Mixing and rotating overt, covert, and forensic technologies can thwart counterfeiters.

By Donald J. Dobert
President and Chief Operating Officer
ATL Security Label Systems

It has been said dozens of times already, there is no silver bullet against counterfeiters and diverters. You’ve got to layer, layer, and layer some more. In the photograph below we have illustrated the different “layers” of a 3D hologram. These invisible layers give the security label three color kinetic movement.

These “layers”, which are not immediately known to the counterfeiters, can be mixed and rotated to protect original products and documents. In the example below a German ID card has hologram layers that reveal a pattern when the card is moved back and forth.

In the photo below, courtesy of Graphic Security Systems Corporation, Lake Worth, FL, you can easily see how (during manufacturing) each “layer” is structured with different anti-counterfeiting properties.

Just what exactly does layering mean? What layer comes first, what layers need constant updates, and what layers stay put? Who decides when and when to layer, when to update the layers, and when do you need to inform FDA?
A “mix and rotate” approach brings multiple technologies together in one package. To “mix and rotate” can be compared to software updates. As computer hackers invent new “bugs,” software companies develop new “anti bugs.” Every time you as a brand owner produce your product, you can “mix and rotate” the following security features:

Tamper-evident breakaway closures.
Invisible, hidden markers.
Anticounterfeiting holograms.
Color-shifting inks.
Tamper-evident unit closure.
Mass-serialization.
Two-dimensional bar codes.
RFID chips.
Void security closures or destructible tapes.

Here is an example. Tamper-evident substrates can employ destructible, paper-based face stock or nonreproducible covert security fibers. Distribution can be limited to approved secure suppliers for a secure chain of custody. Tamper-evident substrates can make label removal impossible without visible damage. Such features effectively deter remarking and help ensure product authenticity. They also provide simple in-field authentication.
In addition, color-shifting inks and other covert features can be public signals of authenticity. Invisible forensic markers alone can be used to detect whether a product has been repackaged or relabeled. Such forensic markers may be used in the varnish on the package as well as customized or serialized codes and holograms.
Combining these technologies, the hologram would be an overt feature, the forensic marker would be a covert one, and the code could be either overt or covert, depending on what you are doing with it. Special codes can be purchased or created that pertain to only one product, which tells the manufacturer where it was made, how it was distributed and on what days. While there are codes that are very obvious and basically list manufacture date and product code, there is a wide range of options in customized codes.
A Ubiquitous Example
Modern U.S. currency has changed many times over the past few years. With the exception of the one-dollar bill, all of these notes are obsolete (see photo below). This is because the U.S. government “mixes and rotates” (M&R) its overt and covert techniques to stay one step ahead of the counterfeiters.

Shown below are examples of anti-counterfeiting “layered levels” of the “ever-changing” “face” of U.S. notes. You will notice the different colors when compared to the notes that are now obsolete:

Overt and covert M&R anticounterfeiting measures include fine detail with raised intaglio printing on bills. This allows nonexperts to easily spot forgeries. As a side note, on coins, milled or reeded (marked with parallel grooves) edges are used to show that none of the valuable metal has been scraped off. This detects the shaving or clipping (paring off) of the rim of the coin. However, this does not detect sweating, or shaking coins in a bag and collecting the resulting dust. Since this technique removes a smaller amount, it is primarily used on the most valuable coins, such as gold.
For paper bills, in the late twentieth century, advances in computer and photocopy technology made it possible for people without sophisticated training to easily copy currency. To combat this, national engraving bureaus began to include new (more sophisticated) anticounterfeiting systems such as holograms, multicolored bills, and embedded devices such as strips, microprinting, and inks whose colors change depending on the angle of the light. New technology also includes the use of design features such as the “Eurion Constellation,” which disables modern photocopiers.

Detecting counterfeit bills often isn’t easy to do by eye. One bogus $100 bill believed to have been made in North Korea, for instance, would be nearly impossible for a novice to identify as a fake. It has the security strip on the left side of the bill and a watermark of Ben Franklin (whose portrait is on the bill) on the right-hand side, as well as replicating other security features. However, its paper contains no starch and doesn’t reflect ultraviolet light, which is one sign of a counterfeit.Photo Below. The portrait on a genuine $50 bill (left) compared to a counterfeit. Notice the relative flatness and lack of detail on the fake bill.

