Attach to Form 990 or 990-EZ.
Information about Schedule O (Form 990 or 990-EZ) and its instructions is at| Return Reference | Explanation |
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| FORM 990 - ORGANIZATION'S MISSION | THE CORPORATION IS ORGANIZED AND WILL BE OPERATED EXCLUSIVELY FOR "CHARITABLE, SCIENTIFIC AND EDUCATIONAL- AND "SOCIAL WELFARE" PURPOSES WITHIN THE MEANING OF SECTIONS 501(C)(3) AND 501(C)(4), RESPECTIVELY, OF THE INTERNAL REVENUE CODE. TO THIS END, THE NONPROFIT SHALL UNDERTAKE ACTIVITIES TO: SUPPORT THE PROVISION OF QUALITY AND DIVERSE INSTRUCTIONAL MEDIA CONTENT AND CAPABILITIES TO EDUCATORS AND STUDENTS, INCLUDING, BUT NOT LIMITED TO, DATA SERVICES AND INSTRUCTIONAL VIDEO PROVIDED TO ACCREDITED EDUCATIONAL INSTITUTIONS AND GOVERNMENTAL ORGANIZATIONS ENGAGED IN THE FORMAL EDUCATION OF ENROLLED STUDENTS. FOSTER OPEN, HONEST AND OUTSPOKEN MEDIA THAT HELP USERS TO BE A POPULAR DEMOCRATIC CHECK ON BOTH GOVERNMENT POWER AND CONCENTRATED PRIVATE PRIVILEGE; EXPAND THE DISSEMINATION OF MEDIA, AND POINTS OF VIEW CARRIED BY THEM, THAT OFFER DISSENTING, ALTERNATIVE, OR CRITICALLY CONSTRUCTIVE INFORMATION AND CONCEPTS TO THE MARKETPLACE OF IDEAS IN BOTH LOCAL AND GLOBAL CONTEXTS; ENGAGE IN ADDITONAL SOCIAL WELFARE, CHARITABLE, SCIENTIFIC, AND/OR EDUCATIONAL ACTIVITIES AS ARE CONSISTENT WITH OPERATIONS THAT MAY BE UNDERTAKEN BY ORGANIZATIONS DESCRIBED IN, AND THUS EXEMPT FROM TAXATION UNDER, SECTION 501(C)(4) OF THE INTERNAL REVENUE CODE, AS NOW ENACTED OR HEREAFTER AMENDED. |
| FORM 990 | BACKGROUND THESE ADDITIONAL, VOLUNTARY DISCLOSURES ARE INTENDED TO GIVE THE INTERESTED READER GREATER INSIGHT INTO HOW AND WHY INSTRUCTIONAL TELECOMMUNICATIONS FOUNDATION D/B/A VOQAL USA OPERATES ITS NUMEROUS PROGRAMS AND INITIATIVES, BOTH THROUGH ITS OWN EFFORTS AND THROUGH THE LIMITED LIABILITY COMPANIES OF WHICH VOQAL USA IS PART OWNER. ON BEHALF OF A NUMBER OF NONPROFIT ORGANIZATIONS, VOQAL USA'S PRESIDENT, JOHN SCHWARTZ, LED AN EFFORT TO APPLY FOR WHAT WERE THEN REFERRED TO AS INSTRUCTIONAL TELEVISION FIXED SERVICE (ITFS ) LICENSES FROM THE FEDERAL COMMUNICATIONS COMMISSION. THOSE APPLICATIONS WERE ORIGINALLY SUBMITTED IN THE EARLY 1980S. MR. SCHWARTZ BELIEVED THAT SEPARATE NONPROFIT ORGANIZATIONS WITH LOCAL BOARDS OF DIRECTORS WOULD BETTER SERVE THE SCHOOLS AND COMMUNITIES COVERED BY THESE LICENSES. IN THE END, FIVE NONPROFITS LED BY MR. SCHWARTZ APPLIED FOR AND RECEIVED A TOTAL OF 11 ITFS LICENSES. TODAY, MR. SCHWARTZ REMAINS THE PRESIDENT OF THOSE FIVE NONPROFITS, WHICH WILL HEREAFTER BE REFERRED TO AS THE