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 RESPONDENTS
`HUNAN SIJIU TECHNOLOGY, CO. LTD., HUNAN SIJIU ELECTRIC
`TECHNOLOGY CO., LTD., AND GUANGDONG RONGTU TECHNOLOGY CO.,
`LTD.’S MOTION TO PARTIALLY TERMINATE THE INVESTIGATION BASED
`ON CONSENT ORDER
`[Motion Dkt. 1426-007]
`
`
`
`
`INTRODUCTION
`
`On March 10, 2025, Respondents Hunan Sijiu Technology, Co. Ltd. (f/k/a Hunan
`
`Sijiu Electronic Technology Co., Ltd.), HK Sijiu International Share Co., Ltd.,1 and
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`Guangdong Rongtu Technology Co., Ltd. (collectively, “HTVRont Respondents” or
`
`“HTVRont”) moved to partially terminate this Investigation as to the HTVRont
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`Respondents with respect to U.S. Patent No. D1,029,090 (“the D090 Patent”) based upon a
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`Consent Order Stipulation and [Proposed] Consent Order. Motion Dkt. 1426-007 (Mar. 10,
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`2025) (EDIS Doc. ID 845455) (“Motion”). Complainant Cricut, Inc. (“Complainant” or
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`“Cricut”) does not oppose the Motion.
`
`For the reasons set forth below, the Commission Investigative Staff (“Staff” )
`
`
`1 On March 6, 2025, HK Sijiu International Share Co., Ltd. was added as a respondent and
`Hunan Sijiu Electronic Technology Co., Ltd. was terminated from this Investigation. Order
`No. 10 at 2 (Mar. 6, 2025) (EDIS Doc. ID 845162) (“Order No. 10”) (this Order is pending
`Commission review).
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`supports termination of the investigation as requested in the Motion with respect to
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`HTVRont if the [Proposed] Consent Order is amended to completely identify HK Sijiu
`
`International Share Co., Ltd. (“HK Sijiu”) as a respondent.
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`
`
`BACKGROUND
`
`This Investigation was instituted on December 11, 2024 based upon a complaint filed
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`by Complainant on October 4, 2024, as supplemented on October 24, 25, and 29, 2024. 89
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`Fed. Reg. 99905 (Dec. 11, 2024) (EDIS Doc. ID 839897). The Complaint, as supplemented,
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`alleges violations of section 337 based upon the importation into the United States, the sale
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`for importation, and the sale within the United States after importation of certain crafting
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`machines and components thereof by reason of infringement of certain claims of
`
`U.S. Patent No. 11,208,758; U.S. Patent No. 11,905,646; U.S. Patent No. D893,563; U.S.
`
`Patent No. D910,724; U.S. Patent No. D926,237; and U.S. Patent No. Dl,029,090 ("the
`
`D090 patent").
`
`Cricut named a number of respondents in its Complaint. Respondent Hunan Sijiu
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`Technology, Co. Ltd. (“Hunan Sijiu”) was formerly known as Hunan Sijiu Electronic
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`Technology Co., Ltd. (“HSET”). Order No. 10 at 2. HSET has therefore been terminated
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`from this Investigation pending Commission review because Hunan Sijiu, already a named
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`respondent, is the appropriate party. Id. at 2-3. In addition, HK Sijiu International Share
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`Co., Ltd. (“HK Sijiu”) was added as a named respondent to this Investigation based upon
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`information obtained after the Complaint was filed—this is also pending Commission
`
`review. Id. at 1-3.
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`It is unclear whether HTVRont’s Motion should be granted prior to Commission
`
`review of Order No. 10 to ensure that the parties named in the Consent Order Stipulation
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`and [Proposed] Consent Order (“PCO”) are the parties to the Investigation. See Motion,
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`Attachment A at 2, fn.2 (“Cricut filed an unopposed motion to amend the complaint to add
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`HK Sijiu International Share Co., Ltd. as one of the HTVRont respondents. That motion
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`remains pending.”).
`
`The consent order stipulation and PCO filed with the Motion identify HK Sijiu as
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`the party who is a respondent. Motion, Exh. A at 2 and Exh. 1 at 2. The PCO, however,
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`does not appear to name or provide a principal place of business for HK Sijiu in paragraph
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`2, which identifies the other two HTVRont respondents to this investigation by their
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`principal places of business. Motion, Exh. 1 at ¶ 2. Instead, there is a footnote referencing
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`Complainant’s motion to amend the Complaint to add HK Sijiu that also does not include
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`HK Sijiu’s principal place of business. Id. at fn.2.
