From: David G. Mayer, a business transactions partner of the law firm of Patton Boggs LLP and author of the book, Business Leasing for Dummies® (BLFD). The book is out of print, but copies may still be available; so if you want to find a copy, please search the web today! Thanks for buying my book for over three years.
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"Offering leasing and financing strategies for your success"
MARCH 2005
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Aviation Finance Players Focus on Potential Impact of Cape Town Convention Speculation abounds. The international treaty called the Cape Town Convention on International Interests in Mobile Equipment (Cape Town) and the related Aircraft Protocol (Aircraft Protocol) could enter into force as early as August 1, 2005. As a player in commercial or business aviation, are you ready? Do you understand the treaty and how it operates in deals where you buy, sell, finance and lease aircraft, engines and helicopters in domestic and international markets? Have you begun to revise your documents or reevaluate risk profiles of international transactions under Cape Town? If you answered "no" to any of these questions, you have plenty of company.Cape Town and Aircraft Protocol are designed to facilitate buying, selling, financing and leasing of commercial and business "aircraft objects" worldwide. The treaty is triggered when transaction parties create various "international interests" in those aircraft objects. It will apply to all qualifying aircraft transactions in the United States when the Aircraft Protocol enters into force. Cape Town is in effect, but must be ratified along with the Aircraft Protocol for the combined terms to impact U.S. transactions. *Terms to Know: The term "aircraft objects" refers to (1) airframes of civilian aircraft certified to carry at least eight persons or goods weighing at least 2750 kilograms, (2) aircraft engines using jet propulsion with at least 1750 pounds of thrust or its equivalent and turbine-powered or piston engines with at least 550 rated take-off shaft horsepower or its equivalent, and (3) helicopters certified to carry at least five persons or goods weighing at least 450 kilograms, together with accessories and records of each aircraft object. See: Section 2(b) of Article I of the Protocol. The term "international interests" refers to the interests held by a creditor such as a seller, lender or lessor under a conditional sale agreement, security agreement or leasing agreement. See: Articles 2 and 7 of Cape Town.In anticipation of Cape Town becoming effective, Congress passed the "Cape Town Treaty Implementation Act of 2004" (H.R. 4226) last year (Implementation Act). See: FAA Issues Final Rules to Implement the Cape Town Convention, by David G. Mayer, Business Leasing News (Jan. 2005). The Implementation Act will help ensure the smooth transition to the international registration of aircraft, engines and helicopters under the Aircraft Protocol. The U.S. ratified the Cape Town Convention last year as the fifth country (of the required eight) needed for Cape Town and the Aircraft Protocol to become effective. Once the eighth country ratifies Cape Town, Cape Town and the Aircraft Protocol will take effect on the first day of the month that occurs three months later. See: Protocol Article XXVIII. Significant deliberations by other countries, including Canada and Ireland, suggest that ratification could occur by the eighth country as early as the end of April. In that event, Cape Town will enter into force on August 1, 2005, and the U.S. implementation rules will take effect simultaneously.*Tip: In the long term, Cape Town will make aircraft transactions easier. In the near term, the learning curve will be steep and the treaty creates many substantive questions. But, the effort should be worthwhile for those players in aviation who value the opportunities it is expected to create.Fundamental Objectives of Cape Town Cape Town and the Aircraft Protocol intend to accomplish certain bold economic and legal objectives, including to:
