Certain Boiler Protection for Absorption Refrigeration Systems and Components Thereof; Inv. No. 337-TA-1453 (Violation)

The ALJ granted Complainants' unopposed motion for summary determination and found a violation of section 337 by the four defaulting respondents through importation and sale of RV refrigerator boiler protection products that infringe claims 1, 4, 6 and 10 of U.S. Patent No. 8,056,360. Claim terms took their plain and ordinary meaning, the unrebutted claim charts showed infringement, and the Fridge Defend product practiced the claims, satisfying the technical prong; the economic prong analysis is under way in the excerpt. The ID recommends remedy relief against the defaulting respondents. The table of contents lists a general exclusion order, cease and desist orders and a bond during Presidential review, though the remedy analysis itself is not in the supplied text. The Commission will decide whether to review the initial determination and the recommended determination on remedy and bond. Four respondents (Koofang, RVGIVE, Little Bear Pocket, VISVIC) were found in default, so the complaint's facts are presumed true under 19 C.F.R. 210.16(c)(1). Importation was shown by unrebutted complaint exhibits, and the Commission has authority over the imported goods and the parties. No claim terms needed construction; Complainants and Staff agreed on plain and ordinary meaning, and the ALJ adopted Complainants' definition of the person of ordinary skill. Unmack's declaration and claim charts show the Accused Products infringe apparatus claims 1 and 6; US customer reviews show use practicing method claims 4 and 10. The Fridge Defend product practices claims 1, 4, 6 and 10 (technical prong), and the economic prong is assessed under 1337(a)(3)(A) and (B) with Staff supporting Complainants, at least under Prong B.