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David Addis’s practice encompasses US foreign trade controls, including export controls, technology controls and encryption regulation, and antitrust counseling on mergers and acquisitions, joint ventures and other competitor collaborations, and intellectual property licensing, including IP licensing policies for standard-setting organizations.
Mr. Addis has extensive experience with US foreign trade controls, export regulations and embargo sanctions administered by the Departments of Commerce, Treasury, State and Homeland Security, and advises on compliance, obtaining licensing, and responding to possible enforcement actions.
He advises on encryption regulations, compliance with export regulations for dual-use commercial products as well as defense articles and technology, and cross-border technology transfers in the computer, software and biotechnology sectors. He advises as well on embargo regulations and economic sanctions to combat terrorism, including help to obtain licensing for medical sales to embargoed countries.
Mr. Addis also provides antitrust counseling and transaction planning for mergers and acquisitions, joint ventures and collaborations; intellectual property licensing and cross-licensing agreements; and standards-setting activities. He has extensive experience advising clients on all aspects of complying with the Hart-Scott-Rodino (HSR) Act and regulations. He has represented Microsoft in its participation in a wide range of technical standards setting organizations, advising the company on intellectual property licensing policies and antitrust concerns agreements related to technical standards development.
- Antitrust clearance for mergers, acquisitions, and license grants under the HSR review process before the Federal Trade Commission and the Justice Department’s Antitrust Division.
- Assisting global high-technology companies with export controls affecting encryption items and high-performance computers.
- Representing participants in two different biotechnology cross-licensing and collaboration joint ventures to develop and commercialize gene-based therapies, one investigated under the HSR process by the Federal Trade Commission and one by the Justice Department’s Antitrust Division, and successfully persuading both agencies to close the initial investigations without a challenge.
- Securing export licenses enabling leading pharmaceutical companies to sell medical products to embargoed countries, including Cuba, Iran, Iraq, Libya, and Sudan.
- Antitrust advice on a distribution joint venture formed by leading commercial truck manufacturers.
- Representing US defense subcontractors in enforcement investigations and related export licensing initiatives before the State Department’s Directorate of Defense Trade Controls.
- Antitrust and HSR counseling for a wide array of cross-licensing and R&D collaborations for pharmaceutical and biotechnology companies, and for media/communications joint ventures, including cable channel ventures, joint ventures for video programming and content, and satellite, wireless, and broadcast joint ventures.
Pro Bono
- Amicus briefs in the Courts of Appeal on behalf of the Electronic Privacy Information Center in Junger v. Daly and Bernstein v. Department of State establishing that software source code is expression entitled to full First Amendment protection.
September 22, 2020, Covington Alert
On September 15, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a final rule (the “Final Rule”) amending the requirement to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop one or ...
August 20, 2020, Covington Alert
On August 17, 2020, the Commerce Department’s Bureau of Industry and Security (“BIS”) released a Final Rule (the “August 17 Final Rule”) significantly expanding U.S. export controls restrictions on certain non-U.S. items reexported, exported from abroad, or transferred (in-country) in transactions involving Huawei or its affiliates designated on the BIS Entity ...
May 21, 2020, Covington Alert
In an effort to curtail access by China’s Huawei Technologies Co., Ltd. to products made using U.S. semiconductor software and technology, the Commerce Department’s Bureau of Industry and Security (“BIS”) on May 15, 2020, released an Interim Final Rule expanding and extending U.S. export controls jurisdiction to certain non-U.S. items when destined for Huawei or ...
CFIUS Proposes New Rules Governing Mandatory Filing Requirements for Critical Technology Businesses
May 21, 2020, Covington Alert
On May 21, 2020, the Department of the Treasury, as chair of the Committee on Foreign Investment in the United States (“CFIUS”), published in the Federal Register a proposed rule (the “Proposed Rule”) that would amend the requirements to file with CFIUS certain transactions involving U.S. businesses that produce, design, test, manufacture, fabricate, or develop ...