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`The instant Motion concerns only the infringement allegations leveled at the
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`HTVRont Respondents with respect to the D090 Patent and the earlier version of their
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`cutting machines—the LOKLiK Cutting Machine (“A Generation-Cutter”). Motion at 2.
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`Thus, the D090 Patent infringement allegations are based upon a discontinued product that
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`the HTVRont Respondents claim they stopped importing into the United States in
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`December 2024. Id.
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` TERMINATION BY ENTRY OF CONSENT ORDER
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`Any party may move at any time to terminate an investigation in whole or in part as
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`to any or all respondents on the basis of a consent order. 19 C.F.R. § 210.21(a)(2) (2025).
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`After institution, a proposal to terminate an investigation by consent order must be
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`submitted as a motion to the Administrative Law Judge with a stipulation that incorporates
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`a proposed consent order. See 19 C.F.R. § 210.21(c)(1)(ii) (2025). The stipulation must
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`comply with the requirements of Commission Rule 210.21(c)(3), while the terms of the
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`consent order must comply with the requirements set forth in Commission Rule
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`210.21(c)(4). 19 C.F.R. § 210.21(c)(1)(ii) (2025); see also 19 C.F.R. §§ 210.21(c)(3)-
`
`210.21(c)(4) (2025).
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`A motion for termination by consent order must contain (i) copies of any licensing or
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`other settlement agreement, (ii) a redacted copy of the agreement if it contains confidential
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`business information, (iii) copies of any supplemental agreements, and (iv) a statement that
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`there are no other agreements, written or oral, express or implied between the parties
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`concerning the subject matter of the investigation. See 19 C.F.R. § 210.21(c) (2025).
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`However, if there are no additional agreements, the parties must so state. Id.
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` DISCUSSION
`A.
`
`CONSENT ORDER SUBMITTED BY MOTION
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`As set forth below, the Staff believes that HTVRont’s consent order stipulation meets
`
`the requirements of Commission Rule 210.21(c)(3), which governs the contents of consent
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`order stipulations.
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`As required by Commission Rule 210.21(c), HTVRont has submitted their proposal
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`to terminate the investigation with respect to the D090 Patent by consent order as a motion.
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`The Commission Rules require that the motion be filed “with a stipulation that incorporates
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`a proposed consent order.” 19 C.F.R. § 210.21(c)(1)(ii) (2025). The Motion includes a
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`stipulation that incorporates as Exhibit 1 to the Consent Order Stipulation of HTVRont
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`(“COS”) the [Proposed] Consent Order (“PCO”). Motion, Attachment A at 2, Exh. 1
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`(PCO).
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` Further, HTVRont certifies in the Motion that there are no other agreements,
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`written or oral, express or implied, between HTVRont and Complainant Cricut, Inc.
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`(“Complainant” or “Cricut”) concerning the subject matter of this Investigation. Motion at
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`1, fn. 3.
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`Thus, the form in which HTVRont has presented its proposal to terminate this
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`Investigation by consent order complies with the requirements set forth in Commission Rule
`
`210.21(c). 19 C.F.R. § 210.21(c) (2025).
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`B.
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`CONSENT ORDER STIPULATION
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`As set forth below, the Staff believes that HTVRont’s consent order stipulation
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`substantially meets the requirements of Commission Rule 210.21(c)(3)(i)-(ii), which governs
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`the contents of consent order stipulations.
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`19 C.F.R. 210.21(c)(3)(i)(A). Commission Rule 210.21(c)(3)(i)(A) requires the COS
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`to include “[a]n admission of all jurisdictional facts.”
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`As required, the COS acknowledges that Complainant alleges that HTVRont imports
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`into the United States, sells for importation into the United States, and sells after
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`importation into the United States certain cutting machines and heat press machines for use
`
`in crafting that are alleged to infringe claims of U.S. Patent No. 11,208,758; U.S. Patent No.
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`11,905,646; and the claim in each of U.S. Patent Nos. D893,563; D910,724; D926,237; and
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`D1,029,090. Motion, Attachment A at 1. HTVRont admits the Commission has in rem
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`jurisdiction over the “LOKLiK Cutting Machine (also referred to as, the ”A” generation of
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`cutting plotters/LOKLiK Crafter cutting machine), which allegedly infringes the D090
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`Patent” (“the Subject Article”). Id. at ¶ 1. The COS also admits the Commission has
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`personal jurisdiction over HTVRont for purposes of this Consent Order and subject matter
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`jurisdiction over this Investigation. Id.
