DHL Corporation and Subsidiaries - Page 56

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          is also the rate used by one of respondent’s experts and by                 
          petitioners’ expert, albeit in a discounted form.                           
               Respondent relied on the expertise of Keith Reams, who used            
          a 1-percent rate to arrive at the royalties listed above.  We               
          approve Reams’ approach, with the exception that the royalty rate           
          should be reduced to .75 percent.                                           
               C. Imbalance and Transfer Fees                                         
               Beginning in 1974, DHL performed delivery services in the              
          United States for DHLI.  The services took the form of the                  
          delivery of inbound items and the transfer of items passing                 
          through the United States from one foreign jurisdiction to                  
          another.  Similarly, DHLI performed delivery (but no transfer)              
          services for DHL in DHLI’s international jurisdictions.  Until              
          1987, no reimbursement (of any kind) was made to either entity.             
          In 1987, procedures were implemented that provided that the party           
          with excess outbound shipments to be delivered in the other’s               
          jurisdiction would pay a cost-plus-2-percent payment to the party           
          that handled the excess shipments.  For 1987 through 1990, DHL              
          handled DHLI’s shipments that were in excess of DHL’s outbound              
          shipments (to be delivered outside the United States).  Similar             
          provisions were made for payment for transfer items, which                  
          occurred only in connection with the movement of items through              
          the United States, and so payments were to be made only by DHLI             
          to DHL.  Respondent does not question DHL’s and DHLI’s 1987                 
          agreement or their methodology, but argues that imbalance                   




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