UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`Washington, D.C.
`
`In the Matter of
`
`CERTAIN DIGITAL TELEVISION SET-
`TOP BOXES, REMOTE CONTROL DEVICES,
`AND COMPONENTS THEREOF
`
`INV. NO. 337-TA-1041
`
`ORDER NO. 1=
`
`PROTECTIVE ORDER
`
`_
`
`(March 3, 2017)
`
`WHEREAS, documents and information may be sought, produced or exhibited by and among
`
`the parties to the above captioned proceeding, which materials relate to trade secrets or other
`
`confidential research, development or commercial information, as such terms are used in the
`
`Commission's Rules, 19 C.F.R. § 210.5;
`
`IT IS HEREBY ORDERED THAT:
`
`1. Confidential business information is information which concerns or relates to the trade
`
`secrets, processes, operations, style of work, or apparatus, or to the production, sales, shipments,
`
`purchases, transfers, identification of customers, inventories, amount or source of any income,
`
`profits,
`
`losses, or expenditures of any person, firm, partnership, corporation, or other
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`organization, or other infonnation of commercial value, the disclosure of which is likely to have
`
`the effect of either (i) impairing the Commission's ability to obtain such information as is
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`necessary to perform its statutory functions; or (ii) causing substantial harm to the competitive
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`position of the person, firm, partnership, corporation, or other organization from which the
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`information was obtained, unless the Commission is required by law to disclose such
`
`

`

`information. The term “confidential business information” includes “proprietary information”
`
`within the meaning of section 777(b) of the Tariff Act of 1930 (19 U.S.C. § l677f(b)).
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`2(a). Any information submitted, in pre hearing discovery or in a pleading, motion, or
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`response to a motion either voluntarily or pursuant to order, in this investigation, which is
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`asserted by a supplier to contain or constitute confidential business information shall be so
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`designated by such supplier in Writing, or orally at a deposition,’conference or hearing, and shall
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`be segregated from other information being submitted. Documents shall be clearly and
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`prominently marked on their
`
`face with the -legend:
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`"CONFIDENTIAL BUSINESS
`
`INFORMATION, SUBJECT TO PROTECTIVE ORDER," or a comparable notice.
`
`Such
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`information, whether submitted in Writing or in oral testimony, shall be treated in accordance
`
`with the terms of this protective order.
`
`(b). The Administrative Law Judge or the Commission may determine that information
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`alleged to be confidential is not confidential, or that its disclosure is necessary for the proper
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`disposition of the proceeding, before, during or after the close of a hearing herein.
`
`If such a
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`detemiination is made by the Administrative Law Judge or the Commission, opportunity shall be
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`provided to the supplier of such infonnation to argue its confidentiality prior to the time of such
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`ruling.’
`
`.3. In the absence of written permission from the supplier or an order by the Commission
`
`or the Administrative Law Judge, any confidential documents or business information submitted
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`in accordance with the provisions of paragraph 2 above shall not be disclosed to any person other
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`than:
`
`(i) outside counsel for parties to this investigation, including necessary secretarial and
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`support personnel assisting such counsel; (ii) qualified persons taking testimony involving such
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`documents or information and necessary stenographic and clerical personnel
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`thereof;
`
`(iii)
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`

