BAE Developing Smaller Version of AGS System For … · of the Tomahawk cruise missile, ......

BAE Developing Smaller Version of AGS System For Arleigh Burke-Class Destroyers

By Carlo Munoz

Program officials at BAE Systems are looking to shrink down the company's naval gun system designed for the Navy’s Zumwalt-class destroyer (DDG-1000) and install the smaller version of the weapon system on board the sea service’s Arleigh Burke-class warships (DDG-51).

The Advanced Gun System-Lite (AGS-Lite) will trim 50 percent of the original AGS design and maintain the same 74 nautical-mile range as its larger counterpart on the DDG-100, while firing the same 155mm round, according to John Perry, manager of business development for advanced systems.

A smaller magazine capacity and slower rate of fire are the only real tradeoffs between the AGS-Lite and the larger AGS, Perry said in an April 7 briefing in Arlington, Va. The range of fire provided by both AGS systems dwarfs the 13 nautical mile range of the legacy Mk45 deck gun on the DDG-51 ships, he said.

That 74 nautical mile range provided by the AGS-Lite system matches that of the Tomahawk cruise missile, Perry said. At that range, the new deck gun could provide vital ship-to-shore fire support and supplement Tomahawk strikes against targets inland.

Currently, program officials have only tested the gun’s range up to 60 nauti-cal miles, but are well on track to hit the 74 nautical mile threshold, according to Perry.

The AGS-Lite system also features an automated loading system below deck, which replaces the six-man team normally required to load the Mk45 gun, according to the BAE official.

While no program of record has been established for the AGS-Lite by the Navy, Perry noted that the Navy’s stated requirements for precision fire support, coupled with its decision to truncate the number of DDG-1000s in the fleet, vali-dated the need for the AGS-Lite.

The initial AGS was expected to be the main deck gun for the Navy’s future fleet of Zumwalt-class destroyers. But after serious cost overruns, the sea service opted to cut its DDG-1000 buy to three ships and fill the remainder of that destroyer requirement with more Arleigh-Burke class boats.

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Day 1 • Monday April 11, 2011

Schedule Of Events 7:30am-5:00pm

Attendee RegistrationExhibit Hall Level (Hall E)

9:15amComplimentary Attendee Continental

Breakfast 9:30am-9:45am

Opening Ceremony — Escalator Mezzanine

9:45am-5:00pmExposition Open — Exhibit Hall

10:00am-11:15amService Chief’s Panel: “Seapower:

International Security and America’s Future” — Potomac Ballroom C

Moderator: Vice Admiral Phillip M. Bal-isle, USN (Ret), DRS Technologies, Inc., Senior Vice President, Maritime Strategic Plans and Programs

Speakers: Admiral Gary Roughead, USN, Chief of Naval Operations

General James F. Amos, USMC, Com-mandant of the U.S. Marine Corps

Admiral Robert J. Papp, Jr., USCG, Commandant of the U.S. Coast Guard

The Honorable David T. Matsuda, MARAD, Maritime Administrator

11:00am-5:00pmInternational Maritime ToursExhibit Hall

11:25am-11:55amSea-Air-Space Floor Speaker—Navy

League of the United States Booth #242Rear Admiral Jeffrey A. Lemmons, USN,

Director for International EngagementMaritime Energy Pavilion Floor SpeakerMaritime Energy Theater Booth #213Mr. John P. Quinn, USN, Deputy Director,

Chief of Naval Operations, Energy and Environmental Readiness Division

▶ Continued on page 3

Defense Daily®

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April 11, 2011 Defense Daily 3

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With that decision, it was clear that the current Mk 45 deck gun on board the DDG-51s would have to be replaced with a more advanced ver-sion, according to Perry.

With millions already invested into the AGS for the DDG-1000, it made sense to simply leverage the lessons learned from the research, development and design work for that system, and move that into the Mk 45 replace-ment.

BAE officials have already completed a successful ship integration study of the new deck gun for the DDG-51, Perry said. The results of that study showed the system to be compatible with the legacy destroyer, in terms of power load requirements, deck profile and below deck space, he said.

That said, company officials are on pace to complete final system design and development in the near future, Perry added. n

Raytheon Accelerates Deliveries of Sea Sparrow Missiles To Navy, U.S. Allies

By Carlo Munoz

Missile manufacturer Raytheon [RTN] has ramped up production and deliveries of a key missile system to the U.S. Navy and various American allies in the past year, according to a company statement.

