On July 16, 2015, SawStop, LLC and SD3, LLC (collectively, "SawStop")—both of Tualatin, Oregon—filed a complaint requesting that the ITC commence an investigation pursuant to Section 337.
The complaint alleges that Robert Bosch Tool Corp. of Mount Prospect, Illinois and Robert Bosch GmbH of Germany (collectively, "Bosch") unlawfully import into the U.S., sell for importation, and/or sell within the U.S. after importation certain table saws incorporating active injury mitigation technology and components thereof that infringe one or more claims of U.S. Patent Nos. 7,225,712 (the '712 patent), 7,600,455 (the '455 patent), 7,610,836 (the '836 patent), 7,895,927 (the '927 patent), 8,011,279 (the '279 patent), and 8,191,450 (the '450 patent) (collectively, the "asserted patents").
According to the complaint, the asserted patents generally relate to safety inventions that mitigate injuries from accidents involving table saws. In particular, the '712 patent relates to a woodworking machine with a control system that monitors rotation of a cutting tool and triggers a reaction system only if the cutting tool is moving, thereby distinguishing between potentially safe and unsafe operator contact with the cutting tool. The '455 patent relates to a woodworking machine with a control system that tests whether a reaction system is operational. The '836 patent relates to a woodworking machine with a removable cartridge having a single use component that is expended upon triggering of the cartridge. The '927 patent relates to a woodworking machine having a reaction system that retracts a cutting tool below a work surface within approximately 14 milliseconds after the detection of a dangerous condition. The '279 patent relates to a woodworking machine having a reaction system that uses stored energy to move a component 1/32nd of an inch within approximately 3 milliseconds after a dangerous condition is detected. Lastly, the '450 patent relates to a woodworking machine that retracts a cutting tool by pivoting it away from the cutting region.
In the complaint, SawStop states that Bosch imports and sells products that infringe the asserted patents. The complaint specifically refers to the Bosch GTS-1041A REAXX table saw and replaceable safety cartridges designed for use with such table saw as infringing products.
Regarding domestic industry, SawStop states that all of its table saw products practice at least one claim of each of the asserted patents. SawStop states that its entire business revolves around the exploitation of the asserted patents and that it has made significant and substantial investments in product design, development, manufacture, assembly, programming, service, repair, trouble-shooting, packaging, distribution, marketing, sales, and other activities relating to table saws that practice the asserted patents. SawStop further states that it conducts the foregoing activities at its facility in Tualatin, Oregon.
As to related litigation, SawStop states that, concurrently with the filing of the instant ITC complaint, it is also filing a complaint against Bosch in the U.S. District Court for the District of Oregon, alleging infringement of the asserted patents.
With respect to potential remedy, SawStop requests that the Commission issue a permanent limited exclusion order and a permanent cease and desist order directed at Bosch and related entities.