first-production-cover-letter.docx

1032-00007 · Client 1032 · Correspondence

first-production-cover-letter.docx DOCUMENT Litigation

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CALDERWOOD & HARKNESS LLP Attorneys at Law 1301 K Street NW, Suite 1100 Washington, D.C. 20005 Telephone: (202) 555-7400 Facsimile: (202) 555-7401

November 18, 2025

VIA SECURE FILE TRANSFER

Adrienne Kolb, Esq. Senior Trial Attorney Counterintelligence and Export Control Section National Security Division U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, D.C. 20530

Re: DOJ NSD Inquiry No. NSD-CES-2025-04871 — Halcyon Semiconductor Inc. First Document Production

Dear Ms. Kolb:

We write on behalf of our clients, Halcyon Semiconductor AG ("HSAG"), a corporation organized under the laws of the Federal Republic of Germany with its principal office at Semperstrasse 15, 01069 Dresden, Germany, and its wholly owned U.S. subsidiary, Halcyon Semiconductor Inc. ("HSI"), a Delaware corporation with its principal place of business at 4700 Great America Parkway, Suite 300, San Jose, California 95054 (collectively, "Halcyon" or the "Company"), in connection with the Department of Justice, National Security Division, Counterintelligence and Export Control Section's inquiry bearing reference number NSD-CES-2025-04871. The purpose of this letter is to transmit the Company's first production of documents responsive to the Department's voluntary request for information dated October 9, 2025 (the "Voluntary Request"). This production is being made in a spirit of full cooperation with the Department's inquiry and in furtherance of the Company's commitment to the prompt and transparent resolution of the matters under review.

I. Production Summary

Halcyon's first document production consists of 14,200 documents, bearing Bates numbers HALCYON-DOJ-000001 through HALCYON-DOJ-014200, comprising approximately 187,000 pages in total. The production is being transmitted contemporaneously with this cover letter via the Department of Justice's secure file transfer portal, in accordance with the transmission instructions provided by your office on October 16, 2025.

All documents have been produced in load-file format compatible with standard litigation review platforms (including Crestline Technologies and similar commercially available review tools). The load file includes extracted text, metadata fields, and, where applicable, native-format attachments. To the extent that any documents were produced in image format (TIFF or PDF), searchable OCR text has been provided in an accompanying text file for each such document. Unitization has been performed in accordance with the Department's standing production specifications, and document families (i.e., parent e-mails and their attachments) have been kept together and linked through the appropriate load-file fields.

Should the Department encounter any technical difficulties accessing or loading the production files, we respectfully ask that you contact the undersigned so that any issues may be promptly addressed.

II. Categories of Documents Produced

The documents included in this first production fall within the ten categories described below. For the Department's convenience, we have organized the description by reference to the applicable Bates ranges.

1. Shipment Records (HALCYON-DOJ-000001 – HALCYON-DOJ-003842)

This category contains commercial invoices, packing lists, bills of lading, airway bills, and delivery confirmations relating to the seventeen (17) shipments at issue identified in the Voluntary Request. Of these seventeen shipments, eleven (11) were consigned to Zhonghe Microelectronics Co., Ltd. ("Zhonghe"), located at 12/F, Nanshan Digital Tower, Keji South Road, Nanshan District, Shenzhen 518057, People's Republic of China, and six (6) were consigned to Lansheng Harborline Technologies Technologies Ltd. ("Lansheng"), located at Block C, Tianfu Software Park, No. 599 Shijicheng South Road, Chengdu 610041, People's Republic of China. These shipments occurred during the period from March 12, 2024 through August 19, 2025 and involved HCA-9100 series analog-to-digital converter chipsets classified under Export Control Classification Number ("ECCN") 3A001 on the Commerce Control List, 15 C.F.R. Part 774, Supplement No. 1.

Each of these seventeen shipments followed the same transactional routing: HCA-9100 series products were manufactured at HSAG's fabrication facility in Dresden, Germany, shipped to Archipelago Component Solutions Pte. Ltd. ("Archipelago"), an authorized distributor located at 18 Boon Lay Way, #07-142 TradeHub 21, Singapore 609966, and thereafter forwarded by Archipelago to the PRC-based end users identified above.

In the interest of completeness, and to provide the Department with a fuller picture of the Company's export activities involving ECCN 3A001 products destined for PRC-based customers, this category also includes documentation for an additional twenty-three (23) shipments of ECCN 3A001 products to other PRC-based customers that occurred during the same March 2024 through August 2025 period. These additional shipments were not specifically identified in the Voluntary Request but have been included voluntarily to facilitate the Department's review and to demonstrate the Company's commitment to transparency. The shipment records for these twenty-three additional transactions are organized chronologically following the records for the seventeen shipments at issue.

