`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before The Honorable Dee Lord
`Administrative Law Judge
`
`
`In the Matter of
`
`CERTAIN MICROFLUIDIC SYSTEMS
`AND COMPONENTS THEREOF AND
`PRODUCTS CONTAINING SAME
`
`
`
`Investigation No. 337-TA-1100
`
`
`JOINT MOTION FOR LEAVE TO FILE PUBLIC VERSIONS OF THE PARTIES’ PRE-
`TRIAL FILINGS ON DECEMBER 28, 2018
`
`Ground Rule 3.2 Certification
`
`Complainant 10X Genomics, Inc. (“10X”) and Respondent Bio-Rad Laboratories, Inc.
`
`(“Bio-Rad”) hereby jointly seek leave to file certain pre-trial submission out of time. The parties
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`have met-and-conferred regarding this extension, and counsel for Bio-Rad confirmed with Mr.
`
`Jou that this motion for an extension of time may be filed today, December 21, 2018, seeking the
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`relief requested. The Staff does not oppose this motion.
`
`Order No. 6 provides that the parties must submit public versions of any confidential
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`filings within five (5) business days from the date of the original filing. See Order No. 6
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`(amending Ground Rule 1.9). Likewise, the parties are required to file public versions of their
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`Pre-Trial Briefs and Pre-Trial Statements within ten (10) business days. In this Investigation, the
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`parties’ public versions of their respective Pre-Trial Statements, Pre-Trial Briefs, Motions In
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`Limine, and High Priority Objections and all corresponding exhibits (collectively, the parties’
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`“Pre-Trial Filings”) are due on the same day – December 21, 2018. See Order No. 4.
`
`In addition to these deadlines, the parties’ respective Oppositions to High Priority
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`Objections and Motions In Limine are also due today, December 21, 2018. Id. Despite diligent
`
`JOINT MOTION FOR LEAVE TO FILE PUBLIC
`VERSIONS OF PRE-TRIAL FILINGS ON DEC. 28, 2018
`
`1
`
`INV. NO. 337-TA-1100
`
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`
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`efforts, the parties have been unable to thoroughly review the public submissions that are due
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`today, given the volume of those submissions and the limited support available due to holiday
`
`staffing. Therefore, the parties respectfully request an extension of time to file the public
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`versions of their Pre-Trial Filings until December 28, 2015, after the upcoming holiday.
`
`Good cause exists to grant the parties’ motion, because it is in the interests of all parties
`
`and the Commission that public filings be carefully vetted to avoid inadvertent disclosure of
`
`confidential business information. For the foregoing reasons, the parties respectfully request that
`
`this Motion for an extension be granted.
`
`
`
`JOINT MOTION FOR LEAVE TO FILE PUBLIC
`VERSIONS OF PRE-TRIAL FILINGS ON DEC. 28, 2018
`
`
`2
`
`INV. NO. 337-TA-1100
`
`
`
`
`
`
`
` Respectfully submitted,
`
`
` /s/ Sean Gloth
` Alex Lasher
`Jeffrey Gerchick
`Ethan Glass
`Sean Gloth
`Quinn Emanuel Urquhart & Sullivan, LLP
`1300 I Street NW, Suite 900
`Washington, DC 20002
`Tel.: (202) 538-8000
`
`David Bilsker
`Quinn Emanuel Urquhart & Sullivan, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Tel.: (415) 875-6432
`
`Kevin P.B. Johnson
`Victoria Maroulis
`Brian Cannon
`Quinn Emanuel Urquhart & Sullivan, LLP
`555 Twin Dolphin Dr., 5th Floor
`Redwood Shores, CA 94065
`Tel.: (650) 801-5015
`
`Anne S. Toker
`Sky C. Adams
`Nathan Sun
`Quinn Emanuel Urquhart & Sullivan, LLP
`51 Madison Ave, 22nd Floor
`New York, NY 10010
`Tel: (212) 849-7000
`
`Jeffrey Ung
`Quinn Emanuel Urquhart & Sullivan, LLP
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017
`Tel: (213) 443-3045
`
`Counsel for Respondent Bio-Rad
`Laboratories, Inc.
