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routine and consistent with standard practice in the computer
science field.
Mr. Teixeira reported that debit cards were common by 1989,
and several banks had transaction volumes significantly larger than
Norwest's. Further, by 1990, 673 banks were issuing Visa logo
debit cards. He also found that Norwest's experience with ATM's,
which Norwest used to operate the debit card system, provided a
solid understanding of the technical issues involved, including
interfacing, card issuance, and capacity planning. Additionally,
Mr. Teixeira stated that Norwest's activities in interfacing the
new debit card system with its other systems were consistent with
the deployment of the products by other institutions. Finally, Mr.
Teixeira rejected any claim by Norwest that technical alternatives
were considered in the process of developing the debit card system
and insisted that the alternatives related only to business issues.
We agree with respondent that the development of the Debit
Card system does not constitute qualified research. Dr.
McDermott's own findings that the project's only risk was its
ability to be completed and deployed before those of Norwest's
competitors undermines any claim to the R&E credit. None of the
experts reveal any technical risks, and it is apparent that the
debit card was a fairly common product (nearly 40 percent of the
top 75 banks had the debit card by late 1989) by the time Norwest
entered the market. No new principles of computer science were
discovered by this project, and although alternative approaches
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