Senate Bill sb2656c2

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    Florida Senate - 2006                    CS for CS for SB 2656

    By the Committees on Governmental Oversight and Productivity;
    Commerce and Consumer Services; and Senator Atwater




    585-2351-06

  1                      A bill to be entitled

  2         An act relating to public records; creating s.

  3         288.9623, F.S.; providing definitions; defining

  4         the term "proprietary confidential business

  5         information" and specifying information that

  6         does not constitute proprietary confidential

  7         business information; creating an exemption

  8         from public-records requirements for

  9         proprietary confidential business information

10         held by the Florida Opportunity Fund regarding

11         alternative investments; providing for limited

12         duration of the exemption; authorizing the

13         inspection and copying of confidential and

14         exempt records if the proprietor of the

15         information fails to verify that a record

16         contains certain information within a specified

17         period; authorizing a court to order the

18         release of confidential and exempt records upon

19         making certain findings; providing for future

20         review and repeal; providing a statement of

21         public necessity; providing a contingent

22         effective date.

23  

24  Be It Enacted by the Legislature of the State of Florida:

25  

26         Section 1.  Section 288.9623, Florida Statutes, is

27  created to read:

28         288.9623  Florida Opportunity Fund; public-records

29  exemption.--

30         (1)  As used in this section, the term:

31  

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    Florida Senate - 2006                    CS for CS for SB 2656
    585-2351-06




 1         (a)  "Alternative investment" means an investment by

 2  the Florida Opportunity Fund in a private equity fund, venture

 3  fund, or angel fund or a direct investment in a portfolio

 4  company through a distribution of securities to its partners

 5  or shareholders by an alternative investment vehicle.

 6         (b)  "Alternative investment vehicle" means the limited

 7  partnership, limited liability company, or similar legal

 8  structure through which the Florida Opportunity Fund invests

 9  in a portfolio company.

10         (c)  "Portfolio company" means a corporation or other

11  issuer, any of whose securities are owned by an alternative

12  investment vehicle or the Florida Opportunity Fund and any

13  subsidiary of such corporation or other issuer.

14         (d)  "Portfolio positions" means individual investments

15  in portfolio companies which are made by the alternative

16  investment vehicles, including information or specific

17  investment terms associated with any portfolio company

18  investment.

19         (e)  "Proprietor" means an alternative investment

20  vehicle, a portfolio company in which the alternative

21  investment vehicle is invested, or an outside consultant,

22  including the respective authorized officers, employees,

23  agents, or successors in interest, which controls or owns

24  information provided to the Florida Opportunity Fund.

25         (f)1.  "Proprietary confidential business information"

26  means information that has been designated by the proprietor

27  when provided to the Florida Opportunity Fund as information

28  that is owned or controlled by a proprietor; that is intended

29  to be and is treated by the proprietor as private, the

30  disclosure of which would harm the business operations of the

31  proprietor and has not been intentionally disclosed by the

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    Florida Senate - 2006                    CS for CS for SB 2656
    585-2351-06




 1  proprietor unless pursuant to a private agreement that

 2  provides that the information will not be released to the

 3  public except as required by law or legal process, or pursuant

 4  to law or an order of a court or administrative body; and that

 5  concerns:

 6         a.  Trade secrets as defined in s. 688.002.

 7         b.  Information provided to the Florida Opportunity

 8  Fund regarding a prospective investment in a private equity

 9  fund, venture fund, angel fund, or portfolio company which is

10  proprietary to the provider of the information.

11         c.  Financial statements and auditor reports of an

12  alternative investment vehicle.

13         d.  Meeting materials of an alternative investment

14  vehicle relating to financial, operating, or marketing

15  information of the alternative investment vehicle.

16         e.  Information regarding the portfolio positions in

17  which the alternative investment vehicles invest.

18         f.  Capital call and distribution notices to investors

19  of an alternative investment vehicle.