2. End-User Certificates and End-Use Statements (HALCYON-DOJ-003843 – HALCYON-DOJ-004219)

This category contains end-user certificates ("EUCs") and end-use statements obtained from Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. in connection with each of the seventeen shipments at issue. These certificates and statements were obtained by Archipelago Component Solutions Pte. Ltd. from the respective end users as part of the order-processing workflow and were subsequently provided to HSAG's Trade Compliance department in Dresden for review and retention. Each EUC identifies the end user, the end-use application declared by the customer, and certifications regarding re-export, re-transfer, and non-diversion. Where available, supporting documentation accompanying the EUCs — including signed company letterhead confirmations and translated versions of originally Chinese-language documents — has also been included.

3. Export Classification and Licensing Records (HALCYON-DOJ-004220 – HALCYON-DOJ-005106)

This category comprises the Company's internal ECCN classification worksheets for HCA-9100 series products, including technical parameter analyses that formed the basis for classifying these products under ECCN 3A001. The category also includes license exception analyses prepared by HSAG's Trade Compliance department evaluating the potential applicability of various license exceptions under the Export Administration Regulations ("EAR"), as well as "No License Required" ("NLR") determinations memorialized in HSAG's internal compliance records. Specifically, these records document the Company's analysis of whether the HCA-9100 series products qualified for export or reexport to the PRC under applicable EAR provisions, taking into account the items' technical parameters, the countries of origin and destination, the identity of the end users, and the declared end uses. Where classification analyses were revised or updated during the relevant period, all versions have been included, with the effective date of each version clearly indicated in the document metadata.

4. Restricted-Party Screening Records (HALCYON-DOJ-005107 – HALCYON-DOJ-007891)

This category contains records documenting the restricted-party screening performed in connection with the shipments at issue, as well as the twenty-three additional shipments referenced in Category 1 above. The restricted-party screening records include:

(a) Screenshots and transaction log files from HSAG's Brightmoor Solutions ("SAP GTS") system, reflecting the automated screening of customer names, addresses, and other identifying information against U.S. government restricted-party lists (including the Entity List, the Denied Persons List, the Unverified List, and the Specially Designated Nationals and blocked Persons List), as well as applicable EU and German restricted-party lists, at the time of order entry into HSAG's enterprise resource planning system; and

(b) Screenshots and transaction log files from the Sentinel-powered restricted-party screening system operated by Archipelago Component Solutions Pte. Ltd. Sentinel Compliance Data Services Ltd. ("Sentinel"), headquartered in Edinburgh, United Kingdom, provides the underlying restricted-party list data and screening engine utilized by Archipelago. These records reflect Archipelago's screening results for Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. at the time of order entry and, where available, at the ship-confirm stage.

These screening records are of particular relevance to the Department's inquiry insofar as they bear on the question of whether Zhonghe's addition to the Entity List, 15 C.F.R. § 744.11, effective June 14, 2025, was timely reflected in Archipelago's Sentinel-powered screening database. As detailed more fully in the documents produced in Category 10 below, there was a lag of twelve (12) calendar days — nine (9) business days — between the June 14, 2025 effective date of Zhonghe's Entity List designation and the June 26, 2025 date on which Sentinel pushed the updated data to Archipelago's screening system. The screening records in this category document the results returned by Archipelago's system during this interval.

5. Customer Correspondence (HALCYON-DOJ-007892 – HALCYON-DOJ-011340)

This category comprises e-mail communications between HSI sales personnel and representatives of Archipelago Component Solutions Pte. Ltd. relating to orders placed by Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. for HCA-9100 series products. The correspondence in this category covers the period from January 1, 2024 through October 9, 2025, which encompasses the full period identified in the Voluntary Request as well as a reasonable period preceding the earliest shipment at issue to capture relevant pre-shipment communications.

Among the HSI personnel whose correspondence is included in this production is Ryan Oshiro, Director, Asia-Pacific Sales, HSI, who served as the principal commercial point of contact between HSI and Archipelago for customer accounts in the People's Republic of China during the relevant period. The correspondence includes, among other things, order-related communications, pricing discussions, delivery scheduling, customer technical inquiries, and communications regarding compliance requirements and end-use documentation.

