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Overview of NSA IP Transfer Restriction Framework This section provides an overview of the three principal structural elements of the NSA that, together, establish the comprehensive framework governing the transfer of VPI intellectual property to HSAG and its affiliates: (i) the core prohibition on technology transfer set forth in NSA Section 6; (ii) the Technology Control Plan set forth in NSA Annex B, which operationalizes the Section 6 prohibition through detailed procedures; and (iii) the data segregation and cybersecurity requirements set forth in NSA Annex D, which establish the technical infrastructure within which compliant information sharing must occur

These three elements are mutually reinforcing and must be understood as a unified system rather than as independent obligations

Each proposed transfer must be evaluated and authorized independently under the applicable regulatory regime

These requirements create the technical infrastructure within which all IP transfer compliance must operate

VPI's information technology systems — including all servers, workstations, data storage devices, and network infrastructure — must be physically and logically separated from HSAG's global corporate network

Any electronic communication of non-controlled technical information between VPI and HSAG must pass through a defined "information gateway" that is administered by VPI's Facility Security Officer, Col