In the Matter of Certain Multimedia Display and Navigation Devices and Systems, Components Thereof, and Products Containing Same; Notice of Commission Determination To Review-in-Part a Final Determination of No Violation of Section 337; Schedule for Filing Written Submissions on the Issues Under Review and on Remedy, the Public Interest, and Bonding, 11271-11273 [2011-4452]
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Federal Register / Vol. 76, No. 40 / Tuesday, March 1, 2011 / Notices
production methods; development
efforts; ability to increase production
(including the shift of production
facilities used for other products and the
use, cost, or availability of major inputs
into production); and factors related to
the ability to shift supply among
different national markets (including
barriers to importation in foreign
markets or changes in market demand
abroad). Demand conditions to consider
include end uses and applications; the
existence and availability of substitute
products; and the level of competition
among the Domestic Like Product
produced in the United States, Subject
Merchandise produced in the Subject
Country(ies), and such merchandise
from other countries.
(13) (OPTIONAL) A statement of
whether you agree with the above
definitions of the Domestic Like Product
and Domestic Industry; if you disagree
with either or both of these definitions,
please explain why and provide
alternative definitions.
Authority: These reviews are being
conducted under authority of title VII of the
Tariff Act of 1930; this notice is published
pursuant to section 207.61 of the
Commission’s rules.
By order of the Commission.
Issued: February 23, 2011.
William R. Bishop,
Hearings and Meetings Coordinator.
[FR Doc. 2011–4447 Filed 2–28–11; 8:45 am]
BILLING CODE 7020–02–P
INTERNATIONAL TRADE
COMMISSION
[Investigation No. 337–TA–694]
In the Matter of Certain Multimedia
Display and Navigation Devices and
Systems, Components Thereof, and
Products Containing Same; Notice of
Commission Determination To Reviewin-Part a Final Determination of No
Violation of Section 337; Schedule for
Filing Written Submissions on the
Issues Under Review and on Remedy,
the Public Interest, and Bonding
U.S. International Trade
Commission.
ACTION: Notice.
AGENCY:
Notice is hereby given that
the U.S. International Trade
Commission has determined to review
certain portions of the final initial
determination (‘‘ID’’) issued by the
presiding administrative law judge
(‘‘ALJ’’) on December 16, 2010 finding
no violation of section 337 in the abovecaptioned investigation.
jlentini on DSKJ8SOYB1PROD with NOTICES
SUMMARY:
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Jia
Chen, Office of the General Counsel,
U.S. International Trade Commission,
500 E Street, SW., Washington, DC
20436, telephone (202) 708–4737.
Copies of non-confidential documents
filed in connection with this
investigation are or will be available for
inspection during official business
hours (8:45 a.m. to 5:15 p.m.) in the
Office of the Secretary, U.S.
International Trade Commission, 500 E
Street, SW., Washington, DC 20436,
telephone (202) 205–2000. General
information concerning the Commission
may also be obtained by accessing its
Internet server at https://www.usitc.gov.
The public record for this investigation
may be viewed on the Commission’s
electronic docket (EDIS) at https://
edis.usitc.gov. Hearing-impaired
persons are advised that information on
this matter can be obtained by
contacting the Commission’s TDD
terminal on (202) 205–1810.
SUPPLEMENTARY INFORMATION: The
Commission instituted the instant
investigation on December 16, 2009,
based on a complaint filed by Pioneer
Corporation of Tokyo, Japan and
Pioneer Electronics (USA) Inc. of Long
Beach, California (collectively,
‘‘Pioneer’’). 74 FR 66676 (Dec. 16, 2009).
The complaint alleges violations of
section 337 of the Tariff Act of 1930
(19 U.S.C. 1337) in the importation into
the United States, the sale for
importation, and the sale within the
United States after importation of
certain multimedia display and
navigation devices and systems,
components thereof, and products
containing same by reason of
infringement of various claims of United
States Patent Nos. 5,365,448 (‘‘the ‘448
patent’’), 5,424,951 (‘‘the ‘951 patent’’),
and 6,122,592 (‘‘the ‘592 patent’’). The
complaint names Garmin International,
Inc. of Olathe, Kansas, Garmin
Corporation of Taiwan (collectively,
‘‘Garmin’’) and Honeywell International
Inc. of Morristown, New Jersey
(‘‘Honeywell’’) as the proposed
respondents. Honeywell was
subsequently terminated from the
investigation, leaving only the Garmin
respondents remaining.
