On March 22, 2013, the Commission issued a Notice instituting Certain Products Having Laminated Packaging, Laminated Packaging, And Components Thereof, Inv. No. 337-TA-874 (“the 874 Investigation”). Unlike the typical Notice of Investigation, the Notice in the 874 Investigation directed the Administrative Law Judge (“ALJ”) to issue an early decision on whether the Complainant has satisfied the economic prong of the domestic industry requirement by initial determination (“ID”) “within 100 days of institution”, subject to a limited extension of the ID for good cause.” Because the Complainant in this investigation is a nonpracticing entity (“NPE”), there has been speculation that the Commission may be taking a hardline now with all NPEs who file a Section 337 Complaint and requiring them to prove their domestic industry before addressing the remaining merits of the investigation. However, this may alternatively simply be a more limited reaction by the Commission to the Amended Complaint that initially did not allege that the asserted domestic industry was based on money spent on a licensing program in the United States, and subsequently was amended after considering OUII’s comments during the 30-day preinstitution period. This is not the first time the Commission has directed the ALJ to consider an early motion for summary determination based on allegations in a Complaint. See, e.g., Certain Products And Pharmaceutical Compositions Containing Recombinant Human Erythropoietin, Inv. No. 337-TA-568 (Notice of Investigation).