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UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before The Honorable Cameron R. Elliot
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN ACTIVE ELECTRICAL Investigation No. 337-TA-1446
`CABLES AND COMPONENTS
`THEREOF
`
`JOINT MOTION TO AMEND THE PROCEDURAL SCHEDULE
`
`Pursuant to Ground Rule 2, Complainants Credo Semiconductor Inc. and Credo
`Technology Group Ltd. (collectively, “Credo”) and Respondents Molex, LLC and TE
`Connectivity Corporation (collectively, “Respondents™) (collectively, the “Moving Parties”)
`jointly move to amend the expert report deadlines and intervening exhibit list deadline in the
`procedural schedule in this Investigation. The Moving Parties’ proposed amendment does not
`move any dates other than these three deadlines. The Moving Parties are not proposing any change
`to the hearing dates.
`
`GROUND RULE 3.2 CERTIFICATION
`
`Pursuant to Ground Rule 3.2, the Moving Parties certify that they have met and conferred
`and file this Motion jointly. Counsel for Staff indicates that it does not oppose this Motion.
`MOTION
`On September 19, 2025, the ALJ issued Order No. 19 amending the procedural schedule.
`On October 1, 2025, the U.S. Government shut down (“Shutdown”). On November 12, 2025, the
`U.S. Government re-opened. During the Shutdown, certain discovery disputes raised by
`Complainants arose between the parties in this Investigation that they presented to the ALJ when
`
`the U.S. Government reopened. After the U.S. Government reopened, the ALJ held a Discovery
`
`
`
`
`
`
`
`
`Conference on November 18, 2025, during which both Complainants and Respondents requested
`permission to file motions to compel discovery. The ALJ granted permission to file motions to
`compel but no earlier than November 25, 2025. In the interim, the ALJ instructed the Parties to
`continue working to resolve the disputed issues. Nov. 18, 2025 Discovery Conf. Tr. at 14:10-13,
`15:21-16:4. The ALJ also noted that, if disputes that were affected by the Shutdown remain
`unresolved, “then that would be a very good reason to extend the deadline for expert reports.” Id.
`at 28:10-17.
`
`Since the Discovery Conference, Complainants and Respondents have continued their
`efforts to resolve their disputes, and have resolved the disputes raised by Complainants.
`Complainants assert that certain information to be provided based on the parties’ negotiated
`resolution to the disputes raised by Complainants will impact the upcoming expert reports. Thus,
`the Parties respectfully submit that good cause exists to extend the expert report deadlines.
`
`The Parties have conferred and now jointly present the Joint Proposed Amended
`Procedural Schedule for the remaining deadlines in this Investigation, attached to this Motion as
`Exhibit A. The Parties’ proposal seeks to amend only the deadlines for exchange of initial and
`rebuttal expert reports and the intervening deadline to exchange exhibit lists. All other deadlines
`remain the same.
`
`Wherefore, the Parties submit that there is good cause to amend the procedural schedule
`
`and respectfully request that the ALJ enter the proposed schedule, attached hereto as Exhibit A.
`
`Date: November 23, 2025 Respectfully submitted,
`
`/s/ Charles M. McMahon
`Charles M. McMahon
`Mircea A. Tipescu
`David H. Bluestone
`Samuel J. Ruggio
`
`
`
`
`
`
`
`
`
`Thomas M. DaMario
`
`Kathleen M. Lynch
`
`Carlton J Hemphill
`
`Benesch Friedlander Coplan & Aronoff LLP
`71 South Wacker Drive, Suite 1600
`Chicago, IL 60606
`
`T: 312-212-4949
`Credol446(@beneschlaw.com
`
`Ziyong “Sean” Li
`
`Benesch Friedlander Coplan & Aronoff LLP
`100 Pine Street, Suite 3100
`
`San Francisco, CA 94111
`
`T: 628-600-2250
`Credo1446@beneschlaw.com
`
`Matthew J. Dowd
`
`Robert J. Scheffel
`
`Elliot A. Gee
`
`Dowd Scheffel PLLC
`
`1717 Pennsylvania Avenue, NW
`Suite 1025
`
`Washington, D.C. 20006
`Telephone: (202) 559-9175
`mdowd@dowdscheffel.com
`
`Counsel for Complainants
`Credo Semiconductor Inc. and
`Credo Technology Group Ltd.
