`
`
`
`Michael A. David
`Direct Dial: +1.212.906.2968
`Michael.David@lw.com
`
`
`
`
`
`
`January 26, 2021
`
`
`
`
`
`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:
`
`53rd at Third
`885 Third Avenue
`New York, New York 10022-4834
`Tel: +1.212.906.1200 Fax: +1.212.751.4864
`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 Vehicle Control Systems, Vehicles containing the same, and
`Components Thereof, ITC Inv. No. 337-TA-1235
`
`
`
`
`
`Dear Secretary Barton:
`
`On behalf of Complainants Jaguar Land Rover Limited and Jaguar Land Rover North
`America, LLC (collectively, “JLR” or “Complainants”), enclosed please find the Letter Agreeing
`to Abide by the Protective Order for expert Stephen D. Prowse.
`
`Respectfully submitted,
`
`/s/Michael A. David
`
`Michael A. David
`of LATHAM & WATKINS LLP
`
`
`Enclosures
`cc:
`Service List
`
`
`
`
`
`
`
`
`FTI Consulting
`
`2001 Ross Avenue
`Suite 650
`Dallas, TX 75201
`
`214.397.1600 telephone
`214.397.1784 facsimile
`
`www.fticonsulting.com
`
`
`
`
`
`
`January 26, 2021
`
`
`
`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:
`
`Certain Vehicle Control Systems, Vehicles containing the same, and
`Components Thereof, ITC Inv. No. 337-TA-1235
`
`
`Dear Secretary Barton:
`
`I am an expert retained by counsel to Complainants Jaguar Land Rover Limited and
`Jaguar Land Rover North America, LLC (collectively, “JLR” or “Complainants”), 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 MaryJoan McNamara on December 23,
`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 Complainants, 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
`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
`
`
`
`
`
`2001 Ross Avenue | Suite 650 | Dallas, Texas 75201
`214.397.1600 | fticonsulting.com
`
`
`
`
`
`
`The Hon. Lisa R. Barton
`January 26, 2021
`Page 2
`
`
`
`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,
`
`
`Stephen D. Prowse
`
`
`
`
`Service List
`
`cc:
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`337-TA-1235
`
`By EDIS
`
`By Email:
`McNamara337@usitc.gov
`Michael.Nullet@usitc.gov
`Jae.Lee@usitc.gov
`
`
`By Email:
`VW-JLR@sternekessler.com
`VWGroup-Haug.ITC@Haugpartners.com
`
`
`
`It is hereby certified that copies of LETTER AGREEING TO ABIDE BY THE
`PROTECTIVE ORDER were served on January 26, 2021 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 MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, DC 20436
`
`Daniel E. Yonan
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, NW
`Washington, D.C. 20005
`
`Counsel for Respondents Porsche AG, Porsche Cars
`North America, Inc., Volkswagen AG, Volkswagen
`Group of America, Inc., Automobili Lamborghini
`S.p.A, Automobili Lamborghini America, LLC, Audi
`AG, and Audi of America, LLC
`
`
`
`
`
`
`/s/ E. Alexander Cruz
`E. Alexander Cruz
`LATHAM & WATKINS LLP
`
`
`
`
`
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