The defense industry giant shipped 336 Evolved Sea Sparrow Missile (ESSM) systems to the U.S. military and other foreign armed forces in the past year, it said. That number, it added, nearly doubles the amount of ESSM systems shipped worldwide in 2009.

The acceleration in ESSM deliveries by Raytheon was driven by cus-tomer demand, Rick Nelson, vice president of Naval Weapon Systems at Raytheon Missile Systems, said in the same statement.

The ability to produce such quantities of Sea Sparrows to U.S. and international clients was a reflection of the company’s “robust manufactur-ing and engineering processes,” as well as the ability to leverage its vast net-work of international partners on the program, Nelson said.

That international cooperation comes in the form of the “NATO Sea Sparrow Project.” Including the United States, project participants include Australia, Belgium, Canada, Denmark, Germany, Greece, The Netherlands, Norway , Portugal, Spain and Turkey.

“ESSM protects the fleets of the world as a leading solution for layered defense,” said Ed Roesly, Raytheon Missile Systems ESSM program direc-tor.

The delivery milestone is the culmination of nearly four decades of technology and design improvements backed by the NATO partnership, Roesly said. That said, company officials continue to “conduct studies to identify improvement opportunities required for ESSM to pace the threat with advanced capabilities,” the statement added.

ESSM is a medium-range, all-weather, semi-active radar-guided missile used in surface to air and surface to surface roles by the United States and currently deployed by more than 11 international customers. On the Navy side, the ESSM is primarily used for fleet protection on board the service’s carrier and surface warfare ships. n

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12:00pm-1:30pmSecretary of the Navy LuncheonPotomac Ballroom AKeynote Speaker: The Honorable Ray

Mabus, Secretary of the NavyPresentation of Safety AwardsAdmiral Vern Clark Safety AwardsGeneral James L. Jones Safety Awards

1:45pm-2:15pmSea-Air-Space Floor SpeakerNavy League of the United States

Booth #242Vice Admiral Adam M. Robinson, Jr.,

USN, United States Navy Surgeon General

2:30pm-4:00pmProfessional Development Seminar:

“Foreign Military Sales, Maritime Security and the Future of Interna-tional Partnerships”

Potomac Ballroom CModerator: Commander Fred La-

trash, USN (Ret), ALCOA DefenseVice President, Business Development,

Navy & Air Force ProgramsSpeakers: Mr. Richard A. Genaille,

Jr., Deputy Director, Defense Security Cooperation Agency

Rear Admiral Joseph W. Rixey, USN, Director, Navy International Programs Office

Brigadier General Carl E. Mundy, III, USMC, Director, Strategy and Plans Division

Mr. Michael Tangora, USCG, Deputy Assistant Commandant for Acquisition

Dr. Jennifer Stewart, Ph.D., Chairman of the Foreign Procurement Group


Booth #242Mr. James H. Offut, Navy League of the

United States, National Director and Chairman, Maritime Policy Committee


Booth #242Ms. Donna Hopkins, U.S. Department of

State, Coordinator, Counter Piracy and Maritime Security, Bureau of Political-Military Affairs

5:00pm-6:30pmInternational Maritime Reception(Invitation only)

6:30pm-8:30pmSEAPOWER Magazine Reception(Invitation only)


4 Defense Daily April 11, 2011

Raytheon Delivers First Phalanx Fleet Defense System To South Korean Navy

By Carlo Munoz The South Korean navy took the first steps toward fielding one of the U.S. Navy’s premiere fleet defense sys-

tems on board their warships, taking delivery of the first Phalanx Close-In Weapon System last week. The Raytheon [RTN]-built Phalanx will allow South Korean ships to take out a myriad of short-range threats,

ranging from small vessels to anti-ship missiles in the terminal phase, via a 20mm gun automated to fix, track and destroy such targets, according to a company statement.

The first Phalanx gun system, a Block 1B variant, will be installed onto the lead ship of the South Korean navy’s new frigate-class, known as the Ulsan-1 class FFX, the statement noted. The new FFX-ship class will replace the current Ulsan and other smaller frigates, and will be used primarily for anti-ship, anti-submarine and anti-aircraft warfare.

