UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES AND
`COMPONENTS THEREOF
`
`
`
`
`
`
`Inv. No. 337-TA-1426
`
`
`
`
`
`JOINT MOTION TO AMEND CERTAIN DATES IN
`THE PROCEDURAL SCHEDULE
`
`Pursuant to Ground Rule 4, Complainant Cricut, Inc. (“Cricut”) and Respondents Hunan
`
`Sijiu Technology, Co. Ltd., Hunan Sijiu Electronic Technology, Co. Ltd.,1 and Guangdong Rongtu
`
`Technology Co., Ltd. (collectively, “HTVRONT” or “Respondents”) (all collectively, “the Private
`
`Parties”) move to amend certain dates in Corrected Order No. 6: Procedural Schedule (February
`
`3, 2025) in view of Order No. 10, which moved the evidentiary hearing from August 25-29, 2025
`
`and extended the target date to May 13, 2026. The Parties’ proposed changes would not impact
`
`the dates for the Markman claim construction hearing or any currently scheduled monthly case
`
`management conferences.
`
`Ground Rule 4 provides that “modifications of the procedural schedule by any party shall
`
`be made by written motion showing good cause.” In Order No. 10, the CALJ moved the
`
`evidentiary hearing from August 25-29, 2025, to October 6-10, 2025. The Private Parties submit
`
`that good cause exists to enter the schedule changes in the attached Exhibit A, which represent
`
`commensurate changes to certain other deadlines in the procedural schedule. The Private Parties
`
`
`1 Respondent Hunan Sijiu Technology, Co. Ltd. was formerly known as Hunan Sijiu Electronic
`Technology Co., Ltd. Pending Commission approval of Order No. 10, Hunan Sijiu Electronic
`Technology Co., Ltd. will be terminated from the Investigation and HK Sijiu International Share
`Co., Ltd. (“HK Sijiu”) will be added as a respondent.
`
`1
`
`
`WASHINGTON, D.C.
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES AND
`COMPONENTS THEREOF
`
`
`
`
`
`
`Inv. No. 337-TA-1426
`
`
`
`
`
`JOINT MOTION TO AMEND CERTAIN DATES IN
`THE PROCEDURAL SCHEDULE
`
`Pursuant to Ground Rule 4, Complainant Cricut, Inc. (“Cricut”) and Respondents Hunan
`
`Sijiu Technology, Co. Ltd., Hunan Sijiu Electronic Technology, Co. Ltd.,1 and Guangdong Rongtu
`
`Technology Co., Ltd. (collectively, “HTVRONT” or “Respondents”) (all collectively, “the Private
`
`Parties”) move to amend certain dates in Corrected Order No. 6: Procedural Schedule (February
`
`3, 2025) in view of Order No. 10, which moved the evidentiary hearing from August 25-29, 2025
`
`and extended the target date to May 13, 2026. The Parties’ proposed changes would not impact
`
`the dates for the Markman claim construction hearing or any currently scheduled monthly case
`
`management conferences.
`
`Ground Rule 4 provides that “modifications of the procedural schedule by any party shall
`
`be made by written motion showing good cause.” In Order No. 10, the CALJ moved the
`
`evidentiary hearing from August 25-29, 2025, to October 6-10, 2025. The Private Parties submit
`
`that good cause exists to enter the schedule changes in the attached Exhibit A, which represent
`
`commensurate changes to certain other deadlines in the procedural schedule. The Private Parties
`
`
`1 Respondent Hunan Sijiu Technology, Co. Ltd. was formerly known as Hunan Sijiu Electronic
`Technology Co., Ltd. Pending Commission approval of Order No. 10, Hunan Sijiu Electronic
`Technology Co., Ltd. will be terminated from the Investigation and HK Sijiu International Share
`Co., Ltd. (“HK Sijiu”) will be added as a respondent.
