Shwan << Name removed >> : Please see the attached Notice to Requester with attachments. If you would be so kind as to confirm receipt, I would appreciate it. Thank you, and have a great weekend. Rayni ______________________________________________________ Rayni M. Nakamura-Watanabe | Supervising Attorney Securities Enforcement Branch | Business Registration Division Department of Commerce and Consumer Affairs State of Hawaii 335 Merchant Street, Suite 205 Honolulu, Hawaii 96813 t | (808) 586-2740 f | (808) 586-3977 w | cca.hawaii.gov/sec/<https://cca.ha... Connect with us on [Facebook] <https://www.facebook.com/HISecurities... [Instagram] <https://www.instagram.com/hisecuritie... [Twitter] <https://twitter.com/HISecurities> CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any review, use, disclosure, or distribution by unintended recipients is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. ________________________________…

I will be out of the office from Monday, June 2, 2025, through Wednesday, June 11, 2025. Should you need immediate assistance, please call: (808) 586-2740 or email Kristelle Takeuchi at: <<email address>> Otherwise, I will respond to your email upon my return to the office on Thursday, June 12, 2025. Thank you.

Thank you for your email, Mr. << Name removed >> . I apologize for my delayed response. I was out of the office on vacation and just returned to the office last week Thursday. Regarding your inquiries below, I kindly request additional time to respond as I will need to consult with others regarding the necessary technical information upon which our initial response was based. I appreciate your patience and thank you for your consideration. Rayni ______________________________________________________ Rayni M. Nakamura-Watanabe | Supervising Attorney Securities Enforcement Branch | Business Registration Division Department of Commerce and Consumer Affairs State of Hawaii 335 Merchant Street, Suite 205 Honolulu, Hawaii 96813 t | (808) 586-2740 f | (808) 586-3977 w | investing.hawaii.gov<http://www.in... Connect with us on [Facebook] <https://www.facebook.com/HISecurities... [Instagram] <https://www.instagram.com/hisecuritie... [Twitter] <https://twitter.com/HISecurities> CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any review, use, disclosure, or distribution by unintended recipients is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. ________________________________ From: << Name removed >> << Name removed >> <<name and email address >> Sent: Wednesday, June 4, 2025 9:24 AM To: Rayni M. Nakamura-Watanabe < <name and email address >> Subject: Re: [EXTERNAL] Records Request for Department of Commerce & Consumer Affairs: Complete list of Hawaii Businesses and their officers and agents [#1427] CAUTION: This email originated from outside of Hawaii State Gov't / DCCA. Do not click links or open attachments unless you recognize the sender and are expecting the link or attachment. Dear Sir or Madam, Per your denial, part one, are you stating that because the state uses a vendor to provide the bulk data download, that data is no longer government data subject to UIPA? Per your denial, part two, you claim "BREG does not keep or maintain such a list" of Hawaii businesses and their officers and agents. Could you please clarify if BREG maintains this data in any bulk digital form? Surely it is being provided to your vendor in a bulk digital form? Or BREG, in its oversight capacity, occasionally downloads and verifies the bulk download from the vendor? Please advise me as to which digital forms the data (or a superset of it) *is* available to the public, beyond paying your vendor $3000 for a 3-month minimum subscription. Thank you kindly.

Thank you for your email, Mr. << Name removed >> . As set forth in my last email, your additional inquiries required further consultation with others regarding the necessary technical information upon which BREG’s initial response was based. We are currently still in the process of obtaining the necessary technical information. I anticipate that I will be able to respond to your additional inquiries in the very near future. As such, I kindly request an extension of up to, an including, Tuesday, July 8th, COB, to respond. Thank you in advance for your patience and understanding. Rayni ______________________________________________________ Rayni M. Nakamura-Watanabe | Supervising Attorney Securities Enforcement Branch | Business Registration Division Department of Commerce and Consumer Affairs State of Hawaii 335 Merchant Street, Suite 205 Honolulu, Hawaii 96813 t | (808) 586-2740 f | (808) 586-3977 w | investing.hawaii.gov<http://www.in... Connect with us on [Facebook] <https://www.facebook.com/HISecurities... [Instagram] <https://www.instagram.com/hisecuritie... [Twitter] <https://twitter.com/HISecurities> CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any review, use, disclosure, or distribution by unintended recipients is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message.…

