Representatives of large, sophisticated companies that have been actively working to implement the expected requirements spoke eloquently at an October 2011 SEC Roundtable discussion of the complexity of their supply chains and the difficulty in obtaining solid information from their upstream suppliers on the origins of common, commodity metals like tin, tantalum, tungsten and gold in purchased products and components.

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In the past it was only multinational companies that could afford to compete with global supply chains, not just because of the cost and complexity of operating trucks, aircraft and warehouses on different continents but also because of the difficulty of managing all these diverse elements.

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