`
`1
`
`
`
`submit that good cause exists to enter the schedule changes in the attached Exhibit A. Specifically,
`
`the Private Parties are in discussions regarding a consent order that would resolve the heat press
`
`patents (i.e., all of the currently asserted patents) as to Respondent HTVRONT. In addition,
`
`HTVRONT and Cricut have begun negotiating in good faith regarding a potential settlement that
`
`would resolve the case against HTVRONT. Moving certain deadlines at this time would conserve
`
`the Parties’ resources and promote resolution of the Investigation as to the only participating
`
`Respondent group. This, in turn, would conserve Commission resources because there will likely
`
`be no need for an evidentiary hearing and Cricut’s relief against the non-participating respondents
`
`and request for a GEO can be resolved on the papers. Additionally, the Parties’ proposed schedule
`
`would not impact the dates for the Markman claim construction hearing or any currently scheduled
`
`monthly case management conferences.
`
`Accordingly, as set forth in Exhibit A, the Parties respectfully request that certain deadlines
`
`be adjusted in view of the new evidentiary hearing and target dates.
`
`
`
`GROUND RULE 5.1 CERTIFICATION
`
`Pursuant to Ground Rule 5.1, HTVRONT notified Cricut and Staff of its intent to file the
`
`present motion during the parties’ March 7, 2025, meet and confer and subsequent email
`
`correspondence. Staff indicated that it does not oppose the motion.
`
`
`
`
`
`2
`
`
`
`
`
`Dated: March 13, 2025
`
`
`
`Respectfully submitted,
`
`/s/ Jay H. Reiziss
`Jay H. Reiziss
`Alexander P. Ott
`Timothy M. Dunker
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street, NW
`Washington, DC 20001
`Telephone: (202) 756-8000
`
`David J. Tobin
`MCDERMOTT WILL & EMERY LLP
`2501 North Harwood Street Suite 1900
`Dallas, TX 75201
`Telephone: (214) 210-2793
`
`James M. Oehler
`Tessa M. Kroll
`MCDERMOTT WILL & EMERY LLP
`444 West Lake Street, Suite 4000
`Chicago, IL 60606
`Telephone: (312) 372-2000
`
`Counsel for Complainant
`
`
`/s/ Helena Kiepura
`Helena Kiepura
`DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`Tel: 202.799.4000
`Fax: 202.799.5000
`
`Matthew Satchwell
`Paulina Starostka
`DLA Piper LLP (US)
`444 West Lake Street, Suite 900
`Chicago, IL 60606
`Tel: 312.368.4000
`
`Shaobin Zhu
`DLA Piper LLP (US)
`701 Fifth Avenue
`
`
`
`3
`
`
`
`Suite 6900
`Seattle, WA 98104
`Tel: 206.839.4894
`
`Benjamin Yaghoubian
`DLA Piper LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`Los Angeles, CA 90067
`Tel: 310.595.3000
`
`Claire Schuster
`DLA Piper LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110
`Tel: 617.406.6000
`
`Peter VandeVort
`DLA Piper LLP (US)
`555 Mission St, Suite 2400
`San Francisco, CA 94105
`Tel: 415.836.250
`
`Counsel for HTVRONT Respondents
`
`
`
`
`
`4
`
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`EXHIBIT A
`
`
`
`
`
`
`
`
`
`
`
`
`
`UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON DC
`
`Before the Honorable Clark S. Cheney
`Chief Administrative Law Judge
`
`
`In the Matter of
`
`CERTAIN CRAFTING MACHINES
`AND COMPONENTS THEREOF
`
`
`Inv. No. 337-TA-1426
`
`PROPOSED MODIFIED PROCEDURAL SCHEDULE
`
`
`
`
`
`In view of Order No. 10, the Complainant Cricut, Inc. (“Cricut” or “Complainant”), and
`
`Respondents Hunan Sijiu Technology, Co. Ltd., HK Sijiu International Share Co., Ltd., and
`
`Guangdong Rongtu Technology Co., Ltd. (collectively, “HTVRONT” or “Respondents”) hereby
`
`propose the following procedural schedule:
`
`Event
`
`Preliminary conference
`
`Exchange list of claim terms to be
`construed
`Exchange proposed constructions for
`all terms on all lists
`Meet and confer regarding proposed
`claim constructions
`Monthly case management
`conference
`File chart of agreed and disputed
`constructions
`File opening claim construction briefs
`pursuant to Ground Rule 7.1, which
`shall include any expert Markman
`declarations upon which the party will
`rely.
