mwe.com
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`Jay Reiziss
`Attorney at Law
`jreiziss@mwe.com
`+1 202 756 8646
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`October 25, 2024
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`VIA ELECTRONIC FILING
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`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E. Street, S.W., Room 112-A
`Washington, D.C. 20436
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`Re:
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`Certain Crafting Machines and Components Thereof, Docket No. 337-3774
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`Dear Secretary Barton:
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`On behalf of Complainant Cricut, Inc. (“Cricut”), and pursuant to discussions with the Office of
`Unfair Import Investigations (“OUII”), please find, below and attached, clarifying statements and
`materials in support of Cricut’s Verified Complaint in the above-referenced matter under Section 337 of
`the Tariff Act of 1930, as Amended (“Section 337”).
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`Cricut hereby submits, in accordance with OUII’s request, Exhibit 44, which is the publicly
`accessible Change of Name submission filed with the USPTO for U.S. Application No. 29/915,485,
`issued as U.S. Patent No. D1,029,090 (the ’D090 patent), indicating that Provo Craft & Novelty, Inc.
`(“Provo”) simply changed its name to Cricut, Inc. on March 23, 2018.
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`OUII also requested further information regarding ownership of the ’D090 patent. Cricut is the
`named assignee on the face of the ’D090 patent as issued by the United States Patent and Trademark
`Office (“PTO”). Thus, Cricut owns and has all rights and interest in the ’D090 patent.
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`Complaint Exhibit 16 is an assignment executed by inventor James T. Davis II on August 22,
`2024, which names Provo as the “Assignee,” wherein Mr. Davis states both that he “ha[d] sold,
`assigned, transferred and set over . . . unto Assignee” and that he “do[es] sell, assign, transfer and set
`over unto . . . its successors,” the “entire right, title and interest in and to the above-mentioned
`inventions and applications for Letters Patent [i.e., International Application No. PCT/US14/17524], and
`in and to any . . . continuations and continuations-in-part of said application.” Complaint Exhibit 16.
`That assignment further “acknowledge[d] an obligation of assignment of this invention to Assignee at
`the time the invention was made.” Accordingly, Complaint Exhibit 16 both confirms a prior assignment
`by Mr. Davis, at the time of the invention of the ’D090 patent, to Provo, and reflects a present
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`500 North Capitol Street, N.W. Washington D.C. 20001-1531 Tel +1 202 756 8000 Fax +1 202 756 8087
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`The Honorable Lisa R. Barton
`October 25, 2024
`Page 2
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`assignment by Mr. Davis to Provo’s successor, Cricut. Thus, Mr. Davis assigned all of his ownership
`rights in the ’D090 patent to Cricut.
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`Furthermore, to avoid all doubt, Cricut further submits, as Exhibit 45, another assignment by
`inventor James T. Davis II that explicitly and directly assigns any and all rights to the ’D090 patent to
`Cricut. Cricut will request a certified copy of this assignment from the PTO and submit it as soon as it is
`received.
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`Based on the foregoing, Cricut also requests a one-week extension to the deadline for the
`Commission’s decision whether to institute an investigation, so that the Commission can consider this
`information.
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`Please contact me with any questions regarding this submission. Thank you for your attention to
`this matter.
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` Respectfully submitted,
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`/s/ Jay H. Reiziss
`Jay H. Reiziss
`Counsel for Complainant Cricut, Inc.
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`Enclosure: Exhibit 44 (Change of Name), Exhibit 45 (Assignment)
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