Background

The International Trade Commission is accepting comments through June 29 on a proposed rule that would require the disclosure of entities that have a financial interest in, or exert control with respect to, the parties that appear before the ITC in section 337 intellectual property rights investigations and ancillary proceedings.

The ITC states that the purpose of this disclosure requirement is to (1) facilitate the evaluation of potential conflicts for ITC commissioners, administrative law judges, and employees; e.g., by clarifying whether a party is owned or controlled by another entity or whether an entity other than the party has control over the party’s participation in the investigation, (2) provide early clarity about entities whose rights are at issue in the investigation, and (3) promote transparency to facilitate settlement and bring relevant issues to the ITC’s attention.

The ITC is seeking comments on (1) the benefits to parties, the public, and the ITC of having a disclosure rule like the one proposed, (2) any undue burden the proposed amendments would have on parties, (3) ways to mitigate those burdens while achieving the objectives of the proposed amendments, and (4) the effect this rule is likely to have in section 337 investigations, including whether certain entities or circumstances are likely to be affected more than others.

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