`

`7
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`technical experts and their staffwho are employed for the purposes of this litigation (unless they
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`are otherwise employed by, consultants to, or otherwise affiliated with a non-governmental
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`party, or are employees of any domestic or foreign manufacturer, wholesaler, retailer, or
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`distributor of
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`the products, devices or component parts whichi are the subject of
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`this
`
`investigation); (iv) the Commission, the Administrative Law Judge, the Commission staff, and
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`personnel of any governmental agency as authorized by the Commission; (v) the Commission, its
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`employees and Offices, and contract personnel (a) for developing or maintaining the records of
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`this investigation or related proceedings, or (b) in internal
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`investigations, audits, reviews,
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`evaluations relating to the programs, personnel, and operations of the Commission including
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`under to 5 U.S.C. Appendix 3; and (vi) U.S. government employees and contract personnel,
`
`solely for cybersecurity purposes]
`
`V
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`4. Confidential business information submitted in accordance with the provisions of
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`paragraph 2 above shall not be made available to any person designated in paragraph 3(i)2 and
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`(iii) unless he or she shall have first read this order and shall have agreed, by letter filed with the
`
`Secretary of this Commission:
`
`(i) to be‘ bound by the terms thereof; (ii) not to reveal such
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`confidential business information to anyone other than another person designated in paragraph 3;
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`and (iii) to utilize such confidential business information solely for purposes of this investigation.
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`The letter shall also include the following acknowledgement:
`
`, acknowledge that information submitted
`I, the undersigned, on behalf of
`for purposes of this Investigation may be disclosed to and used: '
`
`(i) by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`intemal investigations, audits, reviews, and evaluations relating to the programs,
`
`1See Commission Administrative Order I6-OI (Nov. 7, 2015).
`2Necessary secretarial and support personnel assisting counsel need not sign onto the protective order themselves
`because they are covered by counsel’s signing onto the protective order.
`
`

`

`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`solely for
`and contract personnel,
`employees
`(ii) by U.S. government
`cybersecurity purposes.
`I understand that all contract personnel will
`sign
`appropriate nondisclosure agreements.
`p
`
`5. If the Commission or the Administrative Law Judge orders, or if the supplier and all
`
`parties to the investigation agree, that access to, or dissemination of information submitted as
`
`confidential business infonnation shall be made to persons not included in paragraph 3 above,
`
`such matter shall only be accessible to, or disseminated to, such persons based upon the
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`conditions pertaining to, and obligations arising from this order, and such persons shall be
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`considered subject to it, unless the Commission or the Administrative Law Judge finds that the
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`information is not confidential business information as defined in paragraph 1 thereof.
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`6.
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`(a). Any confidential business information submitted to the Commission or the
`
`Administrative Law Judge in connection with a motion or other proceeding within the purview
`
`of this investigation shall be submitted under seal pursuant to paragraph 2 above. Any portion of
`
`a transcript
`
`in connection with this
`
`investigation containing "any confidential business
`
`information submitted pursuant to paragraph 2 above shall be bound separately and filed under
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`seal. When any confidential business information submitted in accordance with paragraph 2
`
`above is included in an authorized transcript of a deposition or exhibits thereto, arrangements
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`shall be made with the court reporter taking the deposition to bind such confidential portions and
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`separately label
`
`them "CONFIDENTIAL BUSINESS INFORMATION, SUBJECT TO
`
`PROTECTIVE ORDER." Before a court reporter or translator receives any such information, he
`
`or she shall have first read this order and shall have agreed in writing to be bound by the terms
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`thereof. Altematively, he or she shall sign the agreement included as Attachment A hereto.
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`

`

`Copies of each such signed agreement shall be provided to the supplier of such confidential
`
`business information and the Secretary of the Commission.
`
`(b).
`
`Submittersi are strongly encouraged to encrypt nonpublic documents that are
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`electronically transmitted to the Commission to protect your sensitive information from
`
`unauthorized disclosure. The USITC secure drop-box system and the Electronic Document
`
`Information System (EDIS) use Federal
`
`Information Processing Standards (FIPS) 140-2
`
`cryptographic algorithms to encrypt data in transit. Submitting your nonpublic documents by a
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`means that does not use these encryption algorithms (such as by email) may subject your firm’s
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`nonpublic infonnation to unauthorized disclosure during transmission. If you choose a non­
`
`encrypted method of electronic transmission, the Commission warns you that the risk of such
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`possible Lmauthorizeddisclosure is assumed by you and not by the-Commission.
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`7. The restrictions upon, and obligations accruing to, persons who become subject to this
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`order shall not apply to any information submitted in accordance with paragraph 2 above to
`
`which the person asserting the confidential status thereof agrees in writing, or the Commission or
`
`the Administrative Law Judge rules, after an opportunity for hearing, was publicly known at the
`
`time it was supplied to the receiving party or has since become publicly known through no fault
`
`of the receiving party.
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`8. The Commission, the Administrative Law Judge,‘ and the Commission investigative
`
`attorney acknowledge that any document or information submitted as confidential business
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`information pursuant to paragraph 2 above is to be treated as such within the meaning of 5
`
`U.S.C. § 552(b)(4) and 18 U.S.C. § 1905, subject to a contrary ruling, after hearing, by the
`
`Commission or its Freedom of lnformation Act Officer, or the Administrative Law Judge. When
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`3“Submitters” of confidential business information are the same as “suppliers” of confidential business information
`as that term is used in the context of this order. See Commission Administrative Order 16-01 (Nov. 7, 2015).
`
`