On December 16, 2010, the ALJ issued
a final ID, including his recommended
determination on remedy and bonding.
In his final ID, the ALJ found no
violation of section 337 by Garmin.
Specifically, the ALJ found that the
accused products do not infringe claims
1 and 2 of the ‘448 patent, claims 1 and
2 of the ‘951 patent, or claims 1 and 2
of the ‘592 patent. The ALJ further
found that neither Garmin nor the
FOR FURTHER INFORMATION CONTACT:
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11271
Commission investigative attorney
(‘‘IA’’) has established that claims 1 and
2 of the ‘592 patent are invalid for
obviousness under 35 U.S.C. 103 or for
failing to comply with the written
description requirement under 35 U.S.C.
112. With respect to remedy, the ALJ
recommended that if the Commission
disagrees with the finding of no
violation, the Commission should issue
a limited exclusion order directed to
multimedia display and navigation
devices and systems, and the
components of such devices and
systems, as well as a cease and desist
order. The ALJ recommended that the
limited exclusion order contain a
certification provision. In addition, the
ALJ recommended, in the event that a
violation is found, that Garmin be
required to post a bond equal to 0.5
percent of the entered value of any
accused products that Garmin seeks to
import during the Presidential review
period.
On January 5, 2011, Pioneer, Garmin,
and the IA each filed a petition for
review of the ALJ’s final ID. On January
9, 2011, Pioneer filed a consolidated
reply to Garmin’s and the IA’s petitions
for review. On the same day, Garmin
filed a reply to Pioneer’s petition for
review and a separate reply to the IA’s
petitions for review. Also on the same
day, the IA filed a consolidated reply to
Pioneer and Garmin’s petitions for
review.
Having examined the record of this
investigation, including the ALJ’s final
ID and the submissions of the parties,
the Commission has determined to
review (1) The claim construction of the
limitation ‘‘second memory means’’
recited in claim 1 of the ‘951 patent, (2)
infringement of claims 1 and 2 of the
‘951 patent, (3) the claim construction of
the limitations ‘‘extracting means’’ and
‘‘a calculating device’’ recited in claim 1
of the ‘592 patent, (4) infringement of
claims 1 and 2 of the ‘592 patent, (5)
validity of the ‘592 patent under the
written description requirement of 35
U.S.C. 112, and (6) the economic prong
of the domestic industry requirement.
No other issues are being reviewed.
The parties should brief their
positions on the issues on review with
reference to the applicable law and the
evidentiary record. In connection with
its review, the Commission is
particularly interested in responses to
the following questions:
1. With respect to claim 1 of the ‘951
patent, does the claimed function of the
limitation ‘‘second memory means’’
require ‘‘the read display pattern data’’
stored on the ‘‘second memory means’’
to be in the same data format with ‘‘said
display pattern data * * * from said
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first memory mean’’? Does the scope of
the claimed function allow ‘‘display
pattern data’’ stored on the ‘‘second
memory means’’ to be derived from and
to convey the same conceptual
information as ‘‘display pattern data’’
from the ‘‘first memory means,’’ even
though the display pattern data may be
represented in different formats? Please
provide support for your claim
construction in the claims, the
specification, the prosecution history,
and any extrinsic evidence concerning
how the claim would be understood by
persons skilled in the art.
2. Assume that the scope of the
claimed function of the ‘‘second memory
means’’ limitation recited in claim 1 of
the ‘951 patent encompasses ‘‘display
pattern data’’ stored on the ‘‘second
memory means’’ that are derived from
and represented in a different format
than the ‘‘display pattern data’’ from the
‘‘first memory means,’’ where both
‘‘display pattern data’’ represent the
same conceptual information. Do the
accused product combinations, i.e., the
product combinations identified at the
top of page 3 of complainant’s petition
for review, meet the ‘‘second memory
means’’ limitation?
