Certain Systems, Devices, Software, Compositions, Chemicals, and Laboratory Supplies for Studying Proteins; Inv. No. 337-TA-1508 (Violation)

This supplemental complaint, filed by Seer, Inc. and The Brigham and Women's Hospital, Inc. in response to an OUII request, replaces paragraphs 151-157 and 159 of the original complaint and adds contact information to the cover page, clarifying the domestic industry allegations for the '360, '112, '222, '566 and '948 Patents. It adds no respondents and alleges no additional unfair acts. The supplement firms up the technical and economic domestic industry showing, which is needed before the Commission institutes an investigation into proteome analysis systems and assay kits. It ties Seer's Proteograph XT and ONE assay kits and SP100 and SP200 automation instruments to specific asserted patents and claims, and it gives an R&D investment split between the products. The text does not state the relief sought, nor does it identify respondents. Complainants are Seer, Inc. and The Brigham and Women's Hospital, Inc.; the supplement responds to an OUII request for additional information and clarification of the complaint filed May 28, 2026. Asserted patents named are U.S. Patent Nos. 11,435,360; 11,630,112; 12,050,222; 12,228,566; and 12,590,948. Domestic Industry Products are Seer Proteograph XT and Proteograph ONE Assay kits and the SP100 and SP200 Automation Instruments, marketed as the Proteograph Product Suite. Exhibits 49 through 53 are claim charts offered to show technical domestic industry for each asserted patent, with a table of exemplary practiced claims. Seer alleges significant investments in labor and capital across R&D, engineering, manufacturing, software, sales and support. It says about 53% of claimed R&D went to the XT and SP100 and about 47% to the ONE and SP200, and it reserves the right to rely on alternative allocations. The supplement states it adds no respondents or additional unfair acts and that the original verification remains accurate.