`

`such information is made part of a pleading or is offered into the evidentiary record, the data set
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`forth in 19 C.F.R. § 201.6 must be provided except during the time that the proceeding is
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`pending before the Administrative Law Judge. During that
`
`time,
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`the party offering the
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`confidential business information must, upon request, provide a statement as to the claimed basis
`
`for its confidentiality.
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`9. Unless a designation of confidentiality has been withdrawn, or a determination has
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`been made by the Commission or the Administrative Law Judge that information designated as
`
`confidential, is no longer confidential, the Commission, the Administrative Law Judge, and the
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`Commission investigative attorney shall take all necessary and proper steps to preserve the
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`confidentiality of, and to protect each supplier's rights with respect to, any confidential business
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`information designated by the supplier in accordance with paragraph 2 above, including, without
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`limitation:
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`(a) notifying the supplier promptly of (i) any inquiry or request by anyone for the
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`substance of or access to such confidential business infonnation, other than those authorized
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`pursuant to this order, under the Freedom of Information Act, as amended (5 U.S.C. § 552) and
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`(ii) any proposal to redesignate or make public any such confidential business information; and
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`(b) providing the supplier at least seven days after receipt of such inquiry or request within which
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`to take action before the Commission,
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`its Freedom of Infonnation Act Officer, or the
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`Administrative Law Judge, or otherwise to preserve the confidentiality of and to protect its rights
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`in, and to, such confidential business infonnation.
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`10. If while an investigation is before the Administrative Law Judge, a party to this order
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`who is to be a recipient of any business infonnation designated as confidential and submitted in
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`accordance with paragraph 2 disagrees with respect to such a designation, in full or in part, it
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`shall notify the supplier in writing, and they will thereupon confer as to the status of the subject
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`

`

`information proffered within the context of this order.
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`If prior to, or at the time of such a
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`conference, the supplier withdraws its designation of such information as being subject to this
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`order, but nonetheless submits such information for purposes of the investigation; such supplier
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`shall express the withdrawal,
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`in Writing, and serve such withdrawal upon all parties and the
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`Administrative Law Judge.
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`If the recipient and supplier are unable to concur upon the status of
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`the subject information submitted as confidential business information within ten days from the
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`date of notification of such disagreement, any party to this order may raise the issue of the
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`designation of such a status to the Administrative Law Judge who will rule upon the matter. The
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`Administrative Law Judge may sua sponte question the designation of the confidential status of
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`any information and, after opportunity for hearing, may remove the confidentiality designation.
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`ll. No less than 10 days (or any other period of time designated by the Administrative
`
`Law Judge) prior to the initial disclosure to a proposed expert of any confidential information
`
`submitted in accordance with paragraph 2, the party proposing to use such expert shall submit in
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`writing the name of such proposed expert and his or her educational and detailed employment
`
`history to the supplier.
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`If the supplier objects to the disclosure of such confidential business
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`information to such proposed expert as inconsistent with the language or intent of this order or
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`on other grounds, it shall notify the recipient in writing of its objection and the grounds therefore
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`prior to the initial disclosure.
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`If the dispute is not resolved on an informal basis within ten days
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`of receipt of such notice of objections, the supplier shall submit immediately each objection to
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`the Administrative Law Judge for a ruling.
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`If the investigation is before the Commission the
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`matter shall be submitted to the Commission for resolution. The submission of such confidential
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`business information to such proposed expert shall be withheld pending the ruling of the
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`Commission or the Administrative Law Judge. The terms of this paragraph shall be inapplicable
`
`

