On May 11, 2015, the Federal Circuit issued an Opinion in Lelo Inc. v. Int’l Trade Comm’n, 2013-1582 (Fed. Cir. 2015), reversing the Commission’s determination that complainant Standard Innovation Corporation satisfied the economic prong of domestic industry in Certain Kinesiotherapy Devices and Components Thereof, Inv. No. 337-TA-823, Comm’n Op. (June 17, 2013). In the underlying investigation, the ALJ rejected complainant’s arguments that it satisfied the economic prong of domestic industry through its U.S. purchase of component parts for its devices assembled in China and imported into the United States. The Commission reversed the ALJ, holding that complainant satisfied the domestic industry because its expenditures on components produced domestically are critical to its devices and that the contribution of the components was significant from a qualitative point. The Federal Circuit rejected the Commission’s holding that domestic purchases were significant based entirely on the qualitative contribution of the devices, without any quantitative analysis. The Federal Circuit held that the plain text of §337 requires a quantitative analysis of complainant’s commercial activity, holding that qualitative significance alone is “insufficient to satisfy the ‘significant investment’ or ‘significant employment of labor or capital’ criteria of §337 where there is an absence of evidence that connects the cost of the components to an increase of investment or employment in the United States.”