Photo Below: The portrait on a genuine $50 bill (left) compared to a counterfeit. Notice the relative flatness and lack of detail on the fake bill.

Photo Below. $50 bill with three security features highlighted. A section of the security thread is visible in the circle near the portrait. The large circle to the right shows the watermark, and below that the color-shifting ink is circled.

There is now a scanner that searches for missing covert features in bogus “Super Dollars.” The device looks at several aspects of the bill to confirm its legitimacy. U.S. paper money is printed with magnetic ink, but that’s also used for many fraudulent bills. On real bills, the ink is distributed in a consistent pattern whose magnetic resonance can be mapped. The magnetic map is stored in the scanner, as well as three other maps containing ultraviolet, infrared, and other measurements taken from legitimate bills. Scanning a bill takes less than one second. If there’s any spike or anomaly in any of the threads of data, the scanner rejects the dollar.

Photo Below. Beginning with Series 2004, $10, $20, and $50 bills received a redesign with several changes to their overall look, notably the addition of more colors (see the picture of the $50 bill above). Probably the most important new security feature is the addition of EURion Constellations, a distinct arrangement of symbols (in this case, numbers) which triggers many color photocopiers to refuse to copy the bill.

SUPER LABELS=SUPER DOLLARS

What I have just described is a “layered” approach in anticounterfeiting. You may not be the government fighting “super dollars,” but then again, you are fighting to protect your brand from counterfeiters. The money a brand owner saves in brand protection and litigation should be considered as “super dollars” to the brand owner. In the process (of saving money), the brand owner will be protecting the public, and he can advertise as such.

PUTTING IT INTO PRACTICE
Here’s how forensic authentication works in a M&R layered approach:
A unique digital code, “ATL 12-IDGJ”, is set-up for a brand.
A digital code is incorporated into the label through multiple-entry points (inks, varnishes, adhesives).
The digital code is also incorporated into (or linked to) the pedigree documentation.
A scanner will indicate that “ATL 12-IDGJ” is the established digital code, allowing traceability.

Such uniqueness cannot be duplicated because the invisible, nondegradable forensic digital code is virtually impossible for the counterfeiters to duplicate. It only takes a second to authenticate a product anywhere in the world.

Today, FDA does not need to know what type of anticounterfeiting measures you are taking. In fact, to protect themselves, brand owners should limit such details to a certain number of trained individuals who are monitoring what features are being used and for how long.
Most important in the anticounterfeiting arsenal is the brand owner’s mindset. Nothing changes until this does. Counterfeiters have the mindset that they can break the laws, provide fake or diluted products, and they do not care if they place the public in harms way. We (you and I) have to assume the mindset that says to the counterfeit, “No, you can’t copy my products.”

Thank you for your time. Donald J. Dobert, President, ATL.

You Bet Your Life: The Fakes. A Lesson For You In Loss Prevention.
A counterfeit drug or a counterfeit medicine is a medication or pharmaceutical product which is produced and sold with the intent to deceptively represent its origin, authenticity or effectiveness. For legal drugs, a counterfeit drug may be one which does not contain active ingredients, contains an insufficient quantity of active ingredients, or contains entirely incorrect active ingredients (which may or may not be harmful), and which is typically sold with inaccurate, incorrect, or fake packaging. Fake medicines and generic drugs which are deliberately mislabeled in order to deceive consumers are therefore counterfeit, while a drug which has not received regulatory approval is not necessarily so. Counterfeit drugs are also related to Pharma Fraud.

Most illegal drugs are produced and sold with the intent to deceptively represent its origin, authenticity or effectiveness, at least to some degree. The counterfeiting ranges from drugs which do not contain any active ingredients (e.g., when a bag of lactose is sold as cocaine), to cases where the active ingredients are “cut” with a dilutant or “spiked” with a chemical “enhancer”, to cases where the actual active ingredients differ from the purported active ingredients (e.g., when methamphetamine is sold as cocaine).

You Bet Your Life: Brand Piracy. Prescription and over-the-counter drugs.

Counterfeit legal drugs include falsely-labeled drugs that were previously expired, drugs where the active ingredient is fraudulently diluted, adulterated, substituted, completely misrepresented, or sold with a false brand name. An individual who uses a low quality counterfeit medication may experience a number of dangerous consequences to their health, such as unexpected side effects, allergic reactions, or a worsening of their medical condition. A number of counterfeits do not contain any active ingredients, and instead contain inert substances, which do not provide the patient any treatment benefits. Counterfeit medications may also contain incorrect ingredients, improper dosages of the correct ingredients, or they may contain hazardous ingredients.

