Withdrawn

"The company was reported as potentially selling pump products in Iran. In 2018 CalPERS designated the company as under review. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the regions and/or activities targeted by the Act. CalPERS has maintained the company in “monitor” status for 2020. CalPERS continues to monitor the company for possible changes in status relevant to the Act."

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In 2015, CalSTRS designated Sulzer AG as “Under Review” for potentially having ties to Iran. In 2016, CalSTRS designated Sulzer AG as “Being Monitored” while conducting further review of the company’s internal controls and compliance programs and maintained that designation in 2017. In 2018, CalSTRS removed Sulzer AG from the “Being Monitored“list after reviewing internal controls and receiving confirmation the company ceased doing business in Iran. In 2019 CalPERS changed the designation to “being monitored” because CalPERS’ initial screening has not identified the company as having involvement in the activities targeted by the Act. CalPERS will continue to assess and/or monitor the company for possible changes in status relevant to the Act.

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Sulzer's Middle East contact is listed as an attendee at the Focus Iran Summit & Exhibition that took place from September 26-27, 2016, in Tehran, Iran. (Participating Companies)

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"The Swiss newspaper Sonntag reported that engineering group Sulzer (SUN.S) had since 2009 conducted much less business there than in previous years, citing a company spokeswoman. Sulzer was not immediately available for comment." (Reuters, "ABB, other Swiss firms halting Iran business," 1/31/10)

Alfred Dunhill website does not list a store in Iran. 

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Alfred Dunhill is a subsidiary of Swiss luxury goods holding company Richemont. 

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The British luxury goods company lists Kish Benin as an authorized retailer in Tehran. (Alfred Dunhill Website, “Find a Store,” input: “Iran”) 

As of August 27, 2019, BMW is listed on the Illinois Investment Policy Board Iran Restricted Companies list. 

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On October 2, 2018, the U.S. embassy in Berlin announced BMW would not pursue any economic activities in Iran. (October 2, 2018)

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Sells vehicles in Iran through Persia Khodro.

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An entity claiming to be the "sole BMW importer in Iran" has produced a facebook page displaying the address of a BMW showroom located in Tehran. This points to the possiblity that BMW still maintains an importer in Iran.

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"The Trade Promotion Organization of Iran has announced the list of cars which are allowed to be imported in the current Iranian year, but renowned brands such as Porsche, Benz, BMW, Maserati, and Nissan are not in the list, ISNA news agency reported." (Azer News, "Iran bans imports of renowned car brands," 5/27/2013)

Sungjin Geotec is a subsidiary of South Korean Steel Company POSCO

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According to an Annual Report filed by POSCO for fiscal year 2012: "We acquired a controlling interest in Sungjin Geotec Co., Ltd. (“Sungjin Geotec”), a manufacturer of specialized equipment used in the power and energy industries in May 2010, and we currently hold a 33.0% interest in the company. In recent years, Sungjin Geotec entered into contracts with various suppliers to supply equipment for the development of natural gas fields in Iran, including natural gas fields located in South Pars that is led by Pars Oil and Gas Company, a subsidiary of National Iranian Oil Company. Sungjin Geotec recognized revenues of approximately Won 27 billion in 2010, Won 240 billion in 2011 and Won 134 billion in 2012, and net profits of approximately Won 1 billion in 2010, Won 15 billion in 2011 and Won 25 billion in 2012 related to such activities. Sungjin Geotec has completed or terminated all of its remaining outstanding supply contracts to sell equipment for the development of natural gas fields in Iran, and it does not plan to engage in any sale of equipment in Iran related to the country’s development of petroleum resources in the future."

As of May 17, 2021, Iowa's Public Employee's Retirement System lists POSCO on its Iran Scrutinized Companies List.

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As of August 15, 2019, the state of Iowa listed POSCO on its Iran scrutinized companies list.

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"The latest development in the tug-of-war between Iran and Saudi Arabia has manifested in the kingdom blocking an investment deal by South Korea in Iran’s steel industry. South Korea’s POSCO Engineering & Construction had signed a $1.6 billion memorandum of agreement with the Iranian steelmaker, Pars Kohan Diar Parsian Steel (PKP), in May 2016, to build a steel mill incorporating POSCO’s proprietary technology in Iran’s Chabahar Free Trade-Industrial Zone." (January 23, 2018).

