`Washington, D.C.
`
`Before The Honorable Charles E. Bullock
`Administrative Law Judge
`
`In the Matter of
`
`CERTAIN NOISE CANCELLING
`HEADPHONES
`
`Investigation No. 337-TA-626
`
`COMMISSION INVESTIGATIVE STAFF'S SECOND UNOPPOSED MOTION FOR AN
`EXTENSION OF TIME TO FILE ITS PRE-HEARING BRIEF AND STATEMENT
`
`The Commission Investigative Staff (“Staff”) respectfully moves for an extension of time
`
`to file its pre-trial statement and brief. The Staff requests that the deadline be moved to
`
`November 21, 2008.
`
`Under the current procedural schedule, the pre-trial statement and brief are due this
`
`Friday, October 24, 2008. The Staff has learned that serious settlement negotiations are being
`
`undertaken by the private parties at this time, and that they are optimistic that these negotiations
`
`will succeed. However, the next deadline is that of the Staff’s pre-trial submissions this Friday,
`
`October 24. Accordingly, the Staff is requesting a four-week extension of this deadline to
`
`November 21. This extension will not affect any other dates in the procedural schedule,
`
`including the trial, which is not until December 4-12.
`
`This request is further supported by the fact that the Staff attorney assigned to this
`
`investigation has a Wednesday, October 22 deadline (i.e., tomorrow) for the pre-trial brief in
`
`Investigation No. 337-TA-619, which then goes to trial on Monday, October 27 for two weeks.
`
`
`
`Accordingly, the Staff believes that the additional requested time will greatly assist the Staff in
`
`fully addressing the issues in the instant investigation.
`
`The private parties have been contacted. Counsel for Bose, Creative/Phitek and Audio-
`
`Technica have indicated that they do not oppose the motion for an extension. The Staff has not
`
`heard back from counsel for Panasonic on their position as to this motion.
`
`
`
`October 21, 2008
`
`Respectfully submitted,
`
`/s/ Christopher G. Paulraj
`Lynn I. Levine, Director
`Thomas S. Fusco, Supervisory Attorney
`Christopher G. Paulraj, Investigative Attorney
`OFFICE OF UNFAIR IMPORT INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`(202) 205-3052
`(202) 205-2158 (Facsimile)
`
`
`
`Certain Noise Cancelling Headphones
`
`Investigation No. 337-TA-626
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on October 21, 2008, he caused the foregoing COMMISSION INVESTIGATIVE
`STAFF’S UNOPPOSED MOTION TO FILE ITS PRE-HEARING STATEMENT AND BRIEF to be filed
`with the Secretary, served by hand upon Administrative Law Judge Charles E. Bullock (2 copies), and served upon
`the parties (1 copy each) in the manner indicated below:
`
`Counsel for Complainant Bose Corporation
`
`Ruffin B. Cordell
`Andrew R. Kopsidas
`Jeffrey R. Whieldon
`Autumn J. Hwang, Esq.
`FISH & RICHARDSON P.C .
`1425 K Street, N.W., Suite 1100
`Washington, DC 20005
`Telephone: 202-783-5070
`Facsimile: 202-783-2331
`
`Jordan Fowles
`FISH & RICHARDSON P.C .
`717 Main Street, Suite 5000
`Dallas, TX 75201
`Telephone: 214-747-5070
`Facsimile: 202-747-2091
`
`BY EMAIL AND FIRST CLASS MAIL
`
`BY EMAIL AND FIRST CLASS MAIL
`
`Counsel for Respondents Creative Labs, Inc., Phitek
`Systems Limited, GN Netcom, Inc., and Logitech Inc.
`
`BY EMAIL AND FIRST CLASS MAIL
`
`BY EMAIL AND FIRST CLASS MAIL
`
`William B. Nash
`Dan Chapman
`Mark Fassold
`JACKSON WALKER L.L.P.
`112 E. Pecan Street, Suite 2400
`San Antonio, Texas 78205
`Telephone: 210-978-7700
`Facsimile: 210-242-4620
`
`Alan Cope Johnson
`G. Brian Busey
`Cynthia Lopez
`MORRISON & FOERSTER LLP
`2000 Pennsylvania Ave, N. W.
`Washington, DC 20006
`Telephone: 202-887-1500
`Facsimile: 202-887-0168
`
`
`
`Counsel for Respondent Audio Technica U.S., Inc.
`
`BY EMAIL AND FIRST CLASS MAIL
`
`Arthur Wineburg
`Daniel E. Yonan
`AKIN GUMP STRAUSS HAUER & FELD LLP
`1333 New Hampshire Avenue, N.W.
`Washington, DC 20036
`Telephone: 202-887-4000
`Facsimile: 202-887-4288
`
`BY EMAIL AND FIRST CLASS MAIL
`
`James P. White
`Gerald T. Shekleton
`J. Aron Carnanhan
`WELSH & KATZ, LTD.
`120 South Riverside Plaza, 22”d Floor
`Chicago, IL 60606
`Telephone: 312-655-1500
`Facsimile: 312-655-1501
`
`Counsel for Respondent Panasonic Corporation of North America
`
`BY EMAIL AND FIRST CLASS MAIL
`
`Tom M. Schaumberg
`Jamie D. Underwood
`ADDUCI, MASTRIANI & SCHAUMBERG, LLP
`1200 Seventeenth Street, N.W., Fifth Floor
`Washington, DC 20036
`Telephone: 202-467-6300
`Facsimile: 202-466-2006
`
`BY EMAIL AND FIRST CLASS MAIL
`
`Daniel S. Ebenstein
`Abraham Kasdan
`Joseph M. Casino
`David A. Boag
`AMSTER, ROTHSTEIN & EBENSTEIN LLP
`90 Park Avenue
`New York, NY 10016
`Telephone: 212-336-8000
`Facsimile: 212-336-8001
`
` /s/ Christopher G. Paulraj
`Christopher G. Paulraj
`Investigative Attorney
`
`OFFICE OF UNFAIR IMPORT INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`(202) 205-2575
`(202) 205-2158 (fax)
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