All responsive e-mail communications were collected from HSI's Ashgrove Software environment, HSAG's on-premises e-mail archive, and custodial hard-copy files maintained by Mr. Oshiro and other identified custodians. De-duplication was performed at the family level using MD5 hash values, and communications protected by the attorney-client privilege or the work product doctrine have been withheld and logged on the privilege log described in Section III below.

6. Compliance Policy Documents (HALCYON-DOJ-011341 – HALCYON-DOJ-012003)

This category contains the Company's operative export compliance policies and procedures in effect during the relevant period, including:

(a) HSAG's Global Export Compliance Policy, Version 4.2, effective January 1, 2024 (the enterprise-wide compliance framework governing all HSAG group entities, including HSI);

(b) HSI's U.S. Export Compliance Procedures Manual, Version 3.1, effective March 15, 2024 (the U.S.-specific procedures manual addressing HSI's obligations under the EAR, the International Traffic in Arms Regulations, and applicable sanctions programs administered by the Office of Foreign Assets Control); and

(c) Archipelago Component Solutions Pte. Ltd.'s Trade Compliance Standard Operating Procedures, Version 2.0, effective July 1, 2023 (the trade compliance procedures maintained by Archipelago in its capacity as HSAG's authorized distributor for the Asia-Pacific region).

These policy documents establish the division of compliance responsibilities among HSAG, HSI, and Archipelago, including the respective obligations of each entity with respect to export classification, end-user screening, end-use verification, recordkeeping, and escalation of red flags.

7. Training Records (HALCYON-DOJ-012004 – HALCYON-DOJ-012847)

This category includes records of export compliance training sessions attended by relevant HSI and HSAG personnel during calendar years 2024 and 2025. The training records encompass sign-in sheets documenting individual attendance, training materials (including presentation slides and handouts), completion certificates issued to participating employees, and, where available, training agendas and post-training assessment results. These records document both mandatory annual compliance training and supplemental, ad hoc training sessions conducted in response to regulatory developments, including the expanded Entity List designations announced in 2024 and 2025 relevant to PRC-based semiconductor entities.

8. Organizational Charts and Personnel Records (HALCYON-DOJ-012848 – HALCYON-DOJ-013102)

This category contains organizational charts for: (a) HSAG's Trade Compliance department, based in Dresden, Germany; (b) HSI's Regulatory Affairs group, based in San Jose, California; and (c) the compliance function within Archipelago Component Solutions Pte. Ltd. in Singapore. The organizational charts reflect the reporting structures in effect during the relevant period and identify the individuals occupying key compliance roles within each entity. Also included in this category are position descriptions (or, where formal position descriptions were not maintained, functional summaries) for relevant personnel, including those individuals with direct responsibility for export classification, restricted-party screening, order review, and compliance escalation.

9. Distributor Agreement (HALCYON-DOJ-013103 – HALCYON-DOJ-013488)

This category contains the Authorized Distributor Agreement between HSAG and Archipelago Component Solutions Pte. Ltd. (the "Distributor Agreement"), originally executed on April 1, 2021, together with all subsequent amendments through and including Amendment No. 3, effective September 1, 2024. The Distributor Agreement governs the terms and conditions under which Archipelago is authorized to distribute HSAG products, including HCA-9100 series chipsets, to customers in the Asia-Pacific region. Also included in this category are all export-compliance-related addenda and schedules attached to the Distributor Agreement, including the Trade Compliance Addendum (specifying Archipelago's obligations regarding restricted-party screening, end-user verification, recordkeeping, and compliance reporting) and the Audit Rights Schedule (setting forth HSAG's contractual right to audit Archipelago's compliance records and systems).

The Distributor Agreement and its amendments are relevant to the Department's inquiry insofar as they establish the contractual allocation of compliance responsibilities between HSAG and Archipelago and provide the basis for the Company's exercise of audit rights to obtain records from Archipelago for production in subsequent submissions.

10. Sentinel SLA Documentation (HALCYON-DOJ-013489 – HALCYON-DOJ-014200)

This category contains documents relating to the restricted-party list screening data services provided to Archipelago Component Solutions Pte. Ltd. by Sentinel Compliance Data Services Ltd., headquartered in Edinburgh, United Kingdom. Specifically, this category includes:

(a) The service agreement between Archipelago and Sentinel governing the provision of restricted-party list data and screening engine services (the "Sentinel Service Agreement");

(b) The service level agreement provisions within the Sentinel Service Agreement, which specify, among other things, that Sentinel shall update its restricted-party list databases "within five (5) business days of publication" of changes to applicable governmental restricted-party and denied-party lists;

