cambria itc request

8/18/2019 Cambria ITC Request

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F I S H .FISH & RICHARDSON

DOCKET

number

5 ^ 1

Office oftheSecretary

Int'l TradeCommissionV I A H A N D D E L I V E R Y

April 14, 2016

H o n o r a b l e Lisa R . Bar ton

SecretaryUnited States Internat ional Trade Commiss ion

50 0 E Street, S.W.Washington, D.C. 20436

Re: In the Matter of Certain Quartz Slabs and Portions Thereof; Inv. No. 337-TA-

Fish & R i c ha r d so n P. C .1425 K Street , N.W.1 1 th F lo o rWashington, DC 200052 0 2 783 5 0 7 0 m a i n

2 0 2 783 2331 fa x

Ahmed J. [email protected] 0 2 6 2 6 6379 direct

Dear Secretary Barton:

Enclosed for filing onbehalfof Cambria Company LLC ( Complainant ) are documents insupport of Complainant's request thatthe Commission commencean investigation pursuanttoSection337 of the TariffAct, as amended. Pursuantto the Commission's Rules of Practice andProcedure, a request for confidential treatmentof Exhibits 38 and 39 is submitted concurrently.

Accordingly, Complainant submits the following:

An original and eight (8) copies of the verified Complaintand one (1) CD of the Non-Confidential Exhibitspursuant to 19 C.F.R § 210.8(a)(l)(i);

2. One (1) CD of the ConfidentialExhibits pursuantto 19 C.F.R § 210.8(a)(l)(ii);

3. Two (2) additional copiesof the Complaint and two (2) sets of CDs containing theConfidentialand Non-Confidential Exhibits for the proposed respondents pursuantto 19C.F.R §210.8(a)(l)(iii);

4. One (1) certified copy each of U.S. Design Patent Nos. D712,670, D713.154,D737,058,D737,576. D737,577 and D738,630 ( the '670, '154, '058, '576, '577 & 630 patents' )included with the Complaint as Exhibits 1 through 6 respectively, pursuantto 19 C.F.R §210.12(a)(9)(i);

5. One (1) certified copy each of the prosecution historiesof the '670, '154. '058, '576,'577 & '630 patents, included withthe Complaintas Appendices A through Frespectively, plus three (3) additional copies thereof/pursuantto 9 C.F.R §210.12(c)(1);

f r. com


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F I S H .FI SH & RICHARDSON

April 14,2016Page 2

6. One (1) certified copy of the assignment records of the 670, 154, '058, '576, '577 &'630 patents, included with the Complaint as Exhibits 7 through 12 respectively, pursuantto 19 C.F.R§ 210.12(a)(9)(H);

7. Four (4) CDs of the technical references identified in the prosecution histories of the'670, '154, '058, '576, '577 & '630 patents, included with the Complaint as AppendicesG through L respectively, pursuant to 19 C.F.R § 210.12(c)(2);

8. A request for the confidential treatment of the accompanying Confidential Exhibitspursuant to 19 C.F.R § 201.6(b); an d

9. A statement regarding the public interest pursuant to 19 C.F.R § 210.8(b).

Sincerely,


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F I S H .FISH & RICHARDSON

Fish & Richardson P.C.1425 K Stree t, N.W.11 th F loorWashington, DC 200052 02 7 83 5070 m a i n20 2 78 3 2331 fa x

A h m e d J. [email protected] 6 2 6 6 3 7 9 direct

V I A H A N D D E L I V E R Y

April 14,2016

H o n or a bl e L i sa R . Bar ton

SecretaryUnited States International Trade Commission

500 E Street, S.W.Washington, D.C. 20436

Re: In the Matter of Certain Quartz Slabs and Portions Thereof; Inv. No. 337-TA-

Dear Secretary Barton:

Cambria CompanyLLC ( Complainant ) by counsel, hereby requests,pursuant to 9 C.F.R. §201.6, confidentialtreatment of the confidentialbusiness informationcontained in ConfidentialExhibits 38 and 39 to Complainant'sComplaint transmitted herewith.Confidentialtreatment issought forthe following Confidential Exhibits:

38C which describes, among other things,facts and informationsupporting the domesticindustry allegations; and

2. 39C which describes, among other things,non-public facts and information relatingto theimportation of the accused products.

