Certain Secondary Cylindrical Batteries, Components Thereof, and Products Containing the Same; Inv. No. 337-TA-1518 (Violation)

This supplemental complaint, filed at OUII's request, makes limited corrective changes to LG Energy Solution Ltd. and LG Energy Solution Arizona, Inc.'s July 21, 2026 Section 337 complaint over secondary cylindrical batteries, including a respondent address fix, clarified paragraphs, and updated exhibits. The supplement clarifies the scope of the accused products (rechargeable cylindrical batteries and downstream products) and the domestic industry allocation, helping the Commission institute the investigation. The complaint states it is otherwise unchanged. The text does not describe the relief sought, so no exclusion order details are given here. Complainants are LG Energy Solution Ltd. and LG Energy Solution Arizona, Inc., represented by Quinn Emanuel. The supplement corrects the address of proposed respondent Nanjing Chervon Industry Co., Ltd. Paragraph 5 now defines secondary as rechargeable. Paragraph 91 adds that claim charts compare asserted claims to representative EVE products (20P, 29V, 50E, 40PL, 50PL) and that downstream products from Bosch, Koki, and Chervon are also accused. Paragraph 125 now identifies the concurrent Eastern District of Texas case as No. 2:26-cv-00598-JRG-RSP. Updated certified copies are submitted for the '257, '866, '924, '965, and '735 patents, their assignment records, and prosecution histories, plus the provisional application history for the '924 patent. Complainants clarify that the building/real estate and labor investments in Confidential Exhibit 23C can be allocated to each Domestic Industry Product later.