(c) Incident logs maintained by Archipelago documenting Sentinel's performance against the contractual database-update service levels, including records of instances in which updates were not delivered within the specified five-business-day window; and

(d) Correspondence between Archipelago and Sentinel relating to the delay in updating Sentinel's database to reflect Zhonghe Microelectronics Co., Ltd.'s addition to the Entity List. As reflected in these documents, Zhonghe was added to the Entity List, 15 C.F.R. § 744.11, effective June 14, 2025. However, the updated entry for Zhonghe was not pushed to Archipelago's Sentinel-powered screening system until June 26, 2025 — a lag of twelve (12) calendar days and nine (9) business days, which exceeded the contractual service level of five (5) business days by four (4) business days. The correspondence in this sub-category documents the parties' communications regarding the cause and remediation of this delay.

These documents are central to understanding the circumstances under which Archipelago's screening system failed to flag Zhonghe as an Entity List party during the interval between June 14 and June 26, 2025, and are therefore directly responsive to the Department's inquiries regarding the Company's compliance controls and their operational effectiveness.

III. Privilege Log

Accompanying this production is a privilege log identifying all documents that have been withheld from production, in whole or in part, on the basis of the attorney-client privilege, the work product doctrine, or both. The privilege log has been provided as a separate attachment in Microsoft Excel format, under the file name "HALCYON_DOJ_Privilege_Log_Prod1.xlsx."

The privilege log identifies a total of 312 documents that have been withheld or redacted. For each withheld or redacted document, the privilege log identifies: (a) the date of the document; (b) the author or sender; (c) the recipient(s) and, where applicable, individuals copied; (d) the general type or nature of the document (e.g., memorandum, e-mail, legal analysis); and (e) the specific basis or bases for the privilege assertion (i.e., attorney-client privilege, work product protection, or both). Where a document has been produced in redacted form rather than withheld in its entirety, the privilege log so indicates and describes the nature of the redacted material.

The Company has endeavored to assert privilege narrowly and only with respect to materials that fall squarely within the scope of recognized protections. Should the Department wish to discuss or challenge any specific privilege assertion, we are prepared to address such issues promptly and, where appropriate, to provide the documents at issue for in camera review.

IV. Reservations

The Company makes the following reservations in connection with this production:

1. This production is made on a voluntary basis and in the spirit of cooperation with the Department's inquiry. Nothing in this production or in this cover letter shall be construed as a waiver, in whole or in part, of any right, privilege, defense, or objection available to the Company under applicable law, including but not limited to any rights under the Fourth and Fifth Amendments to the United States Constitution, the attorney-client privilege, the work product doctrine, or any other applicable evidentiary privilege or protection.

2. The production of any document herein does not constitute an admission by the Company as to the relevance, authenticity, accuracy, completeness, or admissibility of such document in any proceeding, whether administrative, civil, or criminal in nature.

3. The Company reserves the right to supplement, correct, or amend this production as additional information becomes available, including as a result of the Company's ongoing internal review. The Company's investigation into the matters identified in the Voluntary Request is ongoing, and the Company anticipates producing additional documents in the coming weeks. In particular, the Company expects to produce records obtained from Archipelago Component Solutions Pte. Ltd. pursuant to the Company's contractual audit rights under the Distributor Agreement, which records are currently being collected and reviewed for responsiveness and privilege. The Company will advise the Department promptly regarding the anticipated timing of this supplemental production.

4. This production is made without prejudice to the Company's right to object to any future requests for information, documents, or testimony, and shall not be deemed to establish any precedent or practice with respect to the scope, format, or timing of any future production.

We trust that this production will be of assistance to the Department in its review. Halcyon remains committed to cooperating fully and transparently with the Department's inquiry into the matters referenced above, and the Company will continue to devote the resources necessary to respond to the Department's requests in a thorough and timely manner. We are available to discuss this production, including its organization, scope, and contents, at the Department's convenience. Please do not hesitate to contact the undersigned or Howard Quinn at (202) 555-7412 to arrange a call or meeting at a mutually agreeable time.

We appreciate the Department's willingness to engage constructively with the Company as this matter proceeds.