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POSCO is the parent company of Sungjin Geotec Co., LtdPOSCO, and Daewoo Internationalbsp;POSCO has an extensive American presence through its subsidiaries and joint ventures including POSCO America Corp., United Spiral Pipe LLCUSS-POSCO Industries

POSCO reportedly participating in the Iran Mines & Mining Industries Summit, being held in Tehran May 31-June 1, 2015. (IMIS Website, “List of companies participating in IMIS”)

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"Iranian Mines and Mining Industries Development and Renovation Organization (IMIDRO) welcome cooperation with South Korean POSCO (Pohang Iron and Steel Company) in implementing new steel projects in southern Iran, deputy minister said Saturday... Deputy Industries, Mines and Commerce Minister and head of IMIDRO Mehdi Karbasian made the comment in a meeting with the visiting top manger of POSCO Jin Sik Choi, further elaborating that Iran-Korea cooperation in steel field will be along the southern coasts of Iran, including in Chabahar, Bandar Abbas and Asaluyeh... The top POSCO manager said that his multinational firm is ready to assist Iran in implementing its steep plants using the modern 'Finex' technology. Jin Sik Choi said that POSCO has recently assembled a steel plant with nominal annual production capacity of two million tons and before that a steel factory with annual 1.5 million ton production, both using the Finex technology." (IRNA, "Iran welcomes South Korean cooperation in steel projects," 1/31/15)

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"South Korea's POSCO has announced readiness to invest in Iran's steel projects, the Fars News Agency reported on March 15. A number of officials from POSCO met with officials from Iran's Mobarakeh Steel Company in the Iranian city of Isfahan. Korea's export-import companies are expected to benefit as the Obama administration issued a statement on January 20 that it would temporarily lift sanctions against Iran, according to Businesskorea website. South Korea regained the right to resume the export of automobile parts and steel and import of oil from Iran, which has historically been its major supplier…The steel industry is among the beneficiaries of the ease of sanctions. Sales of steel products totaled $373 million. The market share of steel products is also 24.3 percent, nearly a quarter of the whole market. Particularly, the demand for steel plates for automobiles is expected to rise, and overall, Iran's focus on manufacturing is expected to help to increase the general demand for steel as a whole.” (Trend, “South Korea’s POSCO ready to participate in Iran’s steel projects,” 3/15/14)

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"South Korean steelmaker POSCO , minority-owned by Warren Buffett's Berkshire Hathaway, has cut ties with government entities and sensitive industries in Iran such as energy and continues to trade with private firms, a letter showed... In a letter sent to U.S. pressure group United Against Nuclear Iran (UANI) dated Feb. 28 and seen by Reuters, POSCO, a top global steelmaker, said it had scaled down business  with Iran. 'Certain of POSCO's subsidiaries continue to engage in transactions in Iran,' POSCO's chief legal officer Song Se-Bin wrote in the letter. 'However, these transactions involve only the civil market. Moreover, these POSCO entities engage in transactions only with Iranian entities that POSCO believes, based on its best due diligence efforts, are not owned or controlled by the Iranian government.' Song said POSCO entities had 'completed, terminated or assigned all of their activities related to the sensitive sectors of the Iranian economy - the energy, defence and nuclear sectors.' 'Although these efforts have resulted in the loss of certain projects and substantial financial losses to the POSCO entities, POSCO believes it important that it be regarded as a responsible corporate citizen.' A targeted campaign by UANI, which includes former U.S. ambassadors as well as former CIA and British intelligence chiefs on its board, has led to several foreign companies in sectors including shipping to exit Iran. UANI, which is funded by private donations and backs tougher sanctions on Tehran, had called on POSCO to cease its Iran trade. UANI chief executive Mark Wallace said it appreciated the company had taken multiple steps to reduce its Iran business. 'We continue to call, however, for POSCO to fully end its business in Iran,' said Wallace, a former U.S. ambassador to the United Nations.  'Given the nature of the business, the only way for POSCO to eliminate its exposure to the Iranian regime and IRGC-controlled entities is to completely pull out of the country,' he said, referring to the Revolutionary Guards, which reports directly to Iran's Supreme Leader. POSCO, which is 5.1 percent owned by Berkshire Hathaway , is the world's No.5 steelmaker by output. Buffett's business partner Charlie Munger has frequently praised POSCO as being, in his opinion, the best-run steelmaker in the world. Buffett, via his assistant, could not be immediately reached for comment. When contacted about its Iran deals, POSCO spokeswoman Jiyoung Kim said: 'POSCO and its subsidiaries stopped trades with Iranian government and state-run Iranian companies.'POSCO will abide by the law regarding U.S. sanctions on Iran, and plans to actively cooperate with U.S. policies.'... POSCO's Song said in the letter it followed strict guidelines on trading with Iran which required written confirmation from the Korea Strategic Trade Institute, which is under Seoul's economy ministry, that any investment or trading did not directly or significantly contribute to enhancing Iran's oil capabilities or involve blacklisted entities or individuals. Song said POSCO personnel would 'face disciplinary action for non-compliance' if they did not adhere to its trading policies in Iran.  'POSCO shares UANI's goal of thwarting Iran's nuclear programme,' Song said." (Reuters, "S.Korean POSCO cuts back on Iran steel business," 3/12/2013)
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"We engage in limited business activities and investments relating to Sanctions Targets, including Iran, Myanmar and Sudan . . . Our subsidiaries also engage in limited business activities and investments relating to Sanctions Targets . . . We expect to continue operations and investments relating to countries targeted by United States and European Union economic sanctions." (SEC, "Form 20-F," 4/30/12)