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`19 C.F.R. 210.21(c)(3)(i)(B). Commission Rule 210.21(c)(3)(i)(B) requires the COS
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`to include “[a] statement identifying the asserted patent claims … and whether the
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`stipulation calls for cessation of importation, distribution, sale, or other transfers (other than
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`exportation) of subject articles in the United States and/or specific terms relating to the
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`disposition of existing U.S. inventories of subject articles.”
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`In compliance with the Commission Rule, the COS identifies the asserted patent that
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`the consent order is intended to address—the D090 Patent. Motion, Exh. A at ¶ 2. The
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`COS states that HTVRont will not sell for importation, import, or sell after importation the
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`Subject Article, either directly or indirectly, and shall not aid, abet, encourage, participate
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`in, or induce the sale for importation, the importation, or the sale after importation, except
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`under consent or license from Complainant. Motion, Attachment A at ¶ 2. Additionally,
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`HTVRont has agreed that it will export any existing U.S. inventories of the Subject Article
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`within 60 days after the COS is executed. Id.
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`Here, HTVRont has included a service and warranty repair exception up to the date
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`before the COS is entered. Id. The Staff has conferred with Complainant, who agrees with
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`this service and warranty exemption and does not oppose HTVRont’s Motion. Motion at 4.
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`19 C.F.R. 210.21(c)(3)(i)(C). Commission Rule 210.21(c)(3)(i)(C) requires that the
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`COS include “[a]n express waiver of all rights to seek judicial review or otherwise challenge
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`or contest the validity of the consent order.”
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`Consistent with the Commission Rule, in the COS, HTVRont expressly waives all
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`rights to seek judicial review or otherwise challenge or contest the validity of the Consent
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`Order. Motion, Attachment A at ¶ 4.
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`19 C.F.R. 210.21(c)(3)(i)(D). Commission Rule 210.21(c)(3)(i)(D) requires the COS
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`to include “[a] statement that the signatories to the consent order stipulation will cooperate
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`with and will not seek to impede by litigation or other means the Commission's efforts to
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`gather information under subpart I of this part.”
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`As required, the COS states that HTVRont shall cooperate with and will not seek to
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`impede by litigation or other means the Commission’s efforts to gather information under
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`Subpart I of the Commission’s Rules of Practice and Procedure, 19 C.F.R. Part 210.
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`Motion, Attachment A at ¶ 5.
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`19 C.F.R. 210.21(c)(3)(i)(E). Commission Rule 210.21(c)(3)(i)(E) requires the COS
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`to include “[a] statement that the enforcement, modification, and revocation of the consent
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`order will be carried out pursuant to subpart I of this part, incorporating by reference
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`the Commission's Rules of Practice and Procedure.” 19 C.F.R. 210.21(c)(3)(i)(E) (emphasis
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`added).
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`Paragraph 6 of the COS states that enforcement, modification, or revocation of the
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`Consent Order will be carried out pursuant to, and incorporates by reference Subpart I of
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`the Commission’s Rules of Practice and Procedure. Motion, Attachment A at ¶ 6.
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`19 C.F.R. 210.21(c)(3)(i)(F). Commission Rule 210.21(c)(3)(i)(F) permits the COS
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`to include “[a] statement that the signing thereof is for settlement purposes only and does
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`not constitute admission by any respondent that an unfair act has been committed, if
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`applicable.”
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`The COS submitted by HTVRont does not appear to have a provision that
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`corresponds to Commission Rule 210.21(c)(3)(i)(F), which is optional. See generally COS.
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`19 C.F.R. 210.21(c)(3)(i)(G). Commission Rule 210.21(c)(3)(i)(G) requires the COS
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`to include “[a] statement that the consent order shall have the same force and effect and
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`may be enforced, modified, or revoked in the same manner as is provided in section 337 of
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`the Tariff Act of 1930 and this part for other Commission actions, and the Commission may
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`require periodic compliance reports pursuant to subpart I of this part to be submitted by
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`the person entering into the consent order stipulation.”
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`Paragraph 7 of the COS expressly includes the required statement and acknowledges
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`that the Commission may require periodic compliance reports. Motion, Attachment A at
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`¶ 7.