Respectfully submitted,

CALDERWOOD & HARKNESS LLP

By: ________

Liam Donahue Associate 1301 K Street NW, Suite 1100 Washington, D.C. 20005 Telephone: (202) 555-7425 E-mail: ldonahue@calderwoodharkness.com

cc: Howard Quinn, Partner, Calderwood & Harkness LLP Jonathan Weir, Trial Attorney, Counterintelligence and Export Control Section, National Security Division, U.S. Department of Justice

CALDERWOOD & HARKNESS LLP Attorneys at Law 1301 K Street NW, Suite 1100 Washington, D.C. 20005 Telephone: (202) 555-7400 Facsimile: (202) 555-7401
November 18, 2025
VIA SECURE FILE TRANSFER
Adrienne Kolb, Esq. Senior Trial Attorney Counterintelligence and Export Control Section National Security Division U.S. Department of Justice 950 Pennsylvania Avenue NW Washington, D.C. 20530
Re: DOJ NSD Inquiry No. NSD-CES-2025-04871 — Halcyon Semiconductor Inc. First Document Production
Dear Ms. Kolb:
We write on behalf of our clients, Halcyon Semiconductor AG ("HSAG"), a corporation organized under the laws of the Federal Republic of Germany with its principal office at Semperstrasse 15, 01069 Dresden, Germany, and its wholly owned U.S. subsidiary, Halcyon Semiconductor Inc. ("HSI"), a Delaware corporation with its principal place of business at 4700 Great America Parkway, Suite 300, San Jose, California 95054 (collectively, "Halcyon" or the "Company"), in connection with the Department of Justice, National Security Division, Counterintelligence and Export Control Section's inquiry bearing reference number NSD-CES-2025-04871. The purpose of this letter is to transmit the Company's first production of documents responsive to the Department's voluntary request for information dated October 9, 2025 (the "Voluntary Request"). This production is being made in a spirit of full cooperation with the Department's inquiry and in furtherance of the Company's commitment to the prompt and transparent resolution of the matters under review.
I. Production Summary
Halcyon's first document production consists of 14,200 documents, bearing Bates numbers HALCYON-DOJ-000001 through HALCYON-DOJ-014200, comprising approximately 187,000 pages in total. The production is being transmitted contemporaneously with this cover letter via the Department of Justice's secure file transfer portal, in accordance with the transmission instructions provided by your office on October 16, 2025.
All documents have been produced in load-file format compatible with standard litigation review platforms (including Crestline Technologies and similar commercially available review tools). The load file includes extracted text, metadata fields, and, where applicable, native-format attachments. To the extent that any documents were produced in image format (TIFF or PDF), searchable OCR text has been provided in an accompanying text file for each such document. Unitization has been performed in accordance with the Department's standing production specifications, and document families (i.e., parent e-mails and their attachments) have been kept together and linked through the appropriate load-file fields.
Should the Department encounter any technical difficulties accessing or loading the production files, we respectfully ask that you contact the undersigned so that any issues may be promptly addressed.
II. Categories of Documents Produced
The documents included in this first production fall within the ten categories described below. For the Department's convenience, we have organized the description by reference to the applicable Bates ranges.
1. Shipment Records (HALCYON-DOJ-000001 – HALCYON-DOJ-003842)
This category contains commercial invoices, packing lists, bills of lading, airway bills, and delivery confirmations relating to the seventeen (17) shipments at issue identified in the Voluntary Request. Of these seventeen shipments, eleven (11) were consigned to Zhonghe Microelectronics Co., Ltd. ("Zhonghe"), located at 12/F, Nanshan Digital Tower, Keji South Road, Nanshan District, Shenzhen 518057, People's Republic of China, and six (6) were consigned to Lansheng Harborline Technologies Technologies Ltd. ("Lansheng"), located at Block C, Tianfu Software Park, No. 599 Shijicheng South Road, Chengdu 610041, People's Republic of China. These shipments occurred during the period from March 12, 2024 through August 19, 2025 and involved HCA-9100 series analog-to-digital converter chipsets classified under Export Control Classification Number ("ECCN") 3A001 on the Commerce Control List, 15 C.F.R. Part 774, Supplement No. 1.
Each of these seventeen shipments followed the same transactional routing: HCA-9100 series products were manufactured at HSAG's fabrication facility in Dresden, Germany, shipped to Archipelago Component Solutions Pte. Ltd. ("Archipelago"), an authorized distributor located at 18 Boon Lay Way, #07-142 TradeHub 21, Singapore 609966, and thereafter forwarded by Archipelago to the PRC-based end users identified above.
In the interest of completeness, and to provide the Department with a fuller picture of the Company's export activities involving ECCN 3A001 products destined for PRC-based customers, this category also includes documentation for an additional twenty-three (23) shipments of ECCN 3A001 products to other PRC-based customers that occurred during the same March 2024 through August 2025 period. These additional shipments were not specifically identified in the Voluntary Request but have been included voluntarily to facilitate the Department's review and to demonstrate the Company's commitment to transparency. The shipment records for these twenty-three additional transactions are organized chronologically following the records for the seventeen shipments at issue.