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"We acquired a controlling interest in Sungjin Geotec Co., Ltd. (“Sungjin Geotec”), a manufacturer of specialized equipment used in the power and energy industries in May 2010, and we currently hold a 36.7% interest in the company. In recent years, Sungjin Geotec entered into contracts with various suppliers to supply equipment for the development of natural gas fields in Iran, including natural gas fields located in South Pars that is led by Pars Oil and Gas Company, a subsidiary of National Iranian Oil Company." (SEC, "Form 20-F," 4/30/12)

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"POSCO, a construction company in which we hold an 89.5% interest, engages in the planning, design and construction of industrial facilities in Iran."(SEC, "Form 20-F," 4/30/12)

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"Daewoo International, a global trading company in which we hold a 66.6% interest, engages in the trading of steel, raw materials and other items with Sanctions Targets, including Iran and Sudan."  (SEC, "Form 20-F," 4/30/12)

"So despite concerns over regulation and reputation, that opportunity explains the caravan of container carriers that started resuming service to Iran back in January. The Iranian port at Bandar Abbas now welcomes ships from Evergreen, Hyundai, OOCL, Hanjin, “K” Line, KMTC, X-Press, Yang Ming, and many more..." (Global Trade, "Transportation/Logistics:Iran is Back Open for Business," 11/1/2016).

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"Taiwanese lines Evergreen and Yang Ming Marine said they had pulled out, while Singapore's Pacific International Lines has also cut ties along with two top South Korean shipping firms." (Reuters, "Chinese Firms Drop Iran as Latest U.S. Sanctions Bite," 07/01/2013)

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On June 23, 2011, the U.S. Treasury Department sanctioned Tidewater Middle East Co. (“Tidewater”), Iran’s major port operator, because the IRGC owns it and uses it for illicit activities

including weapons shipments. (U.S. Department of the Treasury Press Center, “Treasury Sanctions Major Iranian Commercial Entities,” 6/23/11)  The EU followed with its own sanctions against Tidewater on January 23, 2012. (Official Journal or the European Union: Council Decision 2012/35/CFSP)

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Operates as a liner & feeder in Iranian ports.  (Ports and Maritime Organization: Shipping Lines which operating in Iranian Ports)

Uses Tidewater Middle East Co.’s private terminals in the Shahid Rajaee Port Complex. (Tidewater: Reflection of Tomorrow)

"Singapore shipping company Pacific International Lines (PIL) has ceased acceptance of cargoes in and out of Iran.

What is more, the shipping company has terminated all calls to Iran." (Offshore Energy, "PIL Terminates Vessel Calls to Iran due to US Sanctions," 10/15/18)

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"The Islamic Republic of Iran Shipping Line (IRISL) has penned a Memorandum of Understanding with Singapore-based counterpart Pacific International Lines (PIL), Iran’s Mehr News Agency reports. Under the MoU, the two countries laid the groundwork for collaboration in the field of maritime transport, including through establishment of feeder lines in South East Asia, Southern Asia, the Middle East, the Black Sea and other regions, along with cooperation in ship construction and technology transfer." (March 4, 2016).

