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Page 1 Table Of Contents Welcome to 2022 2 Capture (of More Than Words), Scent, Process, and More: An Interview With Harvey Spencer 3 On the Web 16 Page 2 Thanks for reading, Bryant Duhon Editor-in-Chief, Document Imaging Report or +1 (301) 275-7496 bdu@info-source.com Comments, criticisms, and witticisms welcomed. We’ll also be ramping up our social sharing efforts to extend our reach. When you see us on LinkedIn and Twitter, please share with your audience (and I’ll be doing the same for all the news I see from all of you). I’m looking forward to this year. Especially ramping up our online content efforts to deliver more information to you regularly. Given that I gave up on ever having all of the good ideas years ago, I would love to hear your thoughts, ideas, and suggestions for topics to cover. Of course, I’ll take volunteers for contributions as well. I’m hoping for a much better and healthier 2022. The pandemic is wearing on all of us. And, while I’ve been fortunate enough to dodge the ‘vid, I’ve felt a little bit like Job with various minor ailments that keep placing me behind the eight ball. Now of□cially this is a 2021 issue, but sending it out over the Holidays didn’t make a lot of sense (to me). That said, welcome to 2022! Welcome to 2022 Page 3 Capture (of More Than Words), Scent, Process, and More: An Interview With Harvey Spencer From OCR to smell to sentiment to opera, we covered a range of topics. Our conversation follows, lightly edited for clarity and length (yes, the initial draft was about thrice as long as this). I began with a top-of-mind topic, security. I know you aren’t a security expert, but I did want to ask you about security. Initially, I thought of security in the capture space from the POV I brought from my time in the copier industry – network-connected hard drives susceptible to hacking and unencrypted data at rest/in transit. However, when I spoke with Kevin Neal, P3iD’s CEO a few months ago [DIR 12-7-21] his perspective was broader – touching on authentication, identity management, etc. As we move to a componentized industry, security becomes a must have. That’s a long wind up to, “What are your thoughts?” DIR: I □rst met Harvey as an editorial intern for AIIM’s sometime in Winter/Spring of 1995/96. Since then, like everyone else in the industry, you pay attention to the man. As he, slowly, rides off into the sunset of a long career and semi-retirement, I thought it’d be interesting to get his thoughts on his experiences and the industry in general. inform Magazine Harvey Spencer is Founder/President of Factorum llc and Co-Founder and Partner of Xamcor. From 1989 to 2019, he in□uended the capture industry as the President of Harvey Spencer Associates. Most recently, he was Vice President of the Infosource Software Division (after Infosource acquired HSA). Page 4 The ad hoc scanner of choice these days is a cell phone. And for one, two pages; it does a wonderful job. OCR classi□es and does all sorts of other clever things. Then you've got the MFPs, people are going to use those if they're convenient. Or they're going to use scanners. They're not going to care which device they use, so they all have to play together in a secure manner. I think TWAIN Direct is 100% correct in that companies don't want to download drivers, they don't want to have to deal with different protocols – is it TWAIN? ISIS? They don’t want to have to update. They just want to use the damn thing. Just like you do a cell phone you want to be able to pick it up or stick a piece of paper in it works perfectly. I think TWAIN begins to go to allow that capability in a multi-vendor environment because there really isn’t much difference in the various scanning devices anymore. And so people go shopping on Amazon or they go shopping Best Buy or whatever and they buy a scanner, usually the cheapest one. You end up with a sort of mixed array of vendors and devices, and you want them to play together. I’m giving a TWAIN presentation [Ed note: on Dec. 9, 2021. Not currently available on the .]and was talking to Kevin [Neal] earlier. TWAIN Direct has got end-to-end encryption for transport, but what they haven't got is the identi□cation or authentication capabilities. Today anyway. The Importance of TWAIN in Tomorrow’s Computing Environment TWAIN website So, as Kevin says, when you're trying to sell to big clients, major clients who've got LDAP security, which is embedded in copiers, that can't interface to Twain very easily, maybe with P3iD, but certainly not under the current spec. So that's going to be a stumbling block, particularly, because you can't look at scanners as a as an entity anymore, I don't think you could look at scanning devices. There was a report years ago about retired MFPs sitting in a warehouse. They brought a security expert in and removed a few hard drives at random. On them, they found personally identi□able information on 10s of thousands of healthcare provider’s patients. MFP manufacturers then began to encrypt hard drives and the data, solving that problem. Spencer: 60 Minutes [Ed note: Not as exciting as shredding or drilling holes into hard drives as a solution to the disposal problem.] Page 5 You seem to be talking about two different situations here: the work