3. Assuming that the accused product
combinations meet all of the recited
limitations of claim 1 of the ‘951 patent,
do they also meet dependent claim 2’s
limitation ‘‘wherein said second
memory means has a plurality of
memory locations to store said position
coordinate data and said position
display data to indicate said display
pattern as a pair?’’ Please cite to all
evidence in the record for support.
4. With respect to the proper
construction of the function of the
‘‘extracting means’’ limitation recited in
claim 1 of the ‘592 patent, does claim 1
require that the recited ‘‘plurality of
locations’’ be physically segregated into
different categories in memory in view
of the intrinsic evidence (see, e.g., ‘592
patent, Figure 27 and Col. 16).
5. If the answer to question 4 is yes,
do the accused devices meet the
‘‘extracting means’’ limitation of the ‘592
patent? Please cite to all evidence in the
record for support.
6. With respect to the proper
construction of the corresponding
structure of the ‘‘extracting means’’
limitation recited in claim 1 of the ‘592
patent, should the Commission modify
the corresponding structure identified
by the ALJ from the specification as
‘‘CPU programmed to read location data
from memory and a CD–ROM drive,
wherein the memory is RAM configured
to store the location data as depicted in
Figure 27 ’’? Please provide support for
your claim construction in the claims,
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the specification, the prosecution
history, and any extrinsic evidence
concerning how the claim would be
understood by persons skilled in the art.
7. If the answer to question 6 is yes,
do the accused devices meet the
‘‘extracting means’’ limitation of the ‘592
patent? Please cite to all evidence in the
record for support.
8. With respect to the proper
construction of the limitation ‘‘a
calculating device’’ recited in claim 1 of
the ‘592 patent, does the intrinsic
evidence require that the recited term
‘‘said locations’’ refer to the plurality of
locations of the selected category that
has been extracted by the ‘‘extracting
means,’’ rather than all locations of the
selected category?
9. If the answer to question 8 is yes,
do the ‘‘Search Near’’ mode and the
‘‘GPS Simulator’’ mode of the accused
device meet the limitation ‘‘a calculating
device’’? Please cite to all evidence in
the record for support.
10. With respect to the functionality
discussed on page 124, n. 19 of the ID,
please cite to all evidence of record
indicating how this feature operates and
how this feature does or does not meet
the ‘‘a calculating device’’ limitation of
claim 1. Please cite to all evidence in
the record for support.
11. Assuming that the specification of
the ‘592 patent provides adequate
support for the ‘‘extracting means’’
limitation of claim 1 and assuming that
claim 1 is not directed to the disparaged
problem in the prior art, does the
specification provide adequate support
for ‘‘a selector device’’ and ‘‘a location
name display device’’ recited in claim 1
to satisfy the written description
requirement of 35 U.S.C. 112?
12. With respect to the economic
prong of the domestic industry
requirement, what is Pioneer’s
investment as opposed to DVA’s
investment for Pioneer’s licensing
activities with the entity identified on
page 148 of the ID?
13. With respect to Pioneer’s licensing
negotiation efforts with the entity
identified on page 151 of the ID, what
is the contribution by Pioneer’s U.S.
employees?
14. Do payments made to outside
counsel by complainant prior to filing
the instant investigation constitute
investment in exploitation of the patent
under section 337(a)(3)(C)?
15. With respect to the table provided
on pages 87–88 of complainant’s posthearing brief and adopted by the ALJ on
pages 157–158 of the ID, please identify
the targeted licensee for each entry.
16. Is Pioneer’s investment in
exploitation of the asserted patents
through licensing ‘‘substantial’’ under
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section 337(a)(3)(C), in light of the
Commission’s holding on page 31, first
paragraph, of Certain Printing and
Imaging Devices and Components
Thereof, 337–TA–690, Comm’n Op.
(Feb. 1, 2011)?
In connection with the final
disposition of this investigation, the
Commission may (1) issue an order that
could result in the exclusion of the
subject articles from entry into the
United States, and/or (2) issue one or
more cease and desist orders that could
result in a respondent being required to
cease and desist from engaging in unfair
acts in the importation and sale of such
articles. Accordingly, the Commission is
interested in receiving written
submissions that address the form of
remedy, if any, that should be ordered.
