McHenry County Blog

A press release from the U.S. Attorney’s Office:

TWO COMPANIES AND FIVE INDIVIDUALS CHARGED WITH ROLES IN ILLEGAL HONEY IMPORTS; AVOIDED $180 MILLION IN ANTIDUMPING DUTIES

CHICAGO— Five individuals and two domestic honey processing companies have been charged with federal crimes in connection with a nationwide investigation of illegal importations of honey from China that was mislabeled as coming from other countries to avoid antidumping duties or was adulterated with antibiotics not approved for use in honey.

Altogether, the seven defendants allegedly avoided antidumping duties totaling more than $180 million.

None of the charges allege any instances of illness or other public health consequences attributed to consumption of the honey.

The charges represent the second phase of an investigation led by agents of U.S. Immigration and Customs Enforcement’s (ICE) Homeland Security Investigations (HSI). In June 2011, an undercover agent assumed the role of director of procurement at defendant HONEY HOLDING I, LTD., which by then was cooperating with the investigation.
Honey Holding, doing business as Honey Solutions, of Baytown, Tex., and defendant GROEB FARMS, INC., of Onsted, Mich., two of the nation’s largest honey suppliers, have both entered into deferred prosecution agreements with the government, subject to court approval, with Honey Holding agreeing to pay a $1 million fine and Groeb Farms agreeing to the payment of a $2 million fine. Both companies have agreed to implement corporate compliance programs as part of their respective agreements.

The individual defendants include three honey brokers, as well as DOUGLAS A. MURPHY, former director of sales for Honey Holding, and DONALD COUTURE, president of Premium Food Sales, Inc., a broker and distributor of raw and processed honey in Bradford, Ontario.

In December 2001, the Commerce Department determined that Chinese-origin honey was being sold in the United States at less than fair market value, and imposed antidumping duties. The duties were as high as 221 percent of the declared value, and later were assessed against the entered net weight, currently at $2.63 per net kilogram, in addition to a “honey assessment fee” of one cent per pound of all honey. In October 2002, the Food and Drug Administration issued an import alert for honey containing the antibiotic Chloramphenicol, a broad spectrum antibiotic that is used to treat serious infections in humans, but which is not approved for use in honey. Honey containing certain antibiotics is deemed “adulterated” within the meaning of federal food and drug safety laws.

In 2008, federal authorities began investigating allegations involving circumventing antidumping duties through illegal imports, including transshipment and mislabeling, on the “supply side” of the honey industry. The investigation resulted in charges against 14 individuals, including executives of Alfred L. Wolff GmbH and several affiliated companies of the German food conglomerate whose U.S. honey-importing business was based in Chicago, and others for allegedly avoiding approximately $80 million in antidumping duties on Chinese-origin honey. Authorities seized and forfeited more than 3,000 drums of honey that entered the country illegally.
The second phase of the investigation, announced today, involves allegations of illegal buying, processing, and trading of honey that illegally entered the U.S. on the “demand side” of the industry. The investigation is continuing.

Gary Shapiro

“We applaud the efforts of HSI, Customs and Border Protection, and other agencies involved in this complex, long-term investigation to enforce the laws that exist to protect U.S. consumers and the honey market,” said Gary S. Shapiro, United States Attorney for the Northern District of Illinois.

“These businesses intentionally deprived the U.S. government of millions of dollars in unpaid duties,” said ICE Deputy Director Daniel Ragsdale. “Schemes like these result in legitimate importers and the domestic honey-producing industry enduring years of unprofitable operations, with some even being put out of business. We will continue to enforce criminal violations of antidumping laws in all industries and ports of entry so American businesses and foreign producers of goods all play by the same rules.”

Also announcing the charges were Gary Hartwig, Special Agent-in-Charge of HSI Chicago; William A. Ferrara, Acting Director of Field Operations for U.S. Customs and Border Protection (CBP) in Chicago, and Daniel Henson, Special Agent-in-Charge of the Chicago Field Office of the Food and Drug Administration’s Office of Criminal Investigations.
The U.S. Food and Drug Administration operates a toll-free number for consumer inquiries: 1-888-INFO-FDA (463-6332).

The government is being represented by Assistant U.S. Attorney Andrew S. Boutros.