20         g.  Alternative investment agreements and related

21  records.

22         h.  Information concerning investors, other than the

23  Florida Opportunity Fund, in an alternative investment

24  vehicle.

25         2.  The term "proprietary confidential business

26  information" does not include:

27         a.  The name, address, and vintage year of an

28  alternative investment vehicle and the identity of the

29  principals involved in the management of the alternative

30  investment vehicle.

31  

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    Florida Senate - 2006                    CS for CS for SB 2656
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 1         b.  The dollar amount of the commitment made by the

 2  Florida Opportunity Fund to each alternative investment

 3  vehicle since inception.

 4         c.  The dollar amount and date of cash contributions

 5  made by the Florida Opportunity Fund to each alternative

 6  investment vehicle since inception.

 7         d.  The dollar amount, on a fiscal-year-end basis, of

 8  cash or other fungible distributions received by the Florida

 9  Opportunity Fund from each alternative investment vehicle.

10         e.  The dollar amount, on a fiscal-year-end basis, of

11  cash or other fungible distributions received by the Florida

12  Opportunity Fund plus the remaining value of

13  alternative-vehicle assets that are attributable to the

14  Florida Opportunity Fund's investment in each alternative

15  investment vehicle.

16         f.  The net internal rate of return of each alternative

17  investment vehicle since inception.

18         g.  The investment multiple of each alternative

19  investment vehicle since inception.

20         h.  The dollar amount of the total management fees and

21  costs paid on an annual fiscal-year-end basis by the Florida

22  Opportunity Fund to each alternative investment vehicle.

23         i.  The dollar amount of cash profit received by the

24  Florida Opportunity Fund from each alternative investment

25  vehicle on a fiscal-year-end basis.

26         (g)  "Florida Opportunity Fund" means the Florida

27  Opportunity Fund authorized in s. 288.9621.

28         (2)  Proprietary confidential business information held

29  by the Florida Opportunity Fund regarding alternative

30  investments is confidential and exempt from s. 119.07(1) and

31  

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    Florida Senate - 2006                    CS for CS for SB 2656
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 1  s. 24(a), Art. I of the State Constitution for 10 years after

 2  the termination of the alternative investment.

 3         (3)  Notwithstanding subsection (2), a request to

 4  inspect or copy a public record that contains proprietary

 5  confidential business information shall be granted if the

 6  proprietor of the information fails, within a reasonable

 7  period after the request is received by the Florida

 8  Opportunity Fund, to verify the following to the Florida

 9  Opportunity Fund through a written declaration in the manner

10  provided by s. 92.525:

11         (a)  That the requested record contains proprietary

12  confidential business information and the specific location of

13  such information within the record;

14         (b)  If the proprietary confidential business

15  information is a trade secret, that it is a trade secret as

16  defined in s. 688.002;

17         (c)  That the proprietary confidential business

18  information is intended to be and is treated by the proprietor

19  as private, is the subject of efforts of the proprietor to

20  maintain its privacy, and is not readily ascertainable or

21  publicly available from any other source; and

22         (d)  That the disclosure of the proprietary

23  confidential business information to the public would harm the

24  business operations of the proprietor.

25         (4)(a)  Any person may petition a court of competent

26  jurisdiction for an order for the public release of those

27  portions of any record made confidential and exempt by

28  subsection (2).

29         (b)  Any action under this subsection must be brought

30  in Orange County, Florida, and the petition or other initial

31  pleading shall be served on the Florida Opportunity Fund and,

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    Florida Senate - 2006                    CS for CS for SB 2656
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 1  if determinable upon diligent inquiry, on the proprietor of

 2  the information sought to be released.