Facilitate Provide Create Decrease Scope of Cape Town Cape Town will apply to U.S. deals involving international interests in aircraft objects completed after Cape Town and the Aircraft Protocol become effective. It will also cover existing deals that create new international interests, such as a new lien on an aircraft. To trigger Cape Town, the aircraft object must either be registered in a country ratifying Cape Town (a Contracting State) and/or the debtor must be situated in a Contracting State. See: Article 3 of Convention and Article IV of Protocol). The Registry and the Rights Cape Town and the Aircraft Protocol will establish one worldwide-computerized registry of "prospective international interests" (legal interests in aircraft objects such a security interest that will take effect at a future time on closing the related transaction) and "international interests." The treaty already provides a single location in Ireland to file "international interests" in aircraft objects (see Articles I(y) and I(o) and IV-XIX of Cape Town). Cape Town and the Aircraft Protocol will create an array of important new rights and remedies that may constitute new and different rights and remedies from those in effect in a Contracting State. Cape Town and the Aircraft Protocol will also:
Provide Give Alter New Treaty, New Process When Cape Town and the Aircraft Protocol become effective, the functions of the Federal Aviation Administration (FAA) will expand to encompass the treaty’s provisions. The FAA will act in tandem with the "International Registry" in Ireland by serving as the sole entry point of transmission of filings at the International Registry affecting civil aircraft and engines (voluntary by the FAA). The FAA will continue to serve in its existing role and functions to file and record documents regarding aircraft in Oklahoma City for purposes of giving the aircraft its U.S. nationality. However, the FAA rules and process will change to the extent necessary to incorporate the provisions of the Implementation Act, Cape Town and the Aircraft Protocol. For example, the lien filings at the International Registry will alone determine all priority in aircraft objects against which the lien is filed. Those who engage in aircraft transactions will have an opportunity to develop new sale, financing and leasing structures that use the benefits of Cape Town and the Aircraft Protocol. For example, documentation will evolve to capture new remedies for default or insolvency, and include conditions regarding the new filing requirements to protect and perfect rights an international interest in an aircraft object. Similarly, closing procedures for transactions involving aircraft objects will adapt to these new substantive laws and requirements of the Cape Town registry in Ireland. Unlike the FAA, the International Registry will function 24 hours per day and be accessible by approved users of the Cape Town system. Regulations and procedures related to Cape Town authorities will soon be published for more detailed instruction on using the International Registry. Unknown Effective Date No one knows when Cape Town and the Aircraft Protocol will become effective. Once effective, the provisions of Cape Town and the Aircraft Protocol will generally prevail over contrary provisions of international or domestic law of a Contracting State. The laws include the Uniform Commercial Code, the Chicago Convention (Convention on International Civil Aviation, signed at Chicago, 7 December 1944), the Rome Convention (Convention for the Unification of Certain Rules Relating to the Precautionary Arrest of Aircraft, signed at Rome, 29 May 1933, the Geneva Convention (Convention On The International Recognition Of Rights In Aircraft, signed at Geneva, 19 June 1948), and other contrary provisions of existing law and treaties.The status of efforts by various countries to ratify Cape Town often remains shrouded in secrecy. Yet experts at a Cape Town conference sponsored last month by Strategic Research Institute widely expect the treaty to become effective sometime this year and possibly as early as July 1, 2005. Regardless of when that occurs, the time to gain an understanding of Cape Town and the Aircraft Protocol is now. *Action Item: If this topic touches or concerns your business, please feel free to request registration for our March 21, 2005 briefing at Patton Boggs where our unique aviation/transportation team speak, as described in the Message from the Founder’s below.
