DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`www.dlapiper.com
`
`Helena Kiepura
`Helena.Kiepura@us.dlapiper.com
`T 202.799-4000
`F 202.799.5000
`
`December 13, 2024
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Component Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`Enclosed please find the Agreements to be Bound by the Protective Order (Order No. 1) for Helena
`Kiepura, Matthew Satchwell, Shaobin Zhu, Claire Schuster, Benjamin Yaghoubian, Paulina Starostka, and
`Peter VandeVort, filed on behalf of Respondents Hunan Sijiu Technology, Co. Ltd., Hunan Sijiu Electronic
`Technology Co., Ltd. and Guangdong Rongtu Technology Co., Ltd. in the above-referenced matter.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Helena Kiepura
`
`Helena Kiepura
`
`HK:lmm
`Enclosure
`
`1615589173.1
`
`
`500 Eighth Street, NW
`Washington, DC 20004
`www.dlapiper.com
`
`Helena Kiepura
`Helena.Kiepura@us.dlapiper.com
`T 202.799-4000
`F 202.799.5000
`
`December 13, 2024
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, DC 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Component Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`Enclosed please find the Agreements to be Bound by the Protective Order (Order No. 1) for Helena
`Kiepura, Matthew Satchwell, Shaobin Zhu, Claire Schuster, Benjamin Yaghoubian, Paulina Starostka, and
`Peter VandeVort, filed on behalf of Respondents Hunan Sijiu Technology, Co. Ltd., Hunan Sijiu Electronic
`Technology Co., Ltd. and Guangdong Rongtu Technology Co., Ltd. in the above-referenced matter.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Helena Kiepura
`
`Helena Kiepura
`
`HK:lmm
`Enclosure
`
`1615589173.1
`
`
`
`DLA Piper LLP (US)
`444 West Lake Street Suite 900
`Chicago, IL 60606
`www.dlapiper.com
`
`Matthew Satchwell
`matthew.satchwell@us.dlapiper.com
`T 312.368.4000
`F 312.251.5708
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Matthew Satchwell
`
`Matthew Satchwell
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`www.dlapiper.com
`
`Helena D. Kiepura
`helena.kiepura@us.dlapiper.com
`T 202.799.4333
`F 202.799.5300
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Helena D. Kiepura
`
`Helena D. Kiepura
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`701 Fifth Avenue Suite 6900
`Seattle, WA 98104
`www.dlapiper.com
`
`Shaobin Zhu
`shaobin.zhu@us.dlapiper.com
`T 206.839.4894
`F 202.799.5300
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Shaobin Zhu
`
`Shaobin Zhu
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110
`www.dlapiper.com
`
`Claire E. Schuster
`claire.schuster@us.dlapiper.com
`T 617.406.6021
`F 617.406.6121
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Claire E. Schuster
`
`Claire E. Schuster
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`Los Angele, CA 90067
`www.dlapiper.com
`
`Benjamin Yaghoubian
`benjamin.yaghoubian@us.dlapiper.com
`T 310.595.3160
`F 310 595.3360.
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Benjamin Yaghoubian
`
`Benjamin Yaghoubian
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`444 West Lake Street Suite 900
`Chicago, IL 60606
`www.dlapiper.com
`
`Paulina M. Starostka
`Paulina.Starostka@us.dlapiper.com
`T 312.368.2108
`F 312.251.5708
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Paulina M. Starostka
`
`Paulina M. Starostka
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`DLA Piper LLP (US)
`555 Mission Street Suite 2400
`San Francisco, CA 94105
`www.dlapiper.com
`
`Peter D. VandeVort
`peter.vandevort@us.dlapiper.com
`T 415.615.6021
`F 415.659.7321.
