Certain Storage Containers and Toolboxes, Organizers, Component Boxes, Coolers, and Accessories Used Therewith; Inv. No. 337-TA-1409 (Violation)

The Commission found a section 337 violation by Klein Tools as to the '026 and '952 patents, affirming the FID in part, and determined to issue a limited exclusion order and a cease and desist order. It has not reached a final determination on the '167 patent, whose domestic industry issue remains pending. The LEO and CDO bar Klein's infringing interlockable storage containers, toolboxes, organizers and coolers and cover its U.S. inventory, with imports during Presidential review allowed only under an 18 percent bond. The Commission's economic prong holding rests on significant labor employment tied to the two domestically manufactured organizers, which could draw appellate scrutiny. The unresolved '167 patent leaves part of the investigation open. Invalidity: the Commission set aside the FID's finding that the Auer Catalog issued in March 2015, found it publicly available about September 29, 2015, and still affirmed that Klein failed to show by clear and convincing evidence that the Auer System was prior art, because its public use was uncorroborated. Claim construction: 'rib extending [away] from the back wall' takes its plain meaning and is not limited to the single locking rib embodiment, because Klein showed no lexicography or disclaimer and claims are not limited to disclosed embodiments. Technical prong: affirmed for the asserted claims because the DI Products have ribs extending from both the back wall and the side edges, while the FID's alternative finding under Klein's construction was vacated. Economic prong: affirmed under modified reasoning as satisfied under 337(a)(3)(B) for the '026 and '952 patents based on significant labor in domestic manufacturing of the Compact Organizers and Low-Profile Compact Organizers, with onshoring supporting significance; no position on (a)(3)(A). Remedy: an LEO and a CDO against Klein are appropriate because Klein did not contest them and holds commercially significant U.S. inventory, the public interest factors do not weigh against relief, and the bond is set at 18 percent of entered value, not the CALJ's higher recommendation.