The extent of the problem of counterfeit drugs is unknown. Counterfeiting is difficult to detect, investigate, and quantify. What is known is that they occur worldwide and are said to be more prevalent in some developing countries with weak regulatory regimes. It is sometimes estimated that upwards of 10% of drugs worldwide are counterfeit, and in some countries more than 50% of the drug supply is made up of counterfeit drugs. In 2003, the World Health Organization cited estimates that the annual earnings of counterfeit drugs were over $32 billion (US).

The high prices of patented medicines and the great divergence between manufacturing costs and prices are seen as important incentives for counterfeiting, including cases of high quality counterfeiting which can be difficult to detect. Fake antibiotics with a low concentration of the active ingredients can do damage world wide. Courses of antibiotics that are not seen through to completion allow bacteria to regroup and develop resistance.

Above Photo: Which are real and which are fake? Without traceability and authentication, how do you know? Would “You Bet Your Life” on not knowing?

You Bet Your Life: Some Solutions (RFID & Mass Serialization).

There are several technologies that may prove helpful in combating this problem, such as radio frequency identification (RFID). These are electronic devices to track and identify items, such as pharmaceutical products, by assigning individual serial numbers to the containers holding each product. The FDA is working towards an Electronic pedigree (ePedigree) system to track drugs from factory to pharmacy. This technology may prevent the diversion or counterfeiting of drugs by allowing wholesalers and pharmacists to determine the identity and dosage of individual products. Some techniques, such as spectroscopy and Energy Dispersive X-Ray Diffraction (EDXRD) can be used to discover counterfeit drugs while still inside their packaging.Some of the proposed anti-counterfeiting measures present concerns regarding privacy, or the possibility that drug manufactures will seek to use anti-counterfeiting technologies to undermine legitimate parallel trade in medicines. The term “counterfeit” should not be applied to generic drugs that are legally manufactured and sold, and which do not have deceptive labeling concerning the product. According to BBC reports, many of the fake drugs came from the same countries that make normal drugs, especially China and India. In the case of India, while it is against the law to sell fake drugs for domestic use, there is no regulatory regime that applies to the export market.

Graph Above: The top 5 anti-counterfeiting techniques are date codes, various printing, tamper evident, UPC codes, and mass serialization.

China
Many counterfeit drugs sold in the Third World or on the Internet originate in China. The State Food and Drug Administration is not responsible for regulating pharmaceutical ingredients manufactured and exported by chemical companies. This regulatory hole, which has resulted in considerable international news coverage unfavorable to China, has been known for a decade, but failure of Chinese regulatory agencies to cooperate has prevented effective regulation.
The Chinese press agency Xinhua reported that the World Health Organization had established Rapid Alert System (RAS), the world’s first web-based system for tracking the activities of drug counterfeiters, in light of the increasing severity of the problem of counterfeit drugs.

Russia
A few years ago, the Coalition for Intellectual Property Rights, an independent Russian group, conducted a survey that found that 12 percent of the prescription drugs distributed in Russia were counterfeit.

India
According to a report released by the Organization for Economic Co-operation and Development (OECD), 75 per cent of fake drugs supplied world over have some origins in India, followed by 7 per cent from Egypt and 6 per cent from China. It must be noted that India also is a leading source of high quality drugs sold by legitimate drug manufacturers, including most leading brand name drug makers operating in the US and Europe.

United States
The United States has had a growing problem with counterfeit drugs, and to help address it, the U.S. Food and Drug Administration (FDA) holds regular hearings to review trends and problems. The U.S. is an especially attractive market for counterfeiters because 40 percent of worldwide annual prescription drug sales were sold in the United States in 2007.

You Bet You Life: Anti-Counterfeit Platforms.
In 2007, the world’s first free to access anti-counterfeit platform was established in the West African country of Ghana. The platform relies on existing GSM networks in that country to provide pharmaceutical consumers and patients with the means to verify whether their purchased medicines are from the original source through a free two-way SMS message, provided the manufacturer of the relevant medication has subscribed to a special scheme. Still in trial stages, the implementers of the platform announced recently that they are in partnership with Ghana’s Ministry of Health and the country’s specialized agency responsible for drug safety, the FDB (Food & Drugs Board), to move the platform from pilot to full-deployment stage.

