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`APT“ 8= 2°16
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`The HonorableLisaR. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, sw, Room 112
`Washington’ DC 20436
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`_
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`Andrew F. Pr
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`r202.344.43s1
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`int‘!TradeConumssion
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`Re:
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`Certain Electrical Conductor Composite Cores and Components Thereof
`Inv.No.337-TA-_
`
`Dear Secretary Barton:
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`Enclosed for filing on behalf of Complainant CTC Global Corporation (“Complainant”)
`against proposed Respondents Mercury Cable & Energy, Inc., d/b/a Mercury Cable & Energy
`LLC, d/b/a Energy Technology Intemational Company, Inc. and Shenzhen Zm Hesheng Power
`Development C0., Ltd., a/k/a Mercury Composite Co. Ltd. (the ‘fProposed Respondents”) are
`documents in support of C0mplainant’s request that the Commission commence an investigation
`pursuant to Section 337 of the Tariff Act of 1930, as amended. A request for confidential
`treatment of Confidential Exhibit 18C is included with this letter.
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`1. An original and eight (8) copies of the verified Non-Confidential Complaint and the
`Public Interest Statement, one (1) CD of the accompanying Non-Confidential exhibits.
`(19 CFR §§ 201.6(0), 2l0.4(t)(2), 2lO.8(a)(l)(i), and 2l0.8(b).)
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`2. One (1) CD of the accompanying Confidential Exhibit 18C. (19 CFR §§ 201.6(0),
`210.4(t)(2), 2l0.8(a)(l)(ii), and 2l0.8(b).)
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`3. Two (2) additional copies of both the verified Non-Confidential Complaint and the Public
`Interest Statement and two (2) CDs of the Non-Confidential exhibits, for service upon the
`Proposed Respondents. (19 CFR §§ 2l0.8(a)(l)(iii).)
`'
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`4. Two (2) CD of Confidential Exhibit 18C, for service upon the Proposed Respondents. (19
`CFR §§ 2l0.8(a)(l)(iii).)
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`5. One (l) additional copy of the Non-Confidential Complaint for service upon the Embassy
`of The People’s Republic of China in Washington, DC. (2lO.8(l)(iv)).
`
`

`
`VENABLE;
`
`The Honorable Lisa R. Barton
`April 8, 2016
`Page 2
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`6f 1Non-certified cop'ies‘iofUnited stares Patent N0. i7,211;319'(=‘rh¢=319patent’i) and’
`United States Patent No_7,368,162 ( the 162 patent ) (collectively the Asseited
`Patents”); and copies of the patents on CD, cited in the Complaint as Exhibits 1 and 2 (19
`CFR §§ 2l0.8(a)(l)(iii) and 2l0.12(a)(9)(i).)
`'
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`7. Non-certified copiesg of the assignments for the Asserted Patents and copies of the
`assignments for the patents on CD, cited in the Complaint as Exhibits 3 and 4. (19 CFR
`§§ 2l0.8(a)(l)(iii) and 2l0.l2(a)(9)(ii).)
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`8. Certified copies of the prosecution histories of the Asserted Patents included in the
`Complaint as Appendices A and B, and three (3) additional copies of each on separate
`CDs. (19 CFR § 2lO.12.(c)(l).)
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`9. Four (4) copies on separate CDs of patent and technical reference documents identified in
`the prosecution histories of the Asserted Patents, included in the Complaint as
`Appendices C and D. (19 CFR § 210.l2.(c)(2).)
`
`In accordance with Commission Rules 201.6 and 210.5, Complainant requests
`confidential treatment of the business information contained in Confidential Exhibit 18C. A
`certification is provided below pursuant to 19 C.F.R §§ 201.6 and 210.5 requesting confidential
`treatment of Confidential Exhibit 18C.
`
`The infomiation for which confidential treatment is sought is proprietary commercial
`information not otherwise publicly available. Specifically, Confidential Exhibit 18C is a
`declaration that discusses proprietary and confidential business information of Complainant and
`Complainant’s investments in the domestic industry.
`»
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`The information described above qualifies as confidential business information pursuant
`to Commission Rules 201.6 because:
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`a.
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`it is not available to the public:
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`b. unauthorized disclosure of such information could cause substantial harm to the
`competitive position of Complainant; and
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`‘ Complainant has ordered certified copies of the patents at issue, but has not yet received these copies.
`Complainant will submit the certified copies immediately upon receipt.
`2 Complainant has ordered certified copies of the assignment records for the patents at_issue, but has not yet received
`these copies. Complainant will submit the certified copies immediately upon receipt.
`
`

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`VENABLE;
`
`The Honorable Lisa R. Barton
`April 8, 2016
`Page 3
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`c.
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`its disclosure could impair the Commissions’ ability to obtain information necessary
`to perform is statutory function.
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`Thank you for your attention to this matter. Please contact me if you have any questions
`
`Respectfully submitted,
`./“\ '7
`
`N F.Pratt
`
`Enclosures