throbber
Weil, Gotshal & Manges LLP
`Weil, Gotshal & Manges LLP
`
`VIAEDIS
`VIA EDIS
`
`201 Redwood Shores Parkway
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`Redwood Shores, CA 94065
`+1 650 802 3000 tel
`+1 650 802 3000 tel
`+1 6508023100 fax
`+1 650 802 3100 fax
`
`Jill J. Ho
`Jill J. Ho
`+1 6508023163
`+1 650 802 3163
`jill.ho@weil.com
`jill.ho@weil.com
`
`March 14, 2011
`March 14,2011
`
`James R. Holbein
`James R. Holbein
`Acting Secretary
`Acting Secretary
`U.S. International Trade Commission
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Related Software
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`Dear Acting Secretary Holbein:
`
`Enclosed for submission in the above-referenced investigation please find Letters of
`Enclosed for submission in the above-referenced investigation please find Letters of
`Acknowledgment of the Protective Order from David Akopian, Jonathan Aldrich, Ravin Balakrishnan,
`Acknowledgment of the Protective Order from David Akopian, Jonathan Aldrich, Ravin Balakrishnan,
`Leonard Cimini, Jr., Eyal de Lara, Edward Delp, Steven Feiner, George Gerpheide, Richard Goodin,
`Leonard Cimini, Jr., Eyal de Lara, Edward Delp, Steven Feiner, George Gerpheide, Richard Goodin,
`Thomas Kite, Mark Lanning, Narayan Mandayam, Brian Noble, Kent Norman, and William Scherlis,
`Thomas Kite, Mark Lanning, Narayan Mandayam, Brian Noble, Kent Norman, and William Scherlis,
`experts for Respondent Apple Inc., agreeing to be bound by the terms of the Protective Order (Order No.
`experts for Respondent Apple Inc., agreeing to be bound by the terms of the Protective Order (Order No.
`1) issued by Administrative Law Judge Theodore R. Essex.
`1) issued by Administrative Law Judge Theodore R. Essex.
`
`Respectfully submitted,
`Respectfully submitted,
`
`(f-ttv
`
`Jill J. Ho
`Jill J. Ho
`
`

`
`David Akopian
`Consultant
`115 Brae Hill
`San Antonio, TX 78249
`
`Main Affiliation:
`Electrical & Computer Engineering Department
`University of Texas at San Antonio
`One UTSA Circle
`San Antonio, TX 78249-0669
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`David Akopian
`
`

`
`Jonathan Aldrich
`Institute for Software Research
`School of Computer Science
`Carnegie Mellon University
`5000 Forbes Avenue
`Pittsburgh, PA 15213-3891
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`

`
`Ravin Balakrishnan
`166 Ramsey Road
`Little Britain, Ontario
`Canada K0M2C0
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`

`
`Leonard Cimini, Jr.
`1314 Varsity Lane
`Bear, DE 19701
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`

`
`Eyal de Lara
`University of Toronto
`Bahen Centre for Information Technology
`40 St. George Street
`Toronto, Ontario M5S 2E4
`
`March 7, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW. Room 112-A
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 ofthe Protective Order (Order No.1), I have read Order No.1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order:
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order: and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`Sincerely,
`
`Eyal de Lara
`
`

`
`Edward Delp
`2600 Shagbark Lane
`West Lafayette, IN 47906
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`Edward Delp
`
`

`
`Steven Feiner
`Department of Computer Science
`Columbia University
`500 W. 120th St., 450 CS Building
`New York, NY 10027
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`Steven Feiner
`
`

`
`George Gerpheide
`c2mw4 LLC
`P.O. Box 950
`Sandy, UT 84091-0950
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`George Gerpheide
`
`

`
`Richard M Goodin
`659 Cary Towne Blvd Suite 205
`Cary, NC 27511-4219
`
`March 3, 201 t
`
`The llonorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW. Room 112-A
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Related Software
`lnv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`T have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 of the Protective Order (Order No. I l. I have read Order No. I and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business infonnation to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business infonnation solely for the purpose of this
`investigation.
`
`Sincerely,
`
`7L!~AL-
`
`Richard M Goodin
`
`

`
`Thomas Kite
`17202 SW Sarala St.
`Beaverton OR 97007
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. lntemational Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 ofthe Protective Order (Order No. I), I have read Order No. I and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms ofthe Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`Sincerely,
`
`Thomas Kite
`
`

`
`Mark Lanning
`4 Eagles Nest
`Greenville, TX 75402
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`

`
`Narayan Mandayam
`5 Penny Ct
`East Brunswick, NJ 08816
`
`March 4, 20 II
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. lntemational Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Related Soj/ware
`lnv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 of the Protective Order (Order No. I), I have read Order No. I and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`

`
`Brian Noble
`University of Michigan
`Electrical Engineering and Computer Science
`2260 Hayward
`Ann Arbor, MI 48109-2121
`
`March 8, 201 1
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`
`Re: Certain Mobile Devices and Refated Sofiware
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 of the Protective Order (Order No.1), I have read Order No.1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business infOlmation solely for the purpose of this
`i nves(igation.
`
`

