`
`
`
`June 13, 2017
`
`
`
`
`
`VIA EDIS
`
`The Honorable Lisa Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`
`
`
`Re:
`
`
`Certain Digital Television Set-Top Boxes, Remote Control Devices, and
`Components Thereof; ITC Inv. No. 337-TA-1041
`
`
`
`
`
`
`
`Dear Secretary Barton:
`
`Attached for filing on behalf of Complainants OpenTV, Inc., Nagra USA, Inc.,
`
`Nagravision SA, and Kudelski SA (collectively, “Kudelski” or “Complainants”), please find the
`Agreements to be bound by the Protective Order (Order No. 1), in the above referenced
`proceeding for Cheri Bennett and Michael Marinelli.
`
`
`Respectfully submitted,
`
`/s/ Alexander D. Chinoy
`Alexander D. Chinoy
`
`
`
`
`
`
`
`
`
`
`
`
`Enclosures
`
`
`
`cc:
`
`All Counsel of Record
`
`
`
`
`
`Covington 8c Burling LLP
`One CityCenter
`850 Tenth Street, NW
`Washington) DC 20001-4956
`T +1 202 662 6000
`
`June 19, 2017
`
`C O V I N G T 0 N
`
`BEIJING BRUSSELS
`LONDON LOS ANGELES
`NEW YORK SAN FRANCISCO SEOUL
`' SHANGHAI
`SILICON VALLEY WASHINGTON
`
`VIA EDIS
`
`The Honorable Lisa Barton
`
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`
`500 E Street, SW
`Washington, DC 20436
`
`Re:
`
`Certain Digital Television Set—Top Boxes, Remote Control Devices, and
`Components Thereof; ITC Inv. N0. 337—TA—1041
`
`Dear Secretary Barton:
`
`I am a contract attorney retained by Complainants OpenTV, Inc., Nagra USA, Inc.,
`Nagravision SA, and Kudelski SA (collectively, “Kudelski”) as counsel in the above
`referenced proceeding. By this letter, I acknowledge that I have read and agree to the terms
`of the Protective Order No. 1 issued on March 3, 2017, by Administrative Law Judge
`Theodore R. Essex. Specifically, I agree:
`
`(i)
`
`to be bound by the terms of the Protective Order;
`
`(ii)
`
`(iii)
`
`not to reveal confidential information to anyone other than another
`person designated in Paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for purposes
`of this investigation, unless permission is received from the supplier, or the
`Administrative Law Judge, or the Commission to use it for other purposes.
`
`I, the undersigned, on behalf of Kudelski, acknowledge that information submitted
`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 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
`
`
`
`C 0V I N G T O N
`The Honorable Lisa Barton
`
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`
`Page 2 of 2
`
`(ii)
`
`by US. government employees and contract personnel, solely for
`cybersecurity purposes. I understand that all contract personnel will sign
`appropriate nondisclosure agreements.
`
`
`
`Cheri Bennett
`
`
`
`
`
`Covington Sc Burling LLP
`One CityCenter
`850 Tenth Street, NW]
`Washington,
`T +1
`
`June 19, 2017
`
`C
`
`I N G T 0 N
`
`BEIJING BRUSSELS LONDON LOS ANGELES
`NEW YORK SAN FRANCISCO SEOUL
`SHANGHAI
`SILICON VALLEY WASHINGTON
`
`VIA EDIS
`
`The Honorable Lisa Barton
`
`Secretary tO the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`
`500 E Street, SW
`Washington, DC 20436
`
`Re:
`
`Certain Digital Television Set-Top Boxes, Remote Control Devices, and
`Comgonents Thereof; ITC an. NO. 337—TA—1041
`
`Dear Secretary Barton:
`
`1 am a contract attorney retained by Complainants OpenTV, Inc., Nagra USA, Inc.,
`Nagravision SA, and Kudelski SA (collectively, “Kudelski”) as counsel in the above
`referenced proceeding. By this letter, I acknowledge that l have read and agree tO the terms
`of the Protective Order NO. 1 issued on March 3, 2017, by Administrative Law Judge
`Theodore R. Essex. Specifically, I agree:
`
`(i)
`
`to be bound by the terms of the Protective Order;
`
`(ii)
`
`(iii)
`
`not to reveal confidential information to anyone other than another
`person designated in Paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for purposes
`of this investigation, unless permission is received from the supplier, or the
`Administrative law Judge, or the Commission to use it for other purposes.
