`NEW YORK, NY 10022-359.5
`
`1999 AVENUE OF THE STARS
`SUITE 1600
`Los ANOELES, C A 90067-6048
`
`SHANOHAI CENTRE
`SUITE 405
`U76 NANJINO XI Lu
`PEOPLE’S REPUBLIC OF CHINA
`
`KAYE, SCHOLER, FIERMAN, HAYS Ei, HANDLER, LLP
`A N E W YORK L I M I T E D LIABILITY P A R T N E R S H I P
`T H E M c P H E R S O N B U I L D I N G
`901 F I F T E E N T H S T R E E T , N . W . , S U I T E I100
`W A S H I N G T O N , D . C . 2 0 0 0 5 - 2 3 2 7
`
`(202) 602-3500
`FAX (202) 602-3500
`dcameron@kayescholer.com
`
`March 2,2000
`
`-16”
`
`PHILLIPS POINT. WESTTOWER
`S U I T E 1002
`777 S. FLAOLER DRIVE
`WEST PALt4 BEACH, FL 3340 I
`
`NINE QUEEN’S ROAD CENTRAL
`HONO KoNo
`
`WRITER’S DIRECT DIAL NUMBER
`( 2 0 2 ) 682-3630
`
`Secretary
`U.S. International Trade Commission
`500 E. Street, S.W.
`Washington, DC 20436
`
`Re:
`
`Circular Welded Carbon-Ouality Line Pipe; Request
`to Retain Confidential Information Released
`Pursuant to APO Pending Final Decision in WTO
`Appeal
`
`Dear Madam Secretary:
`
`On behalf of the Korean Producers of line pipe who were respondents in the above-
`
`captioned investigation, and as authorized applicants under the administrative protective order
`
`(“APO”) issued therein, we hereby request leave to retain records containing confidential
`
`business information, pending the final outcome of any appeals before the World Trade
`
`Organization (WTO) of safeguard measures imposed by President Clinton on imports of line
`
`pipe pursuant to section 20 1 of the Trade Act.
`
`By letter dated February 28,2000, counsel for the domestic industry requested
`
`permission from the Commission to retain APO documents beyond the normal 60-day period
`
`following conclusion of the investigation, and indicated their consent to allowing counsel for
`
`DOC. t l l 3 0 0 2 8 10. WPD
`
`
`
`KAYE, SCHOLER, FIERMAN, HAYS & HANDLER, LLP
`
`The Honorable Donna R. Koehnke
`March 2,2000
`Page 2
`
`respondents to do the same. As noted by counsel for the domestic industry in its aforementioned
`
`letter, requesting parties’ counsel to destroy their copies of the confidential record in this
`
`proceeding would prejudice their ability to protect their interests in any ensuing WTO appeal.
`
`Allowing authorized APO applicants to retain their materials subject to the terms of the APO
`
`would alleviate this concern without compromising the confidentiality of the APO data.
`
`Accordingly we join counsel for the domestic industry in requesting that we be permitted to
`
`retain, in accordance with the APO, all confidential business information released under the APO
`
`in this investigation, pending a final outcome in any WTO appeal of the Safeguard Measures.
`
`Thank you for your consideration of this request. Please feel free to contact the
`
`undersigned with any questions regarding this matter.
`
`-- .
`
`Donald B. Cameron
`Julie C. Mendoza
`R. Will Planert
`Brady W. Mills
`Counsel to Korean Respondents
`
`cc:
`
`Valerie Newltirk, Room 61 5M
`Lyn M. Schlitt, Esq., Room 707D
`Lynn Featherstone, Room 6 15AA
`
`DOC. 813002810.WPD
`
`
`
`PUBLIC CERTIFICATE OF SERVICE
`
`CIRCULAR WELDED CARBON-QUALITY LINE PIPE
`
`Inv. No. TA-201-70
`
`I hereby certify that on this 2nd day of March, 2000, I caused copies of the foregoing
`submission to be served by hand-delivery on the following parties:
`
`Behalf of Petitioners:
`
`Roger Schagrin, Esq.
`SCHAGRIN ASSOCIATES
`1 100 Fifteenth Street, N. W.
`Suite 700
`Washington, D.C. 20005
`
`Behalf of Stelco, Inc.: and Steelpipe. Inc.:
`
`Christopher Dunn, Esq.
`WILKIE FARR & GALLAGHER
`1155 21st Street, N.W., Suite 600
`Washington, D.C. 20036
`
`Behalf of Borusan Boru Birlesik Fabrikalari
`and Mannesmann Boru Endustrisi:
`
`Arthur J. Lafave, 111, Esq.
`DICKSTEIN, SHAPIRO, MORIN AND
`OSHINSKY
`2101 L Street, N.W.
`Washington, D.C. 20037-1526
`
`Behalf of Kawasaki Steel Corporation;
`Nippon Steel Corporation: NKK
`Corporation; and Sumitomo Metal
`Industries, Ltd.:
`
`Joseph Price, Esq.
`GIBSON, DUNN & CRUTCHER
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036
`
`Behalf of Mitsui and Company KJ.S.A.),
`Incomorated:
`
`Kenneth G. Weigel, Esq.
`Laura Fraedrich. Esq.
`KIFKLAND AND ELLIS
`655 15th Street, N.W.
`Washington, D.C. 20005
`
`Behalf of MHP Mannesmann Praezisrohr
`Gmbh and Mannesmann Pipe and Steel
`Cornoration:
`
`Gunter von Conrad, Esq.
`BARNES RICHARDSON CQLBURN
`1225 Eye Street, N.W., Suite 1150
`Washington, D.C. 20005
`
`Behalf of Hylsa. S.A. de C.V.; Tubacero,
`S .A. de C.V.: Tuberias Procarsa. S.A. de
`C.V.: and Tuberia Laguna, S.A. de C.V.,
`TuberiaNacional. S.A. de C.V.:
`
`Michael J. Chapman, Esq.
`SHEARMAN AND STERLING
`801 Pennsylvania Avenue, N.W.
`Suite 900
`Washington, D.C. 20004-2604
`
`Behalf' of Government of Canada:
`
`Mr. J.P. Gombay
`Counsellor (Economic)
`Canadian Embassy
`50 1 Pennsylvania Avenue, N. W
`Washington, D.C. 20001
`
`
`
`Behalf of British Steel PIC and British Steel
`Incorporated:
`
`Sherry Gilman, Esq.
`STEPTOE AND JOHNSON
`1330 Connecticut Avenue, N.W.
`Washington, D.C. 20036
`
`Anna Snow
`Delegation of the European Commission
`2300 M Street, N.W.
`Washington, D.C. 20037
`
`Brady W. Mills
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