If a party seeks exclusion of an article
from entry into the United States for
purposes other than entry for
consumption, the party should so
indicate and provide information
establishing that activities involving
other types of entry either are adversely
affecting it or likely to do so. For
background, see In the Matter of Certain
Devices for Connecting Computers via
Telephone Lines, Inv. No. 337–TA–360,
USITC Pub. No. 2843 (December 1994)
(Commission Opinion).
If the Commission contemplates some
form of remedy, it must consider the
effects of that remedy upon the public
interest. The factors the Commission
will consider include the effect that an
exclusion order and/or cease and desist
orders would have on (1) the public
health and welfare, (2) competitive
conditions in the U.S. economy, (3) U.S.
production of articles that are like or
directly competitive with those that are
subject to investigation, and (4) U.S.
consumers. The Commission is
therefore interested in receiving written
submissions that address the
aforementioned public interest factors
in the context of this investigation.
If the Commission orders some form
of remedy, the United States Trade
Representative, as delegated by the
President, has 60 days to approve or
disapprove the Commission’s action.
See Presidential Memorandum of July
21, 2005, 70 FR 43251 (July 26, 2005).
During this period, the subject articles
would be entitled to enter the United
States under bond, in an amount
determined by the Commission and
prescribed by the Secretary of the
Treasury. The Commission is therefore
interested in receiving submissions
concerning the amount of the bond that
should be imposed if a remedy is
ordered.
Written Submissions: The parties to
the investigation are requested to file
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jlentini on DSKJ8SOYB1PROD with NOTICES
written submissions on the issues
identified in this notice. Parties to the
investigation, interested government
agencies, and any other interested
parties are encouraged to file written
submissions on the issues of remedy,
the public interest, and bonding. Such
submissions should address the
recommended determination by the ALJ
on remedy and bonding. Complainant
and the Commission investigative
attorney are also requested to submit
proposed remedial orders for the
Commission’s consideration.
Complainant is also requested to state
the date that the patent expires and the
HTSUS numbers under which the
accused products are imported. The
written submissions and proposed
remedial orders must be filed no later
than close of business on March 9, 2011.
Reply submissions must be filed no later
than the close of business on March 18,
2011. The written submissions must be
no longer than 100 pages and the reply
submissions must be no longer than 50
pages. No further submissions on these
issues will be permitted unless
otherwise ordered by the Commission.
Persons filing written submissions
must file the original document and 12
true copies thereof on or before the
deadlines stated above with the Office
of the Secretary. Any person desiring to
submit a document to the Commission
in confidence must request confidential
treatment unless the information has
already been granted such treatment
during the proceedings. All such
requests should be directed to the
Secretary of the Commission and must
include a full statement of the reasons
why the Commission should grant such
treatment. See 19 CFR 210.6. Documents
for which confidential treatment by the
Commission is sought will be treated
accordingly. All non-confidential
written submissions will be available for
public inspection at the Office of the
Secretary.
The authority for the Commission’s
determination is contained in section
337 of the Tariff Act of 1930, as
amended (19 U.S.C. 1337), and in
sections 210.42–46 and 210.50 of the
Commission’s Rules of Practice and
Procedure (19 CFR 210.42–46 and
210.50).
By order of the Commission.
Issued: February 23, 2011.
William R. Bishop,
Hearings and Meetings Coordinator.
[FR Doc. 2011–4452 Filed 2–28–11; 8:45 am]
BILLING CODE 7020–02–P
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INTERNATIONAL TRADE
COMMISSION
[Investigation No. 731–TA–856 (Second
Review)]
Ammonium Nitrate From Russia
United States International
Trade Commission.
ACTION: Institution of a five-year review
concerning the suspended investigation
on ammonium nitrate from Russia.
AGENCY:
The Commission hereby gives
notice that it has instituted a review
pursuant to section 751(c) of the Tariff
Act of 1930 (19 U.S.C. 1675(c)) (the Act)
to determine whether termination of the
suspended investigation on ammonium
nitrate from Russia would be likely to
lead to continuation or recurrence of
material injury. Pursuant to section
751(c)(2) of the Act, interested parties
are requested to respond to this notice
by submitting the information specified
below to the Commission; 1 to be
assured of consideration, the deadline
for responses is March 31, 2011.
