`WASHINGTON, D.C.
`20006-1888
`
`TELEPHONE: 202.887.1500
`FACSIMILE: 202.887.0763
`
`WWW.MOFO.COM
`
`M O R R I S O N & F O E R S T E R L L P
`B E I J I N G , B E R L I N , B R U S S E L S ,
`D E N V E R , H O N G K O N G , L O N D O N ,
`L O S A N G E L E S , N E W Y O R K ,
`N O R T H E R N V I R G I N I A , P A L O A L T O ,
`S A N D I E G O , S A N F R A N C I S C O , S H A N G H A I ,
`S I N G A P O R E , T O K Y O , W A S H I N G T O N , D . C .
`
`August 8, 2017
`
`Writer’s Direct Contact
`+1 (202) 887.1507
`MWhitaker@mofo.com
`
`Via EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`
`Re: Certain Digital Cameras, Software, and Components Thereof,
`Investigation No. 337-TA-1059
`
`Dear Secretary Barton:
`
`Enclosed is an Acknowledgement to Abide by the Protective Order for the above
`referenced matter for Respondents Nikon Corporation; Sendai Nikon Corporation; Nikon
`Inc.; Nikon (Thailand) Co., Ltd.; Nikon Imaging (China) Co., Ltd., and PT Nikon
`Indonesia (collectively, “Nikon”) for Stephen C. Rumsey.
`
`Respectfully submitted,
`
`Mark L. Whitaker
`Counsel for Respondents
`
`Enclosure
`
`dc-885233
`
`
`
`August 8, 2017
`
`ViaEDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`
`Re: Certain Digital Cameras, Software, and Components Thereof,
`Investigation No. 337-TA-1059
`
`Dear Secretary Barton:
`
`I am serving as an expert consultant on behalf of Respondents Nikon Corporation;
`Sendai Nikon Corporation; Nikon Inc.; Nikon (Thailand) Co., Ltd.; Nikon Imaging (China)
`Co., Ltd., and PT Nikon Indonesia (collectively, the "Respondents") in the above-referenced
`investigation. By this letter, I acknowledge that I have read and agree to the terms of the
`Protective Order (Order No. 1) issued by Judge Mary Joan McNamara in this Investigation
`on May 31 , 2017, and, in accordance with that Order, hereby agree:
`
`1.
`
`11.
`
`to be bound by the terms of the Protective Order;
`
`not to reveal 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
`
`111.
`
`to utilize such confidential business information solely for purposes of this
`investigation.
`
`As required by paragraph 4 of the Protective Order, I, the undersigned, on behalf of
`the Respondents, further acknowledge that to the best of my knowledge information
`submitted for purposes of this Investigation may be disclosed to and used:
`
`1.
`
`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
`
`
`
`The Honorable Lisa R. Barton
`August 8, 2017
`Page Two
`
`n.
`
`by U.S. government employees and contract personnel, solely for cybersecurity
`purposes. I understand that all contract personnel will sign appropriate
`nondisclosure agreements.
`
`
`
`CERTIFICATE OF SERVICE
`
`It is hereby certified that STEPHEN C. RUMSEY P.O. SUBSCRIPTION for NIKON
`
`RESPONDENTS’ was filed and served on August 8, 2017 as follows:
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, DC 20436
`
`
`
`The Honorable MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, DC 20436
`
`
`
`Jae Lee
`Attorney Advisor
`U.S. International Trade Commission
`500 E Street, S.W., Room 317
`Washington, DC 20436
`Jae.Lee@usitc.gov
`
`
`
`Joseph V. Colaianni
`Thomas S. Fusco
`FISH & RICHARDSON P.C.
`The McPherson Building
`901 15th Street, N.W., 7th Floor
`Washington, D.C. 20005
`ZeissITC1059@fr.com
`Counsel for Complainants Carl Zeiss AG and
`ASML Netherlands B.V.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` First Class Mail
` Hand Delivery – 2 Copies
` Overnight Delivery
` Facsimile
` EDIS
` Not Served
`
` First Class Mail
` Hand Delivery – 2 Copies
` Overnight Delivery
` Facsimile
` EDIS
` Not Served
`
` First Class Mail
` Hand Delivery – 2 Copies
` Overnight Delivery
` Facsimile
` EDIS
` Not Served
`
` First Class Mail
` Hand Delivery – 2 Copies
` Overnight Delivery
` Facsimile
` EDIS
` Not Served
`
`/s/ Mark A. Ferragamo
`Mark A. Ferragamo
`Sr. Paralegal
`
`
`
`
`
`
`
`
`
`
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