`
`
`
`May 20, 2024
`
`BY EDIS FILING
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`ArentFox Schiff LLP
`1717 K Street, NW
`Washington, DC 20006
`
`202.857.6000
`202.857.6395
`
`MAIN
`FAX
`
`afslaw.com
`
`Janine A. Carlan
`Partner
`DIRECT
`202.715.8506
`
`
`Janine.Carlan@afslaw.com
`
`
`
`Re:
`
`In the Matter of Certain Smart Wearable Devices, Systems, and Components Thereof
`USITC Inv. No. 337-TA-1398
`
`Dear Secretary Barton:
`
`Attached for filing on behalf of Ouraring, Inc. and Ōura Health Oy (collectively, “Ōura”
`or Complainants”) in the above-referenced proceeding, please find the protective order
`subscriptions of Majid Sarrafzadeh, Tajana Rosing, Badal Sharma, Ryan Gutierrez, and Sangjin
`Hyun.
`
`Please contact me if you have any questions.
`
`
`
`Respectfully submitted,
`
`/s/ Janine A. Carlan
`
`Janine A. Carlan
`
`Counsel for Complainants Ouraring,
`Inc. and Ōura Health Oy
`
`
`
`
`
`
`
`Smart In
`Your World®
`
`
`

`

`UNIVERSITY OF CALIFORNIA, LOS ANGELES UCLA
`
`BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO SANTA BARBARA • SANTA CRUZ
`
`
`May 16, 2024
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Suite 112
`Washington, D.C. 20436
`
`MAJID SARRAFZADEH
`COMPUTER SCIENCE DEPARTMENT
`UNIVERSITY OF CALIFORNIA LOS ANGELES (ULCA)
`ENGR VI
`LOS ANGELES, CA 90095-1596
`TEL (310) 794-4303
`FAX (310) 794-5056
`EMAIL MAJID@CS.UCLA.EDU
`
`
`
`
`
`Re:
`
`Certain Smart Wearable Devices, Systems, and Components Thereof
`Inv. No. 337-TA-1398
`
`Dear Secretary Barton:
`
`I have been retained by Complainants, Ouraring, Inc. and Ōura Health Oy
`(“Complainants”), through their counsel ArentFox Schiff LLP in the above-referenced
`investigation. I have read the Protective Order (Order No. 1) issued by Administrative Law Judge
`Doris Johnson Hines on April 17, 2024, and in accordance with that Order, hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`to be bound by the terms thereof;
`
`not to reveal confidential business information covered by the Protective Order to
`anyone other than another person designated in paragraph 3; and
`
`to utilize such confidential business information solely for the 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:
`
`(1)
`
`(2)
`
`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.
`
`
`
`
`
`
`
`
`
`1
`
`

`

`Respectfully submitted,
`
`
`Majid Sarrafzadeh, Ph.D.
`Distinguished Professor of Computer Science
`Professor of Electrical Engineering
`University of California Los Angeles (UCLA)
`
`2
`
`
`
`
`
`

`

`Prof. Tajana S Rosing
`TSRpro LLLC
`11485 Raedene Way
`San Diego, CA 92131
`
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Suite 112
`Washington, D.C. 20436
`
`Re: Certain Smart Wearable Devices, Systems, and Components Thereof
`Inv. No. 337-TA-1398
`
`Dear Secretary Barton:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`May 19, 2024
`
`I have been retained by Complainants, Ouraring, Inc. and Ōura Health Oy
`(“Complainants”), through their counsel ArentFox Schiff LLP in the above-referenced
`investigation. I have read the Protective Order (Order No. 1) issued by Administrative Law Judge
`Doris Johnson Hines on April 17, 2024, and in accordance with that Order, hereby agree:
`
`(1)
`
`(2)
`
`(3)
`
`to be bound by the terms thereof;
`
`not to reveal confidential business information covered by the Protective Order to
`anyone other than another person designated in paragraph 3; and
`
`to utilize such confidential business information solely for the 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:
`
`(1)
`
`(2)
`
`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,
`
`
`______________________________
`Dr. Tajana Rosing
`
`

`

`
`Cipher Group Technologies Inc. dba Lumenci Inc.
`901 S Mopac Expressway Bldg. 1, Ste 300
`Austin, TX 78746 USA
`Tel: +1 (512) 961.0873
`Email: contact@lumenci.com
`
`
`May 16, 2024
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Suite 112
`Washington, D.C. 20436
`
`Re:
`
`
`Dear Secretary Barton:
`
`Certain Smart Wearable Devices, Systems, and Components Thereof
`Inv. No. 337-TA-1398
`
`I have been retained by Complainants, Ouraring, Inc. and Ōura Health Oy
`(“Complainants”), through their counsel ArentFox Schiff LLP in the above-referenced
`investigation. I have read the Protective Order (Order No. 1) issued by Administrative Law
`Judge Doris Johnson Hines on April 17, 2024, and in accordance with that Order, hereby
`agree:
`
`(1)
`
`(2)
`
`(3)
`
`to be bound by the terms thereof;
`
`not to reveal confidential business information covered by the Protective Order
`to anyone other than another person designated in paragraph 3; and
`
`to utilize such confidential business information solely for the 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:
`
`(1)
`
`(2)
`
`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,
`
`
`
`______________________________
`Badal Sharma
`
`
`
`
`
`
`