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`19 C.F.R. 210.21(c)(3)(ii)(A). Commission Rule 210.21(c)(3)(ii)(A) requires the
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`COS to state that the consent order shall become null and void with respect to any claim of
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`any intellectual property right or unfair trade practice that has expired or been found or
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`adjudicated invalid or unenforceable by a court or agency of competent jurisdiction or if any
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`article has been found or adjudicated not to infringe the asserted right in a final decision that
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`is no longer subject to appeal.
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`As required, paragraph 8 of the COS states that if the any of the asserted D090
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`Patent claim is held invalid or unenforceable by a court or agency of competent jurisdiction
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`or if the Subject Article has been found or adjudicated not to infringe the D090 Patent in a
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`final decision, no longer subject to appeal, the Consent Order shall become null and void as
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`to the D090 Patent or as to the Subject Article. Motion, Attachment A at ¶ 8.
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`19 C.F.R. 210.21(c)(3)(ii)(B). Commission Rule 210.21(c)(3)(ii)(B) requires the COS
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`to include “[a] statement that each signatory to the stipulation who was a respondent in the
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`investigation will not seek to challenge the validity of the intellectual property right(s), in
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`any administrative or judicial proceeding to enforce the consent order.”
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`As required, paragraph 9 of the COS expressly states that HTVRont will not
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`challenge the validity or enforceability of the D090 Patent in any administrative or judicial
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`proceeding to enforce the Consent Order. Motion, Attachment A at ¶ 9.
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`* * *
`The Consent Order Stipulation includes provisions corresponding to those required
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`by Commission Rule 210.21(c)(3)(i)(A)-(E), (G) and 210.21 (c)(ii)(A)-(B), and it is signed by
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`an authorized representative of HTVRont. Motion, Attachment A at 4. The Staff is
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`therefore of the view that the Consent Order Stipulation substantially complies with the
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`Commission’s requirements.
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`C.
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`PROPOSED CONSENT ORDER
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`As set forth below, the Staff believes that HTVRont’s PCO will meet the
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`requirements of Commission Rule 210.21(c)(4) once the PCO is amended to identify and
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`include the principal place of business for HK Sijiu.
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`19 C.F.R. 210.21(c)(4)(i). Commission Rule 210.21(c)(4)(i) requires that the PCO
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`include “[a] statement of the identity of complainant, the respondent, and the subject
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`articles, and a statement of any allegation in the complaint that the respondents sell for
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`importation, import, or sell after importation the subject articles in violation of section 337
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`by reason of asserted patent claims, copyright, trademark, mask work, boat hull design, or
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`unfair trade practice.”
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`The PCO identifies Complainant and the HTVRont Respondents.2 Motion, Exh. 1
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`at ¶¶ 1-2. However, Respondent HK Sijiu does not appear to be identified in paragraph 2.
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`Id. at ¶ 2. Nor is its principal place of business listed. Id. Instead, Complainant’s previously
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`filed motion to amend the Complaint is referenced. Id. at fn. 2. This appears to be a defect
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`that needs to be addressed in HTVRont’s Motion.
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`Paragraph 3 identifies the articles subject to the PCO and sets forth the allegations
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`made in the Complaint that HTVRont sells for importation, imports, and/or sells after
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`importation articles accused of infringing the D090 Patent. Id. at ¶ 3.
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`19 C.F.R. 210.21(c)(4)(ii). Commission Rule 210.21(c)(4)(ii) requires the PCO to
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`include “[a] statement that the respondents have executed a consent order stipulation (but
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`the consent order shall not contain the terms of the stipulation).”
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`As required, the third textual paragraph and ¶ 4 of the PCO states that HTVRont has
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`executed a consent order stipulation. Motion, Exh. 1 at 2 and ¶ 4.
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`19 C.F.R. 210.21(c)(4)(iii). Commission Rule 210.21(c)(4)(iii) requires the PCO to
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`include “[a] statement that the respondent shall not sell for importation, import, or sell after
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`importation the subject articles, directly or indirectly, and shall not aid, abet, encourage,
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`participate in, or induce the sale for importation, the importation, or the sale after
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`importation except under consent, license from the complainant, or to the extent permitted
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`by the settlement agreement between complainant and respondent.”
