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A&J - Request for ITC Investigation

A&J - Request for ITC Investigation

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Published by slburstein
A&J - Request for ITC Investigation
A&J - Request for ITC Investigation

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Published by: slburstein on Aug 22, 2013
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09/16/2013

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V
JAMES
ADDUCI
II
LOUIS
S
MASTRIANITOM
M
SCHAUMBERGDEANNA
TANNER OKUN
WILL
E
LEONARD
MUNFORD
PAGE
HALL
II
MICHAEL
L
DOANE
SARAH
E
HAMBLINANDREW
F
PRATI*
WILLIAM
C
SJOBERG
JONATHAN
J
ENGLER
DAVID
H
HOLLANDER
JR
DEBORAH
S
STRAUSSQIAN
SHENG.,
KATHERINE
R
LAHNSTEINDANIEL
F
SMITH
ASHAALLAM
BEAU
A
JACKSONTHOMAS
R
BURNS
JR
ROWAN
M
DOUGHERTYEVAN
H
LANGDON
PAUL
M
BARTKOWSKI
EMI
ITO
ORTIZGREGORY
F
GEARY
OANAL WAITS
MICHAEL
L
BUCKLER''
LAUREN
E
PETERSON"
OF
COUNSEL
JOHN
C
STEINBERGERPAUL
G
HEGLAND
<'!admitted
to
a
bar
other
than DC:
pract1ce
limited
to
federal
courts
&
agencies
HARVEY
B
FOX
[1941-201
OJ
AFFILIATE
AM&S
TRADE SERVICES
LLC
CARLOS MOORE. PRESIDENT
ATTORNEYS
AT
LAW
1133
CONNECTICUT
AVENUE,
N.W.
WASHINGTON,
DC
20036
Tei:(202J
467-6300
Fax:(202J 466-2006 Web:www.adduci.com
August21, 2013
VIA HAND DELIVERY
The Honorable Lisa
R.
BartonActingi_SecretaryU.S. Irltemational Trade
Commis~ion
500 E Street, S.W.Washington, DC 20436
DOCKET
NuMBER
..
__
..
-
..
-
------------
..........
--·-
--------
Office
of
theSecretary
lnt'l
Trade
Commission
Re:
Certain Multiple Mode Outdoor Grills
and
Parts Thereof
Inv. No. 337-TA-Dear Acting Secretary Barton:Enclosed for filing
on
behalf
of
Complainants
A&J
Manufacturing, LLCand A&J Manufacturing, Inc. ("A&J" or "Complainants") are documents insupport
of
A&J's request that the Commission commence an investigationpursuant to Section 337
of
the Tariff Act
of
1930, as amended. A request forconfidential treatment
of
Confidential Exhibit 8C is included
in
this letter.Accordingly, Complainants submit the following documents for filing:
1.
An
original and eight (8) copies
of
the verified Non-ConfidentialComplaint and Public Interest Statement; one (1) CD
of
the Non-Confidentialexhibits and one (1) CD
of
Confidential Exhibit 8C (19 CFR
§§
210.4(£)(2),210.8(a)(1)(i)), 210.8(b) and 210.12(a)(l));
2.
Twenty (20) additional copies
of
the verified Non-confidentialComplaint and Public Interest Statement, twenty (20) CDs
of
the NonConfidential exhibits and twenty (20) CDs
of
native Excel files
of
several exhibitsto Exhibit 7 to the Complaint for service upon the proposed respondents (19 CFR
§§
210.8(a)(l)(iii) and 210.11(a));3. Twenty (20) additional copies
of
Confidential Exhibit 8C on CDs forservice upon the proposed respondents (19 CFR
§
210.8(a)(l)(iii));
 
The Honorable Lisa
R.
BartonAugust 21, 2013
Page2
4. The original certified copies
of
United States Patent Nos. 8,381,712, D660,646and D662,773 (
11
the '712, '646 and '773 patents
.
or
11
patents in issue") and copies
ofthese
patents
on
CD, cited
in
the Complaint as Exhibits
1,
3 and 5, respectively, (210.8(a)(1)(iii),
21
0.12(a)(9)(i));
5.
Copies
of
assignments for the patents in issue on CD and cited in the Complaintas Exhibits 2, 4 and
6,
respectively (210.8(a)(l)(iii) and 210.12(a)(9)(ii)); the original certifiedcopies
of
these assignments will
be
submitted
when
received from the USPTO;
)F
6.
Original. _certified copies
of
the prosecution histories
of
the '712, '646 and '773Patents (Appendices
A;~c
and E) and three (3) additional copies
on
separate CD's (210.12(c)(1)and 210.12(d));
7.
Four (4) CDs
of
the reference documents identified in the prosecution histories forthe patents in issue (Appendices B, D and F) (210.12(c)(2)); and8.One (1) additional copy
of
the Non-confidential Complaint for service upon theEmbassy
of
The People's Republic
of
China
in Washington, D.C. (210.8(a)(l)(iv)).A certification is provided
below
pursuant to 19
CFR
§§
201.6(b) and 210.5(d)requesting confidential treatment
of
Confidential Exhibit 8C.The information for which confidential treatment is sought is proprietary commercialinformation not otherwise publicly available. Specifically, Confidential Exhibit 8C is aconfidential declaration setting forth Complainant's investments
in
the United States establishinga domestic industry.The information described above qualifies as confidential business information pursuantto Commission Rule 201.6 because:
a.
it is not available to the public;b. unauthorized disclosure
of
such information could cause substantial harm to the
c.
VJA:jctEnclosurescompetitive position
of
Complainants; andits' disclosure could impair theComrilission'necessary to perform its statutory function.
CHAR700613.docx
e
if
you have any questions.
 
UNITED STATES INTERNATIONAL TRADE COMMISSIONWASHINGTON, DCIn the Matter
of
------------------
CERTAIN MULTIPLE MODEOUTDOOR GRILLS AND PARTSTHEREOFInvestigation No.
337-TA-_
STATEMENT REGARDING THE PUBLIC INTEREST
Pursuant
to
Commission Rule 210.8(b),
19
C.P.R. § 210.8(b), Complainants A&JManufacturing, LLC and A&J Manufacturing, Inc. (collectively, "Complainants"
or
"A&J")respectfully submit this Statement Regarding the Public Interest. The products
at
issue
in
theComplaint are multiple mode outdoor grills, that is, grills that permit simultaneous cooking withgas and solid fuels, and parts thereofthat infringe U.S. Patent No. 8,381,712 B1, U.S. Patent No.D660,646
S,
and/or U.S. Patent No. D662,773 S (collectively, "the asserted patents"). Exclusion·
of
such products from the United States will not have an adverse effect on the public health andwelfare in the United States, competitive conditions
ii1
the United States economy, theproduction
of
like or directly competitive article in the United States, or United Statesconsumers.
I. HOW THE ARTICLES POTENTIALLY SUBJECT TO THEREMEDIAL ORDERS ARE USED IN THE UNITED STATES
The products at issue in the Complaint are multiple mode outdoor grills, that is, grills thatpermit simultaneous cooking with gas and solid fuels, and parts thereof that infringe the assertedpatents. These products are sold for importation into the United States, imported into the UnitedStates and/or sold in the United States after importation, at least, by proposed respondentsAcademy, Ltd. d/b/a Academy Sports
+
Outdoors, The Brinkmann Corporation, Dongguan

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