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`August 8, 2017
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`VIA EDIS
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. INTERNATIONAL TRADE COMMISSION
`500 E Street, SW
`Washington, DC 20436
`
`
`Fish & Richardson P.C.
`1425 K Street, N.W.
`11th Floor
`Washington, DC 20005
`202 783 5070 main
`202 783 2331 fax
`
`
`Joseph V. Colaianni, Jr.
`Principal
`colaianni@fr.com
`202 626 6434 direct
`
`Re: Certain Digital Cameras, Software, and Components Thereof,
`ITC Inv. No. 337-TA-1059
`
`
`Dear Secretary Barton:
`
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`Attached for filing on behalf of Complainants Carl Zeiss AG and ASML Netherlands
`B.V. in the above referenced proceeding, please find the nondisclosure agreements for translators
`Anna Silcocks, Frank Apps, Francis McGee, and Ronald LeVan.
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`Respectfully submitted,
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`/s/ Joseph V. Colaianni
`Joseph V. Colaianni
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`Attachment A
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`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`I, Emmi,
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`(Si lg at lg s
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`, do solemnly swaar or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`
`in the matter of Certain
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`,
`
`Investigation No. 337~TA—fl,i except as permitted in the
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`protective order issued in this case.
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`I will not directly or indirectly use, or allow the use of such
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`information for any purpose other than that directly associated with my official duties in this
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`case.
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`Further, I will not by direct action, discussion, recommendation, or suggestion to any
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`person reveal the nature or content of any information communicated during any confidential
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`portion of the investigation or hearing in this case.
`
`I also affirm that I do not hold any position or official relationship with any of the
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`participants in said investigation
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`I am aware that the unauthorized use or conveyance of information as specified above is
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`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
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`imprisonment of up to ten (10) years, or both.
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`Signed
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`Dated
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`8 74
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`\
`Firm or affiliation Wadi
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`élOl
`I
`7 4
`(( [dug-l L ltd .
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`Page 10 oflO
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`
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`Attachment A
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`NONDISCLOSURE AGREEMENT FOR REPORTERISTENOGRAPHERH'RANSLATOR
`
`,dosolemnlysweararafihnthztlwfllnmdivulge
`L]
`mhfumafimcummmimfldmmemmywnfidmfiflporflng’gthemwsfigafimmm
`in the matter of Certam___, Investigafion No. 337-'3f['£:lexoept as pemfiued in the
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`protecfiveordcrissundinflfiscase. Iwfllmdimcflyormdimcflyusgoraflowthcuscofmch
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`hfumfionfmanypmposcoihummfiaxdfiecflyassodaedwimmoflidaldufieshthis
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`case.
`
`Funher,lwiflnotbydhectacfiondiscussion,recommendafion,armggesfimmmy
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`person reveal the nature or content of any information communicated during any confidenfial
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`portion ofthciuvesfigafionmheafinginthiscase.
`
`Ialsoaffinnthatldonotholdanyposifionarofiicialrelafionélfip wifiaauyofthe
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`panicipamsinsfidinvcstigafion.
`
`IamawarethattheWmemwnveyanccofinfnmafimasspcnifiodaboveis
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`aviolafionoffimFedetalCriminalCodeandpmfishabiebyafineofup«3310,0930,
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`imprisnnmmt ofWflO} years, or 13011:.
`Signed
`“K
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`.
`Wm“— ' 8 r1
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`_7
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`Page m cm
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`
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`Attachment A
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`NONDISC LOSURE AGREEMENT FOR REPORTERISTENOGRAPHERITRANSLATOR
`
`I.”
`I, / 78/3ch 1 S
`
`,0
`'
`{465/5 . do soiemnly swear or affirm that I will not divulge
`
`any information communicated to me in any confidential portion of the investigation or hearing
`{05‘}
`, Investigation No. 337-TA-__, except as permitted in the
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`in the matter of Certain
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`protective order issued in this case,
`
`I will not directiy or indirectly use. or allow the LL92. of such
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`information for any purpose other than that direoiiy associated with my official duties in this
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`case.
`
`Further, I will not by direct action, discussion recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion ofthe investigation or hearing in this case.
`
`I aiso affirm that I do nol hold any position or official relationship with any of the
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`paflicipants in said investigation.
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`1 am aware that the unauthorized use or conveyance of infommtion as specified above is
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`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
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`,.——7
`imprisonment of‘up to ten (10} years, or both.
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`Dated __
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`a“
`- 7
`‘7
`__<2_”_i_L/d_t-JS:;:~LWM
`A:th Gram/1F; LTD ‘
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`Firm or affiliation m
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`Page 10 of 10
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`
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`Attachment A
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`NONDISCLOSURE AGREEMENT FOR REPORTER/STENOGRAPHER/TRANSLATOR
`
`1, R0 LR “Y!
`
`N . do solemnly swear or affirm that I will not divulge
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`any information communicated to me in any confidential portion of the investigation or hearing
`l0 5 (i
`
`
`, Investigation No. 337~TA—
`, except as permitted in the
`in the matter of Certain
`
`protective order issued in this case.
`
`I will not directly or indirectly use, or allow the use of such
`
`information for any purpose other than that directly associated with my official duties in this
`
`case.
`
`Further, I will not by direct action, discussion, recommendation, or suggestion to any
`
`person reveal the nature or content of any information communicated during any confidential
`
`portion of the investigation or hearing in this case.
`
`I also affirm that I do not hold any position or official relationShip with any of the
`
`participants in said investigation.
`
`I am aware that the unauthorized us: or conveyance of information as specified above is
`
`a violation of the Federal Criminal Code and punishable by a fine of up to $10,000,
`
`imprisonment of up to ten (10) years, or both.
`
`Signed
`Dated g (10 i I?
`
`Firm or affiliation
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`E mg 3
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`0‘“ Sup
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`LT“
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`,
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`w ______ w
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`_
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`Page 10 of 10
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`CERTIFICATE OF SERVICE
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`I hereby certify that true and correct copies of the foregoing NONDISCLOSURE
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`AGREEMENTS FOR TRANSLATORS have been served on this 8th day of August, 2017, on
`the following:
`
`
`
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW
`Washington, DC 20436
`
` Via First-Class Mail
` Via Hand-Delivery
` Via Express Delivery
` Via EDIS
` Via Electronic Mail
`
` Via First-Class Mail
` Via Hand-Delivery
` Via Express Delivery
` Via EDIS
` Via Electronic Mail
`
` Via First-Class Mail
` Via Hand-Delivery
` Via Express Delivery
` Via EDIS
` Via Electronic Mail
`
`The Honorable MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`Email: Jae.Lee@usitc.gov
`
`Mark L. Whitaker
`MORRISON & FOERSTER LLP
`2000 Pennsylvania Ave., NW, Suite 6000
`Washington, DC 20006
`Email: NikonITC1059@mofo.com
`
`Attorneys for Respondents Nikon Corporation, Sendai Nikon
`Corporation, Nikon Inc., Nikon (Thailand) Co., Ltd., Nikon
`Imagining (China) Co., Ltd., and PT Nikon Indonesia
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` /s/ Monika Kapuscinska-Kass
` Monika Kapuscinska-Kass
`
`Litigation Paralegal
`
`FISH & RICHARDSON P.C.
`
`12390 El Camino Real
`San Diego, CA 92130
`Kapuscinska-Kass@fr.com | 858.678.4717
`
`
`
`
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