NeoMedia Technologies, Inc (NEOM)

[Be Confident]

Jack,

I am hardly any type of expert in the matter, however, a brief search yielded the following:

Their domestic offices are subject to US law:
Excerpt:
"(5) Foreign Companies Currently Operating in the U.S.

Most large corporations in the world currently conduct business in the U.S. Many of these companies will establish U.S. subsidiaries with branch offices or factories located in the U.S. or obtain U.S. supplied financing and list their shares on American stock exchanges. For these companies, there is a direct and immediate reason to create compliance or ethics programs, regardless whether their home country has created any legislative incentives to do so. Failure to create programs for the U.S. based operation can result in financial penalties which could otherwise be avoided. Daiwa Bank, as discussed above, is an excellent example of a company which suffered by not having implemented an compliance or ethics program.

According to Jeff Kaplan, the Daiwa Bank lesson is especially important for foreign companies doing business in the U.S., "…[T]he entire disaster occurred not because the bank was greedy or malevolent, but simply because it failed to accord due weight to U.S. regulatory mandates" (Kaplan, 1996:11). According to Lori Tansey, president of the International Business Ethics Institute, "Without question many foreign companies doing business in the United States fail to understand the requirements of United States law. Most are not aware of the sentencing guidelines or their implications" (Kaplan, 1996:11). If this is the case, non-U.S. companies will continue to suffer by not taking into consideration the potential impact of the Guidelines.

For those countries with companies operating in the U.S., there is then a direct benefit to adopting legislation similar to the Guidelines. Non-U.S. corporations would have an automatic incentive to create compliance or ethics programs in their home country, and if the programs are applicable to operations in the U.S., these corporations would gain automatic protection from non-compliance when doing business in the U.S. Unfortunately for some non-U.S. companies, such as Daiwa Bank, they had to learn their lesson the hard way."

http://www.actrav.itcilo.org/actrav-english/telearn/global/ilo/code/whatcan.htm#(5) Foreign Companies Currently Operating in the U.S.

Best,
BC