prototype (which in this case was more than 6 months prior to the Launch Date). See Allied Chemical Corp. v. United States, 17 AFTR 2d 316, 1966). Rirkns Coe UY -6- 139063133.3 EFTA00811135 their own tax advisor. We undertake no obligation to update this memorandum after the date hereof. RthnsCoe LIP -