This initial delivery is the first of six total that Raytheon plans to sell to the South Korean navy. The Block 1B version of the system is the same one on board U.S. Navy ships.

Raytheon has yet to lock in the foreign military sale for the additional five Phalanx systems, which are planned to go on board the new FFX frigates, the company statement said.

South Korea will join 25 other nations, including the United States, which currently field the Phalanx system., the statement added. Nearly 890 Phalanx systems have been deployed worldwide.

“The Phalanx system is fully capable of defending against all types of air and surface threats in the naval environment,” Rick Nelson, vice president of Raytheon’s Naval Weapons Systems, said in the statement.

“Coupled with the reliability and availability of this world-class system, the South Korean fleet will have the best possible ship self-defense available,” he added.

Currently, the Phalanx is the only close-in weapon system in the Navy’s arsenal capable of autonomously performing its own search, detect, evaluation, track, engage and kill assessment functions, according to a service fact sheet.

Additionally, the system can be tied into existing ship combat control systems “to provide additional sensor and fire-control support to other installed ship weapon systems,” the fact sheet said. n

Huntington Ingalls Industries Taps Management Team Huntington Ingalls Industries [HII] last week announced three additions to the company’s senior leadership

team for its corporate business management and finance office functions. D.R. Wyatt has been promoted to corporate vice president, treasurer; Andy Green has joined the company

as corporate vice president, investor relations; and Dwayne Blake has been promoted to corporate vice president internal audit. The three report to Barbara Niland, corporate vice president, business management, and chief financial officer.

HII, previously known as Northrop Grumman Shipbuilding, started operating on March 31 as an inde-pendent, publicly traded company after being spun off from Northrop Grumman [NOC]. It designs, builds and maintains nuclear and non-nuclear ships for the U.S. Navy and Coast Guard and supplies after-market services for military ships worldwide.

The company employs nearly 38,000 in Virginia, Mississippi, Louisiana and California. n

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Raytheon To Begin LRIP Deliveries Of New Radar For P-8By Carlo Munoz

Defense firm Raytheon [RTN] are set to begin low-rate initial production of its new maritime radar system for the Navy's next-generation intelligence, surveillance and reconnaissance aircraft by September.

Production and deliveries of the LRIP versions of the company's APY-10 radar system will coincide with the delivery schedule set by the Navy for the Boeing [BA]-built P-8 Poseidon ISR aircraft, Brad Hopper, senior manager for strategy and business development in Raytheon's ISR division, said in an April 6 briefing.

"When the Navy contracts Boeing for the [LRIP] aircraft...Boeing will contract us," to begin APY-10 deliveries. Currently the Navy has Boeing on contract to produce six planes for LRIP-1 and seven planes for LRIP-2,

Hopper said. Quantities and schedules for the future LRIP buys are still in the works, he added. The P-8 is the replacement for the Navy's legacy P-3 Orion ISR aircraft. Raytheon is a subcontractor to the

Boeing-led P-8 effort. The APY-10 "is a brand new design, specifically to meet the maritime and over land surveillance requirements

for the P-8 platform," with specific focus on anti-submarine and anti-surface warfare, Hopper said. Deliveries of the radar system will begin in September and run through July of next year, according to

Hopper. The Navy granted the P-8 program milestone C clearance last August, clearing the way for the program to begin LRIP production.

Live flight tests of the APY-10 are already underway at Naval Air Station-Paxtuxet River, Md., according to Hopper. He could not comment on the specifics of the ongoing tests, noting that Raytheon has yet to receive an official

report on the flight test results. That said, Hopper noted that preliminary feedback from those tests have shown no major anomalies with the APY-10 test system. n

Navy Defends Plans For Just 16 Missile Tubes On Next Boomer

By Emelie RutherfordA top Navy official stood by the service's decision to outfit the next-generation ballistic-missile submarine

with 16 missile tubes, amid reports that US. Strategic Command (STRATCOM) advocated for 20 tubes.Senate Armed Services Strategic Forces subcommittee Ranking Member Jeff Sessions (R-Ala.) questioned

Navy Strategic Systems Programs (SSP) Director Rear Adm. Terry Benedict last week about news accounts that the sea service and STRATCOM clashed on the missile-carrying capability of the future SSBN(X) submarine.