2. Wind Power Dilemma: Will the Production Tax Credit Expire Again? t happened before in 2003 and it may happen again. The production tax credit (PTC) makes the delivery of wind energy financially competitive with other hydrocarbon fuel sources. Even with oil cost skyrocketing toward $60 per barrel, the Congress may allow the PTC to expire at the end of this year. History has shown that the loss of the PTC damages the continuous development of wind power. As a result, this situation will force many developers to accelerate construction of wind farms into 2005 in such states as Texas, Colorado, Pennsylvania, Kansas, Illinois, California and Minnesota. See: Wind Power Imperiled as Production Tax Credit Expires, by David G. Mayer, Business Leasing News (March 2004).*Technical Point: Section 45(a) of the Internal Revenue Code of 1986, as amended (Code), provides a formula to calculate the amount of the PTC. Before it expires, the PTC for any tax year is an amount equal to the product of 1.5 cents multiplied by the kilowatt-hours (kwh) of specified electricity produced by the taxpayer and sold to an unrelated person during the tax year. See also IRC Section 38. The PTC is available for each taxable year in the 10-year period beginning on the date the facility is originally "placed in service" (put in a state of readiness and availability for its specifically assigned function). The PTC is subject to adjustment in accordance with the Code.On October 4, 2004, President Bush signed into law a two-year extension of the PTC. Section 313 of the Working Families Tax Relief Act of 2004 (H.R. 1308) (Public Law No. 108-311) extended the then 1.8 cent per kilowatt-hour tax credit ($18.00 per MWh) for all facilities placed in service on and after January 1, 2004, and on or before December 31, 2005. See: Wind Energy Tax Credit Revived, Gives Boost to Ailing Wind Power Industry, Business Leasing News (Oct. 2004).*Warning: Strictly comply with the placed in service requirements under the Code; otherwise, the loss of the credit may destroy the assumptions used in economic modeling and dramatically reduce presumed cash flows presented in a wind farm pro-forma. Consult tax counsel regarding the level of operation and use of a wind farm project that will suffice to place a wind farm in service and entitled you or your customers to claim the PTC.While Congress addresses other national issues, the wind power industry worries about the continuation of the PTC and the future development of wind power. At the same time, the states continue to enact or propose legislation to encourage or require the development of energy production from renewable resources, including wind power. For example, Illinois Governor Rod Blagojevich plans for wind farms to generate 3,000 MW of power for the state by 2012. See: Illinois governor to have 4,000 MW of state’s power generated from renewables, Global Power Report, The McGraw-Hill Companies (Feb. 17, 2005). Washington, D.C. and 19 states have created incentives and/or requirements to build renewable energy resources. With the benefit of the PTC, the industry may have a solid year of growth in 2005 with about 2,500 MW of new generation to be installed this year. See: Wind Power Challenged but Turbines Still Turning, by Ken Silverstein, UtiliPoint® International, Inc., reprinted by PowerMarketers.com (March 2, 2005).*Tip: The expiration of the PTC will likely push the wind industry into another boom-bust cycle—from boom this year as developers race to place in service new generation before the PTC expires December 31—to the potential bust in 2006 when the credit may not be available. This problem is compounded by the market reports that the turbine supply for 2005 has been sold, and the turbine manufacturers do not yet have any way to predict demand for 2006 and beyond without the PTC being in effect. Unfortunately, unless Congress acts in the next few months, the bust seems likely to occur early next year because wind power economics do not compete well against other traditional oil and gas energy resources without the boost from the PTC. Consequently, since 2004, the American Wind Energy Association has been calling on Congress to pass a long-term extension of the PTC to provide a stable market environment and unleash the technology’s potential as a energy source.Once again, the wind energy industry finds itself hustling to install new wind generation in 2005 because the PTC expires December 31, 2005. An increasingly viable, technologically sound and environmental friendly power source, wind energy still faces a struggle for long-term financial viability. With the help of Congress, the industry will eventually breeze right into the mainstream of power development and production, but the industry faces the dilemma of what to do in 2006 and beyond while the extension of the PTC remains in doubt.
