Certain Vehicle Space Guards; Inv. No. 337-TA-1509 (Violation)

This amended complaint is filed by Jonathan Black Kotyk against Drop Stop, LLC, 232 Technologies Inc., The Container Store, Walmart and Sportman's Market (Sporty's), alleging induced infringement of claims of U.S. Patent No. 7,527,314 through importation and sale of the Drop Stop Seat Gap Filler, and direct infringement by Drop Stop, LLC. The complaint targets imported vehicle seat gap fillers sold through major U.S. retailers and relies on an inducement theory based on product installation instructions. It seeks a limited exclusion order, cease and desist orders and a bond during the Presidential review period. The domestic industry rests on an individual complainant's company, One More Thing, LLC, practicing the patent under an alleged implied license. Complainant Jonathan Black Kotyk, a Florida individual, owns the '314 Patent, titled Vehicle Gap Guard, which expires March 14, 2027. Asserted independent claims are 1 and 14, with dependent claims 2-4, 6, 8-12, 15-16, 18 and 19. Proposed respondents are Drop Stop, LLC, 232 Technologies Inc., The Container Store, Walmart and Sporty's; Drop Stop is also alleged to directly infringe through its installation instructions. Accused products are Drop Stop Seat Gap Filler units marked as made in China, with inducement alleged through instructions to add double-sided tape or Velcro; direct infringement by non-respondent Christine Black is alleged. Domestic industry is alleged through One More Thing, LLC's Gap Guard product, with investments in plant and equipment, labor and capital, and engineering and marketing, under an implied license. Relief sought is a permanent limited exclusion order, cease and desist orders, a bond, and possible referral to ADR.