`
`/s/ Adam D. Swain
`
`Adam D. Swain
`
`ALSTON & BIRD LLP
`
`950 F Street NW
`Washington, DC 20004
`Telephone: (202) 239-3300
`Facsimile: (202) 239-3333
`Adam.Swain@alston.com
`
`Joshua M. Weeks
`
`ALSTON & BIRD LLP
`
`1201 West Peachtree Street, Suite 4900
`Atlanta, GA 30309
`
`Telephone: (404) 881-7000
`
`Facsimile: (404) 881-7777
`
`
`
`
`
`
`
`
`Joshua.Weeks@alston.com
`
`Natalie C. Clayton
`
`ALSTON & BIRD LLP
`
`90 Park Ave.
`
`New York, NY 10016
`Telephone: (212) 210-9400
`Facsimile: (212) 210-9444
`Natalie.Clayton@alston.com
`
`Dana Zottola
`
`ALSTON & BIRD LLP
`
`55 Second Street
`
`Suite 2100
`
`San Francisco, CA 94105
`Telephone: (415) 243-1000
`Facsimile: (415) 243-1001
`Dana.Zottola@alston.com
`
`Nicholas C. Marais
`
`Mary I. Riolo
`
`ALSTON & BIRD LLP
`Vantage South End
`
`1120 South Tryon Street
`Suite 300
`
`Charlotte, NC 29203
`Telephone: (704) 444-1000
`Facsimile: (704) 444-1001
`Nic.Marais@alston.com
`Mary.Riolo@alston.com
`
`Counsel for Respondent Molex, LLC
`
`/s/ Paul F. Brinkman
`
`Paul F. Brinkman, P.C.
`
`Michael A. Pearson, Jr.
`
`John R. Rhine
`
`Azaad Zimmermann
`
`KIRKLAND & ELLIS LLP
`
`1301 Pennsylvania Avenue, N.W.
`Washington, DC 20004
`Telephone: (202) 389-5000
`Facsimile: (202) 389-5200
`
`Russell E. Levine, P.C.
`
`
`
`
`
`
`
`
`KIRKLAND & ELLIS LLP
`333 West Wolf Point Plaza
`Chicago, IL 60654
`Telephone: (312) 862-2000
`Facsimile: (312) 862-2200
`
`Brandon H. Brown, P.C.
`Eric Provost
`
`KIRKLAND & ELLIS LLP
`555 California Street
`
`San Francisco, CA 94104
`Telephone: (415) 439-1400
`Facsimile: (415) 439-1500
`
`Email: KE-TE-ITC@kirkland.com
`
`Counsel for Respondent
`TE Connectivity Corporation
`
`
`
`
`
`
`
`
`Exhibit A
`
`
`
`
`
`
`
`
`Event
`
`Current Date
`
`Proposed Date
`
`Exchange of initial expert reports (identify
`tests/surveys/data)
`
`Tue, Nov 25, 2025
`
`Mon, Dec 8, 2025
`
`Exchange of rebuttal expert reports
`
`Fri, Dec 19, 2025
`
`Tue, Jan 6, 2026
`
`Exchange of exhibit lists among the parties
`
`Wed, Dec 17, 2025
`
`Wed, Jan 7, 2026
`
`Submit and serve direct exhibits, with physical exhibits
`available — Complainants and Respondents
`
`Wed, Jan 14, 2026
`
`Wed, Jan 14, 2026
`
`Expert discovery cut-off and completion
`
`Fri, Jan 16, 2026
`
`Fri, Jan 16, 2026
`
`Submit and serve direct exhibits, with physical exhibits
`available — Staff
`
`Wed, Jan 21, 2026
`
`Wed, Jan 21, 2026
`
`Deadline for motions to compel expert discovery
`
`Fri, Jan 23, 2026
`
`Fri, Jan 23, 2026
`
`Deadline for filing motions for summary determination
`
`Thu, Jan 29, 2026
`
`Thu, Jan 29, 2026
`
`G.R. 5.3 Final Case-Narrowing Disclosure
`
`Fri, Jan 30, 2026
`
`Fri, Jan 30, 2026
`
`Submit and serve rebuttal exhibits, with rebuttal physical
`exhibits available — all parties
`
`Tue, Feb 10, 2026
`
`Tue, Feb 10, 2026
`
`File pre-trial statements and briefs — Complainants and
`Respondents
`