3. California E-Waste Law Makes a Mess of Leasing Electronics California started a quiet revolution this year when it required compliance with its Electronic Waste Recycling Act of 2003 (SB 20) (CA Act) beginning January 1, 2005. Following California’s lead, about a dozen states, including Colorado, Illinois, Connecticut and New York, have begun to study, draft and/or pass similar legislation. These states and others, in a hodgepodge of rules and regulations, will impose recycling fees, require collection and remission of the fees by various parties, and enforce penalties for non-compliance of electronic waste recycling laws. The sweeping and divergent state approaches have already begun to impact buyers, resellers, lessors, manufacturers and lenders of electronic devices commencing on the sale and continuing through disposal of the devices.The California Electronic Recycling Act The CA Act creates a set of rules and regulations that aim to: Reduce Impose Distribute Establish The Consumer Electronics Retailer Coalition (CERC) has been closely following and summarizing the legislative initiatives in other states. CERC is a public policy trade association dedicated to the concerns of consumer electronics specialty and general retailers, and their customers. CERC has summarized the divergent approaches by the state, recognized the validity of the recycling movement and proposed a comprehensive and consistent federal statutory solution to harmonize the recycling obligations of the affected parties on a national basis.The Problem of Electronic Waste CERC has described the problem of e-waste. It notes that the current infrastructure in the United States for collecting, reusing and/or recycling consumer electronic devices at their end of life has not kept pace with growing waste flows. The huge quantity of consumer electronic products entering the waste stream will increase dramatically unless states or the federal government take immediate action to increase the reuse and recycling efforts and options. For example, consider that users recycle only 10 percent of all of their electronics, 250 million computers will become obsolete in the next 5 years, and 130 million cell phones will be trashed each year, resulting in 65,000 tons of annual e-waste. How to discard these items in an environmentally friendly way poses a daunting and immediate challenge to the state and federal governments.The Cost and Challenge for Lessors and Commercial Markets The CA Act imposes a fee of between $6 to $10 on the "retail sale" of every new or refurbished "covered electronic device" (CED). See: Section 42463 of the Public Resources Code. It also requires a retailer, including a lessor under current law, to collect and remit the e-waste fee. By imposing a fee (rather than a tax), California can charge those entities that may not pay sales taxes in California, but do have a connection to the state relating to the retail sale of CEDs.*Tip: The Equipment Leasing Association has been working hard to limit the exposure and responsibilities of lessors to collect and remit the fee. As of February 16, 2005, California introduced legislation called A.B. 575, to amend the Public Resources Code, in part to accomplish this objective. For more information, call Dennis Brown, ELA Vice President, State Government Relations, at (703) 516-8368 or click on ELA E-Waste Initiatives. For the legislative language and locations of amendments to various California statutes, see: SB 50 Text.Covered Electronic Devices and Transactions Lessors face difficult challenges of determining the scope of the devices that constitute a CED and complying properly with the legislation in the many different states in every transaction involving CEDs. These challenges have been summarized by the ELA.*Terms to Know: Focus on these terms, and then check out the legions of others in the CA Act:
A "refurbished device" refers to a CED that the manufacturer has tested and returned to a condition that meets factory specifications for the device, has repackaged, and has labeled as refurbished. While the terms may seem relatively clear, applying them to leasing or purchase transactions creates some complexity and confusion due to the breadth of the terms and the newness of the rules and regulations. *Warning: Few electronic or technology devices will escape this fee. If the proper parties fail to collect and remit the fee, states like California may impose penalties on the responsible lessors, manufacturers or other retail sellers. Given the vast array of transactions involving CEDs, lessors, manufacturers, buyers, lessees and other sellers must comply with this emerging legislation. In financing and leasing transactions, consider adding provisions to your lease, loan and sale documentation that protect your interests and compliance obligations. Consult knowledgeable counsel before you find yourself liable for unexpected fees and penalties. Closely follow the legislation in states in which you do business so you comply when the states begin to collect new recycling fees.The disposal of electronic waste creates a serious problem for the environment. Taking the lead in the effort to minimize future disposal of electronic devices, California commenced collection of an electronic recycling fee on January 1, 2005. As other states follow, using often-divergent approaches to the problem, lessors, lenders, buyers, manufacturers and other retail sellers will have to comply strictly with the new rules or face serious consequences.