Comments on the adequacy of responses
may be filed with the Commission by
May 16, 2011. For further information
concerning the conduct of this review
and rules of general application, consult
the Commission’s Rules of Practice and
Procedure, part 201, subparts A through
E (19 CFR part 201), and part 207,
subparts A, D, E, and F (19 CFR part
207), as most recently amended at 74 FR
2847 (January 16, 2009).
DATES: Effective Date: March 1, 2011.
FOR FURTHER INFORMATION CONTACT:
Mary Messer (202–205–3193), Office of
Investigations, U.S. International Trade
Commission, 500 E Street, SW.,
Washington, DC 20436. Hearingimpaired persons can obtain
information on this matter by contacting
the Commission’s TDD terminal on 202–
205–1810. Persons with mobility
impairments who will need special
assistance in gaining access to the
Commission should contact the Office
of the Secretary at 202–205–2000.
General information concerning the
Commission may also be obtained by
accessing its Internet server (https://
www.usitc.gov). The public record for
this review may be viewed on the
SUMMARY:
1 No response to this request for information is
required if a currently valid Office of Management
and Budget (OMB) number is not displayed; the
OMB number is 3117–0016/USITC No. 11–5–239,
expiration date June 30, 2011. Public reporting
burden for the request is estimated to average 15
hours per response. Please send comments
regarding the accuracy of this burden estimate to
the Office of Investigations, U.S. International Trade
Commission, 500 E Street, SW., Washington, DC
20436.
PO 00000
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Commission’s electronic docket (EDIS)
at https://edis.usitc.gov.
SUPPLEMENTARY INFORMATION:
Background.—On May 19, 2000, the
Department of Commerce suspended an
antidumping duty investigation on
imports of ammonium nitrate from
Russia (65 FR 37759, June 16, 2000).
Following five-year reviews by
Commerce and the Commission,
effective April 5, 2006, Commerce
issued a continuation of the suspended
investigation on imports of ammonium
nitrate from Russia (71 FR 17080). The
Commission is now conducting a
second review to determine whether
termination of the suspended
investigation would be likely to lead to
continuation or recurrence of material
injury to the domestic industry within
a reasonably foreseeable time. It will
assess the adequacy of interested party
responses to this notice of institution to
determine whether to conduct a full
review or an expedited review. The
Commission’s determination in any
expedited review will be based on the
facts available, which may include
information provided in response to this
notice.
Definitions.—The following
definitions apply to this review:
(1) Subject Merchandise is the class or
kind of merchandise that is within the
scope of the five-year review, as defined
by the Department of Commerce.
(2) The Subject Country in this review
is Russia.
(3) The Domestic Like Product is the
domestically produced product or
products which are like, or in the
absence of like, most similar in
characteristics and uses with, the
Subject Merchandise. In its original
determination and its full first five-year
review determination, the Commission
defined the Domestic Like Product
coextensively with the subject
merchandise: fertilizer grade
ammonium nitrate products with a bulk
density equal to or greater than 53
pounds per cubic foot.
(4) The Domestic Industry is the U.S.
producers as a whole of the Domestic
Like Product, or those producers whose
collective output of the Domestic Like
Product constitutes a major proportion
of the total domestic production of the
product. In its original determination
and its full first five-year review
determination, the Commission defined
the Domestic Industry as all domestic
producers of high density ammonium
nitrate.
(5) An Importer is any person or firm
engaged, either directly or through a
parent company or subsidiary, in
importing the Subject Merchandise into
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Agencies
[Federal Register Volume 76, Number 40 (Tuesday, March 1, 2011)]
[Notices]
[Pages 11271-11273]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2011-4452]
-----------------------------------------------------------------------
INTERNATIONAL TRADE COMMISSION
[Investigation No. 337-TA-694]
In the Matter of Certain Multimedia Display and Navigation
Devices and Systems, Components Thereof, and Products Containing Same;
Notice of Commission Determination To Review-in-Part a Final
Determination of No Violation of Section 337; Schedule for Filing
Written Submissions on the Issues Under Review and on Remedy, the
Public Interest, and Bonding
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: Notice is hereby given that the U.S. International Trade
Commission has determined to review certain portions of the final
initial determination (``ID'') issued by the presiding administrative
law judge (``ALJ'') on December 16, 2010 finding no violation of
section 337 in the above-captioned investigation.