VOQAL NONPROFITS. VOQAL USA IS ONE OF THOSE FIVE. FOR NEARLY THREE DECADES, VOQAL USA PROVIDED FREE EDUCATIONAL VIDEO PROGRAMMING TO SCHOOLS VIA ITS FCC-LICENSED ITFS STATION. WHILE DOING SO, IT SHARED SOME OF ITS OVERHEAD AND ADMINISTRATIVE COSTS WITH THE OTHER FOUR VOQAL NONPROFITS, WHICH WERE PROVIDING VERY SIMILAR SERVICE TO THEIR LOCAL COMMUNITIES. THIS APPROACH RESULTED IN SIGNIFICANT COST SAVINGS, ALLOWING VOQAL USA TO DELIVER BETTER EDUCATIONAL SERVICE. THE SHARING OF PERSONNEL AND OTHER RESOURCES AMONG THE VOQAL NONPROFITS WAS THE BEGINNING OF WHAT WOULD LATER BECOME EBS SUPPORT SERVICES, LLC (EBSSS) - THE UMBRELLA SERVICE ORGANIZATION THAT TODAY PROVIDES PERSONNEL AND OPERATIONAL SUPPORT TO ALL FIVE VOQAL NONPROFITS. WITH THE INCREASED RESOURCES AFFORDED BY THESE MOST RECENT SPECTRUM AGREEMENTS, THE VOQAL NONPROFITS, INCLUDING VOQAL USA, EXPANDED THE NUMBER AND REACH OF THEIR EDUCATIONAL PROGRAMS TO INCLUDE NEW EDUCATION VENTURES, AFFORDABLE INTERNET SERVICE FOR SCHOOLS AND NONPROFITS, CASH GRANTS, EBS SPECTRUM ADVOCACY, AND MORE. AS IT EXPANDED, VOQAL USA CONTINUED TO SHARE RESOURCES WITH THE OTHER VOQAL NONPROFITS. FOR THIS REASON, IN 2009 THE FIVE VOQAL NONPROFITS FORMED EBS SUPPORT SERVICES, LLC. VOQAL USA OWNS 39.47% OF EBS SUPPORT SERVICES, LLC AND REIMBURSES IT FOR THE COST OF LEASED PERSONNEL, AS WELL AS SHARED OFFICE SPACE AND EQUIPMENT. EBSSS, LLC, AS WELL AS THE OTHER LIMITED LIABILITY COMPANIES LISTED BELOW, ARE ALL OWNED EXCLUSIVELY BY THE VOQAL NONPROFITS; THERE ARE NO OTHER OWNERS. IN 2013, TO EXTEND THESE RELATIONSHIPS AND GAIN BETTER PUBLIC RECOGNITION FOR SHARED WORK, EBSSS SECURED THE "VOQAL" TRADEMARK AND THE FIVE NONPROFITS, INCLUDING VOQAL USA, ADOPTED THE VOQAL BRAND. VOQAL HAS STRIVED TO FULFILL THE MISSION OF EBS, FROM ITS BEGINNINGS PROVIDING FREE, ITFS VIDEO TO SCHOOLS TO RECENT EFFORTS TO SUPPORT CHANGE- MAKERS IN EDUCATION. WHILE SOME VOQAL USA PROGRAMS SERVE WHAT MANY WOULD CONSIDER TRADITIONAL EDUCATIONAL ENTITIES LIKE K-12 SCHOOLS, VOQAL EMBRACES A BROADER VIEW OF EDUCATION AND AIMS TO ENSURE EQUAL ACCESS TO KNOWLEDGE TO FOSTER A STRONGER, HEALTHIER DEMOCRACY. OUR PROGRAMS ARE OFTEN AIMED AT THE ROOT CAUSES THAT BAR ACCESS TO KNOWLEDGE BOTH IN AND OUT OF TRADITIONAL BRICK AND MORTAR INSTITUTIONS. EXAMPLES OF MORE TRADITIONAL EDUCATIONAL PROGRAMS INCLUDE OUR CORE BROADBAND INTERNET ACCOUNTS AND MOBILE CITIZEN'S EFFORTS TO ENSURE THAT STUDENTS HAVE ACCESS TO THE INTERNET BOTH AT SCHOOL AND AT HOME. VOQAL EDUCATION'S SUPPORT OF THE CRASH COURSE SERIES ON YOUTUBE AND INDEPENDENT