`

`to experts within the Commission or to experts from other governmental agencies who are
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`consulted with or used by the Commission.
`
`_‘
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`12.
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`If confidential business infonnation submitted in accordance with paragraph 2 is
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`disclosed to any person other than in the manner authorized by this protective order, the party
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`responsible for the disclosure must
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`immediately bring all pertinent facts relating to such
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`disclosure to the attention of the supplier and the Administrative Law Judge and, without
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`prejudice to other rights and remedies of the supplier, make every effort to prevent further
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`disclosure by it or by the person who was the recipient of such infonnation.
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`13. Nothing in this order shall abridge the right of any person to seek judicial review or
`
`to pursue other appropriate judicial_action with respect to any ruling made by the Commission,
`
`its Freedom of Information Act Officer, or the Administrative Law Judge concerning the issue of
`
`the status of confidential business information.
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`14. Upon final termination of this investigation, each recipient of confidential business
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`information that is subject to this order shall assemble and return to the supplier all items
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`containing such information submitted in accordance with paragraph 2 above, including all
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`copies of such matter which may have been made. Alternatively, the parties subject to this order
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`may, with the written consent of the supplier, destroy all items containing confidential business
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`information and certify to the supplier (or his counsel) that such destruction has taken place.
`
`This paragraph shall not apply to the Commission, including its investigative attomey, and the
`
`Administrative Law Judge, which shall retain such material pursuant to statutory requirements
`
`and for other recordkeeping purposes, but may destroy those additional copies in its possession
`
`which it regards as surplusage.
`
`

`

`Notwithstanding the above paragraph, confidential business information may be
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`transmitted to a district court pursuant to Commission Rule 210.5(0).
`
`15.
`
`If any confidential business infonnation which is supplied in accordance with
`
`paragraph 2 above is supplied by a nonparty to this investigation, such a nonparty shall be
`
`considered a "supplier" as that term is used in the context of this order.
`
`'
`
`16. Each nonparty supplier shall be provided a copy of this order by the party seeking
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`information from said supplier.
`
`i’
`
`17. The Secretary shall serve a copy of this order upon all parties.
`
`4
`
`Theodore R. Essex '
`Administrative Law Judge
`
`

`

`Attachment A
`
`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`I,
`
`, do solemnly swear or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`
`in the matter of Certain Digital Television Set-Top Boxes, Remote Control Devices, and
`
`Components Thereof Investigation No. 337-TA-1041, except as pennitted in the protective order
`
`issued in this case. I will not directly or indirectly use, or allow the use of such infonnation for
`
`any purpose other than that directly associated with my official duties in this case.
`
`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`'
`
`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`'
`
`l
`
`I am aware that the unauthorized use or conveyance of infonnation as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`'
`
`Signed
`
`Dated
`
`Finn or affiliation
`
`

`

`'
`O
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`
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`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, DC 20436
`
`ADMINISTRATIVE ORDER: 16-01
`
`DATE: November 7, 2015
`
`SUBJECT: Acknowledgement and Disclaimer Provisions Regarding Disclosure of Confidential
`Business Information or Business Proprietary Information
`
`1. PURPOSE: This order establishes procedures for Commission personnel to follow in using
`acknowledgement and disclaimer provisions regarding the cybersecurity-related disclosure of
`confidential business information (CB1) or business proprietary information (BPI). The
`statutes governing CB1 and BPI generally prohibit the Commission from disclosing CBI and
`BPI to persons outside certain classes of individuals for certain purposes without the consent
`of the information’s submitter. The acknowledgement provision is designed to seek consent
`to permit disclosure to certain other classes of persons for other specified purposes, including
`cybersecurity purposes, while complying with statutory requirements. The disclaimer
`provision is also designed to urge the submission of nonpublic documents using encrypted
`methods and notify the submitter that it assumes the risk of unauthorized disclosure if a non­
`encrypted method is used.
`
`2. REFERENCES
`
`'
`
`a. Statutes imposing restrictions on the disclosure of CBI and BPI, including 18 U.S.C. §
`1905; 19 U.S.C. §§ l332(g), 1337(n), 1677f(b)(1)(A).
`
`b. Section 201.6 of the Commission’s Rules of Practice and Procedures (19 C.F.R. § 201.6).
`
`3. ACKNOWLEDGEMENT AND DISCLAIMER PROVISIONS
`
`a. The acknowledgement provision reads as follows:
`
`I, the undersigned, acknowledge that information submitted in response to this request for
`information and throughout this investigation or other proceeding may be disclosed to
`and used:
`
`