3. The information describedabove qualifies as confidential informationpursuant to 19C.F.R. § 201.6 because it is not available to the public; unauthorizeddisclosure ofsuchinformation couldcause substantial harm to Complainant's competitive position; and thedisclosure ofthe information for which Complainant seeks confidential treatment couldimpair the Commission'sability to obtain information necessaryto perform its statutoryf u n c t i o n s .

A h m e d J. Dav i s

fr.com


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U N I T E D S TAT E S I N T E R N AT I O N A L T R A D E C O M M I S S I O N

WA S H I N G TO N , D .C . 2 04 36

In the Mat te r o f

CERTAIN QUARTZ SLABS ANDP O RTI O NS T H E R E OF

InvestigationN o. 3 3 7 - TA -

C O M P L A I N A N T S S T AT E M E N T O N T H E P U B L I C I N T E R E S T

In support of its complaint filed April 14, 2016, Complainant Cambria Company LLC

( Cambria or Complainant ) herebysubmits this public interest statement, as required by 19

C.F.R. § 210.8(b). As discussed below, the remedy sought against proposed Respondents

Wilsonart LLC and Dorado Soapstone LLC (collectively Respondents ) will not have an

adverse effect on the public health or welfare, competitive conditions in the United States

economy, production of like or directly competitive articles in the United States, or U.S.

o n s u m e r s

Theaccused products in this investigation, as identified in the accompanying complaint,

are certamquartz slabs and portions thereof (hereinafter quartz slabs ),manufactured by or on

behalf of the named Respondents, that infringe one or more of the assertedpatents. The

requested remedial orders, which would exclude only certain quartz slabs manufactured or sold

by Respondents are not contrary to the public interest. The Commissionhas long recognized the

strong public interest in enforcing intellectual property rights. See Certain Baseband Processor

Chips and Chipsets, Transmitter and Receiver Radio Chips, Power Control Chips, and


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orders would only exclude the subset of quartz slabs that copy Complainant's patented design.

The relief sought would notbar importation of quartz slabs generally. The particular designs that

would be the basis for exclusion do not have any particular significancewith respect to the

public health, safety, or public welfare. In this regard, the requestedremedial orders are similar

to those requested in other investigations based solely on the aesthetic appearance of the

particular accused products, e.g., Certain Glassware, Inv. No. 337-TA-767 and Certain

Foldable Stools, Inv. No. 337-TA-693) in whichthe Commission did not delegate the public

interest i ss ue s t o th e ALJ .

Rule 210.8(b)(3) Identification of like or directly competitive articles that

Complainants or third parties make that would replace the subject articles i f they

w e r e t o b e e x c l u d e d

Complainants design, manufacture, and sell quartz slabs in over one hundred different

designs to numerous customers in the United States. In addition, other competitors besides

Complainants and the proposedRespondents exist in the United States marketfor quartz slabs,

suchas E. I. du Pontde Nemours ( DuPont ) and Caesarstone Sdot-Yam ( Caesarstone ).

Quartz slabs sold by such other competitors include numerous designs that would not be affected

by any of the relief soughtin the Complaint. Indeed, even the named respondents sell alternative

quartz slab designs that are not implicated by the relief sought in this investigation. Thus, if the

accused products at issue in this investigation were excluded, consumers would continue to have

ample access to quartz slabs.


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Rule 210.8 b 4 Identification of whether the Complainants have the capacity to

replace the volume of articles subject tothe requested remedial orders in a

commercially reasonable time in the United States

The accused articles in this investigation consist of quartz slabs and portions thereof that

have a particularappearance such that it infringes certain of Cambria's design patents. The

exclusionorders soughtwould not cover any of the numerous alternative countertop designs

available toa purchaser. Further, alternativesother than respondents' quartz slabs are available

inthe market. In 2015, it was reported that only approximately5% ofthe new kitchens inthe

United States had engineered quartz countertops,and it stands to reason that only a portion ofthat 5 represents Respondents' infringing products.

Countertops of other materials,as well as the engineered materials of Cambria can

readily fill the void in the market that wouldresult from the exclusion of the infringing products.

As noted in the previous section, Complainantis a major supplier of countertop productsin the

United States. Moreover, as discussed above,otherparticipants in the United States quartz

