`
`655 Fifteenth Street, N.W.
`Washington, D.C. 20005
`United States
`
`+1 202 879 5000
`
`www.kirkland.com
`
`November 27, 2018
`
`
`
`
`
`Paul F. Brinkman, P.C.
`To Call Writer Directly:
`+1 202 879 5033
`paul.brinkman@kirkland.com
`
`
`
`By EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`
`
`
`Facsimile:
`+1 202 879 5200
`
`
`
`Re:
`
`In the Matter of Certain LTE- and 3G- Complaint Cellular
`Communications Devices, ITC Investigation No. 337-TA-1138
`
`Dear Secretary Barton:
`
`Enclosed for filing, please find subscriptions to the Protective Order for Paul Meyer, an
`expert/consultant for Respondent Apple Inc. in the above-referenced Investigation, and for Brian
`Badala, Bruce Service, Jacob Weniz, Max Roberts, and William Leitsch, who are members of
`Mr. Meyer’s staff.
`
`If you have questions or concerns, please feel free to call me.
`
`Respectfully submitted,
`
`/s/ Paul F. Brinkman, P.C.
`
`Paul F. Brinkman, P.C.
`
`
`Beijing Boston Chicago Dallas Hong Kong Houston
`
`
`London
`
`Los Angeles Munich New York Palo Alto San Francisco Shanghai
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain LTE— and 3G- Complaint Cellular
`Communications Devices, ITC Investigation No. 337-TA—1l38
`
`Dear Secretary Barton:
`
`I was retained as an expert for Respondent Apple Inc. in the above—referenced
`Investigation. By this letter, I acknowledge that I have read the Protective Order (Order No. l)
`issued by Administrative Law Judge MaryJoan McNamara in this investigation on October 19,
`2018 (the “Protective Order”), and, in accordance with paragraph 4 of the protective order,
`hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`
`
`KIRKLAND & ELLIS LLP
`
`The Honorable Lisa R. Barton
`
`November 13, 2018
`Page 2
`
`2. by US government employees and contract personnel, solely for cybersecurity
`purposes.
`I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`Paul K. MeyerW
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain LTE— and 3 G- Complaint Cellular
`Communications Devices, ITC Investigation No. 337—TA-1138
`
`Dear Secretary Barton:
`
`I am on the staff of Paul K. Meyer, who was retained as an expert for Respondent Apple
`Inc. in the above—referenced Investigation. By this letter, I acknowledge that I have read the
`Protective Order (Order No. l) issued by Administrative Law Judge MaryJoan McNamara in this
`investigation on October 19, 2018 (the “Protective Order”), and, in accordance with paragraph 4
`of the protective order, hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`
`
`KIRKLAND & ELLIS LLP
`
`The Honorable Lisa R. Baiton
`
`November 13, 2018
`Page 2
`
`2. by US. government employees and contract personnel, solely for cybersecurity
`purposes.
`I understand that all contract personnel will Sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`WW
`Brian Badala
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain LTE— and 3 G— Complaint Cellular
`Communications Devices, ITC Investigation No. 337-TA—1138
`
`Dear Secretary Barton:
`
`I am on the staff of Paul K. Meyer, who was retained as an expert for Respondent Apple
`Inc. in the above-referenced Investigation. By this letter, I acknowledge that I have read the
`Protective Order (Order No. 1) issued by Administrative Law Judge MaryJoan McNamara in this
`investigation on October 19, 2018 (the “Protective Order”), and, in accordance with paragraph 4
`of the protective order, hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`
`
`KIRKLAND & ELLIS LLP
`
`The Honorable Lisa R. Barton
`
`November 13, 2018
`
`Page 2
`
`2. by US. government employees and contract personnel, solely for cybersecurity
`purposes.
`I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`AA
`
`
`
`Bruce Service
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter ofCertain LTE— ana7 3 G- Complaint Cellular
`Communications Devices, ITC Investigation No. 337-TA—1138
`
`Dear Secretary Barton:
`
`I am on the staff of Paul K. Meyer, who was retained as an expert for Respondent Apple
`Inc. in the above-referenced Investigation. By this letter, I acknowledge that I have read the
`Protective Order (Order No. l) issued by Administrative Law Judge MaryJoan McNamara in this
`investigation on October 19, 2018 (the “Protective Order”), and, in accordance with paragraph 4
`of the protective order, hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`Beijing Boston Dallas Hong Kong Houston London LosAngeIes Munich NewYork PaioAito San Francisco Shanghai Washington, DC.
`
`
`
`KIRKLAND & ELLIS LLP
`
`The Honorable Lisa R. Barton
`
`November 13, 2018
`
`Page 2
`
`2. by US. government employees and contract personnel, solely for cybersecurity
`purposes.
