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` January 25, 2022
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`VIA EDIS
`
`The Honorable Lisa Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`
`Re: In the Matter of Certain Flocked Swabs, Products Containing Flocked Swabs,
` and Methods of Using Same (Inv. No. 337-TA-1279)
`
`
`
`Dear Secretary Barton:
`
`Respondents Wuxi NEST Biotechnology Co., Ltd., NEST Scientific Inc., NEST
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`Scientific USA, Jiangsu Changfeng Medical Industry Co., Ltd., BioTeke Corporation (Wuxi)
`Co., Ltd., Miraclean Technology Co., Ltd. and Huachenyang (Shenzhen) Technology Co.,
`Ltd. (collectively, “Respondents”) enclose for filing Protective Order Subscriptions for
`Michelangelo Andolfo, a freelance interpreter, and Leah Willersdorf, Linda Fleet, and Wendy
`Viner of Planet Depos LLC
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`Enclosures
`cc:
`Per certificate of service
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`Respectfully submitted,
`
`/s/ Daniel E. Valencia
`Daniel E. Valencia
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`Attachment A
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`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`
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`I, ___________________________, do solemnly swear or affirm that I will not divulge
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`any information communicated to me in any confidential portion of the investigation or hearing
`
`in the matter of Certain_______, Investigation No. 337-TA-___, except as permitted in the
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`protective order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case.
`
`
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`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`
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`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`
`
`I am aware that the unauthorized use or conveyance of information as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`Signed __________________________________________________________________
`
`Dated ___________________________________________________________________
`
`Firm or affiliation _________________________________________________________
`
`- 10 -
`
`
`Flocked Swabs, et al.
`
`1279
`
`
`
`Attachment A
`
`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`I, ___________________________, do solemnly swear or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`
`protective order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case. in the matter of Certain Flocked Swabs , Products Containing Flocked Swabs, and
`
`Methods of Using Same, Investigation No. 337-TA-1279, except as permitted in the protective
`
`order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case.
`
`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`I am aware that the unauthorized use or conveyance of information as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`Signed _________________________________________________________________
`
`Dated __________________________________________________________________
`
`Firm or affiliation ______________________________________________
`
`Planet Depos LLC
`
`01.21.22
`
`Linda Fleet
`
`
`
`Attachment A
`
`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`I, ___________________________, do solemnly swear or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`
`protective order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case. in the matter of Certain Flocked Swabs , Products Containing Flocked Swabs, and
`
`Methods of Using Same, Investigation No. 337-TA-1279, except as permitted in the protective
`
`order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case.
`
`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`I am aware that the unauthorized use or conveyance of information as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`Signed _________________________________________________________________
`
`Dated __________________________________________________________________
`
`Firm or affiliation ______________________________________________
`
`Planet Depos LLC
`
`01.21.22
`
`Wendy Viner
`
`
`
`Attachment A
`
`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`I, ___________________________, do solemnly swear or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`
`protective order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case. in the matter of Certain Flocked Swabs , Products Containing Flocked Swabs, and
`
`Methods of Using Same, Investigation No. 337-TA-1279, except as permitted in the protective
`
`order issued in this case. I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case.
`
`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`I am aware that the unauthorized use or conveyance of information as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`Signed _________________________________________________________________
`
`Dated __________________________________________________________________
`
`Firm or affiliation ______________________________________________
`
`Planet Depos LLC
`
`January 20th, 2021
`
`Leah Willersdorf
`
`
`
`CERTIFICATE OF SERVICE
`I, Julie Romanow, hereby certify that on January 25, 2022 copies of the foregoing
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`AGREEMENT TO BE BOUND BY THE PROTECTIVE ORDER
`were served upon the following parties as indicated:
`
`The Honorable Lisa Barton, Secretary
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, D.C. 20436
`
`The Honorable Monica Bhattacharyya
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, D.C. 20436
`
`
`Edward Jou, Esq.
`Michael Maas, Esq
`Attorney Advisor
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Thomas Chen, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Daniel B. Weinger
`Mintz Levin Cohn Ferris
`Glovsky and Popeo PC
`Boston, MA 02111
`Telephone: 617-542-6000
`Facsimile: 617-542-2241
`Counsel to Complainants
`Copan Italia, S.p.A and Copan Industries, Inc.
`
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Filing (EDIS)
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Mail
`Bhattacharyya337@usitc.gov
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Mail
`Edward.Jou@usitc.gov
`Michael.Maas@usitc.gov
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Mail
`Thomas.Chen@usitc.gov
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Mail
`CopanITC@mintz.com
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`Adam D. Swain
`ALSTON & BIRD
`950 F Street NW
`Washington, DC 20004
`Telephone: (202) 239-3622
`Facsimile: (202) 654-4842
`Counsel for Respondent SLMP, LLC dba StatLab
`Medical Products
`
`☐ Via First Class mail
`☐ Via Hand Delivery
`☐ Via UPS Overnight
`☐ Via Facsimile
`☒ Via Electronic Mail
`StatLab-ITC-FlockOSwabs@alston.com
`
`/s/ Julie Romanow
`Julie Romanow
`Patent/ITC Case Manager
`COVINGTON & BURLING LLP
`3000 El Camino Real, 5 Palo Alto Sq.
`Palo Alto, CA 94306
`jromanow@cov.com | 650.632.4902
`
`
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