`WASHINGTON, D.C.
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`NOTICE OF RECEIPT OF COMPLAINT; SOLICITATION OF COMMENTS
`RELATING TO THE PUBLIC INTEREST
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`AGENCY: U.S. International Trade Commission.
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`ACTION: Notice.
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`SUMMARY: Notice is hereby given that the U.S. International Trade Commission has received
`a complaint entitled Certain Location-Sharing Systems, Related Software, Components Thereof,
`and Products Containing Same, DN 3655; the Commission is soliciting comments on any public
`interest issues raised by the complaint or complainant’s filing pursuant to the Commission’s
`Rules of Practice and Procedure.
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`FOR FURTHER INFORMATION CONTACT: Katherine M. Hiner, Acting Secretary to the
`Commission, U.S. International Trade Commission, 500 E Street S.W., Washington, D.C. 20436,
`telephone (202) 205-2000. The public version of the complaint can be accessed on the
`Commission's Electronic Document Information System (EDIS) at https://edis.usitc.gov. For
`help accessing EDIS, please email EDIS3Help@usitc.gov. General information concerning the
`Commission may also be obtained by accessing its Internet server at United States International
`Trade Commission (USITC) at https://www.usitc.gov . The public record for this investigation
`may be viewed on the Commission's Electronic Document Information System (EDIS) at
`https://edis.usitc.gov. Hearing-impaired persons are advised that information on this matter can
`be obtained by contacting the Commission's TDD terminal on (202) 205-1810.
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`SUPPLEMENTARY INFORMATION: The Commission has received a complaint and a
`submission pursuant to § 210.8(b) of the Commission’s Rules of Practice and Procedure filed on
`behalf of Advanced Ground Information Systems, Inc. and AGIS Software Development LLC on
`November 17, 2022. The complaint alleges violations of section 337 of the Tariff Act of 1930
`(19 U.S.C. 1337) in the importation into the United States, the sale for importation, and the sale
`within the United States after importation of regarding certain location-sharing systems, related
`software, components thereof, and products containing same. The complainant names as
`respondents: Google LLC of Mountain View, CA; Samsung Electronics, Co., Ltd. of Korea;
`Samsung Electronics America, Inc. of Ridgefield Park, NJ; OnePlus Technology (Shenzhen)
`Co., Ltd. of China; TCL Technology Group Corporation of China; TCL Electronics Holdings
`Limited of Hong Kong; TCL Communication Technology Holdings Limited of Hong Kong;
`TCT Mobile (US) Inc. of Irvine, CA; Lenovo Group Ltd. of China; Lenovo (United States) Inc.
`of Morrisville, NC; Motorola Mobility LLC of Chicago, IL; HMD Global of Finland; HMD
`Global OY of Finland; HMD America, Inc. of Miami, FL; Sony Corporation of Japan; Sony
`Mobile Communications, Inc. of Japan; ASUSTek Computer Inc. of Taiwan; ASUS Computer
`International of Fremont, CA; Caterpillar Inc. of Peoria, IL; BLU Products of Doral, FL;
`Panasonic Corporation of Japan; Panasonic Corporation of North America of Secaucus, NJ;
`Kyocera Corporation of Japan; Xiaomi Corporation of China; Xiaomi H.K. Ltd. of Hong Kong;
`Xiaomi Communications Co., Ltd. of China; and Xiaomi Inc. of China. The complainant
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`requests that the Commission issue a limited exclusion order and cease and desist orders, and
`impose a bond upon respondent’s alleged infringing articles during the 60-day Presidential
`review period pursuant to 19 U.S.C. 1337(j).
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`Proposed respondents, other interested parties, and members of the public are invited to
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`file comments on any public interest issues raised by the complaint or § 210.8(b) filing.
`Comments should address whether issuance of the relief specifically requested by the
`complainant in this investigation would affect the public health and welfare in the United States,
`competitive conditions in the United States economy, the production of like or directly
`competitive articles in the United States, or United States consumers.
`In particular, the Commission is interested in comments that:
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`(i)
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`explain how the articles potentially subject to the requested remedial orders are
`used in the United States;
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`identify any public health, safety, or welfare concerns in the United States relating
`to the requested remedial orders;
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`identify like or directly competitive articles that complainant, its licensees, or
`third parties make in the United States which could replace the subject articles if
`they were to be excluded;
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`indicate whether complainant, complainant's licensees, and/or third party
`suppliers have the capacity to replace the volume of articles potentially subject to
`the requested exclusion order and/or a cease and desist order within a
`commercially reasonable time; and
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`(ii)
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`(iii)
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`(iv)
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` (v)
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`explain how the requested remedial orders would impact United States
`consumers.
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`Written submissions on the public interest must be filed no later than by close of
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`business, eight calendar days after the date of publication of this notice in the Federal Register.
`There will be further opportunities for comment on the public interest after the issuance of any
`final initial determination in this investigation. Any written submissions on other issues must
`also be filed by no later than the close of business, eight calendar days after publication of this
`notice in the Federal Register. Complainant may file replies to any written submissions no later
`than three calendar days after the date on which any initial submissions were due. No other
`submissions will be accepted, unless requested by the Commission. Any submissions and replies
`filed in response to this Notice are limited to five (5) pages in length, inclusive of attachments.
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`Persons filing written submissions must file the original document electronically on or
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`before the deadlines stated above. Submissions should refer to the docket number (“Docket No.
`3655”) in a prominent place on the cover page and/or the first page. (See Handbook for
`Electronic Filing Procedures, Electronic Filing Procedures1). Please note the Secretary's Office
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`1 Handbook for Electronic Filing Procedures:
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`will accept only electronic filings during this time. Filings must be made through the
`Commission's Electronic Document Information System (EDIS, https://edis.usitc.gov.) No in-
`person paper-based filings or paper copies of any electronic filings will be accepted until further
`notice. Persons with questions regarding filing should contact the Secretary at
`EDIS3Help@usitc.gov.
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`Any person desiring to submit a document to the Commission in confidence must request
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`confidential treatment. All such requests should be directed to the Secretary to the Commission
`and must include a full statement of the reasons why the Commission should grant such
`treatment. See 19 CFR 201.6. Documents for which confidential treatment by the Commission
`is properly sought will be treated accordingly. All information, including confidential business
`information and documents for which confidential treatment is properly sought, submitted to the
`Commission for purposes of this Investigation may be disclosed to and used: (i) by the
`Commission, its employees and Offices, and contract personnel (a) for developing or
`maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
`reviews, and evaluations relating to the programs, personnel, and operations of the Commission
`including under 5 U.S.C. Appendix 3; or (ii) by U.S. government employees and contract
`personnel2, solely for cybersecurity purposes. All nonconfidential written submissions will be
`available for public inspection at the Office of the Secretary and on EDIS3.
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`This action is taken under the authority of section 337 of the Tariff Act of 1930, as
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`amended (19 U.S.C. 1337), and of §§ 201.10 and 210.8(c) of the Commission's Rules of Practice
`and Procedure (19 CFR 201.10, 210.8(c)).
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`By order of the Commission.
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`Issued: November 18, 2022.
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`Katherine M. Hiner,
`Acting Secretary to the Commission.
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`https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf
`2 All contract personnel will sign appropriate nondisclosure agreements.
`3 Electronic Document Information System (EDIS): https://edis.usitc.gov
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