throbber

`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`
`In the Matter of
`
`CERTAIN CAST STEEL RAILWAY
`WHEELS, CERTAIN PROCESSES FOR
`MANUFACTURING OR RELATING TO
`SAME AND CERTAIN PRODUCTS
`CONTAINING SAME
`
`
`
`Investigation No. 337-TA-655
`
`FINAL REPORT OF RESPONDENT BARBER TIANRUI RAILWAY SUPPLY, LLC
`PURSUANT TO SECTION V OF THE ORDER TO CEASE AND DESIST
`
`Pursuant to Section V of the Order to Cease and Desist issued by the Commission on
`
`February 16, 2010, in the above-captioned matter, respondent Barber Tianrui Railway Supply,
`
`LLC (“Barber”) provides its final report covering the period of July 1, 2019 through February
`
`16, 2020 (Reporting Period):
`
`(a)
`
`During the Reporting Period, Barber has neither imported nor sold in the United
`
`States after importation any covered products.1
`
`(b)
`
`As of the close of the Reporting Period, Barber has no inventory of covered
`
`products in the United States.
`
`
`1 The Cease & Desist Order defines “covered products” as follows:
`(G)
`The term “covered products” shall mean cast steel railway wheels manufactured
`using any of the trade secrets asserted by Complainant in this investigation (the
`“ABC Trade Secrets”).
`Cease & Desist Order, Definitions, Part (G).
`
`
`
`

`

`
`
`Dated: May 26, 2020
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/s/ Jason A. Engel
`Alan L. Barry
`Jason A. Engel
`K&L GATES LLP
`70 W. Madison St., Suite 3100
`Chicago, IL 60602
`(312) 372-1121
`
`
`
`Counsel for Respondent
`Barber Tianrui Railway Supply, LLC
`
`
`
`2
`
`
`
`

`

`VERIFICATION
`
`I, Mickey Korzeniowski, declare, in accordance with 19 C.F.R. § 210.71, under penalty
`
`of perjury, that the following statements are true and correct:
`
`1.
`
`I am the General Manager of Standard Car Truck Company, Inc., and I am duly
`
`authorized to sign the foregoing Report on behalf of Barber Tianrui Railway
`
`Supply, LLC;
`
`I have read the foregoing Report; and
`
`To the best of my knowledge, information and belief, the facts stated therein are
`
`2.
`
`3.
`
`true and correct.
`
`Executed this:;JiJ day of May, 2020.
`
`Mickey Korieniowski
`General Manager of Standard Car Truck Company, Inc.
`
`

`

`
`
`Certificate of Service
`
`I hereby certify that on May 26, 2020, true copies of the foregoing FINAL REPORT OF
`RESPONDENT BARBER TIANRUI RAILWAY SUPPLY, LLC PURSUANT TO SECTION
`V OF THE ORDER TO CEASE AND DESIST were served upon the following parties in the
`manner indicated below:
`
`Via Electronic Filing
`
`
`
`Via E-mail
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE
`COMMISSION
`500 E Street, S.W.
`Washington, DC 20436
`
`Office of Unfair Import Investigations
`Jeffrey T. Hsu, Esq.
`Office of Unfair Import Investigations
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`
`jeffrey.hsu@usitc.gov
`
`
`
`Counsel for Complainant Amsted Industries Incorporated
`Via E-mail
`Gregory J. Volger
`Dean A. Pelletier
`Yufeng Ma
`MCANDREWS, HELD & MALLOY, LTD.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`
`amsted-ITC@mcandrews-ip.com
`
`
`
`1
`
`
`
`

`

`
`
`Counsel for Respondents Barber Tianrui Railway Supply LLC, Tianrui Group Foundry
`Company Limited, and Tianrui Group Limited
`Via E-mail
`Tom M. Schaumberg
`David H. Hollander
`Qian Sheng
`Katherine R. Lahnstein- Bertocci
`ADDUCI, MASTRIANI & SCHUMBERG, L.L.P.
`1200 17th Street, N.W. Fifth Floor
`Washington, D.C. 20036-3006
`
`tian@adduci.com
`Ruixue Ran, Esq.
`COVINGTON & BURLING LLP
`2301 Jianguomenwai Avenue
`Chaoyang Dist., Beijing 100022
`CHINA
`
`rran@cov.com
`
`
`Via E-mail
`
`
`
`
`
`
`
`By: /s/ Raquel A. Bacchus
`Raquel A. Bacchus
`Paralegal for Respondent
`Barber Tianrui Railway Supply, LLC
`
`
`
`2
`
`
`
`

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