mwe.com
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`Jay Reiziss
`Attorney at Law
`jreiziss@mwe.com
`+1 202 756 8646
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`October 29, 2024
`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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`Paragraph 37 of the Verified Complaint states that “On information and belief, proposed
`Respondent SainStore Technology Co., Ltd. is a Chinese company doing business under the ‘OffNova’
`name.” In response to OUII’s inquiry regarding the information on which this belief is based, Cricut
`notes the following:
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`• OffNova’s website acknowledges Sainstore as the company behind the OffNova products.
`See https://offnova.com/pages/app-policy (“Sainstore built the OFFNOVA Smart Heating app as
`a Free app. This SERVICE is provided by Sainstore at no cost and is intended for use as is.”)
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`• The applicant for an FCC submission for the accused OffNova Impression 2 Heat Press Machine
`is listed as Tammy Xiang with an email address of tammy.xiang@sainstore.com.
`See https://fcc.report/FCC-ID/2BBKK-IMPRESSION2
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`• U.S. Patent No. D1,036,520 (the ’D520 patent), for which Sainstore Technology Co., Ltd. is the
`assignee, lists Tianle Cheng as the first named inventor and the application for the “OffNova”
`trademark was signed by Tianle Cheng.
`See https://patentsgazette.uspto.gov/week30/OG/html/1524-4/USD1036520-20240723.html;
`https://tsdr.uspto.gov/documentviewer?caseId=sn90506310&docId=FTK20210206094803&link
`Id=13#docIndex=12&page=1
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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
`US practice conducted through McDermott Will & Emery LLP.
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`The Honorable Lisa R. Barton
`October 29, 2024
`Page 2
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`• OffNova’s Tiktok account is run by “Sainstore TTS.”
`See https://www.tiktok.com/@offnovaofficial
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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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