Decision

Acquisition of Pulsic Ltd by Super Orange HK Holding Ltd: notice of final order

Published 17 August 2022

1. The Secretary of State for Business, Energy and Industrial Strategy (“the Secretary of State”) has made a final order pursuant to section 26 of the National Security and Investment Act 2021 (“the Act”), which comes into force 15:00 17 August 2022.

2. The Parties who are subject to the order are:

i. Pulsic Limited
ii. Super Orange HK Holding Limited (“the Acquirer”).

3. The Acquirer proposed to acquire the entire share capital of Pulsic Limited.

4. This acquisition constitutes a trigger event under section 8(2)(c) of the Act.

5. The order has the effect of preventing the acquisition of Pulsic Limited from proceeding.

6. The Secretary of State considers that a risk to national security arises from:

i. the application of the intellectual property, knowledge, processes and techniques for the software developed and owned by the Qualifying Entity for the electronic design automation (EDA) products, to facilitate the building of cutting-edge integrated circuits that could be used in a civilian or military supply chain (dual use);

ii. the potential that the EDA tools could be exploited to introduce features into the design, including automatically and/or without knowledge of the user that could be used to build defence or technological capabilities; and

iii. those risks would arise on the transfer of the Qualifying Entity and the Asset to the Acquirer.

7. The Secretary of State considers that the final order is necessary and proportionate to mitigate the risk to national security.