April 29, 2020, Covington Alert
On April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (“BIS”) published two final rules and one proposed rule to modify certain license exceptions and definitions in the Export Administration Regulations (“EAR”) (15 CFR Parts 730 – 774), based on concern that sensitive products and technologies were being diverted to military uses ...
January 15, 2020, Covington Alert
On January 10, 2020, President Trump issued a new Executive Order (“January 10 Executive Order”) that provides authority for the imposition of sanctions with respect to certain additional sectors of Iran’s economy, including Iran’s construction, mining, manufacturing, and textiles sectors. The January 10 Executive Order introduces both property-blocking ...
December 17, 2019, Covington Alert
On Friday, December 13, Principal Deputy Attorney General David Burns of the Justice Department’s (“DOJ’s” or “the Department’s”) National Security Division (“NSD”), announced a new DOJ policy for business organizations that voluntarily disclose potential criminal violations of the U.S. export controls and sanctions laws to NSD’s Counterintelligence and Export ...
October 10, 2019, Covington Alert
On October 9, the U.S. Department of Commerce issued a Final Rule adding 20 Chinese government entities and eight Chinese private sector entities (“Listed Entities”) to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”).
August 20, 2019, Covington Alert
On August 19, 2019, the Commerce Department’s Bureau of Industry and Security (“BIS”) issued a Final Rule adding 46 non-U.S. affiliates of Huawei Technologies Co., Ltd. (“Huawei”) to the Entity List and extended, through November 18, 2019, a revised Temporary General License (“TGL”) authorizing certain transactions with Huawei and listed Huawei entities.
August 8, 2019, Covington Alert
On August 5, 2019, President Trump issued Executive Order 13884 imposing comprehensive sanctions against the Government of Venezuela. Specifically, the Executive Order blocks all property and interests in property of the Government of Venezuela that are in or that come into the United States or the possession or control of a U.S. person.
May 17, 2019, Covington Alert
The U.S. Department of Commerce yesterday issued a Final Rule adding Huawei Technologies Co., Ltd. (“Huawei”) and 68 non-U.S. Huawei affiliates to the Entity List maintained by the Commerce Department’s Bureau of Industry and Security (“BIS”). While the rule will not be published in the Federal Register until May 21, it was effective immediately upon release ...
April 25, 2019, Covington Alert
The Trump Administration has announced multiple U.S. sanctions measures over the past several weeks, further tightening the sanctions on Iran and imposing additional measures on Venezuela and its allies, Cuba and Nicaragua.
April 3, 2019, Covington Alert
In February 2019, the U.S. Department of Justice (“DOJ”) announced a settlement with Honda Aircraft Company LLC regarding claims that Honda Aircraft violated the Immigration and Nationality Act (“INA”) by discriminating against non-U.S. citizens in an attempt to comply with requirements of the International Traffic in Arms Regulations (“ITAR”) and the Export ...
January 29, 2019, Covington Alert
November 20, 2018, Covington Alert
On November 19, 2018, the U.S. Commerce Department’s Bureau of Industry and Security (“BIS”) released an Advance Notice of Proposed Rulemaking (“ANPRM”) requesting public comment on the criteria to identify emerging technologies essential to U.S. national security. The comments will inform the interagency process that was authorized under the Export Control ...
November 6, 2018, Covington Alert
The Trump Administration yesterday completed the reimposition of sanctions against Iran that previously were suspended as part of the 2015 multilateral nuclear agreement, known as the Joint Comprehensive Plan of Action (“JCPOA”).
August 30, 2018, Covington Alert
On August 27, 2018, the Department of State imposed sanctions against Russia pursuant to the Chemical and Biological Weapons Control and Warfare Elimination Act of 1991 (CBW Act) in response to Russia’s use of a chemical nerve agent against a UK citizen.
August 8, 2018, Covington Alert
On August 6, 2018, President Trump issued Executive Order 13846 (the “Executive Order”) that re-imposes -- and to a limited extent broadens the scope of -- certain U.S. secondary sanctions targeting Iran that had been suspended in January 2016 pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) with Iran.
