`
`
`
`Bert C. Reiser
`Direct Dial: +1.202-637-1026
`bert.reiser@lw.com
`
`
`
`
`
`
`
`October 27, 2020
`
`
`
`
`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
`
`
`
`Re:
`
`555 Eleventh Street, N.W., Suite 1000
`Washington, D.C. 20004-1304
`Tel: +1.202.637.2200 Fax: +1.202.637.2201
`www.lw.com
`
`FIRM / AFFILIATE OFFICES
`Beijing
`Moscow
`Boston
`Munich
`Brussels
`New York
`Century City
`Orange County
`Chicago
`Paris
`Dubai
`Riyadh
`Düsseldorf
`San Diego
`Frankfurt
`San Francisco
`Hamburg
`Seoul
`Hong Kong
`Shanghai
`Houston
`Silicon Valley
`London
`Singapore
`Los Angeles
`Tokyo
`Madrid
`Washington, D.C.
`Milan
`
`
`
`Certain Tobacco Heating Articles and Components Thereof,
`ITC Inv. No. 337-TA-1199
`
`
`
`
`
`
`
`Dear Secretary Barton:
`
`On behalf of Respondents Altria Client Services LLC, Altria Group, Inc., Philip Morris
`USA, Inc., Philip Morris International Inc., and Philip Morris Products S.A., enclosed please find
`Letter Agreeing to Abide by the Protective Order for Razi Safi of Latham & Watkins LLP.
`
`Respectfully submitted,
`
`/s/ Bert C. Reiser
`
`Bert C. Reiser
`of LATHAM & WATKINS LLP
`
`
`Enclosures
`cc:
`Service List
`
`
`
`
`
`
`
`
`
`Razi Safi
`Direct Dial: +1.202.637.2120
`razi.safi@lw.com
`
`
`
`
`
`
`
`October 27, 2020
`
`
`
`
`
`
`BY EDIS
`
`555 Eleventh Street, N.W., Suite 1000
`Washington, D.C. 20004-1304
`Tel: +1.202.637.2200 Fax: +1.202.637.2201
`www.lw.com
`
`FIRM / AFFILIATE OFFICES
`Beijing
`Moscow
`Boston
`Munich
`Brussels
`New York
`Century City
`Orange County
`Chicago
`Paris
`Dubai
`Riyadh
`Düsseldorf
`San Diego
`Frankfurt
`San Francisco
`Hamburg
`Seoul
`Hong Kong
`Shanghai
`Houston
`Silicon Valley
`London
`Singapore
`Los Angeles
`Tokyo
`Madrid
`Washington, D.C.
`Milan
`
`
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`
`
`Re:
`
`Certain Tobacco Heating Articles and Components Thereof,
`ITC Inv. No. 337-TA-1199
`
`
`
`
`
`
`
`Dear Secretary Barton:
`
`I am counsel to Respondents Altria Client Services LLC, Altria Group, Inc., Philip
`Morris USA, Inc., Philip Morris International Inc., and Philip Morris Products S.A. (collectively
`“Respondents”), in the above-referenced investigation. By this letter, I acknowledge that I have
`read and agree to the terms of the Protective Order (Order No. 1), issued by Judge Clark S.
`Cheney on May 15, 2020. Specifically, I agree:
`
`i.
`
`ii.
`
`iii.
`
`to be bound by the terms of the Protective Order;
`
`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 purposes of this
`investigation.
`
`I, the undersigned, on behalf of Respondents, acknowledge that information submitted for
`purposes of this investigation may be disclosed to and used:
`
`i.
`
`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
`
`
`
`
`
`The Honorable Lisa R. Barton
`October 27, 2020
`Page 2
`
`
`
`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
`
`ii.
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate
`nondisclosure agreements.
`
`Respectfully submitted,
`
`/s/ Razi Safi
`
`Razi Safi
`of LATHAM & WATKINS LLP
`
`
`Service List
`
`cc:
`
`
`
`
`
`337-TA-1199
`
`CERTIFICATE OF SERVICE
`
`It is hereby certified that copies of LETTER AGREEING TO ABIDE BY THE
`
`PROTECTIVE ORDER were served on October 27, 2020 as follows:
`
`
`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 Clark S. Cheney
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, DC 20436
`
`Sarah J. Sladic
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW, Room 401
`Washington, DC 20436
`
`David M. Maiorana
`JONES DAY
`901 Lakeside Avenue
`Cleveland, OH 44114
`
`On Behalf of Complainants RAI Strategic
`Holdings, Inc., R.J. Reynolds Vapor Company, and
`R.J. Reynolds Tobacco Company
`
`
`
`
`By EDIS
`
`By Email
`Cheney337@usitc.gov
`
`
`By Email
`sarah.sladic@usitc.gov
`
`
`By Email
`RJRITC1199@jonesday.com
`
`
`
`/s/ E. Alexander Cruz
`E. Alexander Cruz
`LATHAM & WATKINS LLP
`
`
`
`
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