901 New York Avenue, NW . Washington, DC 20001-441 3 . 202.408.4000 . Fax 202.408.4400
`
`www.fin negan .corn
`
`FINN EGAN
`HENDERSON
`FARABOW
`GARRETT &
`DUNNERLLP
`
`SMITH R. BRITTINGHAM IV
`
`202.408.41 58
`smith.brittingham@finnegan.com
`
`February 9,2006
`
`The Honorable Marilyn R. Abbott
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`Re: Certain Automotive Parts
`Inv. No. 337-TA-557
`
`Dear Secretary Abbott:
`
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`Enclosed, please find the original signed verification pages from the Responses
`of TYC Brother Industrial Co., Gordon Auto Body Parts Co., Y.C.C. Parts Manufacturing
`Co. and Depo Auto Parts Industrial Co. to the Notice of Investigation and Complaint of
`Ford Global Technologies, and Affirmative Defenses in this Investigation.
`
`I
`
`1
`
`--;
`
`cc: Certificate of Service
`
`Washington, DC Atlanta, GA . Cambridge, MA Palo Alto, CA . Reston, VA . Brussels Taipei . Tokyo
`
`
`
`www.fin negan .corn
`
`FINN EGAN
`HENDERSON
`FARABOW
`GARRETT &
`DUNNERLLP
`
`SMITH R. BRITTINGHAM IV
`
`202.408.41 58
`smith.brittingham@finnegan.com
`
`February 9,2006
`
`The Honorable Marilyn R. Abbott
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`Re: Certain Automotive Parts
`Inv. No. 337-TA-557
`
`Dear Secretary Abbott:
`
`.l
`i
`.,
`
`3.1
`
`1-
`
`I
`
`. .
`
`1 -
`
`-p>
`I
`.
`
`
`
`'L-I
`
`Enclosed, please find the original signed verification pages from the Responses
`of TYC Brother Industrial Co., Gordon Auto Body Parts Co., Y.C.C. Parts Manufacturing
`Co. and Depo Auto Parts Industrial Co. to the Notice of Investigation and Complaint of
`Ford Global Technologies, and Affirmative Defenses in this Investigation.
`
`I
`
`1
`
`--;
`
`cc: Certificate of Service
`
`Washington, DC Atlanta, GA . Cambridge, MA Palo Alto, CA . Reston, VA . Brussels Taipei . Tokyo
`
`
`
`VERIFICATION OF RESPONSE
`
`I,
`
`I am
`
`Tai- Kuann Ho
`
`, hereby declare under penalty of perjury as follows:
`
`Manager
`
`of TYC Brother Industrial Co., Ltd. and am authorized to
`
`make this verification on behalf of TYC Brother Industrial Co., Ltd.
`
`I have read the Response of TYC Brother Industrial Co., Ltd. to the Notice of
`
`Investigation and the Complaint of Ford Global Technologies, LLC, and Affirmative Defenses in
`
`this Investigation.
`
`To the best of my knowledge, information, and belief, formed after a reasonable inquiry,
`
`the responses and factual statements in this response have evidentiary support or are likely to
`
`have evidentiary support after a reasonable opportunity for further investigation or discovery;
`
`The claims and legal contentions in the complaint are warranted by existing law or by a
`
`nonfrivolous argument for the extension, modification, or reversal of existing law or the
`
`establishment of new law; and
`
`The response is not being presented for any improper purpose, such as to harass or to
`
`cause unnecessary delay or needless increase in the cost of the investigation.
`
`Executed on the 26th day of January, 2006.
`
`
`
`VERIFICATION OF RESPONSE
`
`I,
`
`I-Hung Lin , hereby declare under penalty of perjury as follows:
`
`I am General Manager of Y.C.C. Parts Manufacturing Co., Ltd. and am authorized to
`
`make this verification on behalf of Y.C.C. Parts Manufacturing Co., Ltd.
`
`I have read the Response of Y.C.C. Parts Manufacturing Co., Ltd. to the Notice of
`
`Investigation and the Complaint of Ford Global Technologies, LLC , and Affirmative Defenses in
`
`this Investigation.
`
`To the best of my knowledge, information, and belief, formed after a reasonable inquiry,
`
`the responses and factual statements in this response have evidentiary support or are likely to
`
`have evidentiary support after a reasonable opportunity for further investigation or discovery;
`
`The claims and legal contentions in the complaint are warranted by existing law or by a
`
`nonfrivolous argument for the extension, modification, or reversal of existing law or the
`
`establishment of new law; and
`
`The response is not being presented for any improper purpose, such as to harass or to
`
`cause unnecessary delay or needless increase in the cost of the investigation.