Good afternoon, Mr. << Name removed >> , Thank you for your patience. Please see BREG's responses to your additional inquiries in blue below. 1. Additional Inquiry No. 1: Per your denial, part one, are you stating that because the state uses a vendor to provide the bulk data download, that data is no longer government data subject to UIPA? Response: No. BREG's response is that the requested records accessible via the hyperlink that you provided in your request do not constitute a "government record" maintained by BREG. HRS § 92F-3 defines a "government record" as "information maintained by an agency in in written, auditory, visual, electronic, or other physical form." See HRS § 92F-3. Under HAR § 2-71-2, the term "maintain" means to hold, possess, preserve, retain, store, or administratively control. See § HAR 2-71-2. Tyler Hawaii is provided with a replicated copy of BREG's database in order to carry out its contractual services, which do not include: Entity List Builder and Bulk Data Downloads. Tyler Hawaii, not BREG, controls who is given access to the replicated information. Access to the replicated information is given: (1) in the form of a hyperlink (i.e., a BREG Bulk Data Download) that is generated by Tyler Hawaii, not BREG, and (2) only to those persons who pay a monthly subscription fee directly to Tyler Hawaii, not BREG. Therefore, the requested records accessible via the hyperlink that you provided in your request is not a "government record" maintained by BREG. In the alternative, BREG also supplements its initial response to the first part of your request to add that your request cannot be granted because the information requested is not readily retrievable by BREG in the form in which it is requested. See HRS § 92F-11(c). 2. Additional Inquiry No. 2: Per your denial, part two, you claim "BREG does not keep or maintain such a list" of Hawaii businesses and their officers and agents. Could you please clarify if BREG maintains this data in any bulk digital form? Response: Information regarding a business is collected and maintained by BREG via its Business Registration Information Management System (BRIMS) database. 3. Additional Inquiry No. 3: Surely it is being provided to your vendor in a bulk digital form? Response: As set forth above, none of the information contained in the BRIMS database is provided to Tyler Hawaii in bulk digital form. 4. Additional Inquiry No. 4: Or BREG, in its oversight capacity, occasionally downloads and verifies the bulk download from the vendor? Response: BREG does not download or verify bulk data downloads from Tyler Hawaii. The services provided by Tyler Hawaii are the result of its replication of the BRIMS database. 5. Additional Inquiry No. 5: Please advise me as to which digital forms the data (or a superset of it) *is* available to the public, beyond paying your vendor $3000 for a 3-month minimum subscription. Response: * A person can also conduct a one-time search utilizing the Entity List Builder to build a customized list of all businesses registered in the State of Hawaii. The information provided will include all addresses, officers, trade names, trademarks, and service marks associated with each business. The cost is $0.05 per business record. * Information regarding all businesses registered in the State of Hawaii is also available to the public via the online portal, Hawaii Business Express, by using the Search for Businesses and Buy Documents feature (https://hbe.ehawaii.gov/documents/sea...). A person can refine their search by selecting "Begins with..." from the drop-down list under Search Mode and typing the letter "A" (or any other letter in the alphabet). The search can be further refined by "entity type" and "status" and will result in a list. A person can then click the name of each entity in the list to be provided with the entity's information. A copy of the information can then be downloaded (free of charge) or saved as a pdf (free of charge). * A person can also request a custom Oracle database export. This option, however, is not readily retrievable by BREG. This option requires BREG to request the assistance of the Information Systems and Communication Office (ISCO), another division within the Department of Commerce and Consumer Affairs. ISCO will be required to "write a custom job to filter the appropriate records and fields for its third-party consultant to accomplish and then validate the data." The consultant has estimated that the requested export, regardless of the number of records, will take approximately 40 hours and cost approximately $5,650. The format of the export would be provided in either .csv or other delimited file. Thank you, Rayni ______________________________________________________ Rayni M. Nakamura-Watanabe | Supervising Attorney Securities Enforcement Branch | Business Registration Division Department of Commerce and Consumer Affairs State of Hawaii 335 Merchant Street, Suite 205 Honolulu, Hawaii 96813 t | (808) 586-2740 f | (808) 586-3977 w | investing.hawaii.gov<http://www.in... Connect with us on [Facebook] <https://www.facebook.com/HISecurities... [Instagram] <https://www.instagram.com/hisecuritie... [Twitter] <https://twitter.com/HISecurities> CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any review, use, disclosure, or distribution by unintended recipients is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. From: Rayni M. Nakamura-Watanabe Sent: Monday, June 16, 2025 4:26 PM To: <<email address>> Subject: RE: [EXTERNAL] Records Request for Department of Commerce & Consumer Affairs: Complete list of Hawaii Businesses and their officers and agents [#1427] Thank you for your email, Mr. << Name removed >> . I apologize for my delayed response. I was out of the office on vacation and just returned to the office last week Thursday. Regarding your inquiries below, I kindly request additional time to respond as I will need to consult with others regarding the necessary technical information upon which our initial response was based. I appreciate your patience and thank you for your consideration. Rayni ______________________________________________________ Rayni M. Nakamura-Watanabe | Supervising Attorney Securities Enforcement Branch | Business Registration Division Department of Commerce and Consumer Affairs State of Hawaii 335 Merchant Street, Suite 205 Honolulu, Hawaii 96813 t | (808) 586-2740 f | (808) 586-3977 w | investing.hawaii.gov<http://www.in... Connect with us on [Facebook] <https://www.facebook.com/HISecurities... [Instagram] <https://www.instagram.com/hisecuritie... [Twitter] <https://twitter.com/HISecurities> CONFIDENTIALITY NOTICE: This e-mail message, including any attachments, is for the sole use of the intended recipient(s) and may contain confidential and/or privileged information. Any review, use, disclosure, or distribution by unintended recipients is prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and destroy all copies of the original message. ________________________________ From: << Name removed >> << Name removed >> <<name and email address >> Sent: Wednesday, June 4, 2025 9:24 AM To: Rayni M. Nakamura-Watanabe < <name and email address >> Subject: Re: [EXTERNAL] Records Request for Department of Commerce & Consumer Affairs: Complete list of Hawaii Businesses and their officers and agents [#1427] CAUTION: This email originated from outside of Hawaii State Gov't / DCCA. Do not click links or open attachments unless you recognize the sender and are expecting the link or attachment. Dear Sir or Madam, Per your denial, part one, are you stating that because the state uses a vendor to provide the bulk data download, that data is no longer government data subject to UIPA? Per your denial, part two, you claim "BREG does not keep or maintain such a list" of Hawaii businesses and their officers and agents. Could you please clarify if BREG maintains this data in any bulk digital form? Surely it is being provided to your vendor in a bulk digital form? Or BREG, in its oversight capacity, occasionally downloads and verifies the bulk download from the vendor? Please advise me as to which digital forms the data (or a superset of it) *is* available to the public, beyond paying your vendor $3000 for a 3-month minimum subscription. Thank you kindly.