from home push courtesy of the pandemic, where people might self- provision out of expediency, as well as traditional of□ce environments. DIR: I think what you're asking me to do is dissect the market. We've got the work at home people in a small business environment, or someone like me. I've got four scanning devices here . . . Spencer: Why? DIR: Good question. I've got the cell phone number one. So that's, that's one convenient way out. Then I've got a little all in one, which is basically my printer, but I use occasionally for scanning. Then I've got a nice little WiFi portable device; a ScanSnap, which I use for creating quick PDFs in order to email people a quality image. Then I've got a Canon batch scanner thing for when I have 20 pages or so to scan. Spencer: I’ve got a phone and no desire to □nd space for an MFP. DIR: But you're not going to scan 20 pages on your phone, at least if you do, you're asking for trouble. And not only would you have to □nd somewhere to put it, you’d have to plug it in, install the software and drivers to make things works. That brings us back to TWAIN Direct If you've got a server that basically handles the drivers and software automatically, life becomes much easier. Spencer: Getting back to the WFH and of□ce provisioning split . . . DIR: They’re different. There’s people like me, who always worked out of the home. So I'm a small entity in my own right, the of□ce in the home really isn't a differentiation. But work at home is a different environment, I think. I think mostly it's companies who normally would have you in the of□ce, but have employees working from home due to the pandemic. As work and life eventually return to normal, there’s going to be a mix of work from home, in the of□ce, work from smaller of□ces, or a full-time return to the of□ce. For many, it’ll be a mix of home and of□ce. Regardless of where workers will be, they just want to use scanning devices and of□ce equipment, they don’t want to have to think about it. Spencer: Page 6 Let’s move from hardware to capture software and the cloud. As new companies enter and older companies like Kofax and Hyland work to move on prem software to the cloud, how concerned are you about security? DIR: I think there's three types of companies. And I think this is relevant. There's the legacy companies who started off in the 1960s. And they created their centralized batch systems. And the banks are still in that situation, their main systems, their core systems are still running in COBOL. And they don't touch it. Spencer: Then the next generation was client/server. And so what happened with those companies is they bolted client/server stuff on top of their core systems. Then the new companies who started up in the 1980s and 90s started with client/server, they don't have mainframes, they wouldn't even want a mainframe. Now we’re in a third generation of computing, which is anytime anywhere cloud services. And I think the client/server companies are bolting cloud services on top of their core services. And I think that the client/server people have bolted classic cloud services on top of that, their calls their cloud service stuff. The new companies start with cloud and don't even think about other stuff, unless for regulations they have to. So I think you have to deal with all three environments. One of the things I've been trying to point out for some years is that companies are organic entities. They’re dynamic – continually changing through internal growth and buying other companies. They then somehow have to manage different systems. I believe in hybrid. I don't think you end up with cloud only. In that context, I think IBM has got things right. And I think security obviously becomes a key issue of dovetailing and managing those systems Do you think capture vendors have a good handle on security in that context? DIR: Page 7 No. I think one of the challenges with security is that it’s constantly changing. As soon as you get a clever app to □x a hole, somebody □nds another hole. Spencer: So how retired are you? A few months in now and any lingering doubts of “too soon”? DIR: No, no, de□nitely not too soon. My problem is I’ve got too many ideas. And I've got to settle down and actually focus on something. Spencer: In the grand scheme of things, that's a pretty good problem DIR: You don't get in trouble if you don't get anything done. And so maybe that's what retirement is – you can't make up your mind. I am fairly determined that's not going to be the case, but I'm a little nervous about it. Spencer: I am looking at being on some advisory boards – currently with KnowledgeLake and possibly with Haystack. I think these could be fun. All the fun without a whole lot of the responsibility, sounds pretty good! Are you working on your opera – English or Italian? DIR: Yes, I’ve written the scenario – in English. I need to □nd a musician. Spencer: I know you have a few more things going on too. DIR: I do work with evaluation/valuation of companies for sale (in the $5 to $30 million revenue range operating as Xamcor), and sometimes a little matchmaking. It’s interesting to see the types of companies up for sale. There are a bunch of aging service bureau people who want an exit strategy – old people like me. They haven’t been able to pass the business on to