`
`
`
`February 25, 2022
`
`Kate Saxton
`
`+1 617 526 6253 (t)
`+1 617 526 5000 (f)
`kate.saxton@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`Enclosed for filing in the above-referenced investigation are Agreements to be Bound by
`the Protective Order of Tasha Bahal, Scott Bertulli, Heath Brooks, Annaleigh Curtis, Jean
`Dassie, Peter Dichiara, Michael Esch, Reshma Gogineni, Joseph Haag, Benjamin Ho, Brian
`Jacobsmeyer, Shangxing (Simon) Lu, George Manley, Joseph Mueller, Stephanie Neely, Richard
`O’Neill, Alix Pisani, Kate Saxton, Mark Selwyn, Chelsea Simpson, Timothy Syrett, Phillip
`Takhar, Khoa Tran, and Brittany Warren.
`
`
`Copies of this submission are being served on the Administrative Law Judge and all
`parties to the investigation, as provided in the attached certificate of service.
`
`
`Please contact the undersigned should you have any questions regarding this matter.
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Kate Saxton
`
`Kate Saxton
`
`
`
`
`
`
`
`
`Tasha J. Bahal
`
`+1 617 526 6106 (t)
`+1 617 526 5000 (f)
`tasha.bahal@wilmerhale.com
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity,
`and Smart Watches with cellular Connectivity, Components Thereof, and
`Products Containing Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation. By this
`letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`The Honorable Lisa R. Barton
`February 25, 2022
`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.
`
`
`
`Sincerely,y,
`
`Tasha J. Bahal
`
`
`
`
`
`
`
`February 25, 2022
`
`Scott Bertulli
`
`+1 617 526 6767 (t)
`+1 617 526 5000 (f)
`scott.bertulli@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`
`I, the undersigned, on behalf of Apple, acknowledge that information submitted for
`
`purposes of this Investigation may be disclosed to and used:
`
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`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
`
`(i)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`Page 2
`
`
`
`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/ Scott Bertulli
`
`Scott Bertulli
`
`
`(ii)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Heath A. Brooks
`
`+1 202 663 6973 (t)
`+1 202 663 6363 (f)
`heath.brooks@wilmerhale.com
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`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.
`
`Sincerely,
`
`(cid:18)(cid:86)(cid:18)(cid:3)(cid:43)(cid:72)(cid:68)(cid:87)(cid:75)(cid:3)(cid:36)(cid:17)(cid:3)(cid:37)(cid:85)(cid:82)(cid:82)(cid:78)(cid:86)(cid:3)
`
`Heath A. Brooks
`
`
`
`
`
`
`
`February 25, 2022
`
`Annaleigh E. Curtis
`
`
`+1 212 230 8800 (t)
`+1 212 230 8888 (f)
`annaleigh.curtis@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`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/ Annaleigh E. Curtis
`
`Annaleigh E. Curtis
`
`
`
`February 25, 2022
`Page 2
`
`
`
`(ii)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`
`Jean Dassie
`
`+1 212 230 8877 (t)
`+1 212 230 8888 (f)
`jean.dassie@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`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,
`
`/s/ Jean Dassie
`
`Jean Dassie
`
`
`
`
`
`
`
`February 25, 2022
`
`Peter M. Dichiara
`
`+1 617 526 6466 (t)
`+1 617 526 5000 (f)
`peter.dichiara@wilmerhale.com
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`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.