`
`Kent Norman
`7 Thomas Drive
`Silver Spring, MD 20904-2930
`
`March 2, 2011
`
`The Honorable James R. Holbein
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 112-A
`Washington, D.C. 20436
`Re: Certain Mobile Devices and Related Software
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbein:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`
`paragraph 4 of the Protective Order (Order No. 1), I have read Order No. 1 and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`
`
`
`
`
`
`
`
`
`
`
`
`to be bound by the terms of the Protective Order;
`not to reveal confidential business information to anyone other than another
`person designated in paragraph 3 of the Protective Order; and
`to utilize such confidential business information solely for the purpose of this
`investigation.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Sincerely,
`
`Kent Norman
`
`

`
`William Scherl is
`5854 Aylesbo ro Ave
`Pittsburgh PA 152 17
`
`March 10, 201 1
`
`The Honorable James R. Holbei n
`Acting Secretary
`U.S. International Trade Commission
`500 E Street SW, Room 11 2-A
`Washington, D.C. 20436
`
`Re: Cerwin Mobile Devices and Related Sojhjl(l1'e
`Inv. No. 337-TA-750
`
`Dear Acting Secretary Holbei n:
`
`I have been retained as an expert by Apple Inc. in the above captioned proceeding. Pursuant to
`paragraph 4 of the Protective Order (Order No. I), I have read Order No. I and in accordance with that
`order, hereby agree:
`
`a)
`b)
`
`c)
`
`to be bound by the terms of the Protective Order;
`not to reveal confident ial business informatio n to anyone other than another
`person designated in paragraph 3 of the Protecti ve Order; and
`to ut ilize such confiden tial business infonnation solely for the purpose of this
`investigation.
`
`Sincerely,
`
`William Scherlis
`
`

`
`CERTIFICATE OF SERVICE
`CERTIFICATE OF SERVICE
`
`I hereby certify that a copy of the foregoing was served on March 14, 2011 as indicated, on the
`I hereby certify that a copy of the foregoing was served on March 14, 2011 as indicated, on the
`following:
`following:
`
`Via Hand Delivery (Via EDIS)
`Via Hand Delivery' (Via EDISi
`James R. Holbein
`James R. Holbein
`Acting Secretary
`Acting Secretary
`U.S. International Trade Commission
`U.S. International Trade Commission
`500 E Street SW, Room 112
`500 E Street SW, Room 112
`Washington, D.C. 20436
`Washington, D.C. 20436
`
`Via Email and Hand Delivery
`Via Email and Hand Deliver.r,
`Anne Goalwin
`Anne Goalwin
`Office of Unfair Import Investigations
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 401
`500 E Street, S.W., Room 401
`Washington, D.C. 20436
`Washington, D.C. 20436
`
`anne.goalwin@ustic.gov
`anne. goalwin@ustic.gov
`
`Via Email and Hand Delivery
`Via Email and Hand Delivery'
`Charles F. Schill
`Charles F. Schill
`STEPTOE & JOHNSON LLP
`STEPTOE & JOHNSON LLP
`1330 Connecticut Avenue, N.W.
`1330 Connecticut Avenue, N.W.
`Washington, DC 20036
`Washington, DC 20036
`
`motoro1a750@steptoe.com
`motorola 7 50@steptoe.com
`
`Via Hand Delivery (2 copies)
`Via Hand Delivery' (2 c01l.iesi
`The Honorable Theodore R. Essex
`The Honorable Theodore R. Essex
`Office of the Administrative Law Judge
`Office of the Administrative Law Judge
`U.S. International Trade Commission
`U.S. International Trade Commission
`500 E Street SW, Room 317
`500 E Street SW, Room 317
`Washington, D.C. 20436
`Washington, D.C. 20436
`
`Via Email
`Via Email
`Charles K. Verhoeven
`Charles K. Verhoeven
`Quinn Emanuel Urquhart & Sullivan LLP
`Quinn Emanuel Urquhart & Sullivan LLP
`50 California Street, 22nd Floor
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`San Francisco, CA 94111
`
`David A. Nelson
`David A. Nelson
`Quinn Emanuel Urquhart & Sullivan
`Quinn Emanuel Urquhart & Sullivan
`LLP 500 West Madison Street, Ste. 2450
`LLP 500 West Madison Street, Ste. 2450
`Chicago, IL 60661
`Chicago, IL 60661
`
`Edward J. DeFranco
`Edward J. DeFranco
`Quinn Emanuel Urquhart & Sullivan
`Quinn Emanuel Urquhart & Sullivan
`LLP
`LLP
`51 Madison Avenue, 22nd Floor
`51 Madison A venue, 22nd Floor
`New York, NY 10010
`New York, NY 10010
`
`Apple-Moto-750@quinnemanuel.com
`Apple-Moto-750@quinnemanuel.com
`
`~~
`~olleen Sp~
`
`olleen Spar
`Paralegal
`Paralegal

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