`1501 K STREET, N.W.
`WASHINGTON, D.C. 20005
`+1 202 736 8000
`+1 202 736 8711 FAX
`
`AMERICA • ASIA PACIFIC • EUROPE
`
`February 5, 2021
`
`+1 202 736 8583
`MFRANZINGER@SIDLEY.COM
`
`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:
`Same: Inv. No. 337-TA-1089
`
`Dear Secretary Barton:
`
`Enclosed please find for filing, in the above-referenced investigation, Protective Order
`Subscriptions of Phillip M. Aurentz on behalf of Respondents SK hynix Inc., SK hynix
`America Inc. and SK hynix memory solutions Inc.
`
`We are filing the attached Protective Order Subscription due to parallel litigations that
`are ongoing in Western District of Texas, Case Nos. 6:20-cv-00194 and 6:20-cv-00525. The
`parties have a cross use agreement for their ITC materials and Mr. Aurentz is signing on to
`the protective order in abundance of caution.
`
`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.
`
`
`
`SIDLEY AUSTIN LLP
`2021 MCKINNEY AVENUE SUITE 2000
`DALLAS, TEXAS 75201
`+1 214 981 3300
`+1 214 981 3400 FAX
`
`AMERICA • ASIA PACIFIC • EUROPE
`
`February 5, 2021
`
`+1 212 981 3399
`PAURENTZ@SIDLEY.COM
`
`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:
`Same: Inv. No. 337-TA-1089
`
`Dear Secretary Barton:
`
`I confirm, as counsel representing Respondents SK hynix Inc., SK hynix America Inc.
`and SK hynix memory solutions Inc., that I have read the Protective Order, Order No. 1 and the
`Amending Protective Order No. 3, in the above-captioned Investigation, and agree,
`
`1.
`
`2.
`
`3.
`
`To be bound by the terms of thereof;
`
`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.
`
`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)
`
`(ii)
`
`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.
`
`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.
`
`
`
`Page 2
`
`Very truly yours,
`
`/s/ Phillip M. Aurentz
`
`Phillip M. Aurentz
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`PROTECTIVE ORDER OF PHILLIP M. AURENTZ were served on the following paiiies
`
`I hereby ce1iify that copies of the foregoing SUBSCRIPTION TO THE
`
`
`
`
`
`
`
`
`
`
`
`this 5th day of Febiary, 2021 in the manner indicated below:
`
`The Honorable Lisa R. Bruton
`
`
`Secretaiy to the Commission
`
`U.S. International Trade Commission
`
`500 E Street, SW, Room 112
`
`Washington, DC 20436
`
`VIA EDIS
`
`VIA ELECTRONIC MAIL
`
`The Honorable Chai·les E. Bullock
`
`
`
`Chief Administrative Law Judge
`
`
`Inichael. turner@usitc.gov
`
`U.S. International Trade Commission
`
`500 E Street, SW
`
`Washington, DC 20436
`
`Monisha Deka
`
`VIA ELECTRONIC MAIL
`Office of Unfair Import Investigations
`
`
`monisha.deka@usitc.gov
`
`U.S. International Trade Commission
`
`500 E Street, S.W., Suite 401
`
`Washington, D.C. 20436
`
`Mintz, Levin, Cohn, Fenis, Glovsky and
`
`James M. Wodai·ski
`
`
`
`
`Popep, P.C.
`One Financial Center
`
`Boston, MA 02111
`
`VIA ELECTRONIC MAIL
`
`Netlist-itc-1089@Inintz.com
`
`
`
`Counsel for Complainant Netlist, Inc.
`
`
`
`
`
`Isl Zachary Pierce
`Zachary Pierce
`Paralegal
`
`
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