`
`Sincerely,
`
`/s/ Peter M. Dichiara
`
`Peter M. Dichiara
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Michael D. Esch
`
`+1 202 663 6420 (t)
`+1 202 663 6363 (f)
`michael.esch@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`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,
`
`/s/ Michael D. Esch
`
`Michael D. Esch
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Reshma C. Gogineni
`
`+1 212 937 6301
`reshma.gogineni@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`To be bound by the terms of the Protective Order;
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`Page 2
`
`
`
`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/ Reshma C. Gogineni
`
`Reshma C. Gogineni
`
`
`(ii)
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`
`Joseph F. Haag
`
`+1 650 858 6032 (t)
`+1 650 858 6100 (f)
`joseph.haag@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`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/ Joseph F. Haag
`
`Joseph F. Haag
`
`
`(ii)
`
`
`
`
`
`Page 2
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Benjamin Ho
`
`+1 650 858 6066
`ben.ho@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`To be bound by the terms of the Protective Order;
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`Activ eUS 1 9 3 8 1 0 2 8 5 v .1
`
`
`
`February 25, 2022
`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,
`p
`y
`
`Benjamin Ho
`B j
`i H
`
`Activ eUS 1 9 3 8 1 0 2 8 5 v .1
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Brian Jacobsmeyer
`
`+1 720 274 3166 (t)
`Brian.jacobsmeyer@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`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,
`
`/s/ Brian Jacobsmeyer
`
`Brian Jacobsmeyer
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Shangxing (Simon) Lu
`
`+1 202 663 6430 (t)
`+1 202 663 6363 (f)
`Simon.lu@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`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,
`
`/s/ Shangxing Lu
`
`Shangxing Lu
`
`
`
`
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E. Street, S.W.
`Washington, D.C. 20436
`
`George F Manley
`
`+1 617 526 6111 (t)
`+1 617 526 5000 (f)
`george.manley@wilmerhale.com
`
`Re: Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing Same,
`Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`The Honorable Lisa R. Barton
`February 25, 2022
`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,
`
`/s/ George F. Manley
`
`George F. Manley
`
`
`
`
`
`
`
`
`2
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Joseph J. Mueller
`
`+1 617 526 6396 (t)
`+1 617 526 5000 (f)
`joseph.mueller@wilmerhale.com
`
`Re:
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`February 25, 2022
`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,
`
`/s/ Joseph J. Mueller
`
`Joseph J. Mueller
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Stephanie T. Neely
`
`+1 617 526 6742 (t)
`+1 617 526 5000 (f)
`stephanie.neely@wilmerhale.com
`
`Re:
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`To be bound by the terms of the Protective Order;
`
`Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`February 25, 2022
`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,
`
`/s/ Stephanie Neely
`
`Stephanie T. Neely
`
`
`
`
`
`
`
`February 25, 2022
`
`Richard W. O'Neill
`
`+1 617 526 6497 (t)
`+1 617 526 5000 (f)
`richard.o'neill@wilmerhale.com
`
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`
`Re:
`
`
`
` Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued by
`Administrative Law Judge Shaw in this investigation on February 23, 2022 (the “Protective
`Order”), and hereby agree:
`
`
`To be bound by the terms of the Protective Order;
`
`(1)
`
`(2) Not to reveal any confidential business information (as the term is defined in the
`Protective Order) to anyone other than another person designated in paragraph 3
`of the Protective Order; and
`
`
`(3)
`
`To utilize such confidential business information solely for purposes of this
`Investigation.
`
`
`I, the undersigned, on behalf of Apple, 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
`
`
`
`
`
`
`
`
`
`
`February 25, 2022
`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,(cid:3)
`
`(cid:18)s(cid:18)(cid:3)Richard W. O’Neill(cid:3)
`
`Richard W. O’Neill
`
`
`
`February 25, 2022
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Alix Pisani
`
`+1 213 443 5444 (t)
`+1 213 443 5400 (f)
`alix.pisani@wilmerhale.com
`
`Re:
`
`Certain Mobile Telephones, Tablet Computers with Cellular Connectivity, and Smart
`Watches with Cellular Connectivity, Components Thereof, and Products Containing
`Same, Inv. No. 337-TA-1299
`
`Dear Secretary Barton:
`
`I am counsel for Respondent Apple Inc. (“Apple”) in the above-referenced investigation.
`By this letter, I acknowledge that I have read the Protective Order (Order No. 1) issued
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