UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, D.C.
`
`The Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES AND
`COMPONENTS THEREOF
`
`Investigation No. 337-TA-1426
`
`COMMISSION INVESTIGATIVE STAFF’S RESPONSE TO COMPLAINANT’S
`MOTION FOR LEAVE TO AMEND COMPLAINT AND NOTICE OF
`INVESTIGATION AND ORDER NO. 7
`[Motion Dkt. 1426-002]
`
`On January 16, 2025, complainant Cricut, Inc. (“Cricut” or “Complainant”) moved
`
`to Amend the Complaint and Notice of Investigation to: (1) add a new HTVRONT
`
`Respondent, HK Sijiu International Share Co., Ltd. (“HK Sijiu”), and (2) terminate a
`
`current HTVRONT Respondent, Hunan Sijiu Electronic Technology Co., Ltd. (“HSET”).
`
`Mot. Dkt. 1426-002 at 1 (EDIS Doc. ID 841721) (“Motion”). No party opposed the
`
`requested relief. Id. In response, the Chief Administrative Law Judge issued Ordered No. 7
`
`(Feb. 3, 2025) (EDIS Doc. ID 841898, 842471 (Public. Vers.)). That Order asked
`
`Complainant to clarify the record with the information below:
`
`(i)
`
`clarify who Complainant is seeking to add to the investigation;
`
`(ii) whether HK Sijiu International Share Co., Ltd. (“HK Sijiu”) agreed to be
`added to the investigation, along with any support; and
`
`(iii)
`
`evidence that HK Sijiu has been served with a copy of the Motion and date of
`service.
`
`Id. at 2.
`
`337-TA-1426
`
`1
`
`Staff’s Response to
`Motion Dkt. 1426-002
`
`PUBLIC VERSION
`
`

`

`In response, Complainant supplemented its Motion. Complainant's Supplement to
`
`its Motion to Amend Pursuant to Order No. 7 (Jan. 29, 2025) (EDIS Doc. ID 842089)
`
`(“Motion Supp.”). In its original Motion, Complainant added a party called “HK
`
`International Share Co.” to the amended complaint. This was a typographical error and has
`
`been fixed in the Supplement to the Motion to change “HK Int’l Share Co.” to HK Sijiu
`
`who Complainant intended to add to this investigation. Motion Supp. at 1, Exhs. 1 and 2
`
`thereto.
`
` Second, Commission Rule 210.14(b)(1) requires that a post-institution motion to
`
`amend a complaint must be served on the proposed respondent the Complainant wants to
`
`add to the investigation. 19 C.F.R. 210.14(b)(1) (2025). HK Sijiu, the party Complainant
`
`intended to add, is a part of the Respondent group HTVRont who are already participating
`
`in the investigation now. See Motion, Exh. 3 thereto. HTVRont’s counsel agreed to the
`
`addition of HK Sijiu and the termination of Hunan Sijiu Electric Technology Co., Ltd.1 Id.
`
`at Exh. 3. On January 29, 2025, HTVRont’s counsel, Helena Kiepura from DLA Piper
`
`LLC, expressly stated that she had accepted service by email of the Motion on HK Sijiu’s
`
`behalf when the motion was filed on January 16, 2025. See id. However, it appears that HK
`
`Sijiu was not listed on the Certificate of Service for the Motion or Supplement to the
`
`Motion, even though the Motion was served on HK Sijiu’s counsel (DLA Piper) on January
`
`16, 2025. Id. Staff believes that a corrected Certificate of Service for the Motion and
`
`1 Hunan Sijiu Technology, Co. Ltd., a named respondent, was formerly known as Hunan
`Sijiu Electric Technology Co., Ltd., the respondent that is being terminated from the
`investigation. HTVRONT’s Response to the Complaint and Notice of Investigation at 3,
`n.1 (Dec. 30, 2024) (EDIS Doc. ID 840191)
`
`337-TA-1426
`
`2
`
`Staff’s Response to
`Motion Dkt. 1426-002
`
`PUBLIC VERSION
`
`

