`
`September 22, 2017
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W., Room 112
`Washington, D.C. 20436
`
`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, California 94303-2214
`www.dlapiper.com
`
`Aaron Wainscoat
`aaron.wainscoat@dlapiper.com
`T 650.833.2442
`F 650.687.1135
`
`OUR FILE NO. 351912-000029
`
`
`
`Re:
`
`In the Matter of Certain Non-Volatile Memory Devices and Products Containing Same,
`Inv. No. 337-TA-1046
`
`Dear Secretary Barton:
`
`Enclosed please find the Agreement to be Bound by the Protective Order for Charles F. Graf on behalf of
`Respondents Toshiba Corporation, Toshiba America, Inc., Toshiba America Electronic Components, Inc.,
`Toshiba America Information Systems, Inc., and Toshiba Information Equipment (Philippines) Inc.
`(collectively, “Toshiba”) in the above-referenced proceeding.
`
`Respectfully submitted,
`
`DLA Piper LLP (US)
`
`/s/ Aaron Wainscoat
`
`Aaron Wainscoat
`Partner
`
`Admitted to practice in California
`
`cc: Service list as attached
`
`
`
`EAST\146755520.1
`
`
`
`September 21, 2017
`VIA E-FILING
`
`The Honorable Lisa R. Barton
`
`Secretary
`US. International Trade Commission
`
`500 E Street, S,W.
`Washington, DC. 20436
`
`Re:
`
`In the Matter of Certain Non-Volatile Memory Devices and Products Containing Same
`Inv. No. 337-TA-1046
`
`Dear Secretary Barton:
`
`The undersigned graphics consultant for Respondents Toshiba Corporation, Toshiba America, Inc.,
`
`Toshiba America Electronic Components, Inc., Toshiba America Information Systems, Inc., and Toshiba
`
`Information Equipment (Philippines) Inc., hereby certifies that I have read Order No. 1: Protective Order,
`
`Order No. 3: Amendment to Protective Order, and Order No. 13: Granting Joint Motion to Amend the
`
`Protective Order, issued by Administrative Law Judge Dee Lord in this Investigation on April 10, 12, and
`
`20, 2017. In accordance with Order Nos. 1, 3, and 13, I hereby agree:
`
`a.
`
`b.
`
`c.
`
`to be bound by the terms thereof;
`
`not to reveal such confidential business information to anyone otherthan another person
`
`designated in paragraph 3; and
`
`to utilize such confidential business information solely forthe purposes ofthis
`
`investigation.
`
`I, the undersigned, further acknowledge that information submitted for purposes ofthis 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
`
`(ii)
`
`by US. government employees and contract personnel, solely for cybersecurity
`
`purposes.
`
`I understand that all contract personnel will sign appropriate nondisclosure
`
`agreements.
`
`
`
`The Honorable Lisa R. Barton
`
`September 21, 2017
`Page Two
`
`Respectfully submitted,
`
`Charles F. Graf
`
`Blueprint Trial Consulting
`Partner/ Senior Graphic Consultant
`
`cc:
`
`Service list as attached.
`
`
`
`CERTIFICATE OF SERVICE
`
` Via Hand Delivery
` Via Overnight Courier
` Via E-Filing
`
` Via Hand Delivery
` Via Overnight Courier
` Via Electronic mail
`
` Via Hand Delivery
` Via Overnight Courier
` Via Electronic Email
`
` Via Electronic Mail
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`I, Laurie E. Ouchida, hereby certify that on September 22, 2017, a copy of
`
`AGREEMENT TO BE BOUND BY THE PROTECTIVE ORDER OF CHARLES F.
`GRAF was served on the following as indicated:
`
`The Honorable Lisa R. Barton
`Secretary
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`
`The Honorable Dee Lord
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`E-mail: edward.jou@usitc.gov
`
`Vu Bui
`Office Of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, D.C. 20436
`E-mail: vu.bui@usitc.gov
`
`Complainants Macronix International Co., Ltd. and
`Macronix America, Inc.:
`
`Christian A. Chu
`Fish & Richardson P.C.
`The McPherson Building
`901 15th Street NW, 7th Floor
`Washington, D.C. 20005
`Email: FRService-Macronix/Toshiba@fr.com
`
`
`
`
`
`
`
`/s/ Laurie E. Ouchida
`
`
`Laurie E. Ouchida
`Paralegal Specialist
`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303
`Telephone: 650-833-2000
`Facsimile: 650-833-2001
`
`EAST\144706693.1
`
`
`
`
`
`1
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`
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