An Epedigree is another important system for the automatic detection of counterfeit drugs.

Photo Above: Hard copy of typical pedigree papers.

Photo Above: Pedigree papers can provide traceability of your prescription medications.

States such as California are increasingly requiring pharmaceutical companies to generate and store ePedigrees for each product they handle. On January 5th, 2007 EPCglobal ratified the Pedigree Standard as an international standard that specifies an XML description of the life history of a product across an arbitrarily complex supply chain.

You Bet Your Life: Illegal Drugs.
Illegal drugs can be counterfeited easily because the illegal drug market is an unregulated underground economy that rarely adheres to quality norms or safety standards. While there are some isolated examples of illegal drugs being sold under “brand names” that indicated that certain standards or dosage levels were being adhered to, this is the exception. The illegal “brands” can also be counterfeited by drug dealers who want to be able to sell their product at a higher price.
The use of dilutants in illegal drugs reduces the quality and potency of the drugs, and makes it hard for users to determine the appropriate dosage level. Dilutants include “foodstuffs (flour and baby milk formula), sugars (glucose, lactose, maltose, and mannitol), and inorganic materials such as powder.” The type of dilutants that are used often depend on the way that the drug purchasers will typically consume the drug in a given part of the illegal market. Dr. Hirsch, the New York Medical Examiner, claimed that buying illegal drugs is “… like playing Russian roulette.”

This is why we say that if you take prescription medications without “drug authentication”, you are playing a dangerous game of “You Bet Your Life“.

End.

Below: Article break. Are prices “sky high”?

What is a Y2K+10 (year 2010) bucket shop? How does a bucket shop affect the manufacturer of legitimate brands? Look at the two photos below, one of a counterfeiter’s equipment (the bucket shop), and one of a counterfeiters press (also a bucket shop). These facilities can be in a basement or garage, and are usually filthy.

If you are a regular visitor of “The President’s Corner”, then you know that counterfeiting has been around since the birth of our nation. Early United States currency had “To Counterfeit Is Death” printed on the notes. This was a serious crime in the years 1759 – 1777 (and beyond). But let me try and get you to think about a new paradigm: “To Counterfeit Is Death – Y2K+10 Version”. The counterfeiters of the new millennium (Y2K) really do kill people. Diluted vaccines, tainted baby formula, prescription drugs with very little (or no) active ingredients at all – these are the lowest of all possible crimes. The counterfeiters seldom see their victims. If they get caught, their fines are minuscule, no more than just a “slap on the wrist”. How do the criminals attack your legitimate products? And more importantly – how do you fight back?

Counterfeiters rip you off by reformulating (dilution or complete fakes) and re-packaging – the replacement of labels with copies. This is huge problem at all levels of the supply chain. Fraudulent labels are used to change the dates of expired product, make false claims or misrepresentations, and inflate pricing. (Pricing can be inflated because a 5 mg dose can be reprinted to claim a 40 mg dose). Quite often these (counterfeited) prescription drugs are administered to very weak cancer or aids patients, and the doctors think the drugs are not working because of the advanced state of the disease. Little do the doctors realize they may be giving their patients diluted or fake medicines. This is why I say “To Counterfeit Is Death”.

Brand Owners Can Fight Back. Tamper Evident Labels (ATL Secur-Lock or Pharma- Void) use substrates that effectively deter re-marking and counterfeiting fraud. This helps prevent a negative economic impact on your brand. The label face stock combines a tamper evident feature with covert authentication. Labels using this substrate are very difficult to remove (they destroy themselves when removed) . . . and can be easily distinguished from a fake.
When combined with ATL’s covert printing, tamper evident substrates can be your cornerstone of a highly protective labeling solution. Tamper evident substrates features include:
- Destructible, paper-based face stock
- Non-reproducible covert security fibers
- Distribution limited to approved secure suppliers

Tamper Evident Substrates Benefits
- Label cannot be removed without visible damage
- Effectively deters re-marking
- Assures product authenticity, or provides or provides simple in-field authentication
- Secure chain of custody
- Covert Authentication
- Tamper Evidence

Twelve Elements Of A secure Supply Chain/ Cold-Chain. Quality Management of the distribution channel begins and ends with the brand owner. Below is the first slide of a presentation I recently made to “Cold Chain Distribution Professionals” at the Philadelphia Convention Center.