`

`
`Cipher Group Technologies Inc. dba Lumenci Inc.
`901 S Mopac Expressway Bldg. 1, Ste 300
`Austin, TX 78746 USA
`Tel: +1 (512) 961.0873
`Email: contact@lumenci.com
`
`
`May 16, 2024
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Suite 112
`Washington, D.C. 20436
`
`Re:
`
`
`Dear Secretary Barton:
`
`Certain Smart Wearable Devices, Systems, and Components Thereof
`Inv. No. 337-TA-1398
`
`I have been retained by Complainants, Ouraring, Inc. and Ōura Health Oy
`(“Complainants”), through their counsel ArentFox Schiff LLP in the above-referenced
`investigation. I have read the Protective Order (Order No. 1) issued by Administrative Law
`Judge Doris Johnson Hines on April 17, 2024, and in accordance with that Order, hereby
`agree:
`
`(1)
`
`(2)
`
`(3)
`
`to be bound by the terms thereof;
`
`not to reveal confidential business information covered by the Protective Order
`to anyone other than another person designated in paragraph 3; and
`
`to utilize such confidential business information solely for the 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:
`
`(1)
`
`(2)
`
`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,
`
`
`
`______________________________
`Ryan Gutierrez
`
`
`
`
`
`
`

`

`
`Cipher Group Technologies Inc. dba Lumenci Inc.
`901 S Mopac Expressway Bldg. 1, Ste 300
`Austin, TX 78746 USA
`Tel: +1 (512) 961.0873
`Email: contact@lumenci.com
`
`
`May 16, 2024
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Suite 112
`Washington, D.C. 20436
`
`Re:
`
`
`Dear Secretary Barton:
`
`Certain Smart Wearable Devices, Systems, and Components Thereof
`Inv. No. 337-TA-1398
`
`I have been retained by Complainants, Ouraring, Inc. and Ōura Health Oy
`(“Complainants”), through their counsel ArentFox Schiff LLP in the above-referenced
`investigation. I have read the Protective Order (Order No. 1) issued by Administrative Law
`Judge Doris Johnson Hines on April 17, 2024, and in accordance with that Order, hereby
`agree:
`
`(1)
`
`(2)
`
`(3)
`
`to be bound by the terms thereof;
`
`not to reveal confidential business information covered by the Protective Order
`to anyone other than another person designated in paragraph 3; and
`
`to utilize such confidential business information solely for the 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:
`
`(1)
`
`(2)
`
`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,
`
`
`
`______________________________
`Sangjin Hyun
`
`
`
`
`
`
`

`

`Certain Smart Wearable Devices, Systems,
`and Components Thereof
`
`
`
`Inv. No.: 337-TA-1398
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a copy of the foregoing PROTECTIVE ORDER
`SUBSCRIPTIONS OF MAJID SARRAFZADEH, TAJANA ROSING, BADAL SHARMA,
`RYAN GUTIERREZ, AND SANGJIN HYUN was served upon the following as indicated
`below on May 20, 2024:
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W.
`Washington, DC 20436
`Whitney Winston, Esq.
`Commission Investigative Attorney
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W.
`Washington, DC 20436
`whitney.winston@usitc.gov
`
`Counsel for Respondent Circular SAS
`
`Lesley M. Grossberg
`ICE MILLER LLP
`200 W Madison St, Ste 3500
`Chicago, IL 60606
`lesley.grossberg@icemiller.com
`CircularITC@icemiller.com
`
`Counsel for Respondent RingConn LLC and
`Shenzhen Ninenovo Technology Ltd.
`
`Robert M. Breetz
`JONES DAY
`51 Louisiana Ave., NW
`Washington, D.C. 20001-2113
`rbreetz@jonesday.com
`RingConnITC1398@jonesday.com
`
`
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`X Via EDIS
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`X Via Electronic email
`
`Certificate of Service 1
`
`
`
`
`
`
`
`

`

`☐ Via Hand Delivery
`☐ Via Express Delivery
`☐Via First Class Mail
`☐ Via EDIS
`X Via Electronic email
`
`Counsel for Ultrahuman Healthcare Pvt. Ltd.,
`Ultrahuman Healthcare Ltd., and Ultrahuman
`Healthcare SP, LLC
`
`Timothy J. Murphy
`Carlson, Gaskey & Olds, P.C.
`400 West Maple Rd., Suite 350
`Birmingham, Michigan 48009
`Telephone: (248) 988-8360
`tmurphy@cgolaw.com
`ultrahumanitc@cgolaw.com
`
`
`
`/s/ Janine A. Carlan
`Janine A. Carlan
`
`
`Counsel for Complainants Ouraring, Inc.
`and Oura Health Oy
`
`Certificate of Service 2
`
`
`
`
`
`
`
`