`
`
`
`
`
`Utsav Gupta
`
`
`
`Dated: December 21, 2018
`
`/s/
`
`Matthew D. Powers
`Paul T. Ehrlich
`Azra M. Hadzimehmedovic
`Aaron M. Nathan
`Stefani C. Smith
`Robert L. Gerrity
`Samantha A. Jameson
`Jennifer K. Robinson
`Yi Chen
`Gina Cremona
`Utsav Gupta
`Daniel M. Radke
`TENSEGRITY LAW GROUP, LLP
`555 Twin Dolphin Drive, Suite 650
`Redwood Shores, CA 94065
`Telephone:
`(650) 802-6000
`Facsimile:
`(650) 802-6001
`Email:
`10x_tlg_service@tensegritylawgroup.com
`
`Nicholas Groombridge
`Jennifer H. Wu
`Josephine Young
`Jennifer Rea Deneault
`PAUL, WEISS, RIFKIND,
` WHARTON & GARRISON LLP
`1285 Avenue of the Americas
`New York, New York 10019
`(212) 373-3000 (telephone)
`(212) 757-3990 (facsimile)
`ngroombridge@paulweiss.com
`jwu@paulweiss.com
`jyoung@paulweiss.com
`jdeneault@paulweiss.com
`
`David J. Ball
`Megan F. Raymond
`PAUL, WEISS, RIFKIND,
` WHARTON & GARRISON LLP
`2001 K Street, NW
`Washington, DC 20006
`(202) 223-7300 (telephone)
`
`JOINT MOTION FOR LEAVE TO FILE PUBLIC
`VERSIONS OF PRE-TRIAL FILINGS ON DEC. 28, 2018
`
`
`3
`
`INV. NO. 337-TA-1100
`
`
`
`
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`(202) 223-7420 (facsimile)
`dball@paulweiss.com
`mraymond@paulweiss.com
`
`
`Attorneys for Complainant,
`10X Genomics, Inc.
`
`
`
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`
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`JOINT MOTION FOR LEAVE TO FILE PUBLIC
`VERSIONS OF PRE-TRIAL FILINGS ON DEC. 28, 2018
`
`
`4
`
`INV. NO. 337-TA-1100
`
`
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`CERTAIN MICROFLUIDIC SYSTEMS AND COMPONENTS THEREOF AND
`PRODUCTS CONTAINING SAME
`
`Inv. No. 337-TA-1100
`
`
`
`CERTIFICATE OF SERVICE
`
`
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`I, Stephanie Sandoval, hereby certify that on December 21, 2018, copies of the foregoing
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`documents were served upon the following parties as indicated:
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`
`The Honorable Dee Lord
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, D.C. 20436
`Email: edward.jou@usitc.gov
`
`Monica Bhattacharyya
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`Email: Monica.Bhattacharyya@usitc.gov
`
`Paul T. Ehrlich
`Tensegrity Law Group LLP
`555 Twin Dolphin Drive, Suite 650
`Redwood Shores, CA 94061
`
`Email: 10x_tlg_service@tensegritylawgroup.com
`
`Counsel for Complainants, 10X Genomics, Inc.
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` Via First Class Mail
` Via Hand Delivery (2 copies)
` Via Electronic Mail
` Via EDIS
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` Via First Class Mail
` Via Hand Delivery (2 copies)
` Via Express Delivery
` Via Electronic Mail
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` Via First Class Mail
` Via Hand Delivery
` Via Express Delivery
` Via Electronic Mail
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` Via First Class Mail
` Via Hand Delivery
` Via Express Delivery
` Via Electronic Mail
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`/s/ Stephanie Sandoval
`Stephanie Sandoval
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