their children, so they want to get some money out of the company. Spencer: For instance, our □rst was selling Westbrook Technologies to DocuWare. Ricoh bought DocuWare in July of 2019. We knew Westbrook had an OEM relationship with Ricoh and DocuWare would bene□t from that connection. It's fun. Page 8 As you know, I □nd it fascinating and frustrating that capture/digitization is still a green□eld market (in conversations with DoubleYard and Singularity in 2021 both companies made this point). DIR: Well, one of the things I probably made a mistake on, was continuing to call it capture. I hesitated with it terribly because it was my brand and I didn't want to destroy that. Spencer: What would you have called it otherwise? What nomenclature would you have chosen? DIR: I don't know. But one of the one of the reasons that RPA became so popular, even though they're basically a capture technology, is because they came up with some jazzy new buzz words. And maybe if I had a called that robotic capture something, maybe I would have been. Spencer: RCA – robotic capture automation. DIR: Indeed, then I think, instead of capture 2.0, maybe I would have gotten some more traction. I don't know. Spencer: I've only wondered about this and I'm curious about your perspective on this. One of the things that strikes me about the capture industry suddenly saw the hardware guys who were always talking about feeds and feeds for years, and in the last decade, they're now talking about solutions which is nice. But the software side of things always seem to bounce from buzzword to buzzword, never really solidly going capture. DIR: Okay. So the other problem I've had, and I think it's signi□cant is that as capture becomes embedded into the business process, what we're really dealing with is improving business process management, process automation. So you could argue there isn't a capture industry as such, there's a series of services that enable business process automation. Now, I didn't want to go there, particularly because that would have destroyed my business. Spencer: I don't know that that would have destroyed your business, as opposed to sort of if that concept takes off, which I think I've told you this before, I tend to think that the capture industry and process industry are combining like you just said so it could have been like throwing a match into gasoline. DIR: Page 9 Well, I don't think so because I think to look at the value proposition associated with that, you got to look at the vertical, the actual applications, and, and the value proposition associated with each of those applications. So if you take something simple, like AP automation, the value comes from procure to pay, and the value comes from better treasury. Operations, cash □ow management, and discount management; that's where your value comes from. So really, what you're looking at is the Treasury automation solution, not the scanning and extraction from an invoice. Spencer: Talking about invoices leads me to something for me to do in my non- retirement; look at the future of money. With crypto currency there are lots of questions – what are central banks going to do; how will it affect the consumer, how do the clearing systems work? I mean, there's an initiative going on in Washington called BPC (Business Process Coalition), which is attempting to standardize the electroni□cation of invoices. There's a whole remake going on in the world of money systems at the moment. That’s not new for you. You talked me into running an article on Check 21 about 15 or so years ago. Nearly every time a take a photo of a check for deposit, I think of you. DIR: Yes, when do checks disappear? That's part of that issue. Spencer: So lack of market penetration is a combination of things – marketing, terminology, and the dif□culty of juggling horizontal technologies who have real value (not that accounts payable is a negligible ROI) when they’re paired with a speci□c process like mortgage loan processing. DIR: And I think if we could have done a better job on standards that could have been solved. I did come up, as you may remember, a standard with Betsy Fanning [Director of Standards at AIIM and, for a few years, my boss] to try to adopt PDF417s on documents to encode all the data on it. Spencer: I don’t, but I generally □ed from PDF standards at the time. DIR: I was trying to do two. One was encoding the data with a PDF417 so you could just read it, which was adopted them by a lot of state governments for tax returns. The second was to encode a website with a PDF417 on the document, which is now happened more with QR codes – the same principle. Adobe told me I had robbed them of a patent. Spencer: Page 10 PDF was one of our successes with Zamcor. A friend of mine in Spain had cracked how to create PDF417s without impinging on Adobe and sold it to all state governments in the US. We helped him sell his company to Foxit. Spencer: The older I get, the cooler I □nd PDF as a as an enabler of things that you just read which is nice. DIR: So PDF stands for portable document format. And in that I can have a voice recording, a video recording, 3D models; I can have just about anything I like. So all those things are documents. Spencer: Documents are containers of information, right? DIR: Yes, and capture is the