`Tel: (571) 533-3581
`pbartkowski@bartkowskipllc.com
`
`January 8, 2025
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Rechargeable Batteries and Components Thereof
`Inv. No. 337-TA-1421
`
`Dear Secretary Barton:
`
`On behalf of Complainants LithiumHub, LLC, Lithiumhub Technologies, LLC, and Martin
`Koebler, in the above-referenced proceeding, enclosed please find the Agreement to be Bound
`by the Protective Order of R. Jacob Baker, Ph.D., P.E.
`
`
`
`Respectfully submitted,
`
`/s/ Paul M. Bartkowski
`Paul M. Bartkowski
`
`Enclosures
`
`cc:
`
`
`Service list as attached.
`
`6803 Whittier Ave., Suite 200A, McLean, VA 22101 Tel: (571) 533-3581 Fax: (571) 775-3883 www.bartkowskipllc.com
`
`
`
`
`
`R. Jacob Baker, Ph.D., P.E.
`6775 Agave Azul Court
`Las Vegas, NV 89120
`rjacobbaker@gmail.com
`
`January 8, 2025
`
`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U. S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Rechargeable Batteries and Components Thereof
`Inv. No. 337-TA-1421
`
`Dear Secretary Barton:
`
`I have been retained to serve as an expert by Complainants LithiumHub, LLC, Lithiumhub
`Technologies, LLC, and Martin Koehler ("LithiumHub") in the above referenced proceeding.
`Please be advised that I have read Order No. 1: Protective Order, issued by the Honorable Doris
`Johnson Hines on October 22, 2024, in this investigation and, in accordance with the Order,
`hereby agree:
`
`(i)
`
`(ii)
`
`(iii)
`
`to be bound by 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 purposes of this
`investigation.
`
`I, the undersigned, on behalf of LithiumHub, 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
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate
`nondisclosure agreements.
`
`
`
`January 8, 2025
`Page2
`
`cc:
`
`Service list as attached.
`
`
`
`CERTIFICATE OF SERVICE
`
`
`I, Laurie Ouchida, hereby certify that on January 8, 2025, copies of the foregoing were filed with
`and served upon the following as indicated:
`
`
`
` VIA EDIS
`
` VIA EMAIL
`Ryan.Schmid@usitc.gov
`
` VIA EDIS
` VIA BOX
` VIA EMAIL
`JohnsonHines1421@usitc.gov
`
`Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`
`The Honorable Doris Johnson Hines
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, D.C. 20436
`
`Ryan A. Schmid
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`
`Counsel for Respondents Bass Pro Outdoor World LLC and Cabela’s LLC:
`
`William D. Cramer
`Clark Hill PLC
`901 Main Street, Suite 6000
`Dallas, TX 75202
`
`Counsel for Respondent Navico Group Americas, LLC:
`
`Matthew J. Herko
`Jones Day
`110 N. Wacker Drive, Suite 4800
`Chicago, IL 60606
`
`Counsel for Respondents Dragonfly Energy Corp. and Dragonfly Energy Holdings
`Corp.:
`
`Elizabeth A. DiMarco
`Wolf, Greenfield & Sacks, P.C.
`601 Massachusetts Avenue, NW
`Washington, D.C. 20001
`
`
` VIA EMAIL
`ITC1421@ClarkHill.com
`BassCabela-ITC@reedsmith.com
`
` VIA EMAIL
`NavicoITC1421@jonesday.com
`
` VIA EMAIL
`WGS-Dragonfly-
`ITC1421@WolfGreenfield.com
`
`
`
`Counsel for Respondents Renogy New Energy Co., Ltd. and RNG International Inc.:
`
`Jessica C. Hill
`Covington & Burling LLP
`One CityCenter
`850 Tenth Street, NW
`Washington, D.C. 20001
`
`Counsel for Respondents Shenzhen Fbtech Electronics Ltd, Shenzhen LiTime
`Technology Co., Ltd, Clean Republic SODO LLC, MillerTech Energy Solutions LLC,
`and Relion Battery (Shenzhen) Technology Co.:
`
`Tony V. Pezzano
`Lippes Mathias LLP
`420 Lexington Avenue, Ste. 205
`New York, NY 10170
`
`
`Shenzhen Yichen S-Power Tech Co. LTD
`Floor 7, Building B4b,
`Yingzhan Industrial Zone, Longtian Community,
`Zehgzi Street, Pingshan District,
`Shenzhen, China 518118
`
`
` VIA EMAIL
`LIPPES-ITC-1421@lippes.com
`guping@zhonglun.com
`
` VIA U.S. MAIL
`
`
` VIA EMAIL
`jhill@cov.com
`COV-ITC-Renogy@cov.com
`
`
`
`
`
`
`
`
`
` /s/ Laurie Ouchida
`
`
`Laurie Ouchida
`Senior Paralegal
`BARTKOWSKI PLLC
`E: louchida@bartkowskipllc.com
`
`
`
`2
`
`
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