`

`Supplement to the Motion including HK Sijiu should be filed to clarify that HK Sijiu was
`
`served on January 16, 2025.
`
`Complainant has addressed almost all the CALJ’s questions, including adding new
`
`attachments that are (i) the corrected amended complaint, (ii) a corrected redline of the
`
`amended complaint, and (iii) an email between counsel showing HTVRont’s current
`
`counsel agreed to service on HK Sijiu’s behalf. In addition, the Staff believes that
`
`Complainant should file a corrected certificate of service indicating that it had indeed served
`
`the Motion on HK Sijiu on January 16, 2025 and Supplement to the Motion on January 29,
`
`2025. Once the corrected Certificate of Services are filed, the Staff believes that
`
`Complainant will have responded to all the points of clarification requested by Order No. 7.
`
`Then, the Motion, in view of the Supplement to the Motion, can be granted.2
`
`Respectfully submitted,
`
`/s/ Yoncha L. Kundupoglu
`Margaret D. Macdonald, Director
`David O. Lloyd, Supervisory Attorney
`Yoncha L. Kundupoglu, Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`(202) 205-3323 (office)
`
`February 10, 2025
`
`2 This Investigation was instituted on December 11, 2024. 89 Fed. Reg. 99905 (Dec. 11,
`2024) (EDIS Doc. ID 839897). At that time, the Commission declined to institute against
`two of the respondents—Shanghai Sishun Co., Ltd. and Wuyi Bohai Electric Tools Co.,
`Ltd. Id. Those two parties remain listed on the first amended complaint. However,
`because the Commission already decided not to institute against these parties, Complainant
`has removed those two parties from the complaint in their second motion to amend the
`complaint, which remains pending. Motion Dkt. 1426-005 (Feb. 4, 2025) (EDIS Doc. ID
`842618).
`
`337-TA-1426
`
`3
`
`Staff’s Response to
`Motion Dkt. 1426-002
`
`PUBLIC VERSION
`
`

`

`CERTAIN CRAFTING MACHINES
`AND COMPONENTS THEREOF
`
`337-TA-1426
`
`CERTIFICATE OF SERVICE
`The undersigned certifies that on February 25, 2025, she caused the foregoing public
`version
`COMMISSION INVESTIGATIVE STAFF’S RESPONSE TO COMPLAINANT’S MOTION FOR
`LEAVE TO AMEND COMPLAINT AND NOTICE OF INVESTIGATION AND ORDER NO. 7
`[Motion Dkt. 1426-002]
`
`to be served upon the Administrative Law Judge, by sending one (1) electronic courtesy PDF copy
`by email to the to the Administrative Law Judge’s chambers (Cheney1426@usitc.gov), and
`served the same upon the private parties in the manner indicated below:
`
`For Complainant Cricut, Inc.:
`
`Jay H. Reiziss
`McDermott Will & Emery LLP
`500 North Capitol Street, NW
`Washington, D.C. 20001
`Tel: (202) 756-8000
`
`For Respondents Hunan Sijiu Technology,
`Col Ltd.; Hunan Sijiu Electronic Technology
`Co., Ltd.; and Guangdong Rongtu
`Technology Co., Ltd:
`
`Helena Kiepura
`DLA Piper LLP (US)
`500 Eighth Street, NS
`Washington, D.C. 20004
`Tel: 202.799.4000
`
`For Respondent LiPingZhan:
`
`LiPing Zhan
`No. 187, Yanglinguan Street
`Xingou Town, Jianli County
`Jingzhou, China 433300
`
`For Respondent Shanghai Sishun E-
`Commerce Co., Ltd.:
`
`Shanghai Sishun E-commerce Co., Ltd.
`5th Floor, Building 6, Lane 958, Jinsha
`Jiangxi Road, Jiading District, Shanghai,
`China 201824
`
`By Email:
`
`cricutitc@mwe.com
`
`By Email:
`
`DLA-Sijiu-1426@us.dlapiper.com
`
`By U.S. Air Mail
`
`By U.S. Air Mail
`
`337-TA-1426
`
`1
`
`Certificate of Service
`
`

`

`337-TA-1426
`
`CERTAIN CRAFTING MACHINES
`AND COMPONENTS THEREOF
`
`
`
`For Respondent Bozhou Wanxingui
`Technology Co. Ltd.:
`
`Bozhou Wanxingui Technology Co. Ltd.
`5th Floor, Building 6, Lane 958, Jinsha
`Jiangxi Road, Jiading District, Shanghai,
`China 201824
`
`
`For Respondent Bozhou Zhongdaxiang
`Technology Co., Ltd.:
`
`Bozhou Zhongdaxiang Technology Co., Ltd.
`No. 41, Zhaoyangzhuang Vil., Dawang
`Xingzheng Vil., Niuji Town, Qiaocheng
`Dist., Bozhou, Anhui,
`China 236800
`
`
`By U.S. Air Mail
`
`
`By U.S. Air Mail
`
`
`
`
`
`
`
`
`
`
`/s/ Yoncha L. Kundupoglu
`Yoncha L. Kundupoglu
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW
`Washington, DC 20436
`(202) 205-3323 Office
`
`337-TA-1426
`
`
`
`2
`
`Certificate of Service
`
`

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