With respect to the Presidential Review period under 19 U.S.C. §1337(g), Apple filed a request to the United States Trade Representative (“USTR”), the President’s delegate, to overturn the Commission’s decision to issue an exclusion order in the 794 investigation on June 4, 2013. USTR has decided to undertake a review of this issue. Apple’s Written Submission to the USTR dated June 19, notes that Commissioner Aranoff explicitly invited the President to “decid[e] whether to disprove the remedy the Commission is issuing” and that the Commission’s decision in the 794 investigation is in conflict with the White House’s task force recommendation to harmonize the standard to obtain ITC exclusion orders with the eBay factors test for injunctive relief in the U.S. District Courts. Apple proposes that: “Given the special considerations that attend FRAND patents, the public interest dictates that the ITC could properly issue an exclusion order on a FRAND patent only in limited circumstances – such as where the accused infringer is a foreign entity not subject to jurisdiction in a United States court, or where the alleged infringer had refused to pay FRAND royalties set by a court or arbiter.” In contrast, in its Submission to USTR dated June 19, Samsung proposes that “SEPs should be eligible for an injunction or exclusion order … where the implementer, like Apple here, is unwilling to engage in licensing negotiations or neutral arbitration to arrive at a FRAND license.”