`
`Date
`January 22, 2025, 10am
`ET
`
`Revised Date
`January 22, 2025, 10am
`ET
`
`February 4, 2025
`
`February 4, 2025
`
`February 7, 2025
`
`February 7, 2025
`
`February 12, 2025
`
`February 12, 2025
`
`February 12, 2025,
`10am ET
`
`February 12, 2025, 10am
`ET
`
`February 20, 2025
`
`February 20, 2025
`
`February 20, 2025
`
`February 20, 2025
`
`1
`
`
`
`Event
`File tentative list of fact witnesses a
`party will call to testify at the hearing,
`with an identification of each witness’
`relationship to the party
`File notice of prior art
`Deadline to submit applications for
`subpoenas
`File responsive claim construction
`briefs, including any rebuttal expert
`Markman declarations upon which the
`party will rely.
`Substantial completion of the
`production of documents
`File identification of testifying expert
`witnesses, including their expertise and
`curriculum vitae
`Private Parties submit hyperlinked
`versions of claim construction briefs
`and exhibits thereto via Box
`Markman claim construction hearing
`and case management conference
`Monthly case management
`conference
`Monthly case management
`conference
`Fact discovery cutoff and completion
`Deadline to file motions to compel fact
`discovery
`Exchange of initial expert reports for
`issues for which a party bears the
`burden of proof and to identify and
`produce all tests, surveys, and data
`upon which the expert relies
`Monthly case management
`conference
`Exchange of rebuttal expert reports for
`issues for which a party does not bear
`the burden of proof and to identify and
`
`Date
`
`Revised Date
`
`February 26, 2025
`
`February 26, 2025
`
`February 28, 2025
`Friday, February 28,
`2025
`
`February 28, 2025
`
`Friday, February 28, 2025
`
`March 6, 2025
`
`March 6, 2025
`
`March 7, 2025
`
`March 7, 2025
`
`March 11, 2025
`
`March 11, 2025
`
`March 13, 2025
`
`March 13, 2025
`
`March 20, 2025, 10am
`ET
`April 21, 2025, 2pm
`ET
`May 22, 2025, 2pm
`ET
`April 25, 2025
`
`March 20, 2025, 10am
`ET
`
`April 21, 2025, 2pm ET
`
`May 22, 2025, 2pm ET
`
`Friday, June 6, 2025
`
`April 28, 2025
`
`Monday, June 9, 2025
`
`May 9, 2025
`
`Friday, June 20, 2025
`
`June 26, 2025, 10am
`ET
`
`June 26, 2025, 10am ET
`
`May 30, 2025
`
`Friday, July 11, 2025
`
`2
`
`
`
`Date
`
`Revised Date
`
`
`
`Friday, July 18, 2025
`
`July 24, 2025, 10am
`ET
`June 20, 2025
`
`July 24, 2025, 10am ET
`
`Friday, August 1, 2025
`
`June 23, 2025
`
`Monday, August 4, 2025
`
`June 23, 2025
`
`Monday, August 4, 2025
`
`June 25, 2025
`
`Wednesday, August 6,
`2025
`
`June 30, 2025
`
`Monday, August 11, 2025
`
`June 30, 2025
`
`Monday, August 11, 2025
`
`July 3, 2025
`
`July 3, 2026
`
`Thursday, August 14,
`2025
`
`Thursday, August 14,
`2025
`
`July 8, 2025
`
`Tuesday, August 19, 2025
`
`July 9, 2025
`
`Wednesday, August 20
`
`June 27, 2025
`
`
`
`August 22, 2025
`[proposed] Monday,
`August 25, 2025, 9:00
`a.m. ET
`August 29, 2025
`
`Event
`produce all tests, surveys, and data
`upon which the expert relies
`Respondents serve reply expert report
`on secondary considerations of
`nonobviousness
`Monthly case management
`conference
`Expert discovery cutoff and completion
`Deadline to file motions to compel
`expert discovery
`Deadline for filing summary
`determination motions
`Commission investigative attorney
`discloses contentions that are different
`from those raised by the private parties
`Exchange of exhibit lists among the
`parties
`Private Parties submit hyperlinked
`versions of summary determination
`briefs and exhibits via Box
`File responses to summary
`determination motions
`Complainant and Respondents serve
`proposed direct exhibits and identify
`physical exhibits1
`Commission investigative attorney
`serves proposed direct exhibits and
`identifies physical exhibits
`Serve proposed rebuttal exhibits and
`identify rebuttal physical exhibits
`One-day mediation session
`
`Monthly case management
`conference [Proposed]
`
`Submit joint report on mediation
`
`1 The Parties will meet and confer on a procedure for exchanging prepared demonstrative exhibits at a time that is
`closer to the evidentiary hearing.