method of extracting meaningful information from unstructured information of that type. I just wrote an article about scent. You can digitize scent in a similar way to color. Spencer: So you've mentioned the ability to capture any document anytime … DIR: Looking at a document on the broadest possible sense, yes. I came out with capture 4.0 as integrating customer experience management or CEM. I saw that as integrating with Industry 4.0 in manufacturing – as in making things. Siemens came up with something called industry 4.0. Which is basically a SOAP-driven series of protocols to let industrial machines communicate with each other dynamically. They talk to each other. The Germans are integrating this fairly seriously and the Japanese seem to be picking it up. Spencer: Isn't that Internet of Things? DIR: Probably part of. So again, you need standards. So this is the standards. Spencer: So can you explain Industry 4.0 and how capture relates to it? DIR: Okay, so the industry 4.0 is the same manufacturing machines being able to communicate with each other. One is, I don't know, melting glass, another one is molding glass, and another is packaging. They can all communicate with each other. Spencer: Page 11 So, without people having to recon□gure them, they recon□gure themselves dynamically. From a capture standpoint, what's intrigued me is becoming much more reactive to customer sentiment changes. Are you saying this loops back around to capture and sentiment analysis? DIR: No, I think it's voice related a lot of it, but also.. Spencer: Right, you need to translate voice to text for understanding, right? DIR: Au contraire, there are two types of voice recognition. One is what I call analog voice recognition, which basically looks at how you're speaking, and analyzes your tone and analyzes your sentiment analyzes how excited you're getting. And then the second is, is when you convert it into text, and then you do some sort of analysis from that. So you could do some sentiment analysis based upon the voice Intonation. And currently, people in the call center world are getting scored on how successful they are doing that. Spencer: So if a customer is becoming agitated or upset as they go through an automated voice tree they can be moved to a live person. Or they’re already talking to a CSR and they aren’t calming down, one of two things can happen. One, the script can change. A work□ow kicks in and you get routed to a supervisor. Here’s where I still struggle, where’s the capture part in there? There’s an obvious use for AI and machine learning to analyze text, but . . . DIR: This is where I could be criticized. I put sentiment analysis and semantic understanding language translation into capture. Spencer: That makes sense to me, but I start to lose the plot at the edges of the technology. Things start to blur. DIR: Page 12 I think what happens in the customer call center, and the customer service environment more broadly, is you are having to deal with multiple different elements – or documents, if you will. Voice is just one. For instance, for a claims adjudication, you may want to have a picture of the damage. For a loan application, you may want to have a picture of some collateral material. Spencer: I think the point that you’re making is embedding this stuff [capture technology) into a process much more actively than maybe you are now. Whereas in the past, it was maybe scanned and archived. Now it's scanned into your CRM system or scanned into wherever you want it to go. DIR: It’s important as well that the CRM system, as one example, could also decide that a document has archival or compliance implications and send a document to that queue as well. Spencer: A segue into a social media discussion about compliance; most companies don't have a clue about what's going on in social media – in terms of compliance, regulations, business impact, etc. I think capture plays a huge role in that environment. I know there are tools to capture sentiment on social media, about employees, customers, in□uencers, and competitors, but I’m struggling on the link as I wouldn’t consider those “capture” tools. DIR: I've been saying that I think capture affects all stakeholders in the company. So it affects the customers, obviously – suppliers, employees, and investors. Take AP for example and the cash□ow implications; that has a direct impact on your investors. Spencer: I know there’s research out there from Celonis, a process mining company, that shows a direct impact of AP processes to cash□ow. The combination of capture and process for claims processing is also an easy ROI, if not an easy implementation. DIR: I read recently about automating claims adjudication and trying to merge different metrics. For a car accident, you can look at weather, speed, deceleration, and other factors using cell phone data and data from the vehicle itself to make a fair assessment on how hard the other car was hit. You can also know if someone was wearing a seatbelt. Since many claims include whiplash complaints, these metrics can combine to point to whether the claim is bogus or possibly justi□ed. Spencer: Page 13 Let’s say you bump your Subaru into an old Chevy at minor speed. That should be able to be adjudicated pretty much automatically. You may have to take a picture of