`
`quinn emanuel trial lawyers | washington, dc
`1300 I Street NW, Suite 900, Washington, District of Columbia 20005-3314 | TEL (202) 538-8000 FAX (202) 538-8100
`
`WRITER'S DIRECT DIAL NO.
`(202) 538-8104
`
`WRITER'S EMAIL ADDRESS
`alexlasher@quinnemanuel.com
`
`March 29, 2024
`
`FILED VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112A
`Washington, DC 20436
`
`
`
`
`Re: Certain Cameras, Camera Systems, and Accessories Used Therewith
`
`Dear Secretary Barton:
`
`Enclosed for filing, please find documents in support of a request by GoPro, Inc.
`(“Complainant”) that the U.S. International Trade Commission institute an investigation pursuant
`to Section 337 of the Tariff Act of 1930, as amended, concerning certain cameras, camera
`systems, and accessories used therewith.
`
`There is no confidential business information contained in the complaint itself, but we
`have included a separate letter requesting confidential treatment for six (6) exhibits included with
`this filing.
`
`On March 16, 2020, the Commission provided “notice that it is temporarily waiving and
`amending certain of the Commission’s rules that required the filing of paper copies, CD-ROMS,
`and other physical media in section 337 investigations to address concerns about COVID-19.”
`International Trade Commission, Temporary Changes to Filing Procedures, Federal Register
`Vol. 85, No. 54 (March 19, 2020). Specifically, the Commission approved the temporary
`amendment of various rules “to permit parties to file section 337 complaints, exhibits,
`attachments, and appendices, electronically.” Id. Accordingly, Complainant’s filing only
`contains electronic documents.
`
`Complainant’s submission via EDIS includes the following:
`
`quinn emanuel urquhart & sullivan, llp
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`
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`ABU DHABI | ATLANTA | AUSTIN | BEIJING | BERLIN | BOSTON | BRUSSELS | CHICAGO | DALLAS | DOHA | HAMBURG | HONG KONG | HOUSTON |
`LONDON | LOS ANGELES | MANNHEIM | MIAMI | MUNICH | NEUILLY-LA DEFENSE | NEW YORK | PARIS | PERTH | RIYADH | SALT LAKE CITY |
`SAN FRANCISCO | SEATTLE | SHANGHAI | SILICON VALLEY | SINGAPORE | STUTTGART | SYDNEY | TOKYO | WASHINGTON, DC | WILMINGTON |
`ZURICH
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`1. One (1) electronic copy of Complainant’s Verified Complaint, pursuant to
`Commission Rule 210.8(a)(1)(i).
`
`2. One (1) electronic copy of the public exhibits to the Verified Complaint pursuant to
`Commission Rules 210.8(a)(1)(1) and 210.12(a)(9), including:
`
`a. one (1) electronic certified copy of each of United States Patent Nos.
`10,015,413 (“the ’413 patent”), 10,529,052 (“the ’052 patent”), 10,574,894
`(“the ’894 patent”), 10,958,840 (“the ’840 patent”), 11,336,832 (“the ’832
`patent”), and D789,435 (“the D’435 patent”), copies of which are respectively
`included as Exhibits 1, 3, 5, 7, 9, and 11 to the Verified Complaint pursuant to
`Commission Rule 210.12(a)(9)(1); and
`
`b. one (1) electronic copy of the certified assignment records for each of the
`’413, ’052, ’894, ’840, ’832, and D’435 patents, copies of which are
`respectively included as Exhibits 2, 4, 6, 8, 10, and 12 to the Verified
`Complaint, pursuant to Commission Rule 210.12(a)(9)(ii).
`
`3. One (1) electronic copy of the confidential exhibits to the Verified Complaint,
`pursuant to Commission Rules 201.6(c) and 210.8(a)(1)(ii).
`
`4. One (1) electronic copy of the certified prosecution history for each of the ’413, ’052,
`’894, ’840, ’832, and D’435 patents, which are respectively identified as Appendices
`A, C, E, G, I, and K to the Verified Complaint, pursuant to Commission Rule
`210.12(c)(1).
