from the 20-f filing:

8. Please clarify the status of your relationship with BAE and discuss its terms. If you do not own or have rights to the technology developed by or with them, please clearly state that fact and describe the risks associated with your relationship with BAE.

Response to Comment No. 8

The Company’s wholly-owned subsidiary, ODIS, Inc., has entered into a joint development agreement with BAE, a global defense, security and aerospace technology development company, as disclosed on page 61 of the original Registration Statement. Under ODIS, Inc.’s agreement with BAE, each party maintains an undivided 50% joint interest in all intellectual property developed pursuant to the terms of the agreement (subject to ODIS, Inc.’s licensing obligations to UCONN). The Company has revised the disclosure on page 12 of the Amended Registration Statement to further describe the relationship.