 3         (c)  In any order for the public release of a record

 4  under this subsection, the court shall make a finding that:

 5         1.  The record or portion thereof is not a trade secret

 6  as defined in s. 688.002;

 7         2.  A compelling public interest is served by the

 8  release of the record or portions thereof which exceeds the

 9  public necessity for maintaining the confidentiality of such a

10  record; and

11          3.  The release of the record will not cause damage to

12  or adversely affect the interests of the proprietor of the

13  released information, other private persons or business

14  entities, the Florida Opportunity Fund, or any trust fund, the

15  assets of which are invested by the Florida Opportunity Fund.

16         (5)  This section is subject to the Open Government

17  Sunset Review Act in accordance with s. 119.15 and shall stand

18  repealed on October 2, 2011, unless reviewed and saved from

19  repeal through reenactment by the Legislature.

20         Section 2.  The Legislature finds that it is a public

21  necessity that proprietary confidential business information

22  held by the Florida Opportunity Fund regarding alternative

23  investments be held confidential and exempt from s. 119.07(1),

24  Florida Statutes, and s. 24(a), Art. I of the State

25  Constitution for 10 years after the termination of the

26  alternative investment. Disclosing proprietary confidential

27  business information, including trade secrets as defined in s.

28  688.002, Florida Statutes, used in determining how private

29  equity investments are made or managed by private partnerships

30  investing assets on behalf of the Florida Opportunity Fund

31  would negatively affect the business interests of private

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    Florida Senate - 2006                    CS for CS for SB 2656
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 1  partnerships that rely heavily on their information advantage

 2  to generate investment returns, and competitor partnerships

 3  could gain an unfair competitive advantage if provided access

 4  to such information. The release of proprietary confidential

 5  business information, including trade secrets, revealing how

 6  alternative investments are made could result in inadequate

 7  returns and ultimately frustrate attainment of the investment

 8  objective of the Florida Opportunity Fund. It is the

 9  Legislature's intent to allow the public access to sufficient

10  information in order to be informed regarding the alternative

11  investments of the Florida Opportunity Fund and to balance the

12  public's right to information against the right of private

13  business entities to be protected from harmful disclosure of

14  confidential and exempt proprietary confidential business

15  information, the disclosure of which would injure them in the

16  marketplace. It is also the Legislature's intent to establish

17  consistency with regard to the classification of information

18  relating to alternative investments by the Florida Opportunity

19  Fund as either confidential or suitable for public disclosure.

20  In finding that the public-records exemption created by this

21  act is a public necessity, the Legislature finds that the

22  public and private harm in disclosing proprietary confidential

23  business information relating to alternative investments by

24  the Florida Opportunity Fund significantly outweighs any

25  public benefit derived from disclosure; that the exemption

26  created by this act will enhance the ability of the Florida

27  Opportunity Fund to fulfill its duties as an investment

28  fiduciary by making it more effective and competitive in the

29  marketplace as an investor that is able to gain access to the

30  best alternative investment vehicles; and that the public's

31  ability to be informed regarding the alternative investments

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    Florida Senate - 2006                    CS for CS for SB 2656
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 1  made by the Florida Opportunity Fund is preserved by the

 2  disclosure of information excepted from the created exemption.

 3         Section 3.  This act shall take effect July 1, 2006, if

 4  Senate Bill 2668 or similar legislation is adopted in the same

 5  legislative session or an extension thereof and becomes law.

 6  

 7          STATEMENT OF SUBSTANTIAL CHANGES CONTAINED IN
                       COMMITTEE SUBSTITUTE FOR
 8                            CS/SB 2656

 9                                 

10  Establishes definitions that are applicable for the exemption.

11  Exempts proprietary confidential business information held by
    the Florida Opportunity Fund regarding alternative investments
12  for 10 years after the termination of the alternative
    investment.
13  
    Requires proprietor to file a verified, written declaration
14  that identifies proprietary confidential business information
    in record within reasonable time of receipt by the Florida
15  Opportunity Fund of a public records request. Requires release
    of information if proprietor fails to comply.
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    Permits any person to petition a court for release of
17  confidential and exempt information. Establishes standards for
    court release.
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