2. End-User Certificates and End-Use Statements (HALCYON-DOJ-003843 – HALCYON-DOJ-004219)
This category contains end-user certificates ("EUCs") and end-use statements obtained from Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. in connection with each of the seventeen shipments at issue. These certificates and statements were obtained by Archipelago Component Solutions Pte. Ltd. from the respective end users as part of the order-processing workflow and were subsequently provided to HSAG's Trade Compliance department in Dresden for review and retention. Each EUC identifies the end user, the end-use application declared by the customer, and certifications regarding re-export, re-transfer, and non-diversion. Where available, supporting documentation accompanying the EUCs — including signed company letterhead confirmations and translated versions of originally Chinese-language documents — has also been included.
3. Export Classification and Licensing Records (HALCYON-DOJ-004220 – HALCYON-DOJ-005106)
This category comprises the Company's internal ECCN classification worksheets for HCA-9100 series products, including technical parameter analyses that formed the basis for classifying these products under ECCN 3A001. The category also includes license exception analyses prepared by HSAG's Trade Compliance department evaluating the potential applicability of various license exceptions under the Export Administration Regulations ("EAR"), as well as "No License Required" ("NLR") determinations memorialized in HSAG's internal compliance records. Specifically, these records document the Company's analysis of whether the HCA-9100 series products qualified for export or reexport to the PRC under applicable EAR provisions, taking into account the items' technical parameters, the countries of origin and destination, the identity of the end users, and the declared end uses. Where classification analyses were revised or updated during the relevant period, all versions have been included, with the effective date of each version clearly indicated in the document metadata.
4. Restricted-Party Screening Records (HALCYON-DOJ-005107 – HALCYON-DOJ-007891)
This category contains records documenting the restricted-party screening performed in connection with the shipments at issue, as well as the twenty-three additional shipments referenced in Category 1 above. The restricted-party screening records include:
(a) Screenshots and transaction log files from HSAG's Brightmoor Solutions ("SAP GTS") system, reflecting the automated screening of customer names, addresses, and other identifying information against U.S. government restricted-party lists (including the Entity List, the Denied Persons List, the Unverified List, and the Specially Designated Nationals and blocked Persons List), as well as applicable EU and German restricted-party lists, at the time of order entry into HSAG's enterprise resource planning system; and
(b) Screenshots and transaction log files from the Sentinel-powered restricted-party screening system operated by Archipelago Component Solutions Pte. Ltd. Sentinel Compliance Data Services Ltd. ("Sentinel"), headquartered in Edinburgh, United Kingdom, provides the underlying restricted-party list data and screening engine utilized by Archipelago. These records reflect Archipelago's screening results for Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. at the time of order entry and, where available, at the ship-confirm stage.
These screening records are of particular relevance to the Department's inquiry insofar as they bear on the question of whether Zhonghe's addition to the Entity List, 15 C.F.R. § 744.11, effective June 14, 2025, was timely reflected in Archipelago's Sentinel-powered screening database. As detailed more fully in the documents produced in Category 10 below, there was a lag of twelve (12) calendar days — nine (9) business days — between the June 14, 2025 effective date of Zhonghe's Entity List designation and the June 26, 2025 date on which Sentinel pushed the updated data to Archipelago's screening system. The screening records in this category document the results returned by Archipelago's system during this interval.
5. Customer Correspondence (HALCYON-DOJ-007892 – HALCYON-DOJ-011340)
This category comprises e-mail communications between HSI sales personnel and representatives of Archipelago Component Solutions Pte. Ltd. relating to orders placed by Zhonghe Microelectronics Co., Ltd. and Lansheng Harborline Technologies Technologies Ltd. for HCA-9100 series products. The correspondence in this category covers the period from January 1, 2024 through October 9, 2025, which encompasses the full period identified in the Voluntary Request as well as a reasonable period preceding the earliest shipment at issue to capture relevant pre-shipment communications.
Among the HSI personnel whose correspondence is included in this production is Ryan Oshiro, Director, Asia-Pacific Sales, HSI, who served as the principal commercial point of contact between HSI and Archipelago for customer accounts in the People's Republic of China during the relevant period. The correspondence includes, among other things, order-related communications, pricing discussions, delivery scheduling, customer technical inquiries, and communications regarding compliance requirements and end-use documentation.