the damage and do an assessment for the picture, which is captured. However, if you've bumped into a Ferrari, they may want the Ferrari expert to look at this and get your text and video. The company is doing some real-time analysis, and deciding what pictures you need, what video you're going to be asked to take there and then while you're at the scene of the accident. Now Furthermore, then things like sentiment analysis comes in semantic understanding, and mood comes into this because if you are acutely distressed by this, that will come over, and then they can start dispatching someone to help you and make sure you don't get back in the car. So those types of capture applications fascinate me. So it's like Toyota, Toyota, Toyota, Ferrari, and – boom – a bump into a different work□ow. DIR: I would think so. Spencer: No, I think that that makes sense. I know the KPIs because you're looking at it from a process standpoint is time to □rst touch, which is, you know, the speed of response, how quick it took to get back to a customer when they put the claim in. And then the other thing is, getting to your point, how many requests for documentation do you need? Does the adjudicator get all the documentation quickly or do you have to loop back around to get more information from the customer, which degrades the customer experience. It's exactly what you're talking about. DIR: Another possibility for customer service and saving money is based on minor fender-benders. I know someone in Germany who had their Mercedes’ fender/mudguard slightly dented. After taking photos and submitting a claim, the insurance company deposited 250 euros into his bank account to pay the claim. They also said if it’s more than that, he would have to take it to a repair center. Spencer: He opted to pocket the money and live with the dent. Given that an actual □x would almost certainly have been more than 250 euros, the insurance company got away with paying less. These sorts of things are very intriguing from a process standpoint. And you can start to do a lot of that analysis automatically – maybe even depositing $250 into a customer account automatically within a day. Now, you're gonna go “wow!” as a customer. Page 14 Switching gears back to the “where we work” question about the pandemic and WFH and digital transformation. Do you think the attention paid to digital transformation – especially with digitization and process automation – is a blip or □nally here to stay? DIR: Oh, I think there is an acceleration in digitalization processes, acceleration in standards to try to enable that. There's already a continuous decline in the use of paper in of□ces, and that's going to continue. What my contention is in the presentation I'm giving in on Wednesday, is basically every time paper reduces in volume. The need to process it quickly increases. Spencer: [Ed note: there was some conversation about smell and touch as an input, which I cut for length. However, the next two paragraphs don’t make sense without that bit of context – smell as a capture input.] So it's all to do with sensors, it's all to do in my estimation of capture. Because what I think we're heading for is being able to take all human inputs, and basically make them understandable where they affect business processes or compliance. So tactile side touch is part of that. Let’s get out of sci-□ territory and return to an ongoing trend and something you mentioned earlier, capture lumped into some other industry. DIR: Lots of different industries, lots of different technology areas. So the core technologies, pattern recognition, pattern recognition is the core technology in a lot of ways. And that pattern recognition starts to appear in multiple different ways. Spencer: Just, you know, we've talked about, we've talked about smell, we've talked about scent, well actually smell essentially the same thing. DIR: Oh talking about customer experience and scent. There was an article which I just wrote in in London based on one little thing in the saying that they've discovered that people's preferences for cleaning products scent has moved from being fruit and □ower based to much more related to sanitizers. My comment was the company who □rst identi□es that sort of sentiment shift in the consumer world makes a lot of money. Spencer: DM Magazine Financial Times This is all about speed of business process, speed of understanding, speed of market shifts. Page 15 Some Israeli company has come up with a chip in your cell phone that will analyze your scent. I guess the dentist could use them. So basically, you're saying the use case for this is I've got my cell phone, I'm on a date, and the date is going well. So you breath and you get a big green thumbs up or a big red button that says “mint.” DIR: That's right. Spencer: And the app could be Do I need a mint? DIR: Indeed. I like that. Yes. Then a drone □ies through the door to drop the mints on your lap. Spencer: The last written question I have here is sort of the easiest. I mean, you've seen a lot in your 30 plus years? DIR: Interesting change. For me, that's from going from a bit of paper being digitized to what I'm describing. Spencer: To smell. DIR: Indeed, if you if you want to go that far for this article. Spencer: Let me just ask you one □nal question. What's one