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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
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`Before the Honorable MaryJoan McNamara
`Administrative Law Judge
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`In the Matter of
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`CERTAIN WIRELESS FRONT-END
`MODULES AND DEVICES CONTAINING
`THE SAME
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`Investigation No. 337-TA-1413
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`RESPONDENT’S UNOPPOSED MOTION TO EXTEND THE TIME TO
`RESPOND TO THE COMPLAINT AND NOTICE OF INVESTIGATION
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`Ground Rule 2.2 Certification
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`Respondent Ruijie Networks Co., Ltd. (“Ruijie”) certifies that it made reasonable, good-
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`faith efforts to resolve this matter with all parties at least two business days prior to filing this
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`motion. Complainants, the remaining Respondents, and the Staff do not oppose the extension.
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`Pursuant to Commission Rules 210.13(a) and 210.15(d) and Ground Rule 1.9.1, Ruijie
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`respectfully requests an extension of its deadline to respond to the Complaint and Notice of
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`Institution of Investigation from September 23, 2024, to September 30, 2024. Complainants, the
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`remaining Respondents, and the Staff do not oppose the extension.
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`The Commission instituted this Investigation on August 16, 2024, and the Notice of
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`Institution of Investigation was published in the Federal Register on August 22. See 89 Fed. Reg.
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`67969 (Aug. 22, 2024). Ruijie both accepted service of the Complaint and Notice of Institution of
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`Investigation on September 3, 2024. See Complainants Proof of Service of Complaint (EDIS No.
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`831531). Accordingly, Ruijie’s responses to the Complaint and Notice of Institution of
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`Investigation are currently due on September 23, 2024. See 19 C.F.R. § 210.13(a). Ruijie requests
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`that the deadline be extended one week to September 30, 2024.
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`There is good cause for the requested extension. The requested extension will allow Ruijie
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`to more fully investigate the allegations in the Complaint, to compile the information requested by
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`Commission Rule 210.13(b), and to explore and develop potential defenses. Given the early stage
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`of the Investigation, the extension will not prejudice any party. The Staff and the remaining Private
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`Parties do not oppose it. The Administrative Law Judge has the authority to determine the response
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`date to the Complaint and Notice Institution of Investigation. 19 C.F.R. § 210.13(a). And
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`unopposed motions to extend response deadlines are routinely granted. See, e.g., Certain Solar
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`Power Optimizers, Inverters, and Components Thereof, Inv. No. 337-TA-1327, Order No. 4
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`(September 16, 2022) (EDIS No. 780406); Certain LED Landscape Lighting Devices and
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`Components Thereof, Inv. No. 337-TA-1261, Order No. 4 (April 28, 2021) (EDIS No. 741116)
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`Certain Graphics Processors, DDR Memory Controllers, and Products Containing the Same, Inv.
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`No. 337-TA-1037, Order No. 4 (February 2, 2017) (EDIS No. 602685).
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`Ruijie respectfully requests that this motion be granted and that its deadline for responding
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`to the Complaint and Institution of Investigation be extended to September 30, 2024.
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`DATED: September 19, 2024
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`Respectfully submitted,
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`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
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`By /s/ S. Alex Lasher______________________
` S. Alex Lasher
` 1300 I Street NW, Suite 900
` Washington, DC 20005
` Tel: (202) 538-8000
` Fax: (202) 538-8100
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` Xiao Liu
` Unit 1301, 13th Floor, Central Park Plaza
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` 10 Chaoyang Park South Road,
` Chaoyang District
` Beijing 100026
` China
` Tel: +86 10 53350105
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` Mark Tung
` 555 Twin Dolphin Dr., 5th Floor
` Redwood Shores, CA 94065
` Tel: (650) 801-5000
` Fax: (650) 801-5100
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` Chunmeng Yang
` 1109 First Avenue, Suite 210
` Seattle, WA 98101
` Tel: (206) 905-7000
` Fax: (206) 905-7100
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` Shengling Zhu
` Unit 502-503, 5th Floor, Nordic House
` 3 Fenyang Road, Xuhui District
` Shanghai 200031
` China
` Tel: +86 21 34018600
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` Counsel for Respondent Ruijie
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`CERTAIN WIRELESS FRONT-END MODULES AND DEVICES
`CONTAINING THE SAME
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`Inv. No. 337-TA-1413
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`CERTIFICATE OF SERVICE
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`I, Gracie Wichtendahl, hereby certify that on September 19, 2024, copies of the foregoing
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`document were served upon the following parties as indicated:
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`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
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`The Honorable MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW
`Washington, DC 20436
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`Linda Chang
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street SW, Suite 401
`Washington, DC 20436
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`Counsel for Complainants Skyworks
`Solutions, Inc., Skyworks Solutions Canada,
`Inc., and Skyworks Global Pte. Ltd.
`James M. Dowd, Esq.
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`350 S. Grand Ave, Suite 2400
`Los Angeles, CA 90071
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`Counsel for Respondent Kangxi
`Communication Technologies (Shanghai)
`Co., Ltd. and Grand Chips Labs
`Timothy Shannon
`DUANE MORRIS LLP
`100 High Street, Suite 2400
`Boston, MA 02110
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`Via EDIS
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`Via Email:
`McNamara337@usitc.gov
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`Via Email: linda.chang@usitc.gov
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`Via Email: WHSkyworks-
`KCT1413servicelist@wilmerhale.com
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`Via Email:
`DM_KCT_ITC_1413@duanemorrris.com
`FM-KCT-1413@fostermurphy.com
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`Telephone: 857.488.4200
`Facsimile: 857.488.4201
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`Counsel for Respondent D-Link Corporation
`and D-Link Systems Inc.
`Ric Macchiaroli
`PILLSBURY WINTHROP SHAW
`PITTMAN LLP
`7900 Tysons One Place, Suite 500
`Tysons, VA 22102
`(703) 770-7900
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`Via Email:
`Christopher.kao@pillsburylaw.com
`ric.macchiaroli@pillsburylaw.com
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`/s/ Gracie Wichtendahl____________
`Gracie Wichtendahl
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