Benedict testified at a budget hearing that SSP provided the technical input that led to the decision to have 16 instead of 20 tubes for Trident D-5 ballistic missiles on the SSBN(X). Congress is keeping a close eye on the nascent program, which is slated to reach initial development in 2019, as senior Pentagon officials have warned could overwhelm the Navy's shipbuilding budget.

Benedict said SSP supported analyses of the Navy, STRATCOM, and the Office of the Secretary of Defense leading up the SSBN(X) program's recent entry into the Milestone A phase. The Pentagon's Defense Acquisition Board permitted SSBN(X) to enter into this technology development phase on Jan. 10.

In addition to SSP's technical input regarding the SSBN(X) missile tubes, Benedict said, "other factors were considered" when determining the number of tubes, and "cost was one of them."

Still, he said he shares a viewpoint with Navy Secretary Ray Mabus, Chief of Naval Operations Adm. Gary Roughead, and STRATCOM Commander Air Force Gen. Robert Kehler: "Given the threats that we see today, given the mission that we see today, given the upload capability of the D-5, and given the environment as they saw today, all three of those leaders were comfortable with the decision to proceed forward with 16 tubes," Benedict said.

SSP, he said, examined "the capability of the (D-5) missile itself" and its range."Based on what we understand, the capability of the D-5, today,...as the director of SSP, I am comfortable

with that decision."Meanwhile on Capitol Hill, House Republicans and Senate Democrats continued to spar yesterday over the

▶ Continued on page 8

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size of the federal budget for fiscal year 2011, which began last Oct. 1. Temporary government funding--within a continuing resolution (CR) with mainly FY '10 funding levels--is set to expire tomorrow at midnight.

The House Rules Committee was slated to meet last night, after press time, to set the parameters of House floor debate for a new one-week CR that includes a complete FY '11 defense appropriations bill. However, President Barack Obama and some congressional Democrats have balked at that proposal. The White House has insisted lawmakers agree to a full FY '11 budget for all of the agencies, not just the Pentagon. n

New Laser-Based Weapon For Navy Fleet Protection Operations In The Works

By Carlo Munoz Program officials at BAE Systems are fine-tuning a new directed energy-based concept designed to take out

small, fast moving targets that could evade other defense systems on board Navy ships.The Tactical Laser System (TLS) demonstrator, as envisioned, will be a counterpart to the current Mk38 deck

machine gun and provide a non-kinetic option to detect and engage small targets at various ranges, BAE Business Development Manager for Armament Systems John Perry said.

The Navy awarded BAE last month a $2.8 million contract to develop a prototype of the TLS, according to a company statement. Boeing [BA] will provide the laser technology with BAE performing the integration work onto the Mk38.

The design of the TLS incorporates two types of 10 kilowatt lasers that can be employed based on the distance and nature of the threat, Perry said. The "green" laser can be used as certain ranges as a sensor-type of capability, allowing the sailor manning the Mk 38 to identify the specifics of a given threat--from the presence of small arms to heavy machine guns and rocket-propelled grenades.

Should a target advance closer to a Navy ship equipped with the TLS, the green laser can then be used to temporarily blind those on board, as a way to divert a pending attack non-kinetically or as a way to determine whether the target is an imminent threat, he said.

For targets determined as threats, the TLS can then transition to a high-powered laser that can be used to disable a boat's radar and communication systems, outboard engines or ignite various munitions that may be on board, all before the boat could reach its intended target, Perry said. In cases of inflatable, Zodiac-styled small boats, the high-powered laser could puncture the vessel and sink it, he added.

The transition between the green and high-power laser is instantaneous, with the disabling effects of the high-powered laser taking only a few seconds before a given target is incapacitated or neutralized.

The 15-month long demonstration development contract will focus on maritime applications for the TLS, but Perry noted that if the concept proves successful, company officials are eyeing future applications for the system.

Those options include mounting a TLS-type system on board an unmanned aerial vehicle, as well as increas-ing the kilowatt output to allow the system to engage anti-ship cruise missile threats, Perry noted. n

MDA Awards Multiple Concept Development Deals For Next-Generation SM-3

By Carlo MunozThe Missile Defense Agency has awarded a total of $127 million in three separate contracts to Boeing [BA],

Lockheed Martin [LMT] and Raytheon [RTN] to begin conceptual design and development work on the agency’s next-generation of SM-3 missiles.

