UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

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In the Matter of

GRACOINC.,

a corporation, and

ILLINOIS TOOL WORKS INC.,

a corporation, and

ITW FINISHING LLC,

a limited liability company,

Respondents.

PUBLIC DOCUMENT

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Docket No. 9350

UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

In the Matter of 

GRACOINC., 

a corporation, and 

ILLINOIS TOOL WORKS INC., 

a corporation, and 

ITW FINISHING LLC, 

a limited liability company, 

Respondents. 

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PUBLIC DOCUMENT 

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Docket No. 9350 

02 09 2012 
UNITED STATES OF AMERICA 


FEDERAL TRADE COMMISSION 


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In the Matter of ) 

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GRACO INC., ) 

a corporation, and ) 

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ILLINOIS TOOL WORKS INC., ) Docket No. 9350 

a corporation, and ) 

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ITW FINISHING LLC, ) 

a limited liability company, ) 

Respondents. ) 

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STIPULATED ORDER CONCERNING THIRD-PARTY COMPLETE AUTOMATION, 

INC.'s PRODUCTION OF DOCUMENTS UNDER RESPONDENT'S SUBPOENA 

DUCES TECUM AND RESERVATION OF RIGHT TO SEEK REIMBURSEMENT FOR 

costs AND EXPENSES ASSOCIATED WITH SAID PRODUCTION 

On January 18,2012, third-party Complete Automation, Inc. ("Complete") filed a Motion 

to Quash and/or Limit Subpoena Duces Tecum ("Motion"). On January 30, 2012, Respondent 

Graco, Inc. ("Graco"), filed an Opposition to the Motion. For the reasons set forth in its February 2, 

2012 Order, thisCourt denied Complete's Motion without prejudice. Further, this Court ordered 

that Complete may re-file its motion to limit or quash the Subpoena, no later than February 9, 

2012. 

In lieu of re-filing its motion to limit or quash the Subpoena Duces Tecum to, among 

other things, preserve its right to seek reimbursement for costs and expenses associated with 

production of documents under said Subpoena, Complete's counsel and Respondent's counsel 

have conducted numerous telephone conferences and communicated by email and have agreed to 

the following: 

1. Two (2) weeks from the date of entry of this Order, Complete shall respond to request 

numbers 2,3,5, and 24 of Graco's Subpoena. 
2. One (I) week after responding to the above-referenced requests, Complete shall make 

itself available for deposition, at the office of The Troy Law Firm, on a date that is mutually 

agreeable to counsel. 

3. Upon completion of the above-referenced deposition, Graco shall determine if it requires 

any response from Complete to request numbers 4, 6-7, 11-13, 15, 19-23, and 25 of its 

Subpoena. In the event that Graco requires any further response from Complete, counsel shall 

mutually agree on a date for said production. 

4. At this time, Graco has agreed to withdraw request numbers 1, 8-10, 14, and 16-18 of its 

Subpoena. 

5. Graco and Complete have agreed that Complete shall reserve its right to seek 

reimbursement for costs and expenses associated with responding to request numbers 2,3,5, and 

24 of Graco's Subpoena, at the least, and any further costs and expenses associated with any 

other responses Graco may request. 

Richard 

jtJO~ A. Duncan 

Faegre Baker Daniels LLP Kimberly A. Cochrane 

2200 Wells Fargo Center The Troy Law Firm 

90 South Seventh Street 755 W Big Beaver Road, Ste 1800 

Minneapolis, MN 55402-3901 Troy, MI 48084 

(612) 766-7352 	 (248) 244-9100 

Attorneys for Graco, Inc. 	 Attorneys for Third-Party, Complete 

Automation~ Inc. 

SO ORDERED. 

Dated: ______ 

D. Michael Chappell 

Chief Administrative Law Judge 

Daniel E. Chapman 

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CERTIFICATE OF SERVICE 

I certifY that on February 9, 2012 I electronically filed a document entitled "Stipulated 

Order Concerning Third-Party Complete Automation, Inc.'s Production Of Documents Under 

Respondent's Subpoena Duces Tecum And Reservation Of Right To Seek Reimbursement For 

Costs And Expenses Associated With Said Production" with the Federal Trade Commission 

using the FTC E-Filing System, and that I served the same document upon the following: 

John H. Hinderaker, Esq. J. Robert Robertson, Esq. Katrina Robson 

Richard A. Duncan, Esq. Logan Breed, Esa. O'Melveny& Myers LLP 

Randall E. Kahnke, Esq. Hogan, Lovells US LLP 1625 Eye St., N.W. 

Faegre Baker Daniels LLP Columbia Square Washington, DC 20006 

2200 Wells Fargo Center 555 Thirteenth Street, NW 

90 South Seventh Street Washington, DC 20004 

Minneapolis, MN 55402-3901 

Phillip L. Broyles Honorable D. Michael Chappell 

Peter Richman Chief Administrative Law Judge 

Marc W. Schneider Federal Trade Commission 

Brian J. Telpner 600 Pennsylvania Avenue, N.W. 

Robert E. Friedman Washington, DC 20580 

Amanda Hamilton 

Cathlin Tully 

Anna Chehtova 

Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Washington, DC 20580 

by placing the document in an envelope properly addressed, with First Class postage affixed, and 

depositing it in a receptacle ofthe United States Mail. 

I declare that the above statements are true to the best ofmy information, knowledge, and 

belief. 

Dated: February 9,2012 	 Respectfully submitted, 

THE TROY LAW FIRM 

/s/ Kimberly A. Cochrane 

Daniel E. Chapman (P41043) 

Kimberly A. Cochrane (P73032) 

Attorneys for Non-Party, Complete 

Automation, Inc. 

755 W Big Beaver Rd, Ste 1800 

Troy, MI 48084 

(248) 244-9100 

dchapman@troylawfirnl.com 

kcochrane@troylawfirm.com 

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