The public is reminded that indictments and informations contain only charges and are not evidence of guilt. The defendants are presumed innocent and are entitled to a fair trial at which the government has the burden of proving guilt beyond a reasonable doubt. If convicted, courts must impose a reasonable sentence under federal statutes and the advisory United States Sentencing Guidelines. Three of the five individuals charged have authorized the government to disclose that they intend to plead guilty to the charges against them.

A press release from the U.S. Attorney’s Office:

SUBURBAN CHICAGO WOMAN CONVICTED OF STEALING TRADE SECRETS FROM MOTOROLA BEFORE ATTEMPTING TO TRAVEL TO CHINA

CHICAGO — A former software engineer for Motorola, Inc., now Motorola Solutions, Inc., a telecommunications company based in Schaumburg, was found guilty today of stealing Motorola trade secrets.

The defendant, Hanjuan Jin, a naturalized U.S. citizen born in China, possessed more than 1,000 electronic and paper Motorola proprietary documents when she was stopped by U.S. customs officials as she attempted to travel on a one-way ticket to China in February 2007.

The documents were later seized by U.S. customs officials at O’Hare International Airport.

Jin, 41, of Aurora and formerly of Schaumburg, was found guilty by U.S. District Judge Ruben Castillo following a five-day bench trial from Nov. 7 to 15, 2011.

Jin “criminally betrayed Motorola by stealing its trade secrets,” Judge Castillo said in finding her guilty of three counts of theft of trade secrets.

In a 77-page opinion, Judge Castillo found her not guilty of three counts of economic espionage for the benefit of the People’s Republic of China and its military. She faces a maximum penalty of 10 years in prison on each count of stealing trade secrets.

Jin was ordered to remain in home confinement with electronic monitoring pending sentencing, which was scheduled for April 18 in Federal Court. The government is seeking forfeiture of assorted computer hardware and equipment that Jin possessed in February 2007, which contained a variety of Motorola’s proprietary information.

Patrick Fitzgerald

“The verdict establishes that Jin stole valuable trade secrets from an American company, and we will do everything we can to guard our economic and national security from the theft of American trade secrets.

“This case is a successful example of how we can work with victim corporations to prosecute these cases while protecting the trade secrets involved,” said Patrick J. Fitzgerald, United States Attorney for the Northern District of Illinois, who announced the verdict with Robert D. Grant, Special Agent-in-Charge of the Chicago Office of the Federal Bureau of Investigation.

According to the evidence at trial, Jin began working for Motorola in 1998, and she took a medical leave of absence in February 2006.

Between June and November 2006, while still on sick leave, Jin pursued employment in China with Sun Kaisens, a Chinese telecommunications company that developed products for the Chinese military.

Between November 2006 and February 2007, Jin returned to China and did work for Sun Kaisens on projects for the Chinese military.

During this same period of time, Jin was given classified Chinese military documents by a Sun Kaisens employee to review in order to better assist with the Chinese military projects.

After receiving these documents, Jin agreed to review the documents and provide assistance.

On Feb. 15, 2007, Jin returned to the United States from China.

On Feb. 22, 2007, Jin reserved a one-way ticket to China for a flight scheduled to depart on Feb. 28, 2007.

The following day, on Feb. 23, 2007, Jin advised Motorola that she was ready to end her medical leave and return to work at Motorola, without advising that she planned to return to China to work for Sun Kaisens.

On Feb. 26, 2007, Jin returned to Motorola, purportedly to resume full-time work, and was given no assignments by her supervisor.

Between 9 a.m. and 2 p.m., Jin accessed more than 200 technical documents belonging to Motorola on its secure internal computer network.

At about 9 p.m. that night, Jin returned to Motorola and downloaded additional documents.

At approximately 12:15 a.m. on Feb. 27, 2007, Jin was recorded twice leaving a Motorola building with hard copy documents and other materials.

During the day on Feb. 27, 2007, Jin sent an email to her manager in which she appeared to volunteer for a layoff at Motorola.

At about 10 p.m. that night, she returned to Motorola’s offices and downloaded numerous additional technical documents.

Jin was later recorded leaving a Motorola building with what appeared to be a laptop computer bag.

As she attempted to depart on Feb. 28, 2007, from O’Hare bound for China, authorities seized numerous materials, some of which were marked confidential and proprietary belonging to Motorola.

Some of the documents provided a detailed description of how Motorola provides a specific communication feature that Motorola incorporates into its telecommunications products sold throughout the world.