`
`July 3, 2025
`
`3
`
`
`
`Event
`Complainant and Respondents file pre-
`trial statements and briefs
`File joint list of unopposed exhibits
`Commission investigative attorney files
`pre-trial statement and brief
`
`Date
`
`July 23, 2025
`
`July 25, 2025
`
`August 5, 2025
`
`Deadline for motions in limine
`
`August 7, 2025
`
`File responses to motions in limine
`
`August 14, 2025
`
`August 25, 2025, 9am
`ET
`
`August 25–29, 2025
`
`Final prehearing conference
`
`Evidentiary hearing
`
`Complainant and Respondents file
`post-hearing initial briefs with the
`Secretary and submit final exhibits
`with the Administrative Law Judge
`File final exhibit list
`Private Parties submit hyperlinked
`versions of initial post-hearing briefs
`and exhibits via Box
`
`Revised Date
`Wednesday, September 3,
`2025
`Friday, September 5, 2025
`Tuesday, September 16,
`2025
`Thursday, September 18,
`2025
`Thursday, September 25,
`2025
`[Proposed] October 20,
`2025
`[Proposed] October 20-24,
`2025
`
`Friday, November 14,
`2025
`
`Friday, November 14,
`2025
`Friday, November 21,
`2025
`
`Tuesday, December 2,
`2025
`
`Tuesday, December 2,
`2025
`Tuesday, January 13,
`2026
`Wednesday, May 13,
`2026
`
`September 11, 2025
`
`Thursday, November 6,
`2025
`
`September 12, 2025
`
`Friday, November 7, 2025
`
`September 19, 2025
`
`Staff files post-hearing initial brief
`
`September 19, 2025
`
`Complainant and Respondents file
`post-hearing responsive briefs
`Private Parties submit hyperlinked
`versions of responsive post-hearing
`briefs and exhibits via Box
`
`September 26, 2025
`
`October 3, 2025
`
`Staff files post-hearing responsive brief
`
`October 3, 2025
`
`Final initial determination on
`violation
`Target date for completion of
`investigation (16-month target date)
`
`December 12, 2025
`
`April 13, 2026
`
`
`
`4
`
`
`
`Dated: March 13, 2025
`
`
`
`
`
`/s/ Jay H. Reiziss
`Jay H. Reiziss
`Alexander P. Ott
`Timothy M. Dunker
`MCDERMOTT WILL & EMERY LLP
`500 North Capitol Street, NW
`Washington, DC 20001
`Telephone: (202) 756-8000
`
`David J. Tobin
`MCDERMOTT WILL & EMERY LLP
`2501 North Harwood Street Suite 1900
`Dallas, TX 75201
`Telephone: (214) 210-2793
`
`James M. Oehler
`Tessa M. Kroll
`MCDERMOTT WILL & EMERY LLP
`444 West Lake Street, Suite 4000
`Chicago, IL 60606
`Telephone: (312) 372-2000
`
`Counsel for Complainant
`
`
`/s/ Helena Kiepura
`Helena Kiepura
`DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`Tel: 202.799.4000
`Fax: 202.799.5000
`
`Matthew Satchwell
`Paulina Starostka
`DLA Piper LLP (US)
`444 West Lake Street, Suite 900
`Chicago, IL 60606
`Tel: 312.368.4000
`
`Shaobin Zhu
`DLA Piper LLP (US)
`701 Fifth Avenue
`Suite 6900