FOR FURTHER INFORMATION CONTACT: Jia Chen, Office of the General
Counsel, U.S. International Trade Commission, 500 E Street, SW.,
Washington, DC 20436, telephone (202) 708-4737. Copies of non-
confidential documents filed in connection with this investigation are
or will be available for inspection during official business hours
(8:45 a.m. to 5:15 p.m.) in the Office of the Secretary, U.S.
International Trade Commission, 500 E Street, SW., Washington, DC
20436, telephone (202) 205-2000. General information concerning the
Commission may also be obtained by accessing its Internet server at
https://www.usitc.gov. The public record for this investigation may be
viewed on the Commission's electronic docket (EDIS) at https://edis.usitc.gov. Hearing-impaired persons are advised that information
on this matter can be obtained by contacting the Commission's TDD
terminal on (202) 205-1810.
SUPPLEMENTARY INFORMATION: The Commission instituted the instant
investigation on December 16, 2009, based on a complaint filed by
Pioneer Corporation of Tokyo, Japan and Pioneer Electronics (USA) Inc.
of Long Beach, California (collectively, ``Pioneer''). 74 FR 66676
(Dec. 16, 2009). The complaint alleges violations of section 337 of the
Tariff Act of 1930 (19 U.S.C. 1337) in the importation into the United
States, the sale for importation, and the sale within the United States
after importation of certain multimedia display and navigation devices
and systems, components thereof, and products containing same by reason
of infringement of various claims of United States Patent Nos.
5,365,448 (``the `448 patent''), 5,424,951 (``the `951 patent''), and
6,122,592 (``the `592 patent''). The complaint names Garmin
International, Inc. of Olathe, Kansas, Garmin Corporation of Taiwan
(collectively, ``Garmin'') and Honeywell International Inc. of
Morristown, New Jersey (``Honeywell'') as the proposed respondents.
Honeywell was subsequently terminated from the investigation, leaving
only the Garmin respondents remaining.
On December 16, 2010, the ALJ issued a final ID, including his
recommended determination on remedy and bonding. In his final ID, the
ALJ found no violation of section 337 by Garmin. Specifically, the ALJ
found that the accused products do not infringe claims 1 and 2 of the
`448 patent, claims 1 and 2 of the `951 patent, or claims 1 and 2 of
the `592 patent. The ALJ further found that neither Garmin nor the
Commission investigative attorney (``IA'') has established that claims
1 and 2 of the `592 patent are invalid for obviousness under 35 U.S.C.
103 or for failing to comply with the written description requirement
under 35 U.S.C. 112. With respect to remedy, the ALJ recommended that
if the Commission disagrees with the finding of no violation, the
Commission should issue a limited exclusion order directed to
multimedia display and navigation devices and systems, and the
components of such devices and systems, as well as a cease and desist
order. The ALJ recommended that the limited exclusion order contain a
certification provision. In addition, the ALJ recommended, in the event
that a violation is found, that Garmin be required to post a bond equal
to 0.5 percent of the entered value of any accused products that Garmin
seeks to import during the Presidential review period.
On January 5, 2011, Pioneer, Garmin, and the IA each filed a
petition for review of the ALJ's final ID. On January 9, 2011, Pioneer
filed a consolidated reply to Garmin's and the IA's petitions for
review. On the same day, Garmin filed a reply to Pioneer's petition for
review and a separate reply to the IA's petitions for review. Also on
the same day, the IA filed a consolidated reply to Pioneer and Garmin's
petitions for review.
Having examined the record of this investigation, including the
ALJ's final ID and the submissions of the parties, the Commission has
determined to review (1) The claim construction of the limitation
``second memory means'' recited in claim 1 of the `951 patent, (2)
infringement of claims 1 and 2 of the `951 patent, (3) the claim
construction of the limitations ``extracting means'' and ``a
calculating device'' recited in claim 1 of the `592 patent, (4)
infringement of claims 1 and 2 of the `592 patent, (5) validity of the
`592 patent under the written description requirement of 35 U.S.C. 112,
and (6) the economic prong of the domestic industry requirement. No
other issues are being reviewed.
