`
`
`
`June 12, 2017
`
`J. David Park
` +1 202.942.5646 Direct
`David.Park@apks.com
`
`Inv. No. TA-201-076
`
`PUBLIC DOCUMENT
`
`VIA ELECTRONIC FILING
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW
`Washington, DC 20436
`
`Re: Large Residential Washers, Inv. No. TA-201-076: Entry of Appearance and
`Administrative Protective Order Application
`
`Dear Secretary Barton:
`
`
`
`On behalf of Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc.
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`(“Samsung”), we hereby file an entry of appearance in the above-referenced proceeding.
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`
`
`Lead counsel on behalf of Samsung will be J. David Park, and we request that service be
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`made to his attention at the following address:
`
`
`
`
`
`
`
`
`
`J. David Park
`Arnold & Porter Kaye Scholer LLP
`601 Massachusetts Ave., NW
`Washington, DC 20001
`Tel: (202) 942-5646
`Email: david.park@apks.com
`
`
`Further, we hereby submit an application for disclosure of business proprietary
`
`information placed on the record under administrative protective order (“APO”) in the above-
`
`referenced proceeding.
`
`Arnold & Porter Kaye Scholer LLP
`601 Massachusetts Ave., NW | Washington, DC 20001-3743 | www.apks.com
`
`
`

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`June 12, 2017
`Page 2
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`
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`The application requests access to all business proprietary information under
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`administrative protective order for attorneys J. David Park, Fischer Fox Lynn, Henry D. Almond,
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`Daniel R. Wilson, Sylvia Y. Chen, and Kang Woo Lee.
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`
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`Samsung Electronics Co., Ltd. is a producer of large residential washers and Samsung
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`Electronics America, Inc. is a United States importer of large residential washers. Thus, each are
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`interested parties within the meaning of the Commission’s regulations.
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`*
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`*
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`*
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`*
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`*
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`
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`We are filing this submission today via the Commission’s EDIS system. Because the
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`Commission has not yet published a public service list in this investigation, in accordance with
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`19 C.F.R. § 207.3(b), we will serve this document on all parties when the Commission issues a
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`public service list in this investigation.
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`If you have any questions or desire any additional information, please feel free to contact
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`the undersigned.
`
`Respectfully submitted,
`
`
`
`
`
`/s/ J. David Park
`J. David Park
`Lynn Fischer Fox
`Henry D. Almond
`Daniel R. Wilson
`Sylvia Y. Chen
`Kang Woo Lee
`
`ARNOLD & PORTER KAYE SCHOLER LLP
`Counsel to Samsung
`
`
`
`
`
`

`

`AD/CVD
`APO Application
`Revised March 2005
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, DC 20436
`
`APPLICATION FOR DISCLOSURE OF
`BUSINESS PROPRIETARY INFORMATION
`UNDER ADMINISTRATIVE PROTECTIVE ORDER
`
` TA-201-076
`Inv. No(s).___________________________
`
`I. Authorized applicant status
`
`I, the undersigned, am an authorized applicant, as defined in section 207.7(a)(3) of the Commission's Rules of
`Practice and Procedure (19 C.F.R. §207.7(a)(3), as amended), for the disclosure of business proprietary information
`(BPI) under the administrative protective order (APO) issued in the above-captioned investigation. I represent the
`following interested party, as defined in 19 U.S.C. §1677(9), which is a party to the investigation:
`
`Samsung Electronics Co., Ltd. (producer) and Samsung Electronics America, Inc. (importer)
`____________________________________________________________________________________________
`(State the name of the interested party and its category, e.g., domestic producer, importer, etc.).
`
` I am (check one):
`( ) (1) An attorney, excepting in-house corporate counsel.
`
`✔
`
`( ) (2) An in-house corporate attorney. I am not involved in competitive decisionmaking for the
`interested party I represent. I have attached a written statement describing my job functions, disclosing all financial
`holdings I may have in my employer or its affiliates, and indicating whether I am involved in the formulation of my
`employer's pricing policies.
`
`( ) (3) A consultant or expert under the direction and control of an attorney under paragraph (1) or
`(2) above. That attorney has also signed this application to indicate that the attorney is held responsible for my
`compliance with the APO:
`
`_____________________________________________________________________________________
`(Name of Attorney--Please Print) (Signature of Attorney)
`
`( ) (4) A consultant or expert who appears regularly before the Commission and is not involved in
`competitive decisionmaking for the interested party I represent. I have attached a written statement listing my
`appearances before the Commission in the past three (3) years.
`
`( ) (5) A representative of an interested party that is not represented by counsel. I am not involved
`in competitive decisionmaking for that interested party. I have attached a written statement describing my job
`functions, disclosing all financial holdings I may have in the interested party I represent or its affiliates, and
`indicating whether I am involved in the formulation of the interested party's pricing policies.
`
`Competitive decisionmaking: As defined in section 207.7 of the Commission's rules, involvement in "competitive
`decisionmaking" includes past, present, or likely future activities, associations, and relationships with an interested
`party which is a party to the investigation that involve the prospective authorized applicant's advice or participation
`in any of such party's decisions made in light of similar or corresponding information about a competitor (pricing,
`product design, etc.).
`
`

