On February 6, 2017, J.S.T. Corporation of Farmington Hills, Michigan (“JST”) filed a complaint requesting that the ITC commence an investigation pursuant to Section 337.
The complaint alleges that the following entities (collectively, the “Proposed Respondents”) unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain electrical connectors, components thereof, and products containing the same that infringe one or more claims of U.S. Patent No. 7,004,766 (the ’766 patent):
- Robert Bosch GmbH of Germany
- Bosch Automotive Products (Suzhou) Co., Ltd. of China
- Robert Bosch LLC of Broadview, Illinois
- Robert Bosch, Sistemas Autometrices, S.A. de C.V. of Mexico
- Robert Bosch Ltda. of Brazil
- Hon Hai Precision Industry Co., Ltd. of Taiwan
- Foxconn Interconnect Technology, Ltd. of Taiwan
According to the complaint, the ’766 patent relates to an improved electrical connector that includes a tine plate with through holes that are elongated in the longitudinal direction of the tine plate. The complaint states that the invention reduces the risk of stress build-up on the connector pin solder joints that leads to solder cracking, but still enables the tine plate to successfully serve its primary functions of guiding and supporting the pins.
In the complaint, JST states that the Proposed Respondents import and sell products that infringe the ’766 patent. The complaint specifically refers to the Bosch Global A BCM header connector—also known as the Bosch 183-pin BCM connector—and products that incorporate that connector as infringing products.
Regarding domestic industry, JST states that its S44B-RAD-1AK header practices claims of the ’766 patent. JST further states that it conducts research, development, design, engineering, testing, validation, manufacture, quality control, quality assurance, customer support, and customer training activities in the U.S. relating to its domestic industry products. JST specifically refers to facilities in Michigan, Illinois, and Pennsylvania where it conducts such activities.
As to related litigation, JST states that it is currently asserting the ’766 patent against the Proposed Respondents in the U.S. District Court for the Northern District of Illinois. JST also states that it is currently engaged in an additional litigation against Robert Bosch GmbH and Robert Bosch LLC in the U.S. District Court for the Eastern District of Michigan, where JST is alleging trade secret misappropriation, copyright infringement, unfair competition, unjust enrichment, and breach of a settlement agreement.