`Tue, Feb 17, 2026
`
`Tue, Feb 17, 2026
`
`File pre-trial statement and brief — Staff
`
`Tue, Feb 24, 2026
`
`Tue, Feb 24, 2026
`
`Deadline to file motions in limine
`
`Wed, Feb 25, 2026
`
`Wed, Feb 25, 2026
`
`File responses to motions in limine
`
`Wed, Mar 4, 2026
`
`Wed, Mar 4, 2026
`
`Pre-trial conference
`
`Mon, Mar 30, 2026
`
`Mon, Mar 30, 2026
`
`Hearing
`
`Mon, Mar 30, 2026 -
`Fri, Apr 3, 2026
`
`Mon, Mar 30, 2026 -
`Fri, Apr 3, 2026
`
`File initial post-trial briefs and final exhibit lists —
`Complainants and Respondents
`
`Fri, Apr 17, 2026
`
`Fri, Apr 17, 2026
`
`File initial post-trial briefs and final exhibit lists — Staff
`
`Fri, Apr 24, 2026
`
`Fri, Apr 24, 2026
`
`File reply post-trial briefs — Complainants and
`Respondents
`
`Fri, May 1, 2026
`
`Fri, May 1, 2026
`
`File reply post-trial briefs — Staff
`
`Fri, May 8§, 2026
`
`Fri, May 8§, 2026
`
`Initial Determination
`
`Mon, Aug 17, 2026
`
`Mon, Aug 17, 2026
`
`Target date for completion of investigation
`
`Thu, Dec 17, 2026
`
`Thu, Dec 17, 2026
`
`
`
`
`
`
`
`
`
`IN THE MATTER OF
`CERTAIN ACTIVE ELECTRICAL CABLES & COMPONENTS THEREOF
`
`Inv. No. 337-TA-1446
`
`CERTIFICATE OF SERVICE
`
`I, Jodi Baker, hereby certify that on November 23, 2025, copies of the foregoing document
`were served upon the following parties as indicated:
`
`The Honorable Lisa R. Barton (] Via EDIS
`
`Secretary to the Commission O Via Hand Delivery
`U.S. International Trade Commission O Via Federal Express
`500 E Street, S.W., Room 112 O Via E-Mail
`Washington, DC 20436
`
`The Honorable Cameron R. Elliot O Via EDIS
`Administrative Law Judge O Via Hand Delivery
`U.S. International Trade Commission O Via Federal Express
`500 E Street, SW, Room 317 Via E-Mail
`Washington, D.C. 20436
`
`Email: Michael. Turner@usitc.gov
`
`Steve Shahida, Esq. O Via EDIS
`Investigative Attorney O Via Hand Delivery
`Office of Unfair Import Investigations O Via Federal Express
`U.S. International Trade Commission ] Via E-Mail
`
`500 E Street, SW
`
`Washington, D.C. 20436
`
`Email: Khashayar.Shahida@usitc.gov
`
`Adam D. Swain, Esq. O Via EDIS
`
`Alston & Bird LLP O Via Hand Delivery
`950 F Street, NW O Via Federal Express
`Washington, D.C. 20004 (] Via E-Mail
`Telephone (202) 239-3300
`
`Facsimile: (202) 239-3333
`
`Email: MolexCredoITC@alston.com
`
`Counsel for Respondent Molex, LLC
`
`Paul F. Brinkman O Via EDIS
`KIRKLAND & ELLIS LLP O Via Hand Delivery
`1301 Pennsylvania Avenue, NW O Via Federal Express
`Washington, D.C. 20004 3] Via E-Mail
`Telephone: (202) 389-5000
`
`Facsimile: (202) 389-5200
`
`Email: KE-TE-ITC@kirkland.com
`
`Counsel for Respondent TE Connectivity PLC
`
`
`
`
`
`
`
`
`
`IN THE MATTER OF
`CERTAIN ACTIVE ELECTRICAL CABLES & COMPONENTS THEREOF
`
`Inv. No. 337-TA-1446
`
`/s/ Jodi Baker
`
`Jodi Baker
`IP Litigation Paralegal
`
`
`
`
`
`
`
`
`

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