July 30, 2018, Covington Alert
On July 23, the final text of the Export Control Reform Act of 2018 (“ECRA”) was released as part of the Conference Report to accompany the National Defense Authorization Act (“NDAA”) for fiscal year 2019. The NDAA is a must-pass piece of legislation that authorizes funding for the Department of Defense, and we expect it to be enacted and signed within the next ...
July 30, 2018
SILICON VALLEY—Covington advised GlaxoSmithKline on its multi-year collaboration with and $300 million equity investment in 23andMe. GSK will become 23andMe’s exclusive collaborator for drug target discovery programs. The collaboration will focus on research and development of innovative new medicines and potential cures using human genetics as the basis for ...
July 2, 2018, Covington Alert
In furtherance of President Trump’s May 8, 2018 announcement that the United States is withdrawing from the Joint Comprehensive Plan of Action (“JCPOA”) (discussed in our recent alert), on June 27 the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced several changes to the U.S. sanctions against Iran.
June 15, 2018, Covington Alert
As described in our May 9, 2018, alert, the United States determined on May 8, 2018, to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK, and China.
May 16, 2018, Covington Alert
We are writing to report on the current status of the Foreign Investment Risk Review Modernization Act (“FIRRMA”), legislation to reform the Committee on Foreign Investment in the United States (“CFIUS” or the “Committee”). FIRRMA, a bill introduced by Senator John Cornyn (R-TX) in the Senate and Congressman Robert Pittenger (R-NC) in the House, seeks to ...
May 15, 2018, Covington Alert
On May 8, 2018, the United States announced the decision to end its participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, Germany, France, the UK and China.
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 9, 2018, Covington Alert
On May 8, 2018, President Trump announced his decision to end U.S. participation in the Joint Comprehensive Plan of Action (“JCPOA”) and re-impose sanctions against Iran that had been suspended as part of this 2015 nuclear agreement between the United States, Iran, and certain other governments. This action will have far-reaching effects for both U.S. and ...
May 8, 2018, Covington Alert
It has been publicly reported that the Trump Administration is considering invoking the International Emergency Economic Powers Act (IEEPA) to further regulate—and in certain areas potentially preclude—Chinese direct investment in the United States, beyond the authorities exercised by the Committee on Foreign Investment in the United States (CFIUS). The prospect ...
April 20, 2018, Covington Alert
On April 15, 2018, the U.S. Department of Commerce, Bureau of Industry and Security (“BIS”) lifted its suspension of a denial order against two companies, Zhongxing Telecommunications Equipment Corporation of Shenzhen, China (“ZTE Corporation”) and ZTE Kangxun Telecommunications Ltd. of Hi-New Shenzhen, China (“ZTE Kangxun,” and together with ZTE Corporation, ...
April 6, 2018, Covington Alert
On April 6, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced expanded sanctions against Russian entities and individuals, targeting a number of Russian oligarchs in the energy, banking, and other sectors and companies they own or control, as well as 17 senior Russian government officials.
March 8, 2018, Covington Alert
On February 15, 2018, House Foreign Affairs Committee Chairman Ed Royce (R-CA) introduced bipartisan legislation—the Export Control Reform Act of 2018 (“ECRA”)⸺to modernize U.S. export control regulation of commercial and dual-use items.
November 13, 2017, Covington Alert
On Thursday, November 9, 2017, the U.S. Departments of Treasury and Commerce published regulatory amendments that impose new restrictions on financial, travel, and trade-related transactions with Cuba by persons subject to U.S. jurisdiction.
November 8, 2017, Covington Alert
During the past two weeks, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) and the U.S. Department of State have taken a number of steps toward implementing aspects of the Countering America’s Adversaries Through Sanctions Act (“CAATSA”), a major piece of sanctions legislation passed by the U.S. Congress in July and signed by ...
October 17, 2017, Covington Alert
On October 13, President Trump announced that he would no longer certify to Congress that the suspension of U.S. sanctions against Iran pursuant to the Joint Comprehensive Plan of Action (“JCPOA”) is “appropriate and proportionate” to the steps that Iran has taken to terminate its illicit nuclear program. The President’s much-anticipated announcement does not ...