`
`5. One (1) electronic copy of each patent and applicable pages of each technical
`reference mentioned in the respective prosecution histories of the ’413, ’052, ’894,
`’840, ’832, and D’435 patents, which are respectively identified as Appendices B, D,
`F, H, J, and L to the Verified Complaint, pursuant to Commission Rule 210.12(c)(2).
`
`6. A letter and certification requesting confidential treatment for the information
`contained in confidential exhibits 30-34 and 36 to the Verified Complaint, pursuant to
`Commission Rules 201.6(b) and 210.5(d).
`
`7. A Statement on the Public Interest regarding the remedial orders sought by
`Complainant in the Verified Complaint, pursuant to Commission Rule 210.8(b).
`
`Complainant confirms that it will serve copies of the non-confidential versions of the
`Complaint and all associated exhibits and appendices upon the institution of this investigation on
`the proposed Respondents and all other appropriate entities consistent with 19 C.F.R. part 201
`(including 19 C.F.R. § 201.16) and the Temporary Procedures.
`
`Please contact me with any questions regarding this filing.
`
`
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`2
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`
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`Respectfully submitted,
`
` /s/ S. Alex Lasher
`S. Alex Lasher
`Counsel for Complainant GoPro, Inc.
`
`
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`3
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`
`
`quinn emanuel trial lawyers | washington, dc
`1300 I Street NW, Suite 900, Washington, District of Columbia 20005-3314 | TEL (202) 538-8000 FAX (202) 538-8100
`
`WRITER'S DIRECT DIAL NO.
`(202) 538-8104
`
`WRITER'S EMAIL ADDRESS
`alexlasher@quinnemanuel.com
`
`REQUEST FOR CONFIDENTIAL TREATMENT
`
`March 29, 2024
`
`FILED VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, SW, Room 112A
`Washington, DC 20436
`
`
`
`
`Re: Certain Cameras, Camera Systems, and Accessories Used Therewith
`
`Dear Secretary Barton:
`
`Pursuant to Commission Rule 201.6, Complainant GoPro, Inc. respectfully requests
`
`confidential treatment of certain confidential business information contained in confidential
`exhibits 30-34 and 36 to the Verified Complaint.
`
`The information in the exhibits for which Complainant seeks confidential treatment
`consists of proprietary commercial information, including confidential and proprietary technical
`information related to domestic articles protected by Complainant’s asserted patents, and
`financial data regarding Complainant’s domestic investments in plant, equipment, labor, and
`capital related to domestic articles protected by Complainant’s asserted patents.
`
`The proprietary information described herein qualifies as confidential business
`information under Commission Rule 201.6 because substantially identical information is not
`available to the public, because the disclosure of this information would cause substantial
`competitive harm to Complainant, and because the disclosure of this information would likely
`impede the Commission’s efforts and ability to obtain similar information in the future.
`
`Thank you for your attention. Please contact me with any questions regarding this request
`for confidential treatment.
`
`quinn emanuel urquhart & sullivan, llp
`
`
`
`ABU DHABI | ATLANTA | AUSTIN | BEIJING | BERLIN | BOSTON | BRUSSELS | CHICAGO | DALLAS | DOHA | HAMBURG | HONG KONG | HOUSTON |
`LONDON | LOS ANGELES | MANNHEIM | MIAMI | MUNICH | NEUILLY-LA DEFENSE | NEW YORK | PARIS | PERTH | RIYADH | SALT LAKE CITY |
`SAN FRANCISCO | SEATTLE | SHANGHAI | SILICON VALLEY | SINGAPORE | STUTTGART | SYDNEY | TOKYO | WASHINGTON, DC | WILMINGTON |
`ZURICH
`
`
`
`
`
`
`
`
`
`
`
`

`

`
`
`
`
`Respectfully submitted,
`
` /s/ S. Alex Lasher
`S. Alex Lasher
`Counsel for Complainant GoPro, Inc.
`
`
`
`
`
`
`2
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