All responsive e-mail communications were collected from HSI's Ashgrove Software environment, HSAG's on-premises e-mail archive, and custodial hard-copy files maintained by Mr. Oshiro and other identified custodians. De-duplication was performed at the family level using MD5 hash values, and communications protected by the attorney-client privilege or the work product doctrine have been withheld and logged on the privilege log described in Section III below.
6. Compliance Policy Documents (HALCYON-DOJ-011341 – HALCYON-DOJ-012003)
This category contains the Company's operative export compliance policies and procedures in effect during the relevant period, including:
(a) HSAG's Global Export Compliance Policy, Version 4.2, effective January 1, 2024 (the enterprise-wide compliance framework governing all HSAG group entities, including HSI);
(b) HSI's U.S. Export Compliance Procedures Manual, Version 3.1, effective March 15, 2024 (the U.S.-specific procedures manual addressing HSI's obligations under the EAR, the International Traffic in Arms Regulations, and applicable sanctions programs administered by the Office of Foreign Assets Control); and
(c) Archipelago Component Solutions Pte. Ltd.'s Trade Compliance Standard Operating Procedures, Version 2.0, effective July 1, 2023 (the trade compliance procedures maintained by Archipelago in its capacity as HSAG's authorized distributor for the Asia-Pacific region).
These policy documents establish the division of compliance responsibilities among HSAG, HSI, and Archipelago, including the respective obligations of each entity with respect to export classification, end-user screening, end-use verification, recordkeeping, and escalation of red flags.
7. Training Records (HALCYON-DOJ-012004 – HALCYON-DOJ-012847)
This category includes records of export compliance training sessions attended by relevant HSI and HSAG personnel during calendar years 2024 and 2025. The training records encompass sign-in sheets documenting individual attendance, training materials (including presentation slides and handouts), completion certificates issued to participating employees, and, where available, training agendas and post-training assessment results. These records document both mandatory annual compliance training and supplemental, ad hoc training sessions conducted in response to regulatory developments, including the expanded Entity List designations announced in 2024 and 2025 relevant to PRC-based semiconductor entities.
8. Organizational Charts and Personnel Records (HALCYON-DOJ-012848 – HALCYON-DOJ-013102)
This category contains organizational charts for: (a) HSAG's Trade Compliance department, based in Dresden, Germany; (b) HSI's Regulatory Affairs group, based in San Jose, California; and (c) the compliance function within Archipelago Component Solutions Pte. Ltd. in Singapore. The organizational charts reflect the reporting structures in effect during the relevant period and identify the individuals occupying key compliance roles within each entity. Also included in this category are position descriptions (or, where formal position descriptions were not maintained, functional summaries) for relevant personnel, including those individuals with direct responsibility for export classification, restricted-party screening, order review, and compliance escalation.
9. Distributor Agreement (HALCYON-DOJ-013103 – HALCYON-DOJ-013488)
This category contains the Authorized Distributor Agreement between HSAG and Archipelago Component Solutions Pte. Ltd. (the "Distributor Agreement"), originally executed on April 1, 2021, together with all subsequent amendments through and including Amendment No. 3, effective September 1, 2024. The Distributor Agreement governs the terms and conditions under which Archipelago is authorized to distribute HSAG products, including HCA-9100 series chipsets, to customers in the Asia-Pacific region. Also included in this category are all export-compliance-related addenda and schedules attached to the Distributor Agreement, including the Trade Compliance Addendum (specifying Archipelago's obligations regarding restricted-party screening, end-user verification, recordkeeping, and compliance reporting) and the Audit Rights Schedule (setting forth HSAG's contractual right to audit Archipelago's compliance records and systems).
The Distributor Agreement and its amendments are relevant to the Department's inquiry insofar as they establish the contractual allocation of compliance responsibilities between HSAG and Archipelago and provide the basis for the Company's exercise of audit rights to obtain records from Archipelago for production in subsequent submissions.
10. Sentinel SLA Documentation (HALCYON-DOJ-013489 – HALCYON-DOJ-014200)
This category contains documents relating to the restricted-party list screening data services provided to Archipelago Component Solutions Pte. Ltd. by Sentinel Compliance Data Services Ltd., headquartered in Edinburgh, United Kingdom. Specifically, this category includes:
(a) The service agreement between Archipelago and Sentinel governing the provision of restricted-party list data and screening engine services (the "Sentinel Service Agreement");
(b) The service level agreement provisions within the Sentinel Service Agreement, which specify, among other things, that Sentinel shall update its restricted-party list databases "within five (5) business days of publication" of changes to applicable governmental restricted-party and denied-party lists;
(c) Incident logs maintained by Archipelago documenting Sentinel's performance against the contractual database-update service levels, including records of instances in which updates were not delivered within the specified five-business-day window; and