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`Paragraph 5 of the PCO expressly states that HTVRont shall not sell for importation,
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`import, or sell after importation the Subject Article, directly or indirectly, and shall not aid,
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`2 The PCO identifies HK Sijiu as one of the HTVRont Respondents although the
`Commission has not yet reviewed Order 10, which granted Complainant’s motion to amend
`the Complaint.
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`abet, encourage, participate in, or induce the sale for importation, the importation, or the
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`sale after importation of the accused products except under consent or license from
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`Complainant. Motion, Exh. 1 at ¶ 5.
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`Here, HTVRont has included a service and warranty repair exception up to the date
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`before the COS is entered. Id. The Staff has conferred with Complainant, who agreed to
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`this service and warranty exemption and does not oppose HTVRont’s Motion. Motion at 4.
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`19 C.F.R. 210.21(c)(4)(iv). Commission Rule 210.21(c)(4)(iv) requires the PCO to
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`include “[a] statement, if applicable, regarding the disposition of existing U.S. inventories of
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`the subject articles.”
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`In compliance with the Commission Rule, paragraph 6 of the PCO states that
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`HTVRont will export any existing U.S. inventories of the Subject Article within sixty days
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`after entry of the COS. Motion, Exh. 1 at ¶ 6.
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`19 C.F.R. 210.21(c)(4)(v). Commission Rule 210.21(c)(4)(v) requires the PCO to
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`include “[a] statement, if applicable, whether the respondent would be ordered to cease and
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`desist from importing and distributing articles covered by the asserted patent claims ….”
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`Pursuant to the Commission’s Rule, paragraph 7 of the PCO states that HTVRont
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`shall cease and desist from importing and/or distributing the Subject Article in the United
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`States. Motion, Exh. 1 at ¶ 7.
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`19 C.F.R. 210.21(c)(4)(vi). Commission Rule 210.21(c)(4)(vi) requires the PCO to
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`have “[a] statement that respondent shall be precluded from seeking judicial review or
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`otherwise challenging or contesting the validity of the Consent Order.”
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`Paragraph 8 of the PCO states that HTVRont shall be precluded from seeking
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`judicial review or otherwise challenging or contesting the validity of the Consent Order.
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`Motion, Exh. 1 at ¶ 8.
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`19 C.F.R. 210.21(c)(4)(vii). Commission Rule 210.21(c)(4)(vii) requires the PCO to
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`include “[a] statement that respondent shall cooperate with and shall not seek to impede by
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`litigation or other means the Commission's efforts to gather information under subpart I of
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`the Commission's Rules of Practice and Procedure, 19 CFR part 210.”
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`In accord with the Commission’s Rule, the 9th paragraph of the PCO requires
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`HTVRont to cooperate with, and not impede by litigation or other means, the
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`Commission’s efforts to gather information under subpart I of the Commission’s Rules of
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`Practice and Procedure, 19 C.F.R. Part 210. Motion, Exh. 1 at ¶ 9.
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`19 C.F.R. 210.21(c)(4)(viii). Commission Rule 210.21(c)(4)(viii) requires the PCO to
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`include “[a] statement that Respondent and its officers, directors, employees, agents, and
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`any entity or individual acting on its behalf and with its authority shall not seek to challenge
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`the validity or enforceability of any asserted patent claims … in any administrative or
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`judicial proceeding to enforce the Consent Order.”
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`As required, paragraph 10 of the PCO prohibits HTVRont and its officers, directors,
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`employees, agents, and any entity or individual acting on behalf of HTVRont and its
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`authority from challenging the validity or enforceability of the D090 Patent in any
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`administrative or judicial proceedings to enforce the Proposed Consent Order. Motion,
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`Exh. 1 at ¶ 10.
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`19 C.F.R. 210.21(c)(4)(ix) - (x). Commission Rule 210.21(c)(4)(ix) requires that the
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`PCO have “[a] statement that when the patent … expires the Consent Order shall become
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`null and void as to such.” Commission Rule 210.21(c)(4)(x) requires the PCO to also
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`include “[a] statement that if any asserted patent claim, copyright, trademark, mask work,
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`boat hull design, or unfair trade practice claim is held invalid or unenforceable by a court or
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`agency of competent jurisdiction or if any article has been found or adjudicated not to
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`infringe the asserted right in a final decision, no longer subject to appeal, this Consent Order
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`shall become null and void as to such invalid or unenforceable claim or adjudicated article.”
