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

This amended complaint, filed by Jonathan Black Kotyk, supersedes the original and asserts U.S. Patent No. 7,527,314 ("Vehicle Gap Guard") against proposed respondents in Certain Vehicle Space Guards, withdrawing the general exclusion order request and seeking only a limited exclusion order. The amendment narrows the relief sought from a general exclusion order to a limited exclusion order aimed at named proposed respondents, plus cease and desist orders and a bond during Presidential review. It also modifies the asserted claims and expands the domestic industry allegations, which shapes the scope of the investigation for vehicle space guards. Complainant is Jonathan Black Kotyk; the proposed respondents are not named in the excerpt, and Drop Stop, LLC is alleged to directly and literally infringe one or more claims. Asserted patent is U.S. Patent No. 7,527,314, titled Vehicle Gap Guard, said to claim a vehicle space guard with attachment means such as Velcro or adhesive. Asserted claims are modified to independent claims 1 and 14 and dependent claims 2-4, 6, 8-12, 15-16, 18 and 19. Adds factual and legal support for an implied license to One More Thing, LLC, arising in two stages from D. Pelfrey (2013 to 2023) and from J. Kotyk (2023 to present). Domestic industry section is updated and substantially expanded under each applicable subsection of 19 U.S.C. § 1337(a)(3), with new Confidential Exhibits 32-C through 52. Relief sought is a limited exclusion order, permanent cease and desist orders and a bond during the Presidential review period.