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Operates as a liner in Iranian ports.  (Ports and Maritime Organization: Shipping Lines which operating in Iranian Ports)

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"Taiwanese lines Evergreen and Yang Ming Marine said they had pulled out, while Singapore's Pacific International Lines has also cut ties along with two top South Korean shipping firms." (Reuters, "Chinese Firms Drop Iran as Latest U.S. Sanctions Bite," 7/1/2013)

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Listed by the Iranian Ports and Maritime Organization as doing business with the Iranian company Delta.  (Ports & Maritime Organization: Companies Affairs Department: Liners)

As of July 1, 2021, Iplom is not identified by the US State of Mississippi as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.”

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On June 30, 2020, the Mississippi Department of Finance & Administration identified IPLOM as a company “engaged in investment activities in Iran, providing funds, goods or services valued at $20,000,000 or more in the energy sector of Iran.” 

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In 2017 and 2019 the U.S. state of Mississippi listed IPLOM on its Iran prohibited companies list rendering IPLOM ineligible for investment and/or state contracting.

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Iran continues its quest for new crude buyers, especially in Europe, but its loyal customer base will continue to hinge on countries like India and China, whose demand for Iranian crude has observed a steady rise this year. Iran has found interest for its crude in some unusual places in the past few months as it continues it diversify its list of buyers. Earlier this month it agreed to sell 1 million barrels of crude oil to Hungary via Croatia as it seeks to widen its post-sanctions customer base, which now includes cargoes sold to oil major BP, France's Total, Greece's Hellenic Petroleum, Spain's Repsol and Cepsa, Russia's Lukoil, Poland's Grupa Lotos, Portugal's Petrogal and Italy's Saras and Iplom. Iran said it has held talks with Bosnia and Herzegovina this week as it hopes to expand its list of crude oil export destinations. However, its shipments to Asia remain the pillar of its export market. (Platts, "Analysis: Iran eyes new crude oil buyers, Asia remains linchpin," 11/1/2016).

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“Iplom SpA, [has] reportedly signed long term contracts with the National Iranian Oil Company (NIOC) to purchase crude oil from Iran.” (PressTV, “Italians seal oil purchase deals with Iran,” 6/23/2016).

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"Other oil companies in the Mediterranean including Spain's Cepsa and three other Italian oil firms, ERG, Iplom and Saras have planned to take their last cargoes from Iran in June, other market sources said." (Reuters, "Eni suspends Iran's debt payments in oil," 5/31/2012)

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Iplom imported 30,000 barrels of Iranian crude per day in both March and April of 2012. (Reuters, "Europe's Buyers Trim Iranian Oil Imports in April," 4/18/12)

According to its website, Iranian company Amitis is an authorized representative for KROHNE in Iran.

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Manufacturer of sophisticated measurement systems for the oil and gas industry.  Participated in the 2012 Iran Oil Show.

"Finnish mining technology company Outotec will pull out of Iran due to the new U.S. sanctions, a company spokeswoman said on Monday.

Outotec, which builds plants, makes equipment and offers services for the metal and mineral processing industries, has a long history in Iran and it remained in the market after the United States instituted sanctions against Iran in 2010.

Its business started to normalise after the 2015 nuclear deal with Iran, helping Outotec to book orders from National Iranian Copper Industries Company (NICICO) and Iran International Engineering Company (IRITEC).

The latest sanctions against Iran follow U.S. President Donald Trump’s decision to pull out of the nuclear deal with Tehran. The new sanctions have forced companies across Europe to reconsider their investments there." (Reuters, "Mining tech firm Outotec to pull out of Iran -spokeswoman," 9/24/18)

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Outotec was removed from the May 15, 2019 Iowa Public Employees' Retirement System Iran Prohibited Companies List.

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In 2019 Outotec was removed from the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  

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In 2018 Outotec was listed on the Texas Comptroller List of Companies Engaging in Scrutinized Business Operations in Iran.  
 

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In 2017, CalSTRS designated Outotec OYJ as “Under Review” for potentially having ties to Iran. In 2018, CalSTRS removed Outotec OYJ after reviewing the company’s business with Iran and internal controls to prevent sanction violations.

