According to correspondence filed with the SEC: "Hologic develops and manufactures medical products, including diagnostic products, medical imaging systems, and surgical products primarily focused on serving the healthcare needs of women. The Company has sold small volumes of these products and related components to independent, non-U.S. third party distributors located in Iran and Syria. The Company does not sell its products directly to end users in Iran and Syria. The products sold for use in these countries are medical products, including mammography systems, osteoporosis systems, ThinPrep™ diagnostic kits and related imaging equipment to assist in the diagnosis of cervical cancer, breast biopsy equipment, and related components.
Hologic’s distributors in Iran and Syria are responsible for selling, installing and servicing the Company’s products sold in those jurisdictions. The only service performed by Hologic personnel in those jurisdictions would be a “first-in-country” installation of a particular product. During such first installation, Hologic performs the installation with the distributor, during which the distributor is trained to install and service the equipment. The limited installation, training and technical support provided by Hologic are undertaken, managed and paid for by the Company’s European operations and personnel. None of these personnel are U.S. citizens or permanent residents.
The Company has no subsidiaries, assets or personnel based in Iran or Syria, and to the best of the Company’s knowledge, the Company does not have any agreements, commercial arrangements, or other contacts with the governments of Iran or Syria or entities controlled by those governments, except as such contact may relate to the Company providing its distributors with “first-in-country” installation assistance, as such installation may take place in a government-owned or -controlled hospital or clinic."
Over the last three presidential administrations, the United States government has granted Hologic Inc 56 special licenses to do business in Iran. (New York Times, "Companies with Permission to Bypass Sanctions," 12/24/10)