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January 8, 1997

Chairman of the GSP Subcommittee

of the Trade Policy Staff Committee

Office of the U.S. Trade Representative

600 17th Street NW, Room 517

Washington, DC 20506

                Re:Rebuttal Comments on the Review of Paraguay’s Eligibility as a GSP Beneficiary Developing Country

                Case: Paraguay: 013-CP-95

To the Subcommittee:

The International Intellectual Property Alliance (IIPA) acknowledges that the Embassy of Paraguay kindly forwarded to us this morning a copy of its first filing in this GSP proceeding.  We will be reviewing these documents and providing the Subcommittee with our views in the near future. 

We also take this opportunity to supplement our previous filings (of October 29, 1996 and December 11, 1996) by providing the Subcommittee with an update on our estimated trade losses due to piracy in Paraguay.  On December 18, 1996,  the Business Software Alliance, an IIPA member, released its global software piracy estimates for 1995.  BSA estimates the level of software piracy in Paraguay to be 95%, meaning more than 9 out of every 10 business software programs are unauthorized copies.  The estimated losses due to the piracy of business applications software in Paraguay was $19,106,000 in 1995; this statistic, however, includes losses for non-U.S. companies.  The estimated losses for U.S. companies will be somewhat less than that amount.  We anticipate that the U.S. loss statistic will be available shortly and we will pass it to the Subcommittee at that time.


Respectfully submitted,


Maria Strong

Vice President and Associate General Counsel