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Cert Filed in Arthrex on Appointments Clause Issue

The United States petitioned the Supreme Court for certiorari in Arthrex. Cert. Pet., No. 19-1434 (June 25, 2020). Two additional petitions for writs of certiorari have been filed, one by Arthrex and one by Smith & Nephew...more

Circumstantial Evidence Can Help You Satisfy The Importation Requirement…But Only Under The Right Circumstances

In a recent summary determination order, ALJ Bullock found that complainants cannot always rely on circumstantial evidence to satisfy the Section 337 importation requirement. Certain Height-Adjustable Desk Platforms and...more

ALJ Severs Investigation for Efficient Adjudication Pursuant to 19 C.F.R. § 210.14(h)

In a recent decision, ALJ Cheney determined that severance of an investigation was necessary for efficient adjudication of the issues raised in the Complaint. Certain Light-Emitting Diode Products, Systems, and Components...more

ITC Imposes Fine for Violating Cease and Desist Order

In a recent Enforcement Initial Determination, ALJ Shaw held that Sony had violated previously issued cease and desist orders (“CDOs”) and determined that the appropriate penalty was a fine of $210,134 – Sony’s net profit...more

ITC Denies Termination Following Excessive Redactions to Settlement Agreement

The ITC recently denied a joint motion to terminate an investigation on the basis of settlement after the parties failed to meet the requisite conditions. See In re Certain Child Carriers and Components Thereof, Inv. No....more

ITC Grants Summary Determination Against Defaulting Respondents and Issues GEO

In another example of why defaulting at the ITC can be a dangerous strategy, the ITC recently found all eight named respondents in default and concluded a general exclusion order (GEO) was the appropriate remedy. Since the...more

Ground Rules Preclude New Rebuttal Expert Opinions

Shortly before the evidentiary hearing, ALJ Lord granted Complainant’s motion in limine and excluded certain testimony in the witness statement of Respondents’ expert as precluded by her ground rules governing expert...more

ITC Concludes Early Disposition Program Not Appropriate for Subject Matter Eligibility and Domestic Industry

On April 2, 2019, the Commission issued an order denying Respondents’ requests to use the Early Disposition Program. Certain Data Transmission Devices, Components Thereof, Associated Software, and Products Containing the...more

Product Prototype Built Abroad Satisfies Domestic Industry Requirement

On February 14, 2019, the U.S. International Trade Commission (“ITC”) issued an Initial Determination (“ID”) in the matter of Certain Road Construction Machines and Components Thereof, Inv. 337-TA-1088. In the ID, ALJ Lord...more

ITC Grants General Exclusion Order for Section 337 Violations

A recent initial determination (“ID”) from the ITC resulted in a general exclusion order for products infringing several patents belonging to Complainant National Products Inc. (“NPI”). Certain Mounting Apparatuses For...more

Patent Owner Sanctioned For Ex Parte Communications

Under 37 C.F.R. § 42.5(d), communications with a Board member regarding a specific proceeding are not permitted “unless both parties have an opportunity to be involved in the communication.” This prohibition, however, does...more

ITC Provides a Way to Work Around IPR Estoppel

In In re Certain Magnetic Tape Cartridges and Components Thereof, 337-TA-1058 (ITC October 2, 2018, Order), Administrative Law Judge Cheney ruled that even if a respondent is estopped from raising certain invalidity...more

Sale of Domestic Industry Product Not Required Prior to Filing Complaint

The ITC recently indicated that 19 U.S.C. 1337(a)(2) does not require that a domestic industry product be sold before a complaint is filed for a domestic industry to exist. See Certain Road Construction Machines and...more

Delay in Identifying Prior Art Prevents Their Addition to Notice of Prior Art

In a recent order, Administrative Law Judge Shaw denied in part the Respondents’ Motion to Supplement their Notice of Prior Art. In re Certain Strontium-Rubidium Radioisotope Infusion Systems, And Components Thereof Including...more

Even Unrebutted Experts Need To Do More Than Make Conclusory Assertions

In Diebold Nixdorf, Inc. v. ITC, the Federal Circuit reversed the ITC’s finding of a Section 337 violation based on the ITC’s reliance on unrebutted expert testimony. Diebold, No. 17-2553 (Fed. Cir. Aug. 15, 2018). The case...more

ITC Makes It Easier for Complainants to Meet the Domestic Industry Requirement

In a recent decision, the Commission overruled the ALJ to clarify, and ultimately expand, the universe of investments that complainants can use to meet the economic prong of the domestic industry (“DI”) requirement. Certain...more

ITC Updates Its Rules of Practice and Procedure

Late last week, the International Trade Commission (“ITC”) finalized changes to its rules, which changes were first proposed in late 2015. The new rules are expected to be published in the Federal Register in early May 2018...more

The Commission Doesn’t Rubber Stamp Even Highly Technical Claim Constructions

On February 14, 2018, the Commission affirmed ALJ Pender’s initial determination of non-infringement but based on modified grounds related to the construction of the claim term “single-molecule sequencing.” In re Certain...more

ALJ Precludes Reliance on New Domestic Industry Products

Following up on a previous post, Administrative Law Judge Bullock recently granted Respondents Fujifilm Holdings Corporation, Fujifilm Corporation, Fujifilm Holdings America Corporation, and Fujifilm Recording Media U.S.A.,...more

ALJ Denies Inequitable Conduct “Fishing Expedition”

In a recent order, Administrative Law Judge Lord denied Respondents CSL Behring LLC, CSL Behring GMBH, and CSL Behring Recombinant Facility AG (“CSL Behring”) motion to compel discovery from Complainants Bioverativ Inc.,...more

100-Day Pilot Program Proceedings Remain Rare

In two recent orders, the Commission denied respondents’ requests for entry into its Early Disposition Pilot Program (100-day Pilot Program). It has now been over two years since the ITC issued its proposed rulemaking for the...more

ALJ Doubles Down on Compelling Depositions in the U.S.

ALJ McNamara recently confirmed and tightened her previous order compelling depositions of certain Japanese witnesses in the United States. Certain Digital Cable And Satellite Products, Inv. No. 337-TA-1049, Order No....more

Diagrams Not Considered Source Code Under Modified Protective Order

In a recent Order, ALJ McNamara clarified that while diagrams drawn by an expert depicting the interplay and hierarchy of relevant code modules, inputs, and outputs of source code are to be treated as confidential business...more

ALJ Essex Retires

ALJ Essex has retired from the ITC after a decade of service. News of his retirement was provided in notices issued this week by Chief ALJ Bullock in investigations previously assigned to ALJ Essex....more

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