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"Finnish mining technology company Outotec is yet to decide on leaving the Iranian market, the company's Tehran office announced." 5/30/2018. 

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Finnish mining technology company Outotec expects order intake from Iran to slow after U.S. President Donald Trump’s order to reimpose sanctions on Tehran, the company’s finance chief said on Thursday.CFO Jari Algars told Reuters by email that, if project financing was not available, future orders would decline: “Reinstating the sanctions would not stop business, but it will complicate it and slow it down.” Asked if Outotec was considering leaving the market, Algars said it was “too early to say”. During the sanctions, Outotec made so-called “stop and go” deals in Iran, where it was paid in increments and delivered accordingly, Algars said." (5/17/2018)

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In 2017 the U.S. state of California listed Outotec as a company under review for providing products and expertise for copper smelting in Iran.

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In 2018 the U.S. state of Iowa listed Outotec as an Iran restricted company rendering Outotec ineligible for investment and/or state contracting.

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"Outotec has agreed with National Iranian Copper Industries Company (NICICO) on the delivery of two sulfuric acid plants for the Sarcheshmeh and Khatoon Abad copper smelters in the Kerman province in Iran. The value of the orders, approximately EUR 50 million, has been covered by a confirmed Letter of Credit and booked in Outotec's Q4/2016 order intake. Outotec's scope of delivery includes engineering, main process equipment and instrumentation for the acid plants as well as spare parts and supervisory services for installation and commissioning. Outotec's deliveries will take place in mid-2018." (Outotec Website, "Outotec to Deliver Two Sulfuric Acid Plants to Iran," 1/18/2017). 

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"The executive vice president of the Finnish Outotec sees the prospect of relationships with Iranian companies in the field of mineral industry. The Finnish company has been present in the Iranian market as of the 1970s and today, ties with Iranian companies is strengthening, Adel Hattab told the Tehran Times. Outotec Oyj is a Finland-based company active within the mineral industry, providing process solutions, technologies, and services for the mining and metallurgical industries. “We have been here working in Iran since 1976. We are working within the steel and copper value chain. We look forward to working the within zinc, aluminum, gold and many other commodities,” he said." (Tehran Times, "Finnish Outotec Oyj sees ties with Iran solidifying," 11/22/2016).

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Outotec and Outotec Engineering are listed as attendees at the Iranian Base Metals Conference that took place from September 6-7, 2016 in Tehran, Iran. (Iranian Base Metals Conference Attendees, 2016).

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"Finnish company Outotec has been awarded a contract by Shangdong Province Metallurgical Engineering Co., known as SDM, for the delivery of process equipment to the Iron Concentrate Project Sangan in northeastern Iran. The Iranian Mines and Mining Industries Development and Renovation Organization owns the Sangan mines and SDM is their engineering partner. The contract value is approximately €10 million and the order has been booked in Outotec's 2016 second quarter order intake...The new iron processing plant will process annually 5 million tons of ore. The equipment will be delivered mostly during the second quarter of 2017." (Financial Tribune, "Finnish Firm to Supply Process Equipment to Iran Mine," 7/28/2016)

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"Finland's engineering group Outotec has been awarded a contract for the delivery of technology to set up a new iron ore beneficiation plant in northeast Iran, the company says. The plant owned by Khorasan Steel Complex Co will have a capacity to produce 2.5 million metric tons of pellet feed grade iron ore concentrate per year, expected to be commissioned in 2017. Under an order worth 45 million euros by Iran International Engineering Company (IRITEC), Outotec will provide process technology for 'a complete beneficiation plant and an entire value chain from raw material testing, process development to concentration and dewatering'. The company will be also responsible for basic engineering, and supply of key process equipment, as well as advisory services for detail engineering, construction and commissioning, Outotec said. 'This order is another significant milestone for Outotec in the quickly developing Iranian iron and steel industry,' Kalle Härkki, head of Outotec's Minerals Processing business area, said. The order is similar to one awarded by Bafgh Mineral Complex Iron and Steel Industry Company to Outotec in June to establish an iron ore pelletizing plant in Iran's central Yazd province." (Press TV, "Finland’s Outotec wins Iran iron ore deal," 9/3/2015)  

