`
`
`
`
`
`
`May 13, 2019
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`
`WASHINGTON, D.C. 20436
`
`
`Mark L. Hogge, Esq.
`Dentons US LLP
`1900 K Street, NW
`Washington, DC 20006
`
`Louis S. Mastriani, Esq.
`Adduci Mastriani & Schaumberg LLP
`1133 Connecticut Avenue, NW
`Washington, DC 20036
`
`
`
`
`
`
`
`
`
`Re: Complaint of LG Chem, Ltd. and LG Chem Michigan
`Inc. Concerning Certain Lithium Ion Batteries, Battery
`Cells, Battery Modules, Battery Packs, Components
`Thereof, and Production and Testing Systems and
`Processes Therefor (Docket No. 3383)
`
`
`Dear Messrs. Hogge and Mastriani:
`
`Under Commission Rule 210.9 and 19 C.F.R. § 210.9, the Commission requests that
`
`counsel for Complainants submit evidence of at least one specific instance of “importation
`of articles…into the United Staets or in the sale of such articles by the owner, importer, or
`consignee…” (19 U.S.C. § 1337(a)(1)(A)) resulting from the alleged misappropriation of
`trade secrets by (1) SK Battery America, Inc. and (2) SK Battery Hungary Kft.
`
`If you are not able to provide this information by May 17, 2019, we respectfully
`
`request that you seek a postponement of the deadline by which the Commission must
`decide whether to institute a 337 investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`/s/Andrew Beverina
`
`Andrew Beverina
`Investigative Attorney
`Office of Unfair Import Investigations
`
`
`
`Complaint of LG Chem, Ltd. and LG Chem Michigan Inc. Concerning Certain Lithium
`Ion Batteries, Battery Cells, Battery Modules, Battery Packs, Components Thereof, and
`Production and Testing Systems and Processes Therefor
`(Docket No. 3383)
`
`
`
`Certificate of Service
`
`
`
`
`
`email: LGChem.US@dentons.com
`
`email: LGCHEM-001@adduci.com
`
`
`The undersigned certifies that on May 13, 2019, he caused the foregoing letter to be
`
`served upon the party in the manner indicated below:
`
`By email
`
`Mark L. Hogge, Esq.
`Dentons US LLP
`1900 K Street, NW
`Washington, DC 20006
`
`
`
`Louis S. Mastriani, Esq.
`Adduci Mastriani & Schaumberg LLP
`1133 Connecticut Avenue, NW
`Washington, DC 20036
`
`Counsel for Complainants LG Chem, Ltd. and LG Chem Michigan Inc.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`_/s/ Andrew Beverina_______
`Andrew Beverina
`Investigative Attorney
`OFFICE OF UNFAIR IMPORT
`INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`(202) 205-2077
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