of the coolest things you did? DIR: I don't know. I feel I've been blessed in a being able to do what I enjoy doing and do quite well. I can’t think of anything speci□c off the top of my head. What has been cool for me is that I take disparate pieces of information from multiple different sources and put them together and □gure out where there's a value proposition. I get a real kick out of doing that. Spencer: Is there any one company that you that you thought when they came out, they were going to change everything, and then they didn’t? DIR: I think Kofax could have done so much better, but they lost it. And that's partly because Reynolds [Bish] didn't understand what the cloud is; that the market has moved to services. Spencer: Page 16 The □ip side of that question, is there any company that did better than you expected? DIR: On the Web What IBM has done with Datacap has been pretty impressive. Last year or the year before, they told me that instead of FileNet driving the need to scan it’s been the other way around. And considering that Datacap was a $6ish million company when IBM bought them and is now about $200 million, I would say Scott Blau has got to be pretty proud of that. Spencer: Another big disappointment was MTI Microsystems. The name change to Anydocs showed the company understood the changes it needed to make, but I think Hyland completely failed to □gure out the value proposition. Oh, and I was proud of myself for the Check 21 stuff into the cell phone. I claim that I got Mitek into that business. I went into a day-long strategy session to determine what should they be doing. They were □oundering around trying to do documents. And I said, hey, you need to get into capturing checks on a cell phone. I knew Jim DeBello had come from a cell phone technology area. And cameras of that stage were about one 1.2 megapixels. And they knew they were going to like seven-eight megapixels. And we had this quite intense meeting. And the product managers said, “No, no; it’ll never be of any use and we can't do that.” But they had a Russian technical guy who said, “Oh, that's really fascinating. I enjoy doing that because it lets me use all my mathematical skills to □x the geometrics and so on of the check.” Jim bet on it with credit, and their stock price went from I think it was 30 cents to $13. Almost overnight. I didn’t take stock because that wasn’t my business model. If you get into owning pieces of companies, then you get into inherent con□icts and you're trying to be a neutral analyst. Is Kofax Worth $3 Billion? Recent valuations would seem to say, yes. Page 17 Last week, that the private equity □rm Thoma Bravo was exploring a $3B sale of Kofax. Based in Irvine, CA, Kofax is a long-time Capture market leader that is attempting to expand into the Intelligent Automation space. $3B would be a nice return for Thoma Bravo, which is estimated to have paid $1.5B to Lexmark in 2017 for its Enterprise Software portfolio, which included the former Kofax, ReadSoft, Perceptive and Brainware businesses. Bloomberg reported Read more: https://www.info-source.com/is-kofax-worth-3b/ Fire, Disease, and Shortages Pile Pressures on Document Scanner Manufacturers’ Bottomlines For the of□ce hardware manufacturers, it must seem like the modern equivalent of the Plagues of Egypt have come to visit the industry. The emergence of Covid, the resultant chip shortage, the outbreak of a major □re in Konica Minolta’s toner factory in Tatsuno Japan, which has led to a global shortage of of□ce toner, and more recently the outbreak of the Omicron variant, which is leading to further lockdowns, are all looking likely to have a further devastating impact on the industry. Read more: https://www.info-source.com/□re-disease-and-shortages-pile- pressures-on-document-scanner-manufacturers-bottomlines/ 2020-2021 State of the Information Capture Market in Europe, Middle East, and Africa One key takeaway: The market demand for RPA solutions with Capture capabilities will continue to be strong but mature over the forecast period. Infosource predicts a growing convergence of the Intelligent Information Capture market and the RPA segment. Read more: https://www.info-source.com/2020-2021-state-of-the- information-capture-market-in-europe-middle-east-and-africa/ Page 18 □. Document Capture □. OCR/ICR, AI, and Machine Learning □. RPA □. ECM □. Records Management □. Document Output □. BPM DIR brings you the inside story behind the deals and decisions that affect your business. Vol. 31, No. 11 Managing Editor: Ralph Gammon Email: rg@info-source.com Editor-in-Chief: Bryant Duhon Email: or +1 (301) 275-7496 bdu@info-source.com DIR is published approximately 15 times per year by: Infosource SA Avenues des Grande-Communes 8, 1213 Petit-Lancy, Geneva, Switzerland http://www.info-source.com DIR is the leading executive report on managing documents for e-business. Areas we cover include: Business Trends on Converting Paper Processes to Electronic Format DOCUMENT IMAGING REPORT Page 19 Copyright @ 2021 by InfoSource SA. Federal copyright law prohibits unauthorized reproduction by any means including photocopying or facsimil distribution of this copyrighted newsletter. Such copyright infringement is subject to □nes of up to $25,000. 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