4. Leasing 101: What Is a "Forum Selection Clause”? A "forum selection clause" is a contract provision in which the parties agree to a court in a particular location in which disputes between them will be litigated. The parties basically establish the place to sue and be sued. See: Forum Selection Clause, by Geoffroy Michaux, Cornell Law School (Oct. 31, 2004) (a white paper analyzing the use of forum selection clauses in U.S. and international matters).*Tip: Lessors and lenders typically pick a court near their chief executive or operational offices though they may agree to other locations, such as New York, depending on the parties and the nature of the assets involved. More than one choice of law and forum may be appropriate. For example, a New York law transaction with Texas equipment as collateral may include a choice of Texas law and Texas forum with respect to the assets or the obligations relating to them.A "choice of law" or "governing law" provision will usually accompany a forum selection clause. A choice of law provision provides which state law will apply to the transaction. For example, a deal based on New York law will usually include a forum selection too. The forum typically would be the New York State Supreme Court (the court of basic jurisdiction, not the highest court) or the Southern or Northern District Federal Courts located, in each instance, in New York City. In a different transaction, another company with a significant presence in Minnesota may choose Minnesota law as the governing law of the lease transaction and select the state courts located in Minneapolis as the place where they would litigate disputes, if any, regarding the transaction. A third transaction may involve U.S. and non-U.S. parties and differing national laws on important issues. They may choose a neutral forum and laws such as court in London, England applying appropriate U.K. law. *Tip: The parties should agree to both choice of law and forum selection provisions in separate or combined provisions. For example, a very short form that combines a choice of law and forum selection could read as follows:
The parties may also consent to personal jurisdiction in the selected courts, which indicates their willingness to appear in the selected court without objection, regardless of where they may reside or work. *Warning: The foregoing clause attempts to accomplish that goal too. However, these clauses typically go on at length in separate clauses, and negotiators should consult with counsel to get them right for your deal.Recently, the Norvergence cases have questioned whether the forum selected is enforceable by lessors. In other words, even if a lessor and lessee have agreed in writing to select New York or Minnesota law, the lessee could ask the court to throw out the forum selection provision, and pick a different place to litigate with different law more favorable to the lessee. *Tip: It is very important for lessors and lenders to understand and, through their counsel, properly draft these clauses.
5. BLN Case & Comment: Norvergence Strikes Again - Preferred Capital, Inc. v. Thomas E. Strellec The Norvergence cases continue to send shock waves through the leasing community. In the unreported and pending case of Preferred Capital, Inc. v. Thomas E. Strellec, Jr., et al., Court of App., Cuyahoga County, Ohio (COA No. 85706 et al.) (Feb. 2005), the Court of Appeals in Ohio will hear an appeal to a lower court ruling that the forum selection clause contained in the Norvergence lease (described below) was unenforceable. If upheld, the case would enable the lessee to disregard the choice of the Ohio courts as the forum in which Norvergence’s assignee, Preferred, would settle its disputes with the lessee. BACKGROUND: In this case Norvergence assigned its rights to rental payments under certain Equipment Rental Agreements to Preferred. Though Norvergence did not perform, Preferred, as assignee, nonetheless sued the lessees to perform and pay the rents to Preferred as the assignee for value from Norvergence of the rental payment rights. Preferred had a waiver of defense provision to prevent the lessee from halting payments to Preferred based on the alleged breaches by Norvergence of its duties to the lessee. The lessees refused to pay Preferred, and Preferred brought those suits in Ohio, the forum selected in the lease, to collect the rents. Unfortunately, and in drastic contrast to most other court rulings in Ohio on the same issue, the lower Ohio court ruled in Preferred’s case that the choice of forum clause in its lease was unenforceable. It so decided because the lease did not name the state (Ohio) and court (exact forum) in which disputes would be litigated with Norvergence or its assignee (Preferred). The