To Jim -
 As long as 
 
 1. Repair does not alter the construction and 
    performance of the product as documented. 

 2. Ownership does not change. 

 don't need. 

To Richard - 

 I agree that *retention of ownership* is key here. 
 But, I would ask for a discussion following the 
 shift in ownership with the following.

 Case 1, I agree. 

 Case 2, would be between the original owner 
 (not distributer) and the second owner. 
 The sale of the equipment occured not by 
 you, but between the second owner and the 
 first owner after Jan. 1, 1997. You are 
 now acting as a repair shop. The first 
 owner selling anything after after Jan.1, 1997 
 is responsible for properly representing the 
 compliance of the product. 

 Case 3, would be between the original owner 
 (now being the distributer) and the second owner. 
 The rest would follow as in Case 2. 

To Tania - 

 See Case 3 above. 

This discussion is raising some excellent points. 

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   The comments and opinions stated herein are mine alone,
   and do not reflect those of my employer.
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