The parties should brief their positions on the issues on review
with reference to the applicable law and the evidentiary record. In
connection with its review, the Commission is particularly interested
in responses to the following questions:
1. With respect to claim 1 of the `951 patent, does the claimed
function of the limitation ``second memory means'' require ``the read
display pattern data'' stored on the ``second memory means'' to be in
the same data format with ``said display pattern data * * * from said
[[Page 11272]]
first memory mean''? Does the scope of the claimed function allow
``display pattern data'' stored on the ``second memory means'' to be
derived from and to convey the same conceptual information as ``display
pattern data'' from the ``first memory means,'' even though the display
pattern data may be represented in different formats? Please provide
support for your claim construction in the claims, the specification,
the prosecution history, and any extrinsic evidence concerning how the
claim would be understood by persons skilled in the art.
2. Assume that the scope of the claimed function of the ``second
memory means'' limitation recited in claim 1 of the `951 patent
encompasses ``display pattern data'' stored on the ``second memory
means'' that are derived from and represented in a different format
than the ``display pattern data'' from the ``first memory means,''
where both ``display pattern data'' represent the same conceptual
information. Do the accused product combinations, i.e., the product
combinations identified at the top of page 3 of complainant's petition
for review, meet the ``second memory means'' limitation?
3. Assuming that the accused product combinations meet all of the
recited limitations of claim 1 of the `951 patent, do they also meet
dependent claim 2's limitation ``wherein said second memory means has a
plurality of memory locations to store said position coordinate data
and said position display data to indicate said display pattern as a
pair?'' Please cite to all evidence in the record for support.
4. With respect to the proper construction of the function of the
``extracting means'' limitation recited in claim 1 of the `592 patent,
does claim 1 require that the recited ``plurality of locations'' be
physically segregated into different categories in memory in view of
the intrinsic evidence (see, e.g., `592 patent, Figure 27 and Col. 16).
5. If the answer to question 4 is yes, do the accused devices meet
the ``extracting means'' limitation of the `592 patent? Please cite to
all evidence in the record for support.
6. With respect to the proper construction of the corresponding
structure of the ``extracting means'' limitation recited in claim 1 of
the `592 patent, should the Commission modify the corresponding
structure identified by the ALJ from the specification as ``CPU
programmed to read location data from memory and a CD-ROM drive,
wherein the memory is RAM configured to store the location data as
depicted in Figure 27 ''? Please provide support for your claim
construction in the claims, the specification, the prosecution history,
and any extrinsic evidence concerning how the claim would be understood
by persons skilled in the art.
7. If the answer to question 6 is yes, do the accused devices meet
the ``extracting means'' limitation of the `592 patent? Please cite to
all evidence in the record for support.
8. With respect to the proper construction of the limitation ``a
calculating device'' recited in claim 1 of the `592 patent, does the
intrinsic evidence require that the recited term ``said locations''
refer to the plurality of locations of the selected category that has
been extracted by the ``extracting means,'' rather than all locations
of the selected category?
9. If the answer to question 8 is yes, do the ``Search Near'' mode
and the ``GPS Simulator'' mode of the accused device meet the
limitation ``a calculating device''? Please cite to all evidence in the
record for support.
10. With respect to the functionality discussed on page 124, n. 19
of the ID, please cite to all evidence of record indicating how this
feature operates and how this feature does or does not meet the ``a
calculating device'' limitation of claim 1. Please cite to all evidence
in the record for support.
11. Assuming that the specification of the `592 patent provides
adequate support for the ``extracting means'' limitation of claim 1 and
assuming that claim 1 is not directed to the disparaged problem in the
prior art, does the specification provide adequate support for ``a
selector device'' and ``a location name display device'' recited in
claim 1 to satisfy the written description requirement of 35 U.S.C.
112?
12. With respect to the economic prong of the domestic industry
requirement, what is Pioneer's investment as opposed to DVA's
investment for Pioneer's licensing activities with the entity
identified on page 148 of the ID?
13. With respect to Pioneer's licensing negotiation efforts with
the entity identified on page 151 of the ID, what is the contribution
by Pioneer's U.S. employees?