SPECTRUM'S EFFORTS TO PASS THROUGH ADDITIONAL EDUCATION BENEFITS TO MORE EBS LICENSEES ARE ADDITIONAL EXAMPLES OF THE EDUCATIONAL NATURE OF OUR WORK. EXAMPLES OF SOME OF OUR LESS TRADITIONAL EDUCATIONAL ENDEAVORS INCLUDE THE EFFORTS OF VOQAL FUND AND VOQAL FELLOWSHIP, WHICH ARE RELATED TO EDUCATION IN THE BROADER SENSE OF SUPPORTING THE DISSEMINATION OF ALTERNATIVE IDEAS AND BUILDING A MORE ENGAGED AND EDUCATED PUBLIC. A DESCRIPTION OF SPECIFIC VOQAL USA PROGRAMS IS BELOW. CORE BROADBAND INTERNET ACCOUNTS - OPERATED INDEPENDENTLY BY VOQAL USA AND ADMINISTERED BY EBSSS, LLC. VOQAL USA PROVIDES 39 SCHOOLS IN THE METRO AREAS COVERED BY ITS LICENSES WITH 556 FREE AND 26 SUBSIDIZED HIGH-SPEED WIRELESS BROADBAND INTERNET ACCOUNTS. THE SCHOOLS ARE BOTH PUBLIC AND PRIVATE, SERVICING GRADES K-12. THE ACCOUNTS ARE DISTRIBUTED TO BOTH TEACHERS AND STUDENTS. ACCOUNTS PLACED WITH STUDENTS ALLOW THOSE STUDENTS TO COMPLETE SCHOOLWORK ONLINE AT HOME THAT MIGHT OTHERWISE HAVE TO BE COMPLETED AT PUBLIC LIBRARIES, COFFEE SHOPS WITH WI-FI ACCESS OR OTHER PLACES THAT MIGHT NOT BE CONVENIENT DURING NON- SCHOOL HOURS. WE ESTIMATE THAT THE FAIR MARKET VALUE OF THESE FREE AND SUBSIDIZED ACCOUNTS IS OVER 346,000 ANNUALLY. 2015 WAS A PARTICULARLY CHALLENGING YEAR AS SPRINT REPLACED A PRIOR NETWORK TECHNOLOGY WITH 4G LTE. AS A RESULT, ALL DEVICES VOQAL USA HAD PLACED IN SCHOOLS HAD TO BE REPLACED. VOQAL USA ELECTED TO DONATE SOME OF THE EQUIPMENT TO THE SCHOOLS. THE ESTIMATED VALUE OF THE FREE REPLACEMENT EQUIPMENT WAS ABOUT 84,000. AS OF MARCH 2016, ALL 39 SCHOOLS WERE TRANSITIONED TO THE NEW TECHNOLOGY. VOQAL EDUCATION - OPERATED BY VOQAL USA AND OTHER VOQAL NONPROFITS; ADMINISTERED BY EBSSS, LLC VOQAL EDUCATION IS PROUD TO BE A FUNDER OF CRASH COURSE - GOVERNMENT AND POLITICS. CRASH COURSE IS AN EDUCATIONAL YOUTUBE CHANNEL FEATURING 10- MINUTE VIDEOS THAT CONDENSE COMPLEX TOPICS INTO QUIRKY, ENGAGING TUTORIALS. CRASH COURSE'S YOUTUBE CHANNEL HAS NEARLY 3 MILLION SUBSCRIBERS, AND THE VIDEOS ARE SHOWN IN CLASSROOMS ACROSS THE COUNTRY, AS WELL AS WATCHED BY THE PUBLIC AT LARGE. VOQAL USA PARTLY FUNDED CRASH COURSE'S GOVERNMENT AND POLITICS SERIES, WHICH HAS BEEN VIEWED WELL OVER NINE MILLION TIMES ACROSS ITS 50 EPISODES. VOQAL EDUCATION'S NEWEST EFFORT, THE EDUCATION VENTURE FUND, SEEKS TO CONNECT EARLY STAGE INVESTORS AND DONORS TO BOTH NONPROFIT AND FOR-PROFIT TECHNOLOGY STARTUPS WITH THE GOAL OF REDUCING OPPORTUNITY GAPS IN EDUCATION. 