`
`SIDLEY AUSTIN LLP
`1501 K STREET, N.W.
`WASHINGTON, D.C. 20005
`+1 202 736 8000
`+1 202 736 8711 FAX
`
`
`AMERICA • ASIA PACIFIC • EUROPE
`
`
`
`
`
`
`
`MFRANZINGER@SIDLEY.COM
`+1 202 736 8583
`
`August 31, 2018
`
`
`
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`Re:
`
`Certain Memory Modules and Components Thereof:
`Inv. No. 337-TA-1089
`
`
`
`Dear Secretary Barton:
`
`Enclosed please find for filing, in the above-referenced investigation, the Protective
`Order Subscription of Kevin Murphy on behalf of Respondents SK hynix Inc., SK hynix
`America Inc. and SK hynix memory solutions Inc.
`
`Very truly yours,
`
`/s/ Michael R. Franzinger
`
`Michael R. Franzinger
`
`
`
`
`
`
`
`
`Sidley Austin (DC) LLP is a Delaware limited liability partnership doing business as Sidley Austin LLP and practicing in affiliation with other Sidley Austin partnerships.
`
`
`
`August 31, 2018
`
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`Re: Certain Memory Modules and Components Thereof
` Inv. No. 337-TA-1089
`
`Dear Secretary Barton:
`
`I, Dr. Kevin Murphy, have been retained as an expert by Respondents SK hynix Inc., SK
`hynix America Inc. and SK hynix memory solutions Inc. I have read the Protective Order, Order
`No. 1 and the Amending Protective Order, Order No. 3, in the above-captioned Investigation,
`and hereby agree:
`
`
`To be bound by the terms of thereof;
`
`(1)
`
`(2)
`
`
`
`(3)
`
`
`
`
`(ii)
`
`I, the undersigned, on behalf of Respondents SK hynix Inc., SK hynix America Inc. and
`SK hynix memory solutions Inc., acknowledge that information submitted in response to this
`request for information and throughout this investigation or other proceedings may be disclosed
`to and used:
`
`(i)
`
`Not to reveal such confidential business information to anyone other than
`another person designated in Paragraph 3; and
`
`To utilize such confidential business information solely for the purposes of
`this Investigation.
`
`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 5 U.S.C. Appendix 3; or
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate
`nondisclosure agreements.
`
`
`
`
`
`
`
`
`
`
`The Honorable Lisa R. Barton
`August 31, 2018
`Page 2
`
`
`
`Very truly yours,
`
`
`
`
`
`
`Dr. Kevin Murphy
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that copies of the foregoing PROTECTIVE ORDER SUBSCRIPTION
`
`OF KEVIN MURPHY were served on the following parties this 31st day of August, 2018 in
`
`the manner indicated below:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
`
`The Honorable Thomas B. Pender
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW
`Washington, DC 20436
`
`Monisha Deka
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`
`James M. Wodarski
`Mintz, Levin, Cohn, Ferris, Glovsky and
`Popep, P.C.
`One Financial Center
`Boston, MA 02111
`
`Counsel for Complainant Netlist, Inc.
`
`
`
`VIA EDIS
`
`VIA ELECTRONIC MAIL
`michael.turner@usitc.gov
`
`VIA ELECTRONIC MAIL
`monisha.deka@usitc.gov
`
`VIA ELECTRONIC MAIL
`Netlist-itc-1089@mintz.com
`
`
`
`
`
`
`
`
`
`
` /s/ Michael R. Franzinger
`Michael R. Franzinger
`Counsel for Respondents
`
`
`
`
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