`

`(i) by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in internal
`investigations, audits, reviews, and evaluations relating to the programs, personnel, and
`operations of the Commission including under 5 U.S.C. Appendix 3; or
`(ii) by U.S. govermnent employees and contract personnel, solely for cybersecurity
`purposes; I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`The disclaimer"provision reads as follows:
`
`Submitters are strongly encouraged to encrypt nonpublic documents that are
`electronically transmitted to the Commission to protect your sensitive information fron1
`unauthorized disclosure. The USITC secure drop-box system and the Electronic
`Doctunent Information System (EDIS) use Federal Information Processing Standards
`(FIPS) 140-2 cryptographic algorithms to encrypt data in transit. Submitting your
`nonpublic documents by a means that does not use these encryption algorithms (such as
`by email) may subject your firm’s nonpublic information to unauthorized disclosure
`during transmission. If you choose a non-encrypted method of electronic transmission,
`the Commission warns you that the risk of such possible unauthorized disclosure is
`assumed by you and not by the Commission.
`
`The acknowledgement and disclaimer provisions must he included in all protective orders
`issued in section 337 proceedings and in all Commission requests for CBI or ‘BPI,
`I
`including:
`
`i.
`
`ii.
`
`in questionnaires and instruction booklets, as appropriate, in import injury
`investigations and reviews and in industry and economic analysis
`proceedings; and
`in protective orders issued in section 337 proceedings, and in any other
`appropriate mechanisms for submission of CBI to be determined by the
`Commission’s Administrative Law Judges.
`_
`
`In the acknowledgement provision, the phrase “internal investigations, audits, revicws,
`and evaluations relating to the programs, personnel, and operations of the Commission”
`does not include statutory Commission proceedings (viz, proceedings under our statutory
`authorities, such as 19 U.S.C. §§ 1332, 1337, 2252, and Title VII of the Tariff Act of
`1930 (19 U.S.C. §§ l3()3, 1516A, 1671-l677n)).
`
`The acknowledgement provision does not permit CBI 01‘BPIsubmitted in a statutory
`Commission proceeding to be disclosed or used in any other proceeding, with two
`exceptions. In the case of proceedings under Title VII of the Tariff Act of 1930, the
`Commission and its investigative staff may use BPI in other proceedings involving the
`same or similar merchandise pursuant to the authorization in the questionnaire form. In
`the case of proceedings under section 337 of the Tariff Act of 1930, use of CB1or BPI is
`permitted in related proceedings as defined in Commission Rule 210.3.
`,
`
`­
`­
`

`

`e.
`
`In the acknowledgement provision, the phrase “cybersecurity purposes” means “detecting,
`preventing, analyzing, investigating, responding to, and reporting on eyber vulnerabilities,
`misconfigurations or inappropriate permissions on networks, or known or suspected
`malicious cyber activity.”
`
`f. Protective orders in section 337 proceedings also must include a statement that third party
`suppliers of CB1 should be given a copy of the protective order.
`
`This order supersedes Administrative Order 97-06 and remains in effect until superseded or
`rescinded.
`~
`
`Bvyorder of the Chairman:
`
`
`
`747“ 4<»‘=*»\»-/t.'£»<mLo~q’"
`
`Meredith M. Broadbent
`
`/
`
`

