Alain and Monique Massot - Page 3

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            other fluids in the pharmaceutical, microelectronic, food and                              
            beverage, and aircraft industries.  Later, Millipore diversified                           
            into the manufacturing and sale of precision instrumentation,                              
            chromatography, and the synthesis of DNA and peptides.                                     
                  Petitioner began working for Millipore, S.A., a French                               
            subsidiary of Millipore, in 1971 as a technical sales                                      
            representative in third-world countries.  He was promoted numerous                         
            times–-first as area manager for the USSR, the Middle East, and                            
            Africa, then to sales manager, and in 1979, to general manager and                         
            vice president of Millipore, S.A., where he was responsible for the                        
            company’s European membrane division.                                                      
                  Millipore, S.A. contributed to a retirement account for                              
            petitioner in France.                                                                      
            Relocation to the United States                                                            
                  On May 7, 1986, petitioner was promoted to senior vice                               
            president of worldwide sales for Millipore (for the membrane                               
            division).  Petitioner’s promotion was announced in a general                              
            distribution memorandum.1 Petitioner’s promotion required his and                          

                  1     General distribution memoranda were used by Millipore                          
            to communicate quickly with its employees worldwide.  Pursuant to                          
            Millipore’s practice, such a memorandum would first be duplicated                          
            and distributed to employees in Millipore’s Bedford,                                       
            Massachusetts, headquarters, then faxed to the foreign                                     
            subsidiaries with instructions for further dissemination to                                
            Millipore’s worldwide employees.  Subsequently, the memorandum                             
            would be delivered into the mailboxes of the individual                                    
            employees, displayed on bulletin boards, and translated into                               
            foreign languages.                                                                         

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