UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`
`In the Matter of
`
`CERTAIN SEMICONDUCTOR DEVICES
`HAVING LAYERED DUMMY FILL,
`ELECTRONIC DEVICES, AND
`COMPONENTS THEREOF
`
`
`
`
`
`
`Investigation No. 337-TA-1342
`
`
`
`JOINT STIPULATION REGARDING PUBLIC INTEREST BETWEEN
`COMPLAINANT AND OMNIVISION TECHNOLOGIES, INC.
`
`Complainant Bell Semiconductor, LLC (“Bell Semic” or “Complainant”) and Respondent
`
`Omnivision Technologies, Inc. (“Omnivision”) (together, “the parties”) agree that this stipulation
`
`is limited to the issue of public interest and cannot be used for any other purpose in this or any
`
`other investigation. The parties agree and jointly stipulate as follows:
`
`1.
`
`The parties agree that the remedial orders sought by Complainant in this
`
`investigation would not have any adverse impact on the public interest.
`
`2.
`
`Omnivision does not contend that the remedial orders sought in this investigation
`
`would have an adverse impact on public health and welfare, competitive conditions, production
`
`of like or directly competitive articles in the United States, or on U.S. consumers.
`
`3.
`
`Omnivision hereby withdraws its Sixth Affirmative Defense set forth in the
`
`Response of Omnivision to the Complaint and Notice of Investigation, and its response to
`
`Complainant’s Interrogatory No. 17.
`
`
`WASHINGTON, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`
`In the Matter of
`
`CERTAIN SEMICONDUCTOR DEVICES
`HAVING LAYERED DUMMY FILL,
`ELECTRONIC DEVICES, AND
`COMPONENTS THEREOF
`
`
`
`
`
`
`Investigation No. 337-TA-1342
`
`
`
`JOINT STIPULATION REGARDING PUBLIC INTEREST BETWEEN
`COMPLAINANT AND OMNIVISION TECHNOLOGIES, INC.
`
`Complainant Bell Semiconductor, LLC (“Bell Semic” or “Complainant”) and Respondent
`
`Omnivision Technologies, Inc. (“Omnivision”) (together, “the parties”) agree that this stipulation
`
`is limited to the issue of public interest and cannot be used for any other purpose in this or any
`
`other investigation. The parties agree and jointly stipulate as follows:
`
`1.
`
`The parties agree that the remedial orders sought by Complainant in this
`
`investigation would not have any adverse impact on the public interest.
`
`2.
`
`Omnivision does not contend that the remedial orders sought in this investigation
`
`would have an adverse impact on public health and welfare, competitive conditions, production
`
`of like or directly competitive articles in the United States, or on U.S. consumers.
`
`3.
`
`Omnivision hereby withdraws its Sixth Affirmative Defense set forth in the
`
`Response of Omnivision to the Complaint and Notice of Investigation, and its response to
`
`Complainant’s Interrogatory No. 17.
`
`
`
`4.
`
`Omnivision agrees that it will not pursue any arguments related to the public
`
`interest issue at any time in this investigation, including at the remedial phase before the
`
`Commission.
`
`5.
`
`In view of the foregoing agreements by Omnivision, Complainant agrees to
`
`withdraw its discovery requests to Omnivision directed to the public interest factors and to not
`
`seek further discovery, including deposition testimony, from Omnivision regarding the public
`
`interest factors.
`
`
`
`
`
`
`
`Dated: March 14, 2023
`
`
`
`Respectfully submitted,
`
`By /s/ Andrew Pratt
`Timothy Devlin
`Andrew Pratt
`Alex Chan
`Lowell Jacobson
`Clifford Chad Henson
`DEVLIN LAW FIRM LLC
`1526 Gilpin Ave.
`Wilmington DE 19806
`Bell-337-1342@devlinlawfirm.com
`
`Counsel for Bell Semiconductor, LLC
`
`
`By /s/ Jay Reiziss
`Jay Reiziss
`Joshua M. Revilla
`McDERMOTT WILL & EMERY LLP
`500 North Capitol Street, N.W.
`Washington, D.C. 20001
`Telephone: 202-756-8000
`Facsimile: 202-756-8087
`OmniVisionITC@mwe.com
`
`Charlie McMahon
`Thomas DaMario
`Kat Lynch
`McDERMOTT WILL & EMERY LLP
`444 West Lake Street, Suite 4000
`Chicago, IL 60606-0029
`Telephone: 312-372-2000
`Facsimile: 312-984-7700
`
`David H. Bluestone
`Michael Educate
`BARACK FERRAZZANO KIRSCHBAUM
`& NAGELBERG LLP
`200 West Madison Street
`Suite 3900 Chicago, IL 60606
`Telephone: 312-984-3100
`Facsimile: 312-984-3150
`
`Counsel for Omnivision Technologies, Inc.
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a copy of the foregoing document was served on the following parties in the
`
`manner indicated below on March 14, 2023:
`
`The Honorable Katherine M. Hiner
`Acting Secretary to the Commission
`U.S. International Trade Commission
`500 E Street SW
`Washington, D.C. 20436
`
`
`The Honorable Clark S. Cheney
`Chief Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, DC 20436
`Cheney1342@usitc.gov
`Pyong.Yoon@usitc.gov
`
`John Shin, Esq.
`Jeffrey Hsu, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`John.shin@usitc.gov
`Jeffrey_Hsu@usitc.gov
`
`Daniel E. Yonan
`STERNE, KESSLER, GOLDSTEIN & FOX, P.L.L.C.
`1100 New York Avenue, NW
`Washington, DC 20005
`(202) 371-2600
`MaxLinear1342@sternekessler.com
`
`
`Counsel for Respondent MaxLinear, Inc.
`James M. Dowd
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`350 S. Grand Ave, Suite 2400
`Los Angeles, CA 90071
`Telephone: (213) 443-5300
`WHskyworks-bellsemic1342servicelist@wilmerhale.com
`
`Counsel for Respondent Skyworks Solutions Inc.
`Jay Reiziss
`McDERMOTT WILL & EMERY
`
`☐ Not Served
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`
`500 N. Capital Street, NW
`Washington, DC 20001
`Telephone: (202) 756-8646
`OmniVisionITC@mwe.com
`
`Counsel for Respondent OmniVision Technologies, Inc.
`
`Matthew S. Yungwirth
`DUANE MORRIS
`1075 Peachtree Street NE, Suite 1700
`Atlanta, Georgia 30309
`Telephone: (404) 253.6900
`DM_BellSemi_Inv1342@duanemorris.com
`
`Counsel for Respondent Arlo Technologies, Inc.
`
`☒ Via EDIS
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`☐ Via Hand Delivery
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`/s/ Lauren Mostrom
`
`
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