Tech Governance

ITC Institutes First 100-Day Pilot Program Investigation

  • The U.S. International Trade Commission (ITC) initiated its first investigation under the 100-day pilot program.

  • Purpose: Early determination of a potentially case-dispositive issue.

  • Investigation: Certain Audio Processing Hardware and Software and Products Containing Same, ITC Inv. No. 337-TA-949.

  • Notice of Investigation issued: March 12, 2015.


Complaint Details

  • Filed by Andrea Electronics Corporation (Feb. 9, 2015).

  • Allegations:

    • Unlawful importation of:

      • Microphones and microphone arrays

      • Audio codecs

      • Audio processing software

      • PCs (laptops, desktops, notebooks, tablets)

  • Named Respondents:

    • Acer

    • ASUSTek

    • Dell

    • Hewlett Packard

    • Lenovo

    • Toshiba

    • Realtek Semiconductor


Focus of the 100-Day Pilot Program

  • The Commission directed the ALJ to:

    • Conduct an early evidentiary hearing.

    • Determine whether Andrea has standing to assert the five patents.

  • First time the pilot program was used to examine standing.

  • Pilot program originally created in June 2013.

  • Goal:

    • Reduce litigation costs.

    • Resolve potentially dispositive issues early.

  • ALJ must:

    • Expedite discovery.

    • Issue an Initial Determination (ID) within 100 days of institution.


Respondents’ Standing Challenge

  • Hewlett Packard and Dell requested use of the pilot program.

  • Relied on Andrea’s SEC filings.

  • Alleged:

    • Andrea did not retain full ownership of the patents.

    • Substantial ownership interest assigned to an investment firm.

    • Patents held in escrow as collateral.

    • Andrea obligated to pursue patent monetization.

  • Andrea responded:

    • Agreements cited by Respondents were modified.

    • Alleged arrangements are “inoperative.”


Procedural Impact

  • ALJ Thomas B. Pender assigned to the case.

  • Early Initial Determination (ID) due within 100 days (expected mid-June).

  • If ALJ finds no standing:

    • Investigation will be stayed unless Commission orders otherwise.

  • If standing is upheld:

    • Investigation proceeds without delay toward final determination.


Key Takeaways

  • ITC is using the 100-day pilot program to:

    • Address threshold issues early.

    • Potentially dispose of cases quickly.

  • Standing challenges can be case-dispositive.

  • The program reflects ITC’s effort to streamline Section 337 investigations.

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