FISH.
`
`Fl$i'i 3- Rl.'_§l"A7‘tl')SOl\l
`
`VIA HAND DELIVERY & EDIS
`
`April
`
`15, 2016
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S.
`International
`Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Fish & Richardson P.C.
`I425 K Strccl, NNV.
`llth Floor
`Washington, DC 20005
`202 783 SO70 main
`‘Z02 783 ‘Z331 liix
`
`'
`
`Linda L. Kordziel
`k0rdZicl@l’r com
`
`DOCKEY
`
`NUMBER
`
`’ i
`
`Re:
`
`Certain Hybrid Electric Vehiclesand Componen s
`
`l
`L“/l
`_ _____________________
`__
`-------- -bifiiceofthe
`Secretary
`|nt'l' franc Commission
`ereo ; nv. os.
`
`- A-__
`
`Dear Secretary Barton:
`
`Enclosed for filing on behalf of Paice LLC (“Paice”) and the Abell Foundation, Inc. (“Abell”)
`(collectively, “Complainants”) please find documents in support of Complainants request that the
`Commission commence an investigation pursuant to the provisions of Section 337 ofthe Tariff
`Act of 1930, as amended, I9 U.S.C. § I337. Please note that Confidential Exhibit_59 contains
`Confidential Business Information. Accordingly, pursuant to the Commission’s Rules of
`Practice and Procedure, a request for confidential treatment for Confidential Exhibit 59
`accompanies this filing. Complainants hereby submits the following:
`
`l. One (I) original and eight (8) copies ofComplainants Verified Complaint and the Public
`Interest Statement; one (I) CD containing the Nonconfidential Exhibits and one (1) CD
`containing the Confidential Exhibits (201.6(c), 2lO.4(1‘)(2)and 210.8(a)(l)(i) and
`21 0.8(b));
`'
`'
`
`2. Six (6) additional copies ofthe Verified Complaint, Public Interest Statement and six (6)
`CD5 containing the nonconfidential and confidential exhibits (each set ofexhibits on
`separate CD5), for service upon the following Proposed Respondents: Volkswagen AG;
`Volkswagen Group of America, Inc.; Dr. Ing. I-I.C.F. Porsche AG; Porsche Cars North
`America, Inc.; Audi AG; and Audi of America, LLC (201.6(c), 21O.4(t)(2) and
`2lO.8(a)(1)(i) and 2l0.8(b));
`
`3. Three (3) additional copies ofthe Verified Complaint and Public Interest Statement for
`the Embassy ofthe Federal Republic of Germany (210.8(a)(l)(iv);
`
`trcorn
`
`

`
`F IS H .
`
`F1.“=H R. Fill:-~eAF<=':5;\.T1rJ
`
`One (1) copy ofeach of the following asserted United States Patents: U.S. Patent No.
`7,104,347; U.S. Patent No. 7,237,634; and U.S. Patent No. 8,214,097, included with the
`Complaint as Exhibits 1-3' (2lO.12(a)(9)(i));
`p
`
`One (1) copy and four (4) additional copies (on CD5) ofprosecution histories for each of
`the following asserted United States Patents: U.S, Patent No. 7,104,347; U.S. Patent No.
`7,237,634; and U.S. Patent No. 8,214,097, included with the Complaint as Appendices A­
`C (210.12(c)(1));
`
`One (1) copy of the assignment records for each of the following asserted United States
`Patents: U.S. Patent No. 7,104,347; U.S. Patent No. 7,237,634; and U.S. Patent No.
`8,214,097, included with the Complaint as Exhibits 4-26 (210.12(a)(9)(ii));
`
`Four (4) copies (on CDs) of the technical references mentioned in the prosecution
`histories for each of the following asserted United States Patents: U.S. Patent No.
`7,104,347; U.S. Patent No. 7,237,634; and U.S. Patent No. 8,214,097, included with the
`Complaint as Appendices D-F (210.12(c)(2)); and
`
`A letter and certification pursuant to Commission Rules 201.6(1))and 2l0.5(d) requesting
`confidential treatment of Confidential Exhibit 59.
`
`Please do not hesitate to contact me should you have any questions.
`
`Sincerely,
`
`gt/.;2QZQQ
`
`Linda L. Kordziel
`
`Encl.
`
`"
`
`'
`
`I
`
`' Certified copies ofU.S. Patent No. 7,104,347, U.S. Patent No. 7,237,634, and U.S. Patent No. 8,214,097 have been
`ordered and will be submitted to the Commission upon receipt.
`
`

`
`FISH.
`
`FlS‘1.’_( FilCl"ié'<l-E-.l‘$Ql\l
`
`‘
`'
`'
`VIA HAND DELIVERY & EDIS
`
`April 15, 2016
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Fish & Richardson P.C.
`1425 K Street, NW.
`llth Floor
`Washington, DC 20005
`202 783 5070 main
`202 783 2331 fax
`
`Linda L. Korclziel
`kordziel@fr.com
`
`'
`
`Re:
`
`Certain Hybrid Electric Vehiclesand Components Thereofi Inv. Nos. 337-TA-___
`
`Dear Secretary Barton:
`
`Fish & Richardson P.C. represents Paice LLC (“Paice”) and the AbellFoundation, Inc. (“Abell”)
`(collectively, “Complainants”) in the above referenced matter, which is being filed pursuant to
`Section 337 ofthe TariffAct of 1930, as amended, 19 U.S.C.§ 1337.
`
`Pursuant to Commission Rules 201.6(b) and 2l0.5(d), Complainants respectfully request
`confidential treatment ofthe information contained in Confidential Exhibit 59. Confidential
`Exhibit S9 qualifies as confidential infomiation in that the exhibitdiscloses proprietary
`commercial information and/or proprietary business information not otherwise publicly
`available, would cause substantial harm to Complainants, and would impair the Commission’s
`ability in the future to obtain such types of information in perfonnance of its statutory function.
`
`l certify that the proprietary confidential commercial information and/or proprietary business
`information present in Confidential Exhibit 59 is not reasonably available to the public, and thus
`warrants confidential treatment.
`,
`
`Please do not hesitate to contact me should you have any questions.
`
`Sincerely,
`
`page <<§,_;e
`
`Linda L. Kordziel
`
`Encl.
`
`fr.com