2016 WAS THE FIRST YEAR IN WHICH THE EDUCATION VENTURE FUND MADE INVESTMENTS, WITH VOQAL USA INVESTING A TOTAL OF 100,000 IN THREE DIFFERENT COMPANIES, AS WELL AS PAYING A PORTION OF THE OPERATING COSTS. THE INVESTMENTS RANGE FROM A COMPANY THAT CONNECTS INDUSTRY PROFESSIONALS WILLING TO VOLUNTEER TIME WITH TEACHERS WHO SEEK TO EXPOSE THEIR STUDENTS TO STEM ROLE MODELS TO A FIRM THAT DEVELOPS TECHNOLOGY THAT ENABLES TEACHERS TO ADAPT LESSON PLANS FOR STUDENTS WITH DISABILITIES. MOBILE CITIZEN, LLC - OWNED IN PART (45.0%) BY VOQAL USA MOBILE CITIZEN, LLC IS MADE POSSIBLE BY THE VOQAL NONPROFITS' CURRENT SPECTRUM AGREEMENTS AND THE BROADBAND INTERNET ACCOUNTS RECEIVED AS PART OF THOSE AGREEMENTS. AFTER SEVERAL YEARS OF PROVIDING INTERNET SERVICE INDIVIDUALLY, THE VOQAL NONPROFITS FORMED MOBILE CITIZEN, LLC TO PROVIDE ADMINISTRATIVE SUPPORT FOR THE DISTRIBUTION OF SOME OR ALL OF ITS MEMBERS' BROADBAND ACCOUNTS. MOBILE CITIZEN, LLC SERVES SCHOOLS, NONPROFIT ORGANIZATIONS AND SOCIAL WELFARE AGENCIES AND HAS FOCUSED MUCH OF ITS EFFORT ON BRIDGING THE DIGITAL DIVIDE. MOBILE CITIZEN OFFERS ONE OF THE LOWEST COST MOBILE BROADBAND RATE PLANS AVAILABLE TO SCHOOLS, NONPROFIT ORGANIZATIONS AND SOCIAL WELFARE AGENCIES NATIONWIDE, WITH FEW RESTRICTIONS AND NO DATA THROTTLING. MOBILE CITIZEN WIRELESS BROADBAND SERVICE COSTS APPROXIMATELY ONE-FIFTH THE AMOUNT OF ITS COMMERCIAL EQUIVALENTS, AND IS PROVIDED FREE IN SOME CASES. IN THE USA METRO AREA, MOBILE CITIZEN SERVES SCHOOLS AND NONPROFITS THAT PROVIDE SERVICES AS DIVERSE AS WORKFORCE PREPAREDNESS AND FREE COMPUTER TRAINING AND ACCESS PROGRAMS. THE MONEY THESE ORGANIZATIONS SAVE ON THE INTERNET WITH MOBILE CITIZEN ALLOWS THEM TO PUT THOSE DOLLARS TO USE FULFILLING THEIR ORGANIZATION'S MISSION. ON BEHALF OF VOQAL USA, MOBILE CITIZEN PLACED APPROXIMATELY 9,500 WIMAX WIRELESS BROADBAND ACCOUNTS WITH SCHOOLS AND NONPROFITS BOTH LOCALLY IN THE SEVEN MARKETS WHERE VOQAL USA HOLDS EBS LICENSES AND IN OTHER CITIES ACROSS THE U.S. THE ESTIMATED MARKET VALUE OF THE FREE AND SUBSIDIZED ACCOUNTS IS MORE THAN 4.5 MILLION PER YEAR. INDEPENDENT SPECTRUM, LLC - OWNED IN PART (63.6%) BY VOQAL USA AND MANAGED BY EBSSS, LLC ANOTHER BENEFIT OF THE CURRENT SPECTRUM AGREEMENT WITH A SPRINT SUBSIDIARY IS THE ABILITY, THROUGH CERTAIN PROVISIONS OF THE AGREEMENT, TO ADD ADDITIONAL SPECTRUM AND THUS HELP MAXIMIZE THE EDUCATIONAL POTENTIAL OF OTHER LICENSES. INDEPENDENT SPECTRUM, LLC (IS) WAS FORMED TO DO JUST THAT. IS ACCOMPLISHES THIS TASK IN ONE OF TWO WAYS: 1) THE DIRECT PURCHASE AND TRANSFER OF AN EBS LICENSE TO AN IS SUBSIDIARY AND SUBSEQUENT SPECTRUM USE AGREEMENT WITH SPRINT; OR 2) A SPECTRUM USE AGREEMENT WITH THE EBS LICENSEE AND SUBLICENSE OF SPECTRUM RIGHTS TO SPRINT. THROUGH THE 23 IS SUBSIDIARIES FORMED TO-DATE, IS HAS BEEN ABLE TO PASS THROUGH EDUCATIONAL AND FINANCIAL BENEFITS TO 37 EBS LICENSES. THIS "STRENGTH IN NUMBERS" APPROACH ALLOWS EBS LICENSE HOLDERS TO GAIN OPPORTUNIT |