`I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`
`
`4/7
`
`Ja ob Weniz
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain LTE— and 3 G- Complaint Cellular
`Communications Devices, ITC Investigation No. 337-TA—1 138
`
`Dear Secretary Barton:
`
`I am on the staff of Paul K. Meyer, who was retained as an expert for Respondent Apple
`Inc. in the above—referenced Investigation. By this letter, I acknowledge that I have read the
`Protective Order (Order No. l) issued by Administrative Law Judge MaryJoan McNamara in this
`investigation on October 19, 2018 (the “Protective Order”), and, in accordance with paragraph 4
`of the protective order, hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`
`
`KIRKLAND & ELLlS LLP
`
`The Honorable Lisa R. Barton
`
`November 13, 2018
`Page 2
`
`2. by US. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`
`
`Max Ro
`
`rts
`
`
`
`November 13, 2018
`
`The Honorable Lisa R. Barton
`
`Secretary to the Commission
`US. International Trade Commission
`
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain LTE— and 3G— Complaint Cellular
`Communications Devices, ITC Investigation No. 337—TA-1138
`
`Dear Secretary Barton:
`
`I am on the staff of Paul K. Meyer, who was retained as an expert for Respondent Apple
`Inc. in the above—referenced Investigation. By this letter, I acknowledge that I have read the
`Protective Order (Order No. 1) issued by Administrative Law Judge MaryJoan McNamara in this
`investigation on October 19, 2018 (the “Protective Order”), and, in accordance with paragraph 4
`of the protective order, hereby agree:
`
`1. To be bound by the terms of the Protective Order;
`
`2. Not to reveal confidential information (as the term is defined in the Protective Order)
`to anyone other than another person designated in paragraph 3 of the Order; and
`
`3. To utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, acknowledge that
`information submitted for purposes of this Investigation may be disclosed and used:
`
`1. 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
`
`
`
`KIRKLAND & ELLIS LLP
`
`The Honorable Lisa R. Barton
`
`November 13, 2018
`
`Page 2
`
`2. by US. government employees and contract personnel, solely for cybersecurity
`purposes.
`I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`WA
`
`William Leitsch
`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`In the Matter of Certain LTE- and 3G-Compliant Cellular Communications Devices
`Inv. No. 337-TA-1138
`
`CERTIFICATE OF SERVICE
`
`I, Robert P. Leonard, hereby certify that on November 27, 2018, copies of the foregoing
`document were filed and served upon the following parties as indicated:
`
`
`
`
`
`
`
`
`
`
`
`Via Electronic Filing(EDIS)
`Via Hand Delivery
`Via Federal Express
`Via Electronic Mail
`Via EDIS
`Via Hand Delivery
`Via Federal Express (2 copies)
`Via Electronic Mail
`
`Lisa R. Barton, Secretary
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`Hon. MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`jae.lee@usitc.gov
`Michael.Buckler@usitc.gov
`
`Reginald Lucas, Esq.
`Vu Bui, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, DC 20436
`
`reginald.lucas@usitc.gov
`vu.bui@usitc.gov
`
`On Behalf of Complainant INVT SPE LLC
`Bryan J. Vogel
`
`ROBINS & KAPLAN LLP
`
`199 Park Avenue, Suite 3600
`
`New York, NY 10022
`
`
`RK_INVT_ITC@RobinsKaplan.com
`
`On Behalf of Respondents HTC Corporation and HTC America, Inc.
`Stephen S. Kornicky
`
`Via EDIS
`Sheppard, Mullin, Richter & Hampton LLP
`
`Via Hand Delivery
`12275 El Camino Real, Suite 200
`
`Via Federal Express
`
`
`
`
`
`Via EDIS
`Via Hand Delivery
`Via Federal Express
`Via Electronic Mail
`
`
`
`
`
`
`
`
`Via EDIS
`Via Hand Delivery
`Via Federal Express
`Via Electronic Mail
`
`
`
`
`
`
`
`
`
`
`
`Via Electronic Mail
`
`San Digeo, California 92130
`
`LegalTm-HTC-INVT-ITC@sheppardmullin.com
`
`On Behalf of Respondents ZTE Corporation and ZTE (USA) Inc.
`
`Via EDIS
`Jay H. Reiziss
`
`Via Hand Delivery
`McDermott Will & Emery LLP
`
`Via Federal Express
`500 North Capitol Street, NW
`
`Via Electronic Mail
`Washington, DC 20001
`
`ZTEINVT@mwe.com
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Robert P. Leonard
`Robert P. Leonard
`
`
`
`
`2
`
`
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