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`In compliance with the Commission’s Rules, paragraphs 11-12 of the PCO provide
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`that the PCO will become null and void as to the D090 Patent when it expires. Motion,
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`Exh. 1 at ¶11. The PCO will also become null and void if D090 Patent is found invalid
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`and/or unenforceable by an agency or court of competent jurisdiction, and with respect to
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`articles that have been adjudicated not to infringe in a final decision no longer subject to
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`appeal. Motion, Exh. 1 at ¶ 12.
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`19 C.F.R. 210.21(c)(4)(xi). Commission Rule 210.21(c)(4)(xi) requires the PCO to
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`include “[a]n admission of all jurisdictional facts.”
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`Paragraph 13 of the PCO states that HTVRont admits the Commission has in rem
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`jurisdiction over the accused products, in personam jurisdiction over HTVRont, and subject
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`matter jurisdiction over this Investigation as required. Motion, Exh. 1 at ¶ 13.
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`19 C.F.R. 210.21(c)(4)(xii). Commission Rule 210.21(c)(4)(xii) requires the PCO to
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`include “[a] statement that the investigation is hereby terminated with respect to
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`the respondent; provided, however, that enforcement, modification, or revocation of the
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`Consent Order shall be carried out pursuant to Subpart I of the Commission’s Rules of
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`Practice and Procedure, 19 CFR part 210.”
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`In compliance with the Commission Rule, paragraph 14 of the PCO states that this
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`Investigation is terminated with respect to HTVRont as it relates to the D090 Patent, and
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`that enforcement, modification, or revocation of the consent order shall be carried out
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`pursuant to subpart I of the Commission’s Rules of Practice and Procedure, 19 C.F.R. Part
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`210.
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`* * *
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`As set forth above, the Staff is of the view that, with the exception of the
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`requirements to identify the respondents as required by Commission Rule 210.21(c)(4)(i),
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`the PCO substantially complies with all the requirements set forth in Commission Rule
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`210.21(c)(4).
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`CONCLUSION
`
`The Motion to terminate this Investigation with respect to HTVRont and the D090
`
`Patent by entry of a consent order substantially complies with the requirements set forth in
`
`Commission Rule 210.21(c)(3)-(4) with the exception of Commission Rule 210.21(c)(4)(i).
`
`Settlement of disputes, even in part, such as by consent order, is in the public interest
`
`because it conserves both the Commission’s and the private parties’ resources. See, e.g.,
`
`Certain Mobile Device Holders and Components Thereof, Inv. No. 337-TA-1028, Order No. 10 at
`
`3 (Apr. 13, 2017) (EDIS Doc. ID 60851 (Public Vers.)) (public interest favors settlement to
`
`avoid needless litigation and to conserve public resources).
`
`The Staff is not aware of any information indicating that termination of this
`
`Investigation as to HTVRont based upon the PCO and COS would be contrary to the public
`
`health and welfare, competitive conditions in the U.S. economy, the production of like or
`
`directly competitive articles in the United States, or U.S. consumers.
`
`337-TA-1426
`
`
`
`14
`
`Staff’s Response to
`Motion Dkt. 1426-007
`
`

`

`Therefore, if the PCO is amended to properly identify HK Sijiu as a respondent, the
`
`Staff supports granting the Motion to terminate the Investigation as to the allegations that
`
`the D090 Patent is infringed by the A Generation Cutter made and imported into the United
`
`States by the HTVRont Respondents based upon a consent order stipulation and proposed
`
`consent order.
`
`
`
`
`
`
`
`
`
`March 18, 2025
`
`
`
`
`
`
`
`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)
`
`337-TA-1426
`
`
`
`15
`
`Staff’s Response to
`Motion Dkt. 1426-007
`
`

`

`CERTAIN CRAFTING MACHINES
`AND COMPONENTS THEREOF
`
`
`
`337-TA-1426
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that on March 18, 2025, she caused the foregoing
`
`COMMISSION INVESTIGATIVE STAFF’S RESPONSE TO RESPONDENTS
`HUNAN SIJIU TECHNOLOGY, CO. LTD., HUNAN SIJIU ELECTRIC
`TECHNOLOGY CO., LTD., AND GUANGDONG RONGTU TECHNOLOGY CO.,
`LTD.’S MOTION TO PARTIALLY TERMINATE THE INVESTIGATION BASED
`ON CONSENT ORDER
`[Motion Dkt. 1426-007]
`
`
`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 LiPing Zhan:
`
`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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