At the same time, authorities recovered multiple classified Chinese military documents written in the Chinese language that described certain telecommunication projects for the Chinese military.

Many of these documents were marked “secret” by the Chinese military.

Authorities also recovered approximately $30,000 in U.S. currency that was in six different envelopes, each containing $5,000, all in hundred dollar bills.

The Government is being represented by Assistant U.S. Attorneys Steven Dollear, Sharon Fairley, and Christopher Stetler.

A press release from Congressman Don Manzullo:

Chairman Manzullo: Foreign Aid to China is Wasteful, Works Against American Manufacturers

Don Manzullo

[WASHINGTON] Congressman Don Manzullo (R-IL), Chairman of the House Foreign Affairs Subcommittee on Asia & the Pacific, today said a plan to spend U.S. taxpayer dollars to advance clean energy initiatives in China is wasteful and can harm American manufacturers.

Manzullo, who chaired a subcommittee hearing today entitled “Feeding the Dragon: Reevaluating U.S. Development Assistance to China,” vowed to stop the U.S. Agency for International Development (USAID) from spending $3.95 million in U.S. taxpayer funds to encourage China to adopt clean energy technologies and policies, protect wildlife, and establish law school courses.

Each year, the United States spends more than $39 billion in taxpayer funds to support America’s foreign policy objectives abroad. In the Asia region alone, the President’s request for Fiscal Year 2012 amounts to more than $800 million.

“This type of spending is yet another example of how Washington bureaucrats waste taxpayer funds without full consideration of the damage this project can have on American jobs.

“At a time when America’s debt is close to $15 trillion, USAID is proposing that we borrow more money from China to give back to China to encourage the Chinese government to fix a mess they created,” Manzullo said.

“China already dominates the clean technology manufacturing sector through a combination of illegal government subsidies, artificially low currency, and theft of intellectual property.

“The problem is so rampant that the U.S. Trade Representative launched an official complaint against China at the World Trade Organization.

“Now, USAID says U.S. taxpayer funding is needed to help China build capacity in this area. This makes no sense.”

Don Manzullo

Manzullo to Hold Asia-Pacific Subcom Hearing Thursday Exploring Chinese Abuses Against American Companies

Subcommittee will also consider resolutions supporting NZ, Japan Quake Victims

(WASHINGTON) House Foreign Affairs Asia & the Pacific Subcommittee Chairman Don Manzullo (R-IL) will hold a hearing at 2 p.m. Thursday, March 31, in Room 2360 of the Rayburn House Office Building, entitled “Asia Overview: Protecting American Interests in China and Asia.”

The hearing will also be webcast at http://international.edgeboss.net/wmedia-live/international/60299/300_international-web_101210.asx

Members will examine the Administration’s efforts to promote American exports and assist American firms having trouble overseas. The Chairman and CEO of Fellowes, Incorporated, will testify about the unfair business practices the firm is facing in China.

The Subcommittee will consider resolutions expressing condolences and support to the people of New Zealand (H. Res. 139) and Japan (H. Res. 172) in the wake of their devastating earthquakes.

Hearing witnesses:

• Kurt Campbell, Assistant Secretary of State at Bureau of East Asian and Pacific Affairs.
• James Fellowes, Chairman and CEO at Fellowes, Inc.
• Calman Cohen, President at Emergency Committee on American Trade
• Michael Austin, Director of Japan Studies at American Enterprise Institute

As leaders of China are visiting Chicago, this press release came Don Manzullo, Illinois’ 16th District Congressman:

Manzullo: China Must End Unfair Trade Practices
to Give Americans Chance to Compete for Jobs

(WASHINGTON) Congressman Don Manzullo (R-IL) today said the Obama Administration needs to get tougher in enforcing trade rules on China to give American manufacturers a chance to compete on a level playing field for jobs.

Manzullo, co-chair of the House Manufacturing Caucus, made his remarks during a Foreign Affairs Committee briefing this morning on China’s rise and its impact on the United States. Manzullo is Chairman of the Foreign Affairs Subcommittee on Asia and the Pacific and is planning to hold several hearings this year examining our enforcement of trade rules with China and other countries in Asia.