`Seattle, WA 98104
`Tel: 206.839.4894
`
`
`
`5
`
`
`
`
`
`
`
`
`Benjamin Yaghoubian
`DLA Piper LLP (US)
`2000 Avenue of the Stars
`Suite 400 North Tower
`Los Angeles, CA 90067
`Tel: 310.595.3000
`
`Claire Schuster
`DLA Piper LLP (US)
`33 Arch Street, 26th Floor
`Boston, MA 02110
`Tel: 617.406.6000
`
`Peter VandeVort
`DLA Piper LLP (US)
`555 Mission St, Suite 2400
`San Francisco, CA 94105
`Tel: 415.836.250
`
`Counsel for HTVRONT Respondents
`
`
`
`6
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that, on March 13, 2025, a true and correct copy of the foregoing was
`served upon the following, in the manner indicated below:
`
`
`The Honorable Lisa R. Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, SW, Room 112
`Washington, D.C. 20436
`The Honorable Clark S. Cheney
`Chief Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`Cheney1426@usitc.gov
`Yoncha Kundupoglu, Esq.
`Investigative Attorney
`Office of Unfair Import Investigations
`U.S. International Trade Commission
`500 E Street, SW
`Washington, D.C. 20436
`yoncha.kundupoglu@usitc.gov
`Respondents Hunan Sijiu Technology, Co. Ltd.,
`HK Sijiu International Share Co., Ltd., and
`Guangdong Rongtu Technology Co., Ltd.
`Helena D. Kiepura
`DLA Piper LLP (US)
`500 Eighth Street, NW
`Washington, DC 20004
`DLA-Sijiu-1426@us.dlapiper.com
`
`Tyler V. Snow
`HATCH LAW GROUP, PC
`22 East 100 South, Suite 400
`Salt Lake City, Utah 84111
`T: (801) 869-1919
`email: snow@hatchpc.com
`Respondent LiPing Zhan
`No. 187, Yanglinguan Street,
`Xingou Town, Jianli County,
`Jingzhou, China 433300
`Respondent Shanghai Sishun E-commerce Co.,
`Ltd.
`5th Floor, Building 6, Lane 958, Jinsha Jiangxi Road
`Jiading District, Shanghai, China 201824
`
`
`
`☒Via EDIS
`☐Via Hand Delivery
`☐Via Overnight Courier
`☐Via Email
`☐Via EDIS
`☐Via Hand Delivery
`☐Via Overnight Courier
`☒Via Box
`☒Via Email
`☐Via EDIS
`☐Via Hand Delivery
`☐Via Overnight Courier
`☐Via Box
`☒Via Email
`
`☐Via EDIS
`☐Via Hand Delivery
`☐Via Overnight Courier
`☒Via Email
`
`☐Via EDIS
`☐Via Hand Delivery
`☒Via First Class Mail
`☐Via Email
`☐Via EDIS
`☐Via Hand Delivery
`☒Via First Class Mail
`☐Via Email
`
`
`
`Respondent Bozhou Wanxingyu Technology Co.
`Ltd.
`No. 26, Guangming Rd., Qiaocheng Dist.
`Bozhou, Anhui, China, 236800
`Respondent Bozhou Zhongdaxiang Technology
`Co., Ltd.
`No. 41, Zhaoyangzhuang Vil., Dawang Xingzheng
`Vil., Niuji Town, Qiaocheng Dist.
`Bozhou, Anhui, China 236800
`
`☐Via EDIS
`☐Via Hand Delivery
`☒Via First Class Mail
`☐Via Email
`☐Via EDIS
`☐Via Hand Delivery
`☒Via First Class Mail
`☐Via Email
`
`/s/ Ethan Song
`Ethan Song
`
`
`
`
`
`
`
`
`
`
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