`

`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`properly disclosed pursuant to section 207.7 of the Commission's rules, for the purpose ofrepresenting an interested
`party in the investigation and filing comments on the BPI so disclosed. I agree to be bound by the provisions of the
`APO and section 207. 7.
`
`III. Sanctions and other actions for breach of the APO
`
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`
`me to:
`
`( 1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`
`( 4) Such other administrative sanctions as the Commission determines to be appropriate, including public
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to business proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5) Such other actions, including but not limited to, a warning letter, as the Commission determines to be
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`
`_3_1 _ _ day of_M_a~y ____ _
`(month)
`
`2017
`(year)
`
`, in Washington, DC
`(ci
`
`.
`
`;r
`I ,,
`JDzU~Park
`
`Partner
`
`(Signature)
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`

`

`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`properly disclosed pursuant to section 207.7 of the Commission's rules, for the purpose of representing an interested
`party in the investigation and filing comments on the BPI so disclosed. I agree to be bound by the provisions of the
`APO and section 207.7.
`
`III. Sanctions and other actions for breach of the APO
`
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`
`meto:
`
`(1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`
`( 4) Such other administrative sanctions as the Commission determines to be appropriate, including public
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to business proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5) Such other actions, including but not limited to, a warning letter, as the Commission determines to be
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`
`_3_1 __ day of May (month) ____ 20_l_[y-e-a-r)-' ill WMhin~on, D?21f ~ ~
`~ ~nature)
`
`Lynn Fischer Fox
`
`Counsel
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`

`

`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`properly disclosed pursuant to section 207.7 of the Commission's rules, for the purpose ofrepresenting an interested
`party in the investigation and filing comments on the BPI so disclosed. I agree to be bound by the provisions of the
`APO and section 207.7.
`
`III. Sanctions and other actions for breach of the APO
`
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`
`meto:
`
`(1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`
`( 4) Such other administrative sanctions as the Commission determines to be appropriate, including public
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to business proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5) Such other actions, including but not limited to, a warning letter, as the Commission determines to be
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`
`_3_1 __ day of May ______ , _2_01_7 ___ , in Washington, DC
`(month)
`(year)
`(city, state)
`
`Henry D. Almond
`
`Associate
`
`(Signature)
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`

`

`I
`
`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`· properly disclosed pursuant to section 207. 7 of the Commission's rules, for the purpose of representing an interested
`party in the investigation and filing comments on the BPi so disclosed. I agree to be bound by the provisions of the
`APO and section 207. 7.
`
`III. Sanctions and other actions for breach of the APO
`
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`
`meto:
`
`(1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`
`( 4) Such other administrative sanctions as the· Commission determines to be appropriate, including public
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to btisiness proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5) Such other actions, including but not limited to, a warning letter, as the Commission determines to be
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`-~ - - - - -~ ____ _,
`day of May
`2017
`in Washington, DC
`(month)
`(year)
`
`31
`- - -
`
`(city, stat:) ~------- (Signature)
`
`Daniel R. Wilson
`
`Associate
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`

`

`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`properly disclosed pursuant to section 207. 7 of the Commission's rules, for the purpose of representing an interested
`party in the investigation and filing comments on the BPI so disclosed. I agree to be bound by the provisions of the
`APO and section 207. 7.
`
`III. Sanctions and other actions for breach of the APO
`-
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`I
`
`meto:
`
`(1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`·
`
`(4) Such other administrative sanctions as the Commission determines to be appropriate, including public
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to business proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5) Such other actions, including but not limited to, a warning letter, as the Commission determines to be
`·
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is .true and correct. Executed on this
`
`_31 __ day of_M~a~y _____ . 2017
`(month)
`(year)
`
`, in Washington, DC
`(city, state)
`
`Sylvia Y. Chen
`
`Staff Attorney
`
`(Signature)
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`

`

`II. Request for information
`
`I hereby apply for disclosure to me, subject to the APO issued in the above-captioned investigation, all BPI
`properly disclosed pursuant to section 207.7 of the Commission's rules, for the purpose ofrepresenting an interested
`party in the investigation and filing c9mments on the BPI so disclosed. I agree to be bound by the provisions of the
`APO and section 207, 7:
`
`III. Sanctions and other actions for breach of the APO
`
`I acknowledge that, pursuant to section 207.7(d) of the Commission's rules, breach of the APO may subject
`
`meto:
`
`(1) Disbarment from practice in any capacity before the Commission along with my partners, associates,
`employer, and employees, for up to seven years following publication of a determination that the other has been
`breached;
`
`(2) Referral to the United States Attorney;
`
`(3) In the case of an attorney, accountant, or other professional, referral to the ethics panel of the
`appropriate professional association;
`
`(4) Such other administrative sanctions as the Commission determines to be appropriate, including Pllblic
`release of or striking from the record any information or briefs submitted by, or on behalf of, me or the party I
`represent, denial of further access to business proprietary information in the current or any future investigations
`before the Commission, and issuance of a public or private letter of reprimand; and
`
`(5)Such other actions, including butnot limited to, a warning letter, as the Commission determines to be
`appropriate.
`
`IV. Oath
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
`
`_3_1 __ ·day of_M_a..e..y ____ _ __, 2017
`(month)
`(year)
`
`, in Washington, DC
`(city, sta
`
`Kang Woo Lee
`
`Staff Attorney
`
`(Signature)
`
`(Name--Please Print)
`
`(Title--Please Print)
`
`Arnold and Porter Kaye Scholer LLP
`(Firm--Please Print)
`
`