| FORM 990, PAGE 2, PART III, LINE 2 | THE ORGANIZATION PARTICIPATES IN THE EDUCATION VENTURE FUND AS DESCRIBED ON SCHEDULE O. |
| FORM 990, PAGE 2, PART III, LINE 3 | THE ORGANIZATION CEASED EDUCATION ON DEMAND IN JULY 2015. THIS ENDED THE ERA OF THE ORGANIZATION PROVIDING INSTRUCTIONAL CONTENT TO SCHOOLS. |
| FORM 990, PAGE 6, PART VI, LINE 3 | MANAGEMENT SERVICES ARE PROVIDED BY: EBS SUPPORT SERVICES LLC PO BOX 6060 BOULDER, COLORADO 80306 EBS SUPPORT SERVICES LLC IS OWNED BY FIVE MEMBERS WHICH ARE ALL NONPROFIT ORGANIZATIONS. ITF IS A MEMBER OF EBS SUPPORT SERVICES LLC AND HAS A 39.47% INTEREST. EBS SUPPORT SERVICES WAS CREATED FOR THE PURPOSE OF LEASING PERSONNEL AND PROVIDING SHARED ADMINISTRATIVE SERVICES TO ITS MEMEBRS. SEE FURTHER DISCUSSION REGARDING EBS SUPPORT SERVICES LLC AND THE SERVICES PROVIDED IN SCHEDULE O. ALL OF ITF'S OFFICERS WERE PAID THROUGH EBS. TOTAL COMPENSATION PAID TO THE OFFICERS BY EBS ARE SHOWN IN PART VII OF THE 990. REPORTABLE COMPENSATION PAID TO ITF OFFICERS BY EBS FOR SERVICES PROVIDED TO ITF ARE AS FOLLOWS: --JOHN SCHWARTZ 71,366 --ADAM MILLER 9,900 --PATRICIA DWYER 20,358 |
| FORM 990, PAGE 6, PART VI, LINE 7A | THE PRESIDENT OF THE CORPORATION MAY DESIGNATE UP TO TWO DIRECTORS. |
| FORM 990, PAGE 6, PART VI, LINE 8B | THE ORGANIZATION DOES NOT HAVE A COMMITTEE WITH AUTHORITY TO ACT ON BEHALF OF THE GOVERNING BODY. |
| FORM 990, PAGE 6, PART VI, LINE 11B | THE 990 IS REVIEWED BY THE ORGANIZATIONS ACCOUNTANTS AND EXPERIENCED EXEMPT ORGANIZATIONS TAX COUNSEL, CFO AND AT LEAST ONE CORPORATE OFFICER. ADDITIONALLY THE FORM IS PRESENTED TO THE BOARD MEMBERS AFTER IT IS FILED. |
| FORM 990, PAGE 6, PART VI, LINE 12C | EACH RESPONSIBLE PERSON WHO IS A DIRECTOR OR OFFICER HAS A DUTY TO DISCLOSE TO THE BOARD (OR TO ANY COMMITTEE OF THE BOARD THAT IS CONSIDERING A DECISION TO WHICH THE CONFLICT APPLIED) THE MATERIAL FACTS OF ANY PROPOSED TRANSACTION OR ACTION OF THE ORGANIZATION IN WHICH SUCH RESPONSIBLE PERSON HAS ANY CONFLICTS. EACH RESPONSIBLE PERSON WHO IS A STAFF MEMBER HAS A DUTY TO DISCLOSE TO THE BUSINESS MANAGER OF THE ORGANIZATION AND HIS/HER IMMEDIATE SUPERVISOR THE MATERIAL FACTS OF ANY PROPOSED TRANSACTION OF THE ORGANIZATION IN WHICH SUCH PERSON HAS ANY CONFLICT. IMPLEMENTATION OF THE CONFLICT OF INTEREST POLICY RELIES ON SUCH DISCLOSURE. A RESPONSIBLE PERSON WHO FAILS TO FOLLOW THE PROTOCOLS ESTABLISHED IN THE CONFLICT OF INTEREST POLICY SHALL BE SUBJECTED TO MEANINGFUL DISCIPLINARY ACTION BY THE BOARD OF DIRECTORS UP TO AND INCLUDING REMOVAL FROM THE BOARD OR THEIR POSITION WITHIN THE ORGANIZATION. |