`
`December 13, 2024
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`Re:
`
`In the Matter of Certain Crafting Machines and Components Thereof
`Inv. No. 337-TA-1426
`
`Dear Secretary Barton:
`
`I am an attorney with the law firm of DLA Piper LLP (US) and represent Respondents Hunan Sijiu
`Technology, Co. Ltd., Hunan Sijiu Electronic Technology Co., Ltd. and Guangdong Rongtu Technology
`Co., Ltd. (“HTVRONT”) in the above-referenced proceeding. I have read Order No. 1: Protective Order
`issued by Chief Administrative Law Judge Clark S. Cheney on December 12, 2024 and in accordance to
`that order, hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information supplied to me in accordance with
`the provisions of paragraph 2 of the Protective Order to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`
`to utilize such confidential business information solely for the purposes of this
`investigation.
`
`
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of HTVRONT
`acknowledge that information submitted for purposes of this Investigation may be disclosed to and used:
`
`(i)
`
`by the Commission, its employees and Offices, and contract personnel (a) for
`developing or maintaining the records of this or a related proceeding, or (b) in
`internal investigations, audits, reviews, and evaluations relating to the programs,
`personnel, and operations of the Commission including under 5 U.S.C. Appendix
`3; or
`
`
`
`December 13, 2024
`Page Two
`
`(ii)
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate nondisclosure
`agreements.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Peter D. VandeVort
`
`Peter D. VandeVort
`
`cc:
`
`Service list as attached.
`
`ACTIVE\1606200317.1
`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES AND
`COMPONENTS THEREOF
`
`Inv. No. 337-TA-1426
`
`I, Lisa M. Mix, hereby certify that on December 13, 2024, a copy of Letter to The Honorable
`Lisa R. Barton regarding Protective Order Subscriptions was served on the following as
`indicated:
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`The Honorable Clark S. Cheney
`Chief Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW, Room 317
`Washington, DC 20436
`Cheney1426@usitc.gov
`
`Counsel for Staff:
`
`Yoncha Kundupoglu, Esq.
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`yoncha.kundupoglu@usitc.gov
`
`Complainant Cricut, Inc.:
`
`Jay H. Reiziss
`Alexander P. Ott
`Timothy M. Dunker
`MCDERMOTT WILL & EMERY LLP
`
`1615534223.1
`
`1
`
` Via EDIS
` Via Hand Delivery
` Via Overnight Courier
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Box
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
`
`
`500 North Capitol Street, NW
`Washington, DC 20001
`
`David J. Tobin
`MCDERMOTT WILL & EMERY LLP
`2501 North Harwood Street Suite 1900
`Dallas, TX 75201
`
`James M. Oehler
`Tessa M. Kroll
`MCDERMOTT WILL & EMERY LLP
`444 West Lake Street, Suite 4000
`Chicago, IL 60606
`
`Email: cricutitc@mwe.com
`
`Respondents:
`
`LiPing Zhan
`No. 187, Yanglinguan Street
`Xingou Town, Jianli County
`Jingzhou, 433300
`
`SainStore Technology Co., Ltd
`Room 908, Building 2, No. 16, Keji 4th Road
`Songshan Lake Park, Dongguan City Guangdong
`Province, China 523808
`
`Shanghai Sishun E-commerce Co., Ltd.
`5th Floor, Building 6, Lane 958, Jinsha Jiangxi Road
`Jiading District Shanghai, China 201824
`
`Bozhou Wanxingyu Technology Co. Ltd.
`No. 26, Guangming Rd., Qiaocheng Dist.
`Bozhou, Anhui, China, 236800
`
`Bozhou Zhongdaxiang Technology Co., Ltd.
`No. 41, Zhaoyangzhuang Vil., Dawang Xingzheng
`Vil. Niuji Town, Qiaocheng Dist.
`Bozhou, Anhui, China 236800
`
`1615534223.1
`
`2
`
`Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
` Via First Class Mail
` Via Hand Delivery
` Via Overnight Courier
` Via Facsimile
` Via Email
`
`
`
`/s/ Lisa M. Mix
`Case Manager
`DLA Piper LLP (US)
`
`1615534223.1
`
`3
`
`
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