Contract analysis

I. INTRODUCTION AND PROCEDURAL BACKGROUND Dear Staff Chairperson: On behalf of Halcyon Semiconductor Aktiengesellschaft ("HSAG") and Halcyon US Holdings Inc. ("Halcyon US Holdings"), Calderwood & Harkness LLP respectfully submits this Response to the Second Request for Information ("Second RFI") issued by the Committee on Foreign Investment in the United States ("CFIUS" or the "Committee") in connection with CFIUS Ca

II. DEFINITIONS AND ABBREVIATIONS For ease of reference, the following definitions and abbreviations are used throughout this submission. Unless otherwise defined herein, capitalized terms shall have the meanings ascribed to them in the Joint Voluntary Notice filed on July 14, 2023, which definitions are incorporated herein by reference.

III. SECTION A — VPI INTELLECTUAL PROPERTY TRANSFER RISKS (Questions 1–7) The following responses address Questions 1 through 7 of the Second RFI, which concern the identification and protection of VPI's intellectual property, the proposed Technology Control Plan for IP segregation, government-funded IP considerations, and the measures designed to prevent unauthorized technology transfer to HSAG or non-U.S. persons.

IV. SECTION B — SUPPLY CHAIN DEPENDENCIES (Questions 8–13) The following responses address Questions 8 through 13 of the Second RFI, which concern VPI's supply chain for critical materials and components, supply chain vulnerabilities, VPI's role in the defense industrial base, and export compliance measures for supply chain management. Question 8 Provide a comprehensive map of VPI's supply chain for critical material