Cablegate: Extrancheck: Post-Shipment Verification: Lawrence and Mayo

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DE RUEHNE #4717/01 2971120
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R 241120Z OCT 07
FM AMEMBASSY NEW DELHI
TO RUCPDOC/USDOC WASHDC
RUEAHLC/HQ ICE IAO WASHINGTON DC
INFO RUEHC/SECSTATE WASHDC 8953

UNCLAS NEW DELHI 004717

SIPDIS

SIPDIS

USDOC FOR 532/OEA/M. NICKSON-D/KGAINES/JAY HATFIELD
USDOC FOR 3131/USFCS/OIO/ANESA/KREISSL
USDOC FOR 4530/MAC/ANESA/OSA
ICE HQ FOR STRATEGIC INVESTIGATIONS
STATE FOR EB/ESP

E.O. 12958: N/A
TAGS: ETTC ETRD BEXP IN
SUBJECT: EXTRANCHECK: POST-SHIPMENT VERIFICATION: LAWRENCE AND MAYO
(I) PVT. LTD., MUMBAI

REF: USDOC 08441

1. Unauthorized disclosure of the information provided below is
prohibited by Section 12(c) of the Export Administration Act.

2. On October 17, 2007, Export Control Officer (ECO) Paul Cushman
and BIS FSN Prem Narayan conducted a Post-shipment Verification
(PSV) at Lawrence and Mayo (I) Pvt. Ltd. (L&M), Mumbai.

3. BIS requested a PSV at L&M, a private sector company, located at:
Lawrence & Mayo House, 274 Dr. D.N. Road, Mumbai 400001, Tel:
91-22-2207-7440, Fax: 91-11-2207-0048, Email:
instmum@lawrenceandmayo.co.in, website: lawrenceandmayo.co.in.
Reftel requested BIS New Delhi conduct the PSV at L&M in Panvel,
Maharashtra. Upon establishing contact with L&M, they advised BIS
New Delhi that the Panvel facility is for warehousing only.
Therefore, the PSV was conducted at L&M headquarters in Mumbai. L&M
was listed as the Ultimate Consignee for two SF-2040G Starfire pole
mount receivers for survey/GIS with accessories (radio and
navigational aid apparatus). The exporter was Western Latitudes
(WestLat), Centennial, Colorado. Export License Number: No License
Required (NLR). ECCN: 7A005.

4. ECO and FSN Narayan met with R.H. Mendonsa, Managing Director and
G.V. D'Souza (D'Souza), General Manager, Geometrics & Engineering
Instruments Division, L&M. D'Souza stated that in 2006, WestLat
appointed L&M as the exclusive distributor in India for the entire
NavCom product line.

5. D'Souza stated that the items on check are incorporated into a
sophisticated and rugged Global Positioning System (GPS) used in the
conduct of physical surveys. Clients for this equipment include
real estate developers, construction firms, and engineering firms
involved with infrastructure projects. He stated that prior to
initiating any project, their clients conduct an engineering survey
of the terrain and record topographical data. The data collected
are then used to prepare designs for roads, railroads, canals,
buildings, and townships. The Starfire pole-mounted receiver is
used as a Geographical Information System (GIS) that complements the
GPS to achieve more accurate results.

6. D'Souza stated that the items on check were sold to Reliance Gas
Transportation Infrastructure Ltd. (RGTI) based in Navi Mumbai,
Maharashtra. RGTI's parent company, Reliance Group, is India's
largest private sector enterprise, with subsidiaries in polyester,
fiber intermediates, plastics, petrochemicals, petroleum refining,
oil & gas exploration and production. RGTI purchased the GIS to
collect geographical information in preparation for a pipeline
project. When completed, the pipeline will deliver natural gas to
homes throughout India.

7. To substantiate this sale to RGTI, D'Souza provided the following
documents: WestLat Commercial Invoice, L&M Tax Invoice reflecting
quantity as four GPS sold to RGTI, a receipt for import duties paid
to the Indian Customs Service, delivery challan, and RGTI
acknowledgement of receipt of the items on check.

8. D'Souza then provided the BIS team with a tour of L&M's offices,
a small warehouse where they maintain an inventory of WestLat/NavCom
products, and a small workshop where they assemble new equipment and
repair equipment supplied under warranty. In the L&M workshop,
D'Souza assembled a GPS unit with the Starfire pole-mounted receiver
(similar to that listed in reftel) and demonstrated its usage.

9. Established in 1877, L&M is a small company with two divisions:
Optical and Instruments. The Optical Division is L&M's core
business. It has 43 outlets in 17 Indian cities selling spectacle
frames, prescription lenses, contact lenses, sunglasses, and optical
accessories. In the Instruments Division, L&M represents foreign
firms, marketing their products in India. L&M's Instruments
Division has 16 sales offices in India. The products that L&M
handles include surveying, material testing, environmental
monitoring equipment, scientific instruments, vacuum pumps, vacuum
systems, vacuum oil and vacuum accessories. D'Souza mentioned
several times that L&M supplies vacuum systems to Bhabha Atomic
Research Centre (BARC). L&M's other clients include Indian
Railways, collieries, oil industry, universities and engineering
colleges, quality control and research laboratories. L&M employs
approximately 130 personnel. L&M's sales for FY-07 were
approximately 5 million USD.

10. Recommendation: Based on the interview and inspection of
documents provided, the business operations of Lawrence & Mayo (I)
Pvt. Ltd. appear to be legitimate. However, because a physical
inspection of the listed items could not be accomplished, the PSV

for this transaction remains inconclusive.
MULFORD

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