I recommended a 12 step approach to strengthen their cold-chains (the logistical system of safely delivering their products). My advice to them is detailed in “The President’s Corner” published October 4th, 2008.
If you would like to discuss your anti-counterfeiting needs, please contact ATL for a no obligation conversation” about your supply chain. We feel that we have solid experience in anti-counterfeiting. I’ll say this over and over – our main focus is not that you buy something from ATL, rather that you learn from knowledgeable people about the perils of counterfeiting.

I will end this segment with the following words of wisdom: “Believe it is possible to solve your problem. Tremendous things happen to the believer. So believe the answer will come. It will.” — Norman Vincent Peale

Question. Do I have to notify FDA before I start to use covert markings or materials in my labels?

Answer. The current labeling requirements for pharmaceuticals are part of 21 CFR Parts 210 and 211 – Current Good Manufacturing Practice In Manufacturing, Processing, Packing or Holding of Drugs; General and Current Good Manufacturing Practice For Finished Pharmaceuticals. These are the cGMP’s (Current Good Manufacturing Practices).

The cGMP’s deal mainly with overt labeling features. These include, but are not limited to:
Written procedures designed to assure that correct labels, labeling, and packaging materials are used for drug products. These written procedures must be followed. These procedures incorporate the following features:
(a) Prevention of mixups and cross-contamination by physical or spatial separation from operations on other drug products.
(b) Identification and handling of filled drug product containers that are set aside and held in unlabeled condition for future labeling operations to preclude mislabeling of individual containers, lots, or portions of lots. Identification need not be applied to each individual container but shall be sufficient to determine name, strength, quantity of contents, and lot or control number of each container.
(c) Identification of the drug product with a lot or control number that permits determination of the history of the manufacture and control of the batch.
(d) Examination of packaging and labeling materials for suitability and correctness before packaging operations, and documentation of such examination in the batch production record.
(e) Inspection of the packaging and labeling facilities immediately before use to assure that all drug products have been removed from previous operations. Inspection shall also be made to assure that packaging and labeling materials not suitable for subsequent operations have been removed. Results of inspection shall be documented in the batch production records.

As for pharmaceuticals and tamper-evident packaging: Each manufacturer who packages an OTC drug product (except a dermatological, dentifrice, insulin, or lozenge product) for retail sale must package the product in a tamper-evident package, if this product is accessible to the public while held for sale. A tamper-evident package is one having one or more indicators or barriers to entry which, if breached or missing, can reasonably be expected to provide visible evidence to consumers that tampering has occurred. To reduce the likelihood of successful tampering and to increase the likelihood that consumers will discover if a product has been tampered with, the package is required to be distinctive by design or by the use of one or more indicators or barriers to entry that employ an identifying characteristic (e.g., a pattern, name, registered trademark, logo, or picture).

The term “distinctive by design” means the packaging cannot be duplicated with commonly available materials or through commonly available processes.

Photos Below: “Distinctive By Design” examples from August 13, 1776. This New York ten dollar bill had a distinctive pattern on the back. Please note the penalty that was printed on the bill: “Tis Death To Counterfeit”.

A tamper-evident package may involve an immediate-container and closure system or secondary-container or carton system or any combination of systems intended to provide a visual indication of package integrity. The tamper-evident feature must be designed to and must remain intact when handled in a reasonable manner during manufacture, distribution, and retail display.

Covert features lack the standardization that you would find in cGMP’s. To my knowledge, the FDA supports covert features, but there are no standards that are mandated. This is why “The International Organization of Standardization” (ISO) has approved the creation of a new Technical Committee (TC) on fraud countermeasures and controls to help address development of standards related to combating fraud. The TC, proposed by the American National Standards Institute (ANSI) in conjunction with the North American Security Products Organization (NASPO), focuses on the development of standards in the areas of brand and intellectual property protection, identity management, and financial fraud.

The proposal, identified as ISO/TS/P 206, hopes to bring together fraud experts, law enforcement, government agencies, criminologists, brand owners, and solution providers to develop relevant security standards for the use of private industries and governments worldwide. ISO recognition and support from other international standards organizations will help to counter the rising financial and social cost of worldwide fraud activity.
The new committee provides a framework to engage international fraud experts with existing ISO technical committees to create solutions to complex issues. Standards will affect parties concerned with brand protection, intellectual property, drug counterfeiting, supply chains for products of value, authentication of goods, food supply chains, identity credentials, identity management, identity theft, customs and immigration enforcement, and financial fraud. Although the scope may appear broad, it effectively addresses the wide variety of fraud throughout industry segments.