`
`Executed on the 27* day of January, 2006.
`
`
`
`VERIFICATION OF RESPONSE
`
`W
`
`W
`
`, hereby declare under penalty of perjury
`
`v;(-Q bast 4 4 J -
`
`of Gordon Auto Body Parts Co., Ltd. and
`
`I,
`as follows:
`
`I am
`
`I
`am authorized to make this verification on behalf of Gordon Auto Body Parts Co., Ltd.
`
`I have read the Response of Gordon Auto Body Parts Co., Ltd. to the Notice of
`
`Investigation and the Complaint of Ford Global Technologies, LLC, and Affirmative Defenses in
`
`this Investigation.
`
`To the best of my knowledge, information, and belief, formed after a reasonable inquiry,
`
`the responses and factual statements in this response have evidentiary support or are likely to
`
`have evidentiary support after a reasonable opportunity for further investigation or discovery;
`
`The claims and legal contentions in the complaint are warranted by existing law or by a
`
`nonfrivolous argument for the extension, modification, or reversal of existing law or the
`
`establishment of new law; and
`
`The response is not being presented for any improper purpose, such as to harass or to
`
`cause unnecessary delay or needless increase in the cost of the investigation.
`
`Executed on the - day of January, 2006.
`
`
`
`VERIFICATION OF RESPONSE
`
`I,
`
`Shiu-Min Hsu , hereby declare under penalty of perjury as follows:
`
`I am
`
`President of Depo Auto Parts Industrial Co., Ltd. and am authorized to make this
`
`verification on behalf of Depo Auto Parts Industrial Co., Ltd.
`
`I have read the Response of Depo Auto Parts Industrial Co., Ltd. to the Notice of
`
`Investigation and the Complaint of Ford Global Technologies, LLC, and Affirmative Defenses in
`
`this Investigation.
`
`To the best of my knowledge, information, and belief, formed after a reasonable inquiry,
`
`the responses and factual statements in this response have evidentiary support or are likely to
`
`have evidentiary support after a reasonable opportunity for further investigation or discovery;
`
`The claims and legal contentions in the complaint are warranted by existing law or by a
`
`nonfrivolous argument for the extension, modification, or reversal of existing law or the
`
`establishment of new law; and
`
`The response is not being presented for any improper purpose, such as to harass or to
`
`cause unnecessary delay or needless increase in the cost of the investigation.
`
`Executed on the >%bay
`
`of January, 2006.
`
`
`
`Certain Automotive Parts
`
`Inv. No. 337-TA-557
`
`CERTIFICATE OF SERVICE
`
`The Honorable Marilyn R. Abbott, Secretary
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, D.C. 20436
`(Original and 6 Copies)
`
`I, Joanna Grauel, hereby certify that on February 9,2006, a copy of the forgoing
`document was filed and served as indicated:
`0 Via First Class Mail
`[XI Via Hand Delivery
`0 Via Overnight Courier
`0 Via Facsimile
`0 Via Electronic mail
`0 Via First Class Mail
`Via Hand Delivery
`0 Via Overnight Courier
`0 Via Facsimile
`0 Via Electronic mail
`
`The Honorable Paul J. Luckern
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, D.C. 20436
`(2 Copies)
`
`Juan Cockburn, Esq.
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W., Room 401
`Washington, D.C. 20436
`
`Counsel for Ford Global Technologies.
`
`Ernie L. Brooks
`Frank A. Angileri
`Sangeeta G. Shah
`Brooks Kushman P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, Michigan 48075
`
`V. James Adduci I1
`Adduci, Mastriani & Schaumberg LLC
`1200 17~'' Street N.W.
`Washington, D.C. 20036
`
`Via First Class Mail
`Via Hand Delivery
`0 Via Overnight Courier
`0 Via Facsimile
`0 Via Electronic mail
`
`0 Via First Class Mail
`0 Via Hand Delivery
`[XI Via Overnight Courier
`0 Via Facsimile
`0 Via Electronic mail
`
`0 Via First Class Mail
`[XI Via Hand Delivery
`0 Via Overnight Courier
`0 Via Facsimile
`0 Via Electronic mail
`
`901 New York Avenue, N.W.
`Washington, D.C. 20001
`(202) 408-4000
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