forum clause in that lease said the parties chose the law of "the State in which the assignee’s principal offices are located" and any case would be "venued exclusively in a state or federal court located within that State." ISSUE AND ANSWER: Is the forum selection clause enforceable as written? The lower court said no, which resulted in this appeal.LAW OF CASE: While many cases uphold forum selection clauses, one case stands out. InThe Bremen v. Zapata Off-Shore Co., 407 U.S. 1, 523 (1972), the U.S. Supreme Court recognized that forum selection clauses provide "an indispensable element… in trade, commerce, and contracting." The court found that these clauses should be enforced unless the objecting party demonstrates that it is unreasonable. Other courts have expanded on the fundamental premise in Bremen. They have concluded that these clauses will be valid and enforceable, in general, if:
OUTCOME: Unknown. The question remains open in the Preferred cases.*Comment: A loss for Preferred could deter lessors and lenders from taking assignments of rents or other cash flows in transactions with small to mid-sized (and other) businesses. A loss could create less predictability in enforcing these assignment deals. A loss would introduce new elements of risk that may cause assignees like Preferred to increase the financing rate to take an assignment of rents or debt. The point is that lessors and lenders should not do business as usual and ignore the challenges raised in the Preferred case. Perhaps the old adage would have paid off here: "An ounce of prevention is worth a pound of cure." As prescribed in Bremen, lessors or lenders should not select a forum that is so "gravely difficult and inconvenient … that he (the other party) will for all practical purposes be deprived of his day in court. Absent that, there is no basis for concluding that it (a forum selection clause) would be unfair, unjust, or unreasonable to hold that party to his bargain." See: 401 U.S. 1, 19. It does not appear to me that Preferred breached the Bremen standard, and that this forum selection clause should be held valid and enforceable against the lessee in this case.As a result of concern for the commercial position of lessors, the Equipment Leasing Association filed an extensive Amicus Curiae brief in favor of Preferred on this issue. While the outcome will not be known by press time, the case sends a warning shot over the bow of leasing and financing transactions to proceed with care in using forum and choice of law provisions in small ticket to middle ticket leases.*Tip: As a lessor or lender, you should consider protecting yourself in future transaction documents regardless of the outcome. For example, you could specifically name the federal or state court in your lease documents in conspicuous lettering. In addition, for small to mid-sized businesses as lessees, you could obtain such lessee’s or borrower’s written acknowledgment of the forum and governing law provisions (which the lessee or borrower can separately initial as a binding approval). Finally, lessors and lenders could request that lessee consult counsel on the consequences of selecting a particular forum and governing law, and provide written evidence of that consultation (though in small ticket deals, such a requirement may be commercially burdensome and unrealistic).
6. About Patton Boggs LLP and My Law Practice; Recent Publications; Upcoming Speeches About Patton Boggs LLP and My Law Practice I am a member of the Patton Boggs LLP Corporate Finance Group in our Dallas office. Patton Boggs LLP is a law firm of more than 400 lawyers located in five offices in the United States and internationally in Doha, Qatar. The firm has extensive capabilities in over 50 distinct areas of legal practice that include leasing, secured transactions, personal property financing, corporate finance, syndications, power project regulatory, development and finance disciplines, mezzanine financing, bankruptcy, real estate, public policy, litigation, intellectual property and technology law, and much more. The leasing and secured transaction practices regularly involve the buying, selling, financing and leasing of real and personal property of all kinds, including business aircraft, energy, facility, production, power plant, technology and health care assets. We also structure, negotiate and close secured transactions of all kinds, securitizations, tax-exempt and federal leasing arrangements, and corporate and portfolio acquisitions, among a full range of financing and acquisition transactions. Despite the improving economy, we continue to assist our clients with troubled deals and bankruptcies, including repossessions, lift stay actions, true lease contests, deficiency litigation, workouts