Lockheed Martin garnered the lion’s share of the $127 million, with MDA awarding the company $43.3 mil-lion for the effort. Raytheon, which is the prime contractor on the SM-3 missile, netted $42.7 million toward its work on the follow-on system, with Boeing being awarded $41.1 million for their concept development program, according to the contracts issued on April 7.

▶ Continued from page 6

April 11, 2011 Defense Daily 9


Under these contracts, each company “will work with MDA on the concept definition and program planning “toward the development of the Block IIB version of the [SM-3],” including defining and assessing “viable and affordable missile configurations” with support from trade studies, ultimately leading to an “executable develop-ment plan.”

Each company was also awarded $1.4 million in DOD research, development, test and evaluation (RDT&E) funds appropriated in the fiscal year 2011 defense spending bill to “incrementally fund this effort,” the contract notices state.

The Block 1A version of the SM-3 is currently deployed on Navy warships and is the backbone of the service’s sea-based Aegis ballistic missile defense system. Service and industry officials anticipate fielding the Block 1B vari-ant of the weapon on a land-based version of the Aegis system in Eastern Europe.

The Block IIA and eventual Block IIB versions of the missile will be developed in a block approach, based system technologies on board the IA and IB missiles.

Both the Block IA and IB are key to the Pentagon’s European Phased Adaptive Approach (EPAA) for missile defense, approved in September 2009 by Defense Secretary Robert Gates, Chairman of the Joint Chiefs of Staff Adm. Michael Mullen, and President Obama.

However, former Missile Defense Agency (MDA) director Lt. Gen. Trey Obering said last week that problems with the Block IA system would likely find their way into the new Block IB variant of the weapon. Given the spiral approach for SM-3 development, those problems would “tend to cycle through” all current and future variants of the weapon--including the IIA and IIB versions (Defense Daily, April 6).

Obering is currently an executive with Booz Allen Hamilton [BAH], served as director of MDA from 2004-2009.Frank Wyatt, vice president of Raytheon Air and Missile Defense Systems, dismissed Obering’s claims dur-

ing an April 5 interview, noting the company has been and would continue to meet all the SM-3 development and deployment timelines set by the White House and DOD to comply with the EPAA. n



Precision-Guided Version of Marine Hydra Rocket To Enter Theater By September

By Carlo MunozDeliveries of a new, precision-guided version of the Marine Corps’ legacy air-to-ground Hydra rocket are

set to begin this summer, with the weapon slated to hit the skies above Afghanistan and elsewhere by September, according to a senior industry official.

Marine Corps rotary-wing units will begin getting the Advanced Precision Kill Weapon System (APKWS) in July, once the weapon clears initial operational testing and evaluation this summer, BAE Systems Business Development Manager for Electronic Solutions George Adamakos said.

The APKWS is an advanced guidance system developed by BAE Systems that can be attached to the Marine Corps current stockpile of Hydra 70 rockets used on the service’s AH-1 SuperCobra attack helicopters.

Once attached, the APKWS will allow SuperCobra aircrews to precisely engage moving and stationary targets within a 40 degree field of view, utilizing the four-pronged sensor suite attached to the APKWS guidance system.

Navy acquisition officials inked the initial low-rate initial production agreement for the advanced guidance platform with BAE Systems last year. That deal covered 325 guidance units for the Marine Corps. In January, service officials came to terms on the second LRIP tranche of APKWS weapons, this time acquiring 600 systems, Adamakos said.

But in both LRIP deals, the Navy agreed to only buy the APKWS guidance system, opting to retrofit the Marine Corps backlog of Hydra 70 rockets already in the service arsenal. That said, company officials are also offering full-up APKWS missiles, including both the Hydra 70 munition and guidance system as a single package.

To date, according to Adamakos, BAE Systems is close to completing a direct sale for 5,000 APKWS weapons to an undisclosed foreign military. The company official declined to comment on which country was acquiring the system, but he did note the sale would only be for the guidance system and not the complete weapon package.

Aside from weapon sales, the company has also been contracted by the Air Force and Navy to develop a Joint Capability Technology Demonstrator that would allow a full-up APKWS to be mounted on a Marine Corps’ AV-8 Harrier and an Air Force A-10 Thunderbolt, according to Adamakos.