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"Finland's engineering group Outotec has won an order for design and delivery of technology and services for an iron ore pelletizing plant in Iran, the company has said. Bafgh Mineral Complex Iron and Steel Industry Company in Iran's central Yazd province has awarded Outotec as part of its greenfield investment program to build a new plant to produce 5 million metric tons of iron ore pellets a year. Outotec said the parties have agreed not to disclose the contract value but such projects normally range between $87-$109 million, depending on scope and specification. The Finnish group said its work in the project includes providing the technology license, basic engineering of the pelletizing plant, detailed engineering and supply of proprietary and key equipment and automation, as well as advisory site services for installation, commissioning and start-up. The company said the new plant is expected to become operational in 2018. Platts quoted head of Outotec's Europe, Middle East and Africa region Adel Hattab as saying that the company's pelletizing technology was selected due to its strong track record in Iran. 'Our technologies are widely used in the Iranian iron ore and copper operations, as Outotec has delivered sustainable technologies to Iran since 1970s,' he said. Hattab said Outotec was currently executing several other projects in Iran." (Press TV, "Finland Firm Wins Iran Pelletizing Project", 6/6/15)

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Outotec reportedly participating in the Iran Mines & Mining Industries Summit, being held in Tehran May 31-June 1, 2015. (IMIS Website, “List of companies participating in IMIS”)

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"Deputy Ministry of Industry, Mines and Trade Mehdi Karbasian said many European companies lost the chance of cooperation with Iran in the past but now Iran's mines and mining industry enjoys a high quality of which foreign companies can take advantage. Speaking in a meeting with Thomas Schwalm, deputy of the Finnish-German Outotec Company, Karbasian said establishment of Outotec representative office in Iran will facilitate technical and economic relations of the two sides... During the meeting Thomas Schwalm announced readiness of his company to supply Iran's mines and mining industry projects with the required technology." (IRNA, "Iranian mines, mining industry suitable for foreign companies," 12/5/14) 

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"Finnish mining technology company Outotec signed a deal with Iranian Mines and Mining Industries Development and Renovation (IMIDRO) worth €9.3 million to transfer Nepheline syenite production technology. The deal was signed on Saturday and the technology will be transferred over the course of eight months, Iran's IRNA news agency reported on November 23. The industrial use of Nepheline syenite includes refractories, glass making, ceramics and, in pigments and fillers. It is also used as construction facade, interior wall texture, and countertops. The project is aimed to produce 200,000 tons of alumina powder and 150,000 tons of industrial salts per year. Iran needs around 800,000 tons of alumina powder annually." (Trend, "Iran’s IMIDRO signs €9.3M deal with Outotec," 11/23/14) 

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"Outotec has been awarded multiple orders, worth a total of Eur265 million ($326 million), for technology deliveries to National Iranian Copper Industries Co.'s copper and molybdenum projects in Iran, the Finnish engineering group said Tuesday.Outotec will deliver technology and services to NICICO's Khatoon Abad copper smelter, Miduk copper concentrator expansion, Nowchun copper and molybdenum concentrator and Sarcheshmeh copper concentrator expansion. Outotec 'makes thorough examinations and works closely with the concerned authorities to ensure that its activities and technology deliveries are compliant with the restrictive measures against Iran,' the company said. In anticipation of possible future changes in the regulatory framework, the orders will be booked in Outotec's order backlog gradually during 2012-16 according to each year's overall progress of the particular project. Around Eur58 million of these contracts will be booked in Outotec's third-quarter order intake with the revenues recognized gradually during 2012-16, the company said." (Platts, "Finland's Outotec gets orders for Iran copper/molybdenum projects," 7/10/12)

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"Outotec has been selected by Gol-E-Gohar Mining & Industrial Co. to design and provide technology for an iron ore pelletizing plant located in the Kerman province of Iran. The plant's annual capacity is approximately five million tonnes iron ore pellets. Outotec's scope of delivery includes technology for a traveling grate pelletizing plant, engineering, key process equipment and advisory services. A local contractor will be responsible for civil works and local supply. The value of equivalent deliveries for comparable plant sizes is approximately EUR 80-85 million." (Reuters, "Press Release: Outotec to deliver iron ore pelletizing technology to Gol-E-Gohar, Iran," 4/18/12)