and forbearance arrangements. If I, or any other lawyer at Patton Boggs LLP can help you with your legal or business challenges, feel free to call me at (214) 758-1545 or e-mail me at dmayer@pattonboggs.com for information about any of these areas or the many others available at Patton Boggs LLP, or to discuss anything I have written in Business Leasing News. We welcome the opportunity to build a relationship with you!Recent Publications Here are two feature articles published in January by David G. Mayer: Off Balance Sheet Leasing: Is the End in Sight?, The Bright Side of Big Deficits, Upcoming Speeches On Monday, March 14, 2005, at 9:30 a.m., I will speak at a Legal Symposium on Equipment Leasing Risks, Rewards and Strategies at the Las Vegas Convention Center, sponsored by the National Stone, Sand & Gravel Association. On Monday, March 21, 2005, from 8:00 a.m. to 2:00 p.m., I will lead a distinguished panel at a special breakfast briefing at Patton Boggs LLP in our Dallas office, entitled The New Era of Business Aviation. We will discuss the business and legal impact of the forthcoming Cape Town Convention and related Aircraft Protocol, the New Fractional Share Rules, use of special purpose entities to own aircraft and increased DOT/FAA Regulatory Enforcement Actions against owners and operators. This event will be by invitation only. See Founder’s Message below for more on this event. On Sunday, May 15, 2005, Bob Downey of Caterpillar Financial Services Corporation and I will speak on Leasing to State and Federal Government: A Primer in Specialized Markets, at the 2005 Legal Forum sponsored by the Equipment Leasing Association, at the Loew’s Miami Beach Hotel, Miami, Florida. On Tuesday, May 17, 2005, Stephen T. Whelan of Thacher Profitt & Wood, LLC, and I will be conducting an interactive "Breakout Session" on Complex Transactions. Steve will address credit support issues in securitizations and I will talk about the fundamentals of The Cape Town Convention and related Aircraft Protocol. We will present at the 2005 Legal Forum sponsored by the Equipment Leasing Association, at the Lowe's Miami Beach Hotel, Miami, Florida.
A Message From the Founder, David G. Mayer On Monday, March 21, 2005, from 8:00 a.m. - 2:00 p.m., Patton Boggs LLP will present a briefing for The New Era of Business Aviation. Our unique line up of speakers from Patton Boggs LLP will provide an insightful and succinct discussion of the hottest issues in business aviation. The speakers include: Rodney E. Slater, former Secretary of Transportation (DOT) in the Clinton Administration; Gregory S. Walden Stephen McHale, former Deputy Administrator of the U.S. Transportation Security Administration (TSA); and David G. Mayer, Author of Business Leasing For Dummies and Founder of Business Leasing News. As the first article in this issue suggests, the changes coming soon under the Cape Town Convention and the related Aircraft Protocol demand the immediate attention of individuals who engage in business aviation transactions. But we will go much further to help those who attend not only understand the hot issues, but also to get to know the significant resources that Patton Boggs LLP provides in the combined team listed above. We will also focus on:
This program will be useful and informative. It is free of charge to registered guests, and we will provide supporting materials on request. This event will also afford the participants the opportunity to network and interact with the panelists. Many of the spots for this invitation-only event have been filled, but we have some room remaining. As a BLN subscriber, we will do our best to accept your request for registration. For more details, feel free to call me at (214) 758-1545 and if you would like to attend, please request registration by submitting your contact information to dallasrsvp@pattonboggs.com. We will notify you by e-mail when our registration list is completed to confirm your registration status. If you have any special arrangement you would like to make, let us know in your e-mail and we will assist you. Have a great March and thanks, as always, for reading BLN. Thanks to the BLN Staff I extend special thanks to BLN’s editors at Patton Boggs LLP for their comments on this edition, J. Atwood Jeter, a real estate and wind power associate, Margaret Anderson, Adrian Nicole McCoy and the rest of our great BLN staff, as well as our primary web site review partner, Jeff Turner. The technical team, consisting in part of George Barber and Winston Jackson, provide you the easy-to-use e-mail navigation and artistic appearance of BLN. Claire Campbell, our Chief Librarian in Dallas, provides research for BLN. All the best, David
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