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Topic: Conflict Minerals

The attached memos outline recent developments regarding the Dodd-Frank "conflict minerals” in Court Case No. 12-1422. This report outlines recent developments regarding the Dodd-Frank "conflict minerals” statute. For those watch companies that must comply - - because they are retailers and must register with the SEC - - the first

Memorandum from our attorneys at Covington & Burling regarding the exemption in the Dodd-Frank statute that exempts retailers from the "conflict minerals” reporting requirements where the retailer does not "contract to manufacture” a product, such as a watch, that contains gold, tin and other metals from the Congo and adjacent