ZX appears to maintain a presence in the Iranian market through its relationship with the Bahman Group, as evidenced by the Bahman Group website featuring the ZX logo. (Bahman Group website, “Homepage”).

 NKM Noell Special Cranes' references focused on the above mentioned cranes and scope of supply with 2 reactors in Iran.

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NKM attended 4th Iran International Aluminium Conference (the “Conference”) held in Tehran on May 11-12, 2016. (4th Iran International Aluminium Conference Website, “List of International Attendees”). The conference was organized by the Iran Mines and Mining Industries Development and Renovation Organization (“IMIDRO”), which is sanctioned by the Office of Foreign Assets Control, part of the U.S. Department of the Treasury, because “U.S. Persons Must Continue to Block the Property and Interests in Property of this Person Pursuant to Executive Order 13599.” (OFAC, “Sanctions Search [IMIDRO]).

JSL attended the Iranian Steel Pipe & Tube Conference (the “Conference”) held in Tehran on May 24-25, 2016. (MetalBulletin Events, “Iranian Steel Pipe & Tube Conference”). The Conference purported to offer “a unique opportunity to gain crucial insight into the Iranian market and the networking with leading Iranian companies is not to be missed.”

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JSL has maintained a constant presence in Iran since at least 2009. Between 2004 and 2011, Iran, the UAE, Qatar, Syria and “other gulf countries” comprised 15% of JSL’s total sales. (JSL website, “Milestones,”).

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Vishal Steel and Hi-Tech Metal and Tubes identify themselves as distributers of JSL stainless steel pipes in Iran. (Vishal Steel website, “Jindal Steel,”; Hi-Tech Metal and Tubes website, “Hitech Pipes & Tubes is Leading Exporters of Jindal Saw Pipes Tubes,”).

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In 2011, a company spokesman explained that “its [overseas] business is mainly spread in Iran, Iraq and Saudi Arabia.” (Reuters, “Jindal Saw to buy logistic firm to ramp up scale,” 3/22/2011).