`
`I, the undersigned, on behalf of Kudelski, acknowledge that information submitted
`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 internal investigations, audits, reviews, and evaluations relating to
`the programs, personnel, and Operations of the Commission including under
`
`
`
`C CV | N G TO N
`The Honorable Lisa Barton
`
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`
`Page 2 of 2
`
`5 U.S.C. Appendix 3; or
`
`(ii)
`
`by US. government employees and contract personnel, solely for
`cybersecurity purposes. I understand that all contract personnel will Sign
`appropriate nondisclosure agreements.
`
`Respectfully submitted,
`fl
`
`Michael Marinelli
`
`
`
`
`
`In the Matter of Certain Digital Television Set-Top Boxes,
`Remote Control Devices, and Components Thereof
`
`
`Investigation No. 337-TA-1041
`
`
`CERTIFICATE OF SERVICE
`
`
`Via EDIS
`
`
`
`Via hand delivery and E-mail:
`Benjamin.Richards@usitc.gov
`
`
`
`I, Danute D. Abrishami, certify that on June 19, 2017, copies of the foregoing
`
`AGREEMENTS TO BE BOUND BY THE PROTECTIVE ORDER were delivered,
`pursuant to U.S. International Trade Commission regulations, to the following interested parties
`as indicated:
`
`The Honorable Lisa Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`The Honorable Theodore R. Essex
`Administrative Law Judge
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW, Room 317
`Washington, DC 20436
`
`Cortney Hoecherl
`Investigative Attorneys
`Office of Unfair Imports Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW,
`Washington, DC 20436
`
`Joshua B. Pond
`KILPATRICK TOWNSEND & STOCKTON LLP
`607 14th Street, NW, Suite 900
`Washington, DC 20005
`
`
`
`
`Counsel for OUII
`
`
`
`
`Via E-mail: Cortney.Hoecherl@usitc.gov
`
`Barbara A. Murphy
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1899 L Street, NW, Suite 1150
`Washington, DC 20036
`
`
`
`
`Counsel for 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
`
`Via E-mail: ARRIS-OpenTV-337-TA-
`1041@kilpatricktownsend.com
`
`Counsel for Respondents Comcast
`Corporation, Comcast Cable
`Communications, LLC, Comcast Cable
`Communications Management, LLC, Comcast
`Business Communications, LLC and Comcast
`STB Software 1, LLC
`
`Via Email:
`FM-Comcast-1041@fostermurphy.com;
`KNOITC-KVP@KVN.com
`
`Certificate of Service
`Page 1
`
`
`
`Investigation No. 337-TA-1041
`
`
`In the Matter of Certain Digital Television Set-Top Boxes,
`Remote Control Devices, and Components Thereof
`
`Mark G. Davis
`GREENBERG TRAURIG, LLP
`2101 L Street, NW, Suite 1000
`Washington, DC 20037
`
`
`
`
`Counsel for Respondents Universal
`Electronics Inc., Gemstar Technology
`(China) Co. Ltd., Gemstar Technology
`(Qinzhou) Co. Ltd., and Gemstar
`Technology (Yangzhou) Co. Ltd.
`
`Via Email:
`UniversalITCAll@gtlaw.com
`
`
`
`
`
`/s/ Danute D. Abrishami
`Danute D. Abrishami
`Senior IP Litigation Specialist
`COVINGTON & BURLING LLP
`One CityCenter
`850 Tenth Street, NW
`Washington, DC 20001
`dabrishami@cov.com | 202.662.6573
`
`
`
`Certificate of Service
`Page 2
`
`
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