So, for now, the FDA is concerned with 21 CFR 210 and 211. These standards do not encompass covert features.

Notable & Quotable: “Your true value depends entirely on what you are compared with.” — Bob Wells

Increase in Drug Tampering Reports & Loss Prevention Spark New Security Considerations

Photo Above: Your profits and consumer loyalty can explode and literally “go up in smoke”, just as these defective (fake OEM) batteries did. Take simple steps in loss prevention through security packaging.

Efforts to identify and intercept phony medications are taking on a greater urgency amid increased concerns that tampering and counterfeiting may become an attractive vehicle for organized crime rings and even terrorists. Very few companies treat these events as viable loss prevention opportunities.

The profitability of expensive new drugs used to combat cancer and other diseases along with the growth of Internet and cross-border purchasing has raised the potential for exploitation motivated by greed.
Over the last decade there’s been a huge increase of tampering with or copying high value drugs that were largely injectables; now the trend seems to be more in changing labels-buying low potency materials then affixing high potency labels.

For example, vials of the anti-anemia drug Epogen were discovered with phony lot numbers. After analyzing the contents, the drug’s manufacturer sent letters alerting pharmacists and distributors that the vials each contained 2,000 units of the drug-far less than the 40,000 claimed on the labels.

A month later, manufacturer Ortho Biotech Products issued a warning to health care professionals that counterfeit lot numbers of their anti-anemia drug Procrit had been uncovered in Texas. In the process of the Epogen investigation, the Procrit vials were also found to contain concentrations of the active ingredient 20 times lower than the amount listed on the labels. How does this affect you, the consumer? How does this affect you, the brand owner? Simple: as a consumer, any fake drug can kill you. As a brand owner, lawsuits can cripple your company, and loss of public faith in your product could be devastating.

Photo Above: Security Label. Where is the covert feature? In the ink? In the adhesive? In the varnish? Just on page three? As a brand owner, only you will know, and this can be changed from production run to production run.

Consider the following loss prevention steps.

Secure your packaging against counterfeiting, tampering, fraud and diversion. This requires collaboration with someone who has the expertise and resources to provide a solution that is tailored specifically for your brand. ATL is one of the most respected security solutions providers. We offer a wide variety of technology, and we have the engineering capability to design, manufacture, and implement a security packaging solution that makes sense for you.

Photo Above: Security Labels can be “tracked and traced” all over the world, in a matter of seconds. This is a very valuable attribute for inventory controls and loss prevention.

Our printing, holographic, and overt/ covert layering production experience allows ATL to customize a security solution that can incorporate a combination of security layers such as holography, forensic digital codes, micro text, serialization, bar-coding (including 2D), track and trace, and tamper evident materials. We can combine these techniques to develop an effective security packaging solution that can work in combination with each other, or as a rotated defense (different features with varried production runs).

Photo Above: Jim Stiglich and Jeff Lord (ATL Security Label Specialists) travel the globe educating consumers and brand owners alike in anti-counterfeiting loss prevention.

Many of these solutions add a decorative dimension to your package – adding brand authentication and brand protection to your design. These same solutions reaffirm to your customers that you care about their safety and well being. And here is the kicker….

Loss Prevention. As a brand owner you can solicit your insurance company to reduce your rates. You can prove to them that you have the necessary security features that will aid law enforcement agents in the field. You will also have the evidence in place that will stand up in court. At pennies per unit, isn’t preventing a loss worth your time and effort?

Photo Above: Donald Dobert, President, ATL, speaks at the Pennsylvania Convention Center (Cold Chain Conference). The subject was anti-counterfeiting and loss prevention. Other speakers included Phil Viggani (ID Global Corp.), Nathaniel Lipkus (Gilbert’s LLP, Lawyers, Patent & Trademark Agents), and Craig Thurber (United States Department of Homeland Security).

Earl Nightingale said it best: “As Ye Sow, Ye Shall Reap…..”
“We will receive not what we idly wish for but what we justly earn. Our rewards will always be in exact proportion to our service.”