According to BIS, subsequently Seagate entered into a three-year "strategic cooperation agreement" with Huawei that identified Seagate as "Huawei's strategic supplier" and granted Seagate "priority basis over other Huawei suppliers." As a result of these continued sales, BIS determined that between August 2020 and September 2021, Seagate ultimately engaged in 429 exports, reexports, or transfers of approximately 7.4 million HDDs subject to the EAR valued at over $1 billion to Huawei without the required authorization from BIS. BIS determined that the cause of these violations was that Seagate had incorrectly interpreted the Huawei foreign direct product rule as requiring evaluation of only the last stage of its HDD manufacturing process, instead of evaluating the entire process. BIS explained that Seagate had HDD manufacturing sites in China, Northern Ireland, Malaysia, Singapore, and Thailand that used equipment, including testing equipment, that were subject to the EAR.