Don Manzullo

“On one hand, China’s remarkable economic growth provides export opportunities to a market of over 1.3 billion consumers.”However, as experience has shown, China’s unfair trade practices, including currency manipulation, illegal subsidies, and lax enforcement of intellectual property theft, make it difficult for the hardworking people of America to compete on a level playing field and benefit from this relationship,”

Manzullo said.

In the northern Illinois Congressional district Manzullo represents, there are more than 1,400 manufacturers that support more than 51,000 jobs, according to the National Association of Manufacturers. Manzullo continually hears from manufacturers in northern Illinois and throughout the country about their difficulties trying to compete on a level playing field with manufacturers in China.

“These hardworking men and women want to know what their government is doing to enforce our trade laws with China and preserve America’s industrial base,” Manzullo said.

“My experience with the Chinese Government is that it is in fact capable of stopping violators when they see it is in their interests to do so.

“With so many Americans out of work, now is the time for the Administration to work with Congress to hold China responsible and give American manufacturers a chance to compete with China on a level playing field so they can create jobs.”

Don Manzullo joined congressional colleagues to define undervalued currency as an illegal export subsidy. The 16th District Congressman’s press release follows:

Manzullo Votes to Crack Down on Unfair Chinese Trade Practices

that Put Americans Out of Work

[WASHINGTON] On a mission to level the global playing field for U.S. manufacturers, Congressman Don Manzullo (R-IL) today voted to give the federal government a new tool to penalize China and other foreign countries that illegally undervalue their currencies to make their companies more competitive at a cost to U.S. manufacturers and agricultural producers.

The Currency Reform for Fair Trade Act (H.R. 2378), which the House passed 348-79 this afternoon, would define foreign currency undervaluation as an illegal export subsidy actionable under U.S. trade law. It would allow the U.S. to slap countervailing duties on any country deliberately undervaluing its currency for a trade advantage. Click here to view Manzullo’s floor speech today on the issue.

Don Manzullo at MCC Town Hall Meeting in 2009 on Health Care Reform.

“For years, China and other countries have undervalued their currencies to give their companies a competitive advantage over U.S. manufacturers, encouraging offshoring of U.S. jobs and putting Americans out of work,” said Manzullo, co-founder of the House Manufacturing Caucus and an original cosponsor of the bill.

“This legislation would give Americans a tool to strike back against these unfair trade practices, level the playing field for our industry, and put Americans back to work. I have no doubt that American manufacturers and farmers can compete with anyone in the world, but the competition must be fair.”

Most countries in the world allow their currencies to “float” so they are valued by market conditions. China and a few other Asian countries take actions to weaken the value of their currencies.

A lower currency makes it less expensive for a foreign company to import its goods into the United States. A lower currency also makes U.S. exports more expensive in that country. In the United States, this has contributed to the influx of Asian imports and offshoring of U.S. jobs.

Economists estimate China’s currency undervaluation alone gives Chinese products a 15-40 percent competitive advantage over products made in the United States. The Peterson Institute for International Economics estimates that correction of all Asian currency undervaluations would cut our trade deficit by about $100 billion and generate approximately 700,000 U.S. jobs.

Manzullo has been extremely active in cracking down on Asian currency undervaluation practices, going back to 2003. Manzullo previously authored a House Resolution to urge the Executive Branch to use all available means to force various Asian nations to stop manipulating their currencies to the detriment of U.S. manufacturers and agricultural producers.

Manzullo and Senator Olympia Snowe (R-ME), former chairs of the House and Senate Small Business Committees, also instructed the General Accounting Office to conduct an investigation to quantify the damage currency manipulation causes to U.S. industry.

Manzullo has held several committee hearings on the issue of currency manipulation and has testified on numerous occasions for the need to halt foreign currency undervaluation to level the playing field for U.S. manufacturers and farmers.

For the second time today, the U.S. Attorney’s Office has taken action concerning illegalities on the part of Chinese business.  First, there were indictments against Chicagoans, Germans and Chinese for illegally importing Chinese honey.

Now, a plea agreement has been reached with David Yen Lee, a former Valspar chemist.

FORMER PAINT MANUFACTURING CHEMIST PLEADS GUILTY
TO STEALING TRADE SECRETS VALUED UP TO $20 MILLION

CHICAGO — A former chemist for a northwest suburban paint manufacturing company pleaded guilty today to theft of trade secrets, admitting that he stole numerous formulas and other proprietary information valued up to $20 million as he prepared to go to work for an overseas competitor.

David Yen Lee, formerly a technical director in Valspar Corp.’s architectural coatings group since 2006, admitted using his access to Valspar’s secure internal computer network to enter databases containing trade secrets and to download approximately 160 original batch tickets, or secret formulas for paints and coatings.  He also obtained raw materials information, chemical formulas and calculations, sales and cost data, and other internal memoranda, product research, marketing data, and other materials from Valspar’s offices in Wheeling.

Lee, 54, formerly of Arlington Heights and currently of Jersey City, N.J., pleaded guilty to one count of theft of trade secrets after being charged in early 2009.  U.S. District Judge Robert Gettleman set sentencing for Nov. 23.  He faces a maximum penalty of 10 years in prison and a $250,000 fine, or twice the gross gain or gross loss resulting from the offense.  A written plea agreement contemplates an advisory federal sentencing guideline range of 57 to 71 months in prison.  The Court also must order mandatory restitution.

According to the plea agreement, between September 2008 and February 2009, Lee negotiated employment with Nippon Paint, located in Shanghai, China.  On Feb. 27, 2009, Lee accepted employment with Nippon as vice president of technology and administrator of research and development beginning on April 1, 2009, in Shanghai.  Lee purchased a ticket to fly from Chicago to Shanghai on March 27, 2009.  He did not inform Valspar that he had accepted a job at Nippon until he resigned on March 16, 2009.

At Valspar, Lee’s duties included scouting new paint technologies, coordinating with other paint laboratories, coordinating staffing and projects with Huarun Limited, a Valspar subsidiary located in China, and overseeing Valspar’s technical service group, which conducted experiments for paint coloring.

Between November 2008 and March 2009, Lee downloaded technical documents and materials belonging to Valspar, including the paint formula batch tickets.  He further copied certain downloaded files to external thumb drives to store the data, knowing that he intended to use the confidential information belong to Valspar for his own benefit.  The total value of the trade secret  information Lee took is estimated at between $7 million and $20 million, the plea agreement states.

The guilty plea was announced by Patrick J. Fitzgerald, United States Attorney for the Northern District of Illinois, and Robert D. Grant, Special Agent-in-Charge of the Chicago Office of Federal Bureau of Investigation.

The government is being represented by Assistant U.S. Attorney Jessica Romero.

It took months to find out.

It seemed to me reasonable to ask whether Huntley School Superintendent John Burkey was “working” on the taxpayers’ dime for his junket (for which the district paid only registration) or on an officially recognized vacation, that is, using up some of his 20 days of vacation.

I wrote this story in early September.

John Burkey

When I first asked, this was the result:

“Information on how specific days by District employees are accounted for is exempt from disclosure per 5ILCS 140, Section 7(b), “information that, if disclosed would constitute a clearly unwarranted invasion of personal privacy…(emphasis added)”

So, I asked again:

That reply, I admit was infuriating:

In response to the number of vacation days taken each month in FY09 and FY10:

“Information on how specific days by District employees are accounted for is exempt from disclosure per 5ILCS 140, Section 7(b, “information, that, if disclosed, would constitute a clearly unwarranted invasion of personal privacy…(emphasis added)”

Let me offer a reason why vacation days might be relevant. What if you were a House Republican staff member and had been told to go help a state representative under challenge by “outsider?”

If someone called up the campaign office of the incumbent on the Friday before the election and the House GOP staffer answered the phone, should you—or I, in this quite real example—as a taxpayer have the right to know whether said staffer was being paid by taxpayers or the campaign?

(I never found out, despite the so-called Ethics bill that former Governor Rod Blagojevich bragged about signing, which, supposedly significantly, required legislative staffers to fill out time sheets for every 15-minute part of the day. I sued, along with Christina Tobin, and a loophole in the law—surprise, surprise—prevented us from getting copies of the time sheets.  That’s what a Cook C0unty circuit court judge ruled.)

In a new January Freedom of Information Act request filed after the new amendments went into effect, I asked again and, guess what, Huntley School District finally coughed up the information about Burkey’s China vacation.

Burkey did use vacation days.

June vacation time sheet (click to enlarge)

June-July vacation time sheet (click to enlarge)

Does that make you wonder why Burkey didn’t want to answer the question the first time I asked it?

And, now that we know the Supt. was on vacation, the next question is why the school district paid $900 for his registration fee?

“A total of $900.00 for the registration fee was paid using District 158 funds for Dr. Burkey’s trip to China. A copy of the registration invoice and board approval is enclosed.”

I’ve been trying to find out if Huntley School District 158 Superintendent John Burkey takes his vacation.

The article you see is what piqued my interest. It said Burkey was in China for eight days. It sparked this article:

Burkey gets a full month (20 work days) of vacation each year, “exclusive of weekends and legal holidays,” according to his contra

It seems to me a reasonable question to ask and get an answer as to whether he was “working” on the taxpayers’ dime for his junket (for which the district paid only registration) or on an officially recognized vacation, that is, using up some of his 20 days of vacation.

When I first asked, this was the result:

I rephrased my question to ask how many days vacation Burkey took in FY09 and FY10.

The reply came recently:

“In response to the number of vacation days taken each month in FY09 and FY10:

Information on how specific days by District employees are accounted for is exempt from disclosure per 5ILCS 140, Section 7(b, “information, that, if disclosed, would constitute a clearly unwarranted invasion of personal privacy…”

So, taxpayers.

You don’t have a right to know if your school superintendent used up any vacation days in June to visit China or wherever.

I had a junket once.

It was the fall of 1976. State Senator Mark Rhoades called me and asked if I wanted to go to Europe in September. He had been selected to go on a trip by the American Association of Young Political Leaders and couldn’t make the trip.

I didn’t have a fall opponent, so I decided to go.

Great trip.

Germany was having its elections. We got to talk to the counterpart of Barry Goldwater’s campaign manager the week before the election.

What a bus man’s holiday!

We spent a day in Brussels, went to a NATO support group conference, toured NATO headquarters, where I met a Democratic Party opponent of Congressman Robert C. McClory, went to the Netherlands, met young Danish legislators (they call the waterfront liberals “Railroad Liberals, rather than our “Limousine Liberals”), went to a beach near Copenhagen, took another side trip in Denmark where I learned my minimal German could be understood–at least once–to get directions to a Viking boat museum, took the ferry to Sweden or Norway, stuff like that.

Great vacation!

Oh, yes, the association describes it’s objectives like this:

“To enable emerging political leaders in the U.S. to experience firsthand the political and cultural dynamics of other countries; to offer politically active young people in other countries a similar experience in the United States.”

But, as a state representative, I didn’t have vacation days. I pretty much worked every day I was in office.

But it was a vacation, no doubt about that.

Huntley School District 158 Superintendent John Burkey went on a junket to China, as you can see from the front page Daily Herald article above.

I asked two normal reporter’s questions:

• How much was on the taxpayers’ tab?
• Was Burkey taking vacation days?

I was told to file a Freedom of Information request, which I did on July 23rd.

Today I received a reply.

“A total of $900.00 for the registration fee was paid using District 158 funds for Dr. Burkey’s trip to China. A copy of the registration invoice and board approval is enclosed.”

To the question about whether vacation days were used, here’s the answer:

“Information on how specific days by District employees are accounted for is exempt from disclosure per 5ILCS 140, Section 7(b), “information that, if disclosed would constitute a clearly unwarranted invasion of personal privacy…”

I don’t suppose Burkey will be surprise if a lot of taxpayers take that answer as a “Yes.”

I can only wonder if Dan Walker’s Secretary of Transportation Langhorne Bond would have replied similarly, had the Freedom of Information Act been in effect, when I sent a tenacious intern to check out every vacation and personal day that Walker political operative Gary Fears had taken.

His job title was “Rest Stop Inspector,” but his real duties, well, let’s just say I was suspicious.

When Fears had used all of his vacation and personal days, he went off the IDOT payroll, which was my goal all along. (Fears ended up getting a loan to build a motel in the MetroEast area the same time Bill Cellini’s group got a loan to build the hotel in Springfield.)

So, there can be legitimate policy reasons to know when people take vacation and personal days.

And, in lots of school administrators’ cases, unused vacation days used to be cashed in at retirement. They boosted pensions, if memory serves me correctly.

Not that Burkey is ready for retirement.

But the taxpaying public in Huntley and Lake in the Hills surely deserve to know whether the school board not only paid the tour’s registration fee, but also allowed him to say he was working all eight of his junket days.