| FORM 990, PAGE 6, PART VI, LINE 15A | ALL SERVICES PERFORMED ARE FROM SHARED EMPLOYEES OF A SHARED SERVICES COMPANY. THIS COMPANY HAS AN OVERSIGHT COMMITTEE MADE UP OF BOARD MEMBERS OF NON-PROFIT ORGANIZATIONS THAT IT SERVES. THIS OVERSIGHT COMMITTEE HAS BEEN CHARGED BY THE NONPROFIT ORGANIZATION BOARDS TO OVERSEE PERSONNEL MATTERS INCLUDING EXECUTIVE AND STAFF COMPENSATION. STAFF PREPARED A SEMI- ANNUAL SALARY BENCHMARKING REPORT FOR ALL STAFF POSITIONS AND AN ANNUAL CEO SALARY REVIEW THAT DESCRIBED EACH POSITION AND COMPARED THE POSITION TO THREE SALARY SURVEYS: MOUNTAIN STATES EMPLOYERS COUNCIL 2014 NON- PROFIT/FOUNDATION COMPENSATION, MOUNTAIN STATES EMPLOYERS COUNCIL 2015 COLORADO BENCHMARK COMPENSATION, AND 2014 COLORADO NON-PROFIT ASSOCIATION SALARY AND BENEFITS SURVEY. IN ADDITION, THE SALARY BENCHMARKING REPORT WAS REVIEW BY AN INDEPENDENT THIRD PARTY CONTRACTOR TO ENSURE THE USE OF PROPER METHODOLOGY AND ETHICAL STANDARDS. THIS REPORT, THE THIRD PARTY CONTRACTOR REPORT AND SUPPORTING DOCUMENTATION WAS REVIEWED IN DEPTH BY THE OVERSIGHT COMMITTEE WHICH SUMMARIZED ITS REVIEW TO ALL OF THE BOARDS |
| FORM 990, PAGE 6, PART VI, LINE 15B | SEE THE EXPLANATION SHOWN FOR FORM 990, PART VI, LINE 15A. |
| FORM 990, PAGE 6, PART VI, LINE 19 | THE ORGANIZATION DID NOT NOT MAKE ITS GOVERNING DOCUMENTS, CONFLICT OF INTEREST POLICY, AND FINANCIAL STATEMENTS AVAILABLE TO THE PUBLIC |
| FORM 990, PART VII | EBS SUPPORT SERVICES, LLC(D/B/A VOQAL) IS OWNED BY FIVE MEMBERS WHICH ARE ALL NONPROFIT ORGANIZATIONS. ITF IS A MEMBER OF VOQAL AND HAS A 39.47% INTEREST. VOQAL LEASES AND PROVIDES PERSONNEL AND SHARED ADMINISTRATIVE SERVICES TO ITS MEMBERS. THE INDIVIDUALS LISTED ON PART VII, SECTION A THAT HAVE AMOUNTS IN COLUMNS E & F WORK WITH VOQAL TO PROVIDE THEIR SERVICES TO VOQALS MEMBERS AND OTHER COMPANIES THE MEMBERS JOINTLY OWN. ITF REIMBURSES VOQAL FOR THE PERSONNEL COST FOR SERVICES THEY PROVIDE TO ITF AS WELL AS TO VOQAL'S OTHER FOUR MEMBERS IN THE 2015 CALENDAR YEAR. THE AMOUNTS OF REPORTABLE COMPENSATION AND OTHER COMPENSATION PAID BY VOQAL TO THESE INDIVIDUALS THAT IS ATTRIBUTABLE SOLELY TO FILER IS DISCLOSED IN RESPONSE PART VI, LINE 3 PROVIDED EARLIER IN THIS SCHEDULE. |
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