14. Do payments made to outside counsel by complainant prior to
filing the instant investigation constitute investment in exploitation
of the patent under section 337(a)(3)(C)?
15. With respect to the table provided on pages 87-88 of
complainant's post-hearing brief and adopted by the ALJ on pages 157-
158 of the ID, please identify the targeted licensee for each entry.
16. Is Pioneer's investment in exploitation of the asserted patents
through licensing ``substantial'' under section 337(a)(3)(C), in light
of the Commission's holding on page 31, first paragraph, of Certain
Printing and Imaging Devices and Components Thereof, 337-TA-690, Comm'n
Op. (Feb. 1, 2011)?
In connection with the final disposition of this investigation, the
Commission may (1) issue an order that could result in the exclusion of
the subject articles from entry into the United States, and/or (2)
issue one or more cease and desist orders that could result in a
respondent being required to cease and desist from engaging in unfair
acts in the importation and sale of such articles. Accordingly, the
Commission is interested in receiving written submissions that address
the form of remedy, if any, that should be ordered. If a party seeks
exclusion of an article from entry into the United States for purposes
other than entry for consumption, the party should so indicate and
provide information establishing that activities involving other types
of entry either are adversely affecting it or likely to do so. For
background, see In the Matter of Certain Devices for Connecting
Computers via Telephone Lines, Inv. No. 337-TA-360, USITC Pub. No. 2843
(December 1994) (Commission Opinion).
If the Commission contemplates some form of remedy, it must
consider the effects of that remedy upon the public interest. The
factors the Commission will consider include the effect that an
exclusion order and/or cease and desist orders would have on (1) the
public health and welfare, (2) competitive conditions in the U.S.
economy, (3) U.S. production of articles that are like or directly
competitive with those that are subject to investigation, and (4) U.S.
consumers. The Commission is therefore interested in receiving written
submissions that address the aforementioned public interest factors in
the context of this investigation.
If the Commission orders some form of remedy, the United States
Trade Representative, as delegated by the President, has 60 days to
approve or disapprove the Commission's action. See Presidential
Memorandum of July 21, 2005, 70 FR 43251 (July 26, 2005). During this
period, the subject articles would be entitled to enter the United
States under bond, in an amount determined by the Commission and
prescribed by the Secretary of the Treasury. The Commission is
therefore interested in receiving submissions concerning the amount of
the bond that should be imposed if a remedy is ordered.
Written Submissions: The parties to the investigation are requested
to file
[[Page 11273]]
written submissions on the issues identified in this notice. Parties to
the investigation, interested government agencies, and any other
interested parties are encouraged to file written submissions on the
issues of remedy, the public interest, and bonding. Such submissions
should address the recommended determination by the ALJ on remedy and
bonding. Complainant and the Commission investigative attorney are also
requested to submit proposed remedial orders for the Commission's
consideration. Complainant is also requested to state the date that the
patent expires and the HTSUS numbers under which the accused products
are imported. The written submissions and proposed remedial orders must
be filed no later than close of business on March 9, 2011. Reply
submissions must be filed no later than the close of business on March
18, 2011. The written submissions must be no longer than 100 pages and
the reply submissions must be no longer than 50 pages. No further
submissions on these issues will be permitted unless otherwise ordered
by the Commission.
Persons filing written submissions must file the original document
and 12 true copies thereof on or before the deadlines stated above with
the Office of the Secretary. Any person desiring to submit a document
to the Commission in confidence must request confidential treatment
unless the information has already been granted such treatment during
the proceedings. All such requests should be directed to the Secretary
of the Commission and must include a full statement of the reasons why
the Commission should grant such treatment. See 19 CFR 210.6. Documents
for which confidential treatment by the Commission is sought will be
treated accordingly. All non-confidential written submissions will be
available for public inspection at the Office of the Secretary.
The authority for the Commission's determination is contained in
section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and
in sections 210.42-46 and 210.50 of the Commission's Rules of Practice
and Procedure (19 CFR 210.42-46 and 210.50).
By order of the Commission.
Issued: February 23, 2011.
William R. Bishop,
Hearings and Meetings Coordinator.
[FR Doc. 2011-4452 Filed 2-28-11; 8:45 am]
BILLING CODE 7020-02-P