(d) Correspondence between Archipelago and Sentinel relating to the delay in updating Sentinel's database to reflect Zhonghe Microelectronics Co., Ltd.'s addition to the Entity List. As reflected in these documents, Zhonghe was added to the Entity List, 15 C.F.R. § 744.11, effective June 14, 2025. However, the updated entry for Zhonghe was not pushed to Archipelago's Sentinel-powered screening system until June 26, 2025 — a lag of twelve (12) calendar days and nine (9) business days, which exceeded the contractual service level of five (5) business days by four (4) business days. The correspondence in this sub-category documents the parties' communications regarding the cause and remediation of this delay.
These documents are central to understanding the circumstances under which Archipelago's screening system failed to flag Zhonghe as an Entity List party during the interval between June 14 and June 26, 2025, and are therefore directly responsive to the Department's inquiries regarding the Company's compliance controls and their operational effectiveness.
III. Privilege Log
Accompanying this production is a privilege log identifying all documents that have been withheld from production, in whole or in part, on the basis of the attorney-client privilege, the work product doctrine, or both. The privilege log has been provided as a separate attachment in Microsoft Excel format, under the file name "HALCYON_DOJ_Privilege_Log_Prod1.xlsx."
The privilege log identifies a total of 312 documents that have been withheld or redacted. For each withheld or redacted document, the privilege log identifies: (a) the date of the document; (b) the author or sender; (c) the recipient(s) and, where applicable, individuals copied; (d) the general type or nature of the document (e.g., memorandum, e-mail, legal analysis); and (e) the specific basis or bases for the privilege assertion (i.e., attorney-client privilege, work product protection, or both). Where a document has been produced in redacted form rather than withheld in its entirety, the privilege log so indicates and describes the nature of the redacted material.
The Company has endeavored to assert privilege narrowly and only with respect to materials that fall squarely within the scope of recognized protections. Should the Department wish to discuss or challenge any specific privilege assertion, we are prepared to address such issues promptly and, where appropriate, to provide the documents at issue for in camera review.
IV. Reservations
The Company makes the following reservations in connection with this production:
1. This production is made on a voluntary basis and in the spirit of cooperation with the Department's inquiry. Nothing in this production or in this cover letter shall be construed as a waiver, in whole or in part, of any right, privilege, defense, or objection available to the Company under applicable law, including but not limited to any rights under the Fourth and Fifth Amendments to the United States Constitution, the attorney-client privilege, the work product doctrine, or any other applicable evidentiary privilege or protection.
2. The production of any document herein does not constitute an admission by the Company as to the relevance, authenticity, accuracy, completeness, or admissibility of such document in any proceeding, whether administrative, civil, or criminal in nature.
3. The Company reserves the right to supplement, correct, or amend this production as additional information becomes available, including as a result of the Company's ongoing internal review. The Company's investigation into the matters identified in the Voluntary Request is ongoing, and the Company anticipates producing additional documents in the coming weeks. In particular, the Company expects to produce records obtained from Archipelago Component Solutions Pte. Ltd. pursuant to the Company's contractual audit rights under the Distributor Agreement, which records are currently being collected and reviewed for responsiveness and privilege. The Company will advise the Department promptly regarding the anticipated timing of this supplemental production.
4. This production is made without prejudice to the Company's right to object to any future requests for information, documents, or testimony, and shall not be deemed to establish any precedent or practice with respect to the scope, format, or timing of any future production.
We trust that this production will be of assistance to the Department in its review. Halcyon remains committed to cooperating fully and transparently with the Department's inquiry into the matters referenced above, and the Company will continue to devote the resources necessary to respond to the Department's requests in a thorough and timely manner. We are available to discuss this production, including its organization, scope, and contents, at the Department's convenience. Please do not hesitate to contact the undersigned or Howard Quinn at (202) 555-7412 to arrange a call or meeting at a mutually agreeable time.
We appreciate the Department's willingness to engage constructively with the Company as this matter proceeds.
Respectfully submitted,
CALDERWOOD & HARKNESS LLP
By: ________
Liam Donahue Associate 1301 K Street NW, Suite 1100 Washington, D.C. 20005 Telephone: (202) 555-7425 E-mail: ldonahue@calderwoodharkness.com
cc: Howard Quinn, Partner, Calderwood & Harkness LLP Jonathan Weir, Trial Attorney, Counterintelligence and Export Control Section, National Security Division, U.S. Department of Justice

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