The JCTD deal was signed in February, with BAE Systems agreeing to provide roughly 92 full missile units for the effort, he said. The program is still in the very preliminary phases, with company and military officials still trying to gauge the necessary capabilities and system attributes needed to fire a helicopter-based weapon from a much faster fixed-wing fighter.

Even though the test demonstrator is focused only on the AV-8 and the A-10, company officials are already exploring possible applications for the weapon on board the Navy’s F/A-18 and the Air Force’s F-16 fighters. n

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PEO Land Systems: Industry Must Help Tighten Budget BeltBy Emelie Rutherford

The Marine Corps’ sole program executive officer (PEO) said the

weapon-system programs in his portfolio have all stabilized and he now

is focusing sharply on cost-savings measures with the defense industry.

William Taylor, the program executive officer for Land Systems, oversees eight high-profile

programs, including the Expeditionary Fighting Vehicle (EFV), Joint Light Tactical Vehicle

(JLTV), Medium Tactical Vehicle Replacement (MTVR), and Ground/Air Task Oriented Radar

(G/ATOR). Taylor started his current stint as the service’s first-ever PEO in 2007 as a colonel,

before retiring two years ago.“I am at the point now where everything that we’ve tried to focus on and invest our time and

energy in, in terms of the infrastructure around which programs can flourish, has apparently paid

off,” Taylor told Defense Daily in September. “I can very confidently tell you that we’ve finally

reached a point in time where across the entire PEO Land Systems portfolio all our programs are

stable from a technical standpoint, they’re adequately resourced, and they’re executing superbly

well. So that’s something that I probably couldn’t have said several years ago when we had various

programs struggle.”However, the U.S. economic crunch and Pentagon’s multi-part efficiency initiative now are

having major impacts PEO Land Systems, Taylor said in a wide-ranging interview.

He said biggest acquisition challenges these days are “driven primarily by fiscal con-

straints.”Ashton Carter, the under secretary of defense for acquisition, technology, and logistics, out-

lined 23 significant changes to how the Pentagon contracts for goods and services in a Sept. 14

memo to the Defense Department’s acquisition professionals and the defense industry (Defense

Daily, Sept. 15). Going forward, affordability will be a firm requirement for each new weapon

Modern Day Marine Military Expo Daily

© 2010 by Access Intelligence, LLC. Federal copyright law prohibits unauthorized reproduction by any means and imposes fines of up to $100,000 for violations.

Published By:Defense Daily® Visit us at the Modern Day Marine Expo Sept. 28 - Sept. 30 • Booth 1503


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Schedule of Events8:00am – 3:00pmRegistration9:45am – 10:00amOpening Ceremony10:00am – 3:30pm Exhibit Area Open

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FBCB2-BFT Evolving To Battle Command SystemBy Ann Roosevelt

Northrop Grumman’s [NOC] Force XXI Battle Command Brigade

and Below (FBCB2) is moving far beyond the original concept of a situa-

tional awareness tool toward a battle command system, a company official

said. Recent advances include the next-generation software, called Joint

Capabilities Release (JCR), that is undergoing formal Army testing.

“Our experiences in Iraq underscored the importance of creating a

joint FBCB2/BFT solution acceptable to the Marine Corps and the Army,”

Joe Taylor, vice president of the Ground Combat Systems operating unit

within Northrop Grumman’s Information Systems sector, said. “The serv-

ices reached an agreement on a common set of requirements almost five

years ago. To converge on JCR is a pretty big deal. Once they go through

this fielding process then you’ll have both organizations on the same sys-

tem.”JCR offers a significant increase in network bandwidth, allowing

the system to move more information to more users within seconds rather

than minutes. It is also compatible with all the FBCB2 BFT tracking equipment

that’s out there, some 85,000 systems now worldwide.

The JCR will continue planned tests through 2010, fielding in con-

junction with the newly-awarded production contract for an improved

Blue Force Tracking 2 (BFT2) transceiver with full encryption and lower

latency. Additionally, this summer, the Army awarded Northrop Grumman

an $18 million increment of a potential $300 million contract to provide

encryption devices to upgrade the communications security of FBCB2-

BFT. The software is fully compatible with JCR.

“It’s a new way of utilizing the satellite that allows much, much

lower latency and much higher bandwidth,” Taylor said. © 2010 by Access Intelligence, LLC. Federal copyright law prohibits unauthorized reproduction by any means and imposes fines of up to $100,000 for violations.

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