`

`CERTAIN DIGITAL TELEVISION SET-TOP BOXES,
`REMOTE CONTROL DEVICES, AND COMPONENTS
`THEREOF
`
`Inv. No. 337-TA-1041
`
`.
`
`PUBLIC CERTIFICATE OF SERVICE
`
`1, Lisa R. Barton, hereby certify that the attached ORDER NO. 1 has been served by
`hand upon the Commission Investigative Attomey, Courtney Hoecherl, and the following parties
`as indicated, on 3/3/2017
`
`On Behalf of Complainants:
`
`Alexander D. Chinoy, Esq.
`COVINGTON & BURLING LLP
`One CityCenter
`850 Tenth Street, NW
`Washington, DC 20001
`
`Lisa R. Barton, Secretary
`U.S. lntemational Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
`
`III Via Hand Delivery
`CI Via Express Delivery
`IE’Via First Class Mail
`|:\ Other:
`
`On Behalf of Respondents ARRIS International plc. ARRIS Group, Inc.. ARRIS
`Technology, Inc., ARRIS Enterprises LLC. ARRIS Solutions. Inc.. ARRIS Global Ltd.,
`Pace Americas. LLC. and Pace USA, LLC:
`
`Joshua B. Pond, Esq.
`KILPATRICK TOVVNSEND
`& STOCKTON LLP
`607 14"‘Street NW, Suite 900
`Washington, DC 20005
`
`Respondents:
`
`Comcast Corporation
`One Comcast Center
`1701 John F. Kennedy Boulevard
`Philadelphia, PA 19103
`
`'
`
`Comcast Cable Communications, LLC
`One Comcast Center
`1701 John F. Kennedy Boulevard
`Philadelphia, PA 19103
`
`III Via Hand Delivery
`II] Via Express Delivery
`IZ Via First Class Mail
`III Other:
`
`I1 Via Hand Delivery
`1:1Via Express Delivery
`E2’Via First Class Mail
`E] Other:
`
`l:| Via Hand Delivery
`U Via Express Delivery
`@'Via First Class Mail
`El Other:
`
`

`

`CERTAIN DIGITAL TELEVISION SET-TOP BOXES,
`REMOTE CONTROL DEVICES, AND COMPONENTS
`THEREOF
`Certificate of Service —Page -2
`‘
`Comcast Cable Communications Management , LLC
`One Comcast Center
`1701 John F. Kemedy Boulevard
`Philadelphia, PA 19103
`
`Comcast Business Communications, LLC
`One Comcast Center
`1701 John F. Kennedy Boulevard
`Philadelphia, PA 19103
`
`Comcast STB Software I, LLC
`1201 N. Market Street, Suite 1000
`Wilmington, DE 19801
`
`Universal Electronics Inc.
`201 E Sandpointe Avenue,
`Santa Ana, CA 92707
`
`Gemstar Technology (China) Co. Ltd.
`Gemstar Industrial Park, No. 45, Zhong’Er Section
`Shinguang Road, Guangzhuou
`51 1495 China
`
`Gemstar Technology (Qinzhou) Co. Ltd.
`Hedong Industrial Park
`Qinzhou, Guangxi Province,
`535000 China
`
`Gemstar Technology (Yangzhou) Co. Ltd.
`1 Junshen Road Industry Park
`Fanshui Industrial Zone, Baoying,
`Yanzhou, 225800 China
`
`1
`
`Inv. N0. 337-TA 1041
`
`1:1Via Hand Delivery
`1:1Via Express Delivery
`B Via First Class Mail
`1:1 Other:
`
`U Via Hand Delivery
`U Via Express Delivery
`12 Via First Class Mail
`1] Other:
`
`III Via Hand Delivery
`III Via Express Delivery
`El Via First Class Mail
`III Other:
`
`|:l Via Hand Delivery
`|:l Via Express Delivery
`El Via First Class Mail
`1:1 Other:
`
`1:1Via Hand Delivery
`1:1Via Express Delivery
`[Z Via First Class Mail
`l:| Other:
`l
`
`Cl Via Hand Delivery
`E] Via Express Delivery
`E’Via First Class Mail
`El Other:
`
`.
`
`1:1Via Hand Delivery
`U Via Express Dclivcry
`El'Via First Class Mail
`Cl Other:
`
`