September 22, 2017, Covington Alert
President Trump has issued an Executive Order (“the Order”), effective September 21, 2017, imposing additional sanctions on persons doing business in certain sectors of the North Korean economy or engaging in certain trade or financial activities involving North Korea. President Trump issued the Order in response to North Korea’s recent intercontinental ...
August 29, 2017, Covington Alert
Last week, President Trump issued an Executive Order imposing new economic sanctions on the Venezuelan government in response to President Nicolás Maduro’s increasingly authoritarian actions. The new sanctions expand the U.S. restrictions against Venezuela, which previously were comprised of sanctions against a few key individuals, but they do not amount to a ...
Covington Advises Aristocrat in Acquisition of Plarium and Related Acquisition Financing
August 15, 2017
WASHINGTON—Covington, together with Israeli-based law firm Allens and Herzog Fox & Neeman, is representing Aristocrat Leisure Limited, a leading provider of gaming solutions, in its acquisition of Plarium Global Limited and the related acquisition financing. Aristocrat will make an upfront cash payment of $500 million plus earn-out payments based on Plarium’s ...
July 28, 2017, Covington Alert
Congress has passed and sent to President Trump, for his signature or veto, a bill that would impose significant new sanctions against Russia, Iran, and North Korea. The legislation—the Countering America’s Adversaries Through Sanctions Act—enjoys broad bipartisan support, having passed the U.S. House of Representatives on July 25 by a vote of 419-3, and the ...
U.S. Tightens Cuba Embargo; Senate Passes Iran/Russia Sanctions Bill; Arab Nations Boycott Qatar
June 19, 2017, Covington Alert
On Friday, June 16, 2017, President Donald J. Trump announced a tightening of the United States’ long-standing Cuba embargo, rolling back some of the easing implemented during the Obama Administration and described in our prior client alerts. The Trump Administration’s approach is outlined in a National Security Presidential Memorandum, but the full scope of ...
January 13, 2017, Covington Alert
In response to “positive actions” taken by the Government of Sudan over the past six months, the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) announced today an amendment to the Sudanese Sanctions Regulations (“SSR,” 31 C.F.R. Part 538) that effectively suspends virtually all of the U.S. sanctions against Sudan by authorizing ...
January 13, 2017, Covington Alert
Over the past few months, the agencies responsible for criminal and civil enforcement of U.S. export control and economic sanctions laws have implemented a number of important changes in their enforcement practices. In October 2016, the U.S. Department of Justice (“DOJ”), National Security Division (“NSD”) published guidance on voluntary self-disclosures of ...
October 17, 2016, Covington Alert
Effective today, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) has amended the Cuban Assets Control Regulations (“CACR”) and the U.S. Commerce department’s Bureau of Industry and Security (“BIS”) has amended the Export Administration Regulations (“EAR”) to expand permissible dealings involving Cuba, further easing the longstanding U.S. ...
June 9, 2016, Covington Alert
The U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) yesterday published new Frequently Asked Questions (“FAQs”) that help clarify the scope of certain measures taken by the United States in January to ease its sanctions against Iran in accordance with the Joint Comprehensive Plan of Action (“JCPOA”), the multilateral agreement signed in ...
May 4, 2016, The Wall Street Journal
David Addis is quoted by The Wall Street Journal in an article discussing technology exports to Iran, and how the Iran nuclear deal may pave the way for those exports. According to Addis, “Companies that were allowed to do trade in Iran found that even though they were able to sell devices, they had difficulty finding a financial actor” to facilitate the action. ...
October 8, 2015
WASHINGTON, DC, October 8, 2015 — Covington advised Prosper Marketplace, a leading online marketplace that connects borrowers and investors, in its acquisition of BillGuard, a personal finance analytics company. The financial terms of the deal were not announced. According to the company’s press release, the acquisition will enable Prosper Marketplace to offer ...
September 21, 2015, Covington Alert
July 15, 2015, Covington Alert
6/12/2015, Covington Alert
Developments in U.S. and EU Sanctions Against Russia and the Occupied Crimea Region of Ukraine
December 24, 2014, Covington E-Alert
December 17, 2014, Covington E-Alert
December 17, 2014, Covington E-Alert
September 22, 2014, Covington E-Alert
September 13, 2014, Covington E-Alert
August 15, 2014, Covington E-Alert
August 12, 2014, Covington E-Alert
July 23, 2014, Covington E-Alert
July 18, 2014, Global Policy Watch
On July 16, 2014, the U.S. Treasury Department’s Office of Foreign Assets Control (“OFAC”) imposed an additional wave of sanctions against Russian entities in the financial, energy, and defense sectors. OFAC established a new Sectoral Sanctions Identifications List (the “SSI List”), which identifies two Russian financial institutions and two Russian energy ...
July 10, 2014, Covington E-Alert
June 23, 2014, Covington E-Alert
May 23, 2014, Covington E-Alert
May 12, 2014, Covington E-Alert
April 15, 2014, Covington E-Alert
March 21, 2014, Covington E-Alert
United States and European Union Impose Additional Sanctions in Response to the Crisis in Ukraine
March 18, 2014, Covington E-Alert
March 6, 2014, Covington E-Alert
March 4, 2014, Covington E-Alert
November 25, 2013, Covington E-Alert
January 4, 2013, Covington E-Alert
Covington Advises Meda on Acquisition of Jazz Pharmaceuticals’ Women’s Health Products
September 6, 2012
LONDON, 06 September, 2012 — Covington & Burling LLP acted as legal advisers to Meda in an agreement with Jazz Pharmaceuticals to acquire a portfolio of six pharmaceutical products for women for $95 million in cash. The largest and most important product in the portfolio is Elestrin, a patented product with sales of almost 100 MSEK, that doctors prescribe for ...
August 14, 2012, Covington E-Alert
May 7, 2012, Covington E-Alert
January 4, 2012, Covington E-Alert
The Next Step in Export Control Reform: Proposed Revisions to Controls On Military Aircraft Unveiled
November 15, 2011, Covington E-Alert
September 7, 2011, Covington E-Alert
September 2, 2011, Covington E-Alert
May 6, 2011, Covington E-Alert
February 28, 2011, Covington E-Alert
December 23, 2010, Covington E-Alert
Covington Advises SandRidge Energy on Closing of Merger with Arena Resources, Creating a $6.2 Billion Company
July 20, 2010
NEW YORK, July 20, 2010 — SandRidge Energy, Inc. has completed its acquisition of Arena Resources, Inc., creating a combined company with an enterprise value of approximately $6.2 billion. Covington & Burling LLP advised SandRidge Energy on the transaction. The merger closed on July 16 following special meetings of the stockholders of each company. The ...
June 25, 2010, Covington E-Alert
May 13, 2010
WASHINGTON, DC, May 13, 2010 — Montreal-based CGI Group Inc. has announced an agreement to acquire Stanley Inc., headquartered in Arlington, Virginia, in a transaction valued at $1.07 billion. Covington & Burling LLP is advising Stanley on the national security and export control aspects of the transaction. Stanley is a provider of information technology ...
Senate Passes New Iran Sanctions Legislation Targeting Non-U.S. Companies in Petroleum Industry
February 2, 2010, Covington E-Alert
January 22, 2010, Covington E-Alert
September 16, 2009, Covington E-Alert
April 14, 2009, Covington E-Alert
U.S. Regulation of Technology Exports
April 2004, Law Seminars International Conference, Houston
Antitrust Considerations for Negotiating and Structuring Technology Agreements
January 2004, Law Seminars International Conference, Fort Lauderdale
2003, E-Commerce Law & Business
Licensing Sales of Medical Products to Embargoed Countries: Trade Sanctions Reform and Export Enhancement Act (TSRA)
December 2002, Pharmaceutical International Lawyers Legal Seminars (PILLS)
Post 9/11 Sanctions
March 2002, The Conference Board's Council of Senior International Attorneys, Miami
Antitrust Litigation Seminar
1995-2001, University of Virginia Law School
Taught at the seminar with other firm lawyers.
July 16, 1998, Lawmoney