DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, California 94303-2250
`www.dlapiper.com
`
`Mark Fowler
`Mark.Fowler@us.dlapiper.com
`T 650.833.2048
`F 650.687.1166
`
`OUR FILE NO. 430938-000009
`
`June 21, 2022
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Barcode Scanners, Mobile Computers with Barcode Scanning
`Capabilities, Scan Engines, and Components Thereof
`Inv. No. 337-TA-1285
`
`Dear Secretary Barton:
`
`On behalf of Complainants Honeywell International Inc., Hand Held Products, Inc., and Metrologic
`Instruments, Inc., in the above-referenced proceeding, enclosed please find the Agreement to be Bound
`by the Protective Order and Attachment A – Nondisclosure Agreement for Reporter/Stenographer/
`Translator of James Skelly and Attachment A of Abe Ortega of Blueprint Trial Consulting.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Mark Fowler
`
`Mark Fowler
`
`Enclosures
`
`cc:
`
`Service list as attached.
`
`EAST\193046510.1
`
`
`2000 University Avenue
`East Palo Alto, California 94303-2250
`www.dlapiper.com
`
`Mark Fowler
`Mark.Fowler@us.dlapiper.com
`T 650.833.2048
`F 650.687.1166
`
`OUR FILE NO. 430938-000009
`
`June 21, 2022
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Barcode Scanners, Mobile Computers with Barcode Scanning
`Capabilities, Scan Engines, and Components Thereof
`Inv. No. 337-TA-1285
`
`Dear Secretary Barton:
`
`On behalf of Complainants Honeywell International Inc., Hand Held Products, Inc., and Metrologic
`Instruments, Inc., in the above-referenced proceeding, enclosed please find the Agreement to be Bound
`by the Protective Order and Attachment A – Nondisclosure Agreement for Reporter/Stenographer/
`Translator of James Skelly and Attachment A of Abe Ortega of Blueprint Trial Consulting.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Mark Fowler
`
`Mark Fowler
`
`Enclosures
`
`cc:
`
`Service list as attached.
`
`EAST\193046510.1
`
`
`
`James W.Skelly
`James.W.Skelly@gmail.com
`
`June 17, 2022
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Barcode Scanners, Mobile Computers with Barcode Scanning
`Capabilities, Scan Engines, and Components Thereof
`Inv. No. 337-TA-1285
`
`Dear Secretary Barton:
`
`| have beenretained to serve as an expert by DLA Piper LLP (US), counsel for Complainants Honeywell
`International Inc., Hand Held Products, Inc., and Metrologic Instruments Inc. Please be advised that |
`have read Order No. 1: Protective Order issued by Administrative Law Judge Monica Bhattacharyya on
`November 1, 2021, and in accordanceto that order, hereby agree:
`
`a.
`
`b.
`
`Cc.
`
`to be boundby the terms thereof;
`
`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 the purposesofthis
`investigation.
`
`|, the undersigned, acknowledgethat information submitted for purposesofthis Investigation may be
`disclosed to and used:
`
`(i)
`
`(ii)
`
`by the Commission, its employees and Offices, and contract personnel(a) for
`developing or maintaining the recordsofthis 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
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes.
`| understandthat all contract personnel will sign appropriate nondisclosure
`agreements.
`
`
`
`The Honorable Lisa R. Barton
`June 17, 2022
`Page Two
`
`Respectfully submitted,
`
`Zi,Hii
`
`James W.Skelly
`
`cc:
`
`Servicelist as attached.
`
`
`
`Attachment A
`
`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`, do solemnly swearoraffirm that I will not divulge
`Jamu okelly
`I,
`any information communicated to mein any confidential portion of the investigation or hearing
`Barcode Scanners
`, Investigation No. 337-TA-1285 except as permitted in the
`
`in the matter of Certain
`
`protective order issued in this case.
`
`I will notdirectly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with myofficial 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 hearingin this case.
`
`I also affirm that I do not hold any position or official relationship with any of the
`
`participants in said investigation.
`
`1 am aware that the unauthorized use or conveyance of informationas specified aboveis
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonmentofup to ten (10) years, or both.
`
`Signed fh Bella
`
`
`
`6/Ze/ 2222
`Dated
`OO—
`Firm oraffiliation
`
`
`
`-10-
`
`
`
`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
`Barcode Scanners
`1285
`in the matter of Certain_______, Investigation No. 337-TA-___, 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 _________________________________________________________
`
`- 10 -
`
`06/16/22
`
`Blueprint Trial Consulting
`
`Abe Ortega
`
`
`
`CERTIFICATE OF SERVICE
`
`I, Laurie E. Ouchida, hereby certify that on June 21, 2022, a copy of the foregoing was filed and
`served on the following as indicated:
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`The Honorable Monica Bhattacharyya
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Ted Jou
`Michael Maas
`Email:
`edward.jou@usitc.gov
`michael.maas@usitc.gov
`Bhattacharyya337@usitc.gov
`
`Counsel for Respondents Zebra Technologies
`Corporation and Symbol Technologies, Inc.:
`
`S. Alex Lasher
`Quinn Emanuel Urquhart & Sullivan LLP
`1300 I Street, N.W., Suite 900
`Washington, D.C. 20005
`Email:
`alexlasher@quinnemanuel.com
`Zebra-Honeywell-ITC-1285@quinnemanuel.com
`
` Via EDIS
`
` Via EDIS
` Via Electronic Mail
`
` Via Electronic Mail
`
` /s/ Laurie E. Ouchida
`
`Laurie E. Ouchida
`Case Manager
`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303
`Telephone: 650-833-2000
`
`1
`
`
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