated CJ re

6. Exhibit Status. All Exhibits referenced in this CJ request (Exhibits A through H) are placeholder references in this draft. WAL is requested to provide final versions of the following materials for attachment to the filing: • Exhibit A: Unclassified system specification sheet and technical data package for WPX-4200 • Exhibit B: SC07 Module technical description • Exhibit C: Copy of prior CJ determination CJ-2018-0

7. Parallel OFAC/Sanctions Screening. This CJ request is being filed in parallel with ongoing OFAC and restricted-party sanctions screening activities related to the prospective Kantara transaction. Counsel notes that the CJ determination is jurisdictional in nature and does not require identification of end-users or intermediaries at this stage. However, the DSP-5 and TAA applications will require detailed end-user

8. Congressional Notification. As noted in Section 8.3, the estimated total program value of $91.3 million exceeds the $14 million MDE Congressional notification threshold under AECA § 36(b) for NATO-member countries. Calderwood & Harkness will coordinate with DDTC on Congressional notification timing and content in connection with the DSP-5 application. WAL should be aware that Congressional notification may add app