On July 2, 2015, Administrative Law Judge David Shaw issued a 320-page Final Initial Determination On Violation And Recommended Determination On Remedy in Certain Marine Sonar Imaging Devices (Inv. No. 337-TA-921) determining that a violation of Section 337 had not occurred with respect to the asserted patents. The investigation had been instituted in July 2014 based on a Complaint by Navico Holdings AS and Navico, Inc. (“Navico”) accusing marine imaging devices, namely, underwater scanning devices using “DownScan” sonar technology, imported by Garmin International, Inc., Garmin USA, Inc., and Garmin (Asia) Corp. (“Garmin”) of infringing Navico’s patents. Navico had alleged that Garmin hired former Navico engineers, including the three named inventors of the asserted patents, to develop the infringing products. After the hearing, ALJ Shaw ordered the parties to submit supplemental briefing on the effects of the Federal Circuit’s precedential opinion concerning the economic prong of the domestic industry requirement in Lelo Inc. v. Int’l Trade Comm’n, No. 13-1582 (Fed. Cir. May 11, 2015). The determination of no violation was announced by Notice stating that the public version of the Initial Determination will be available within 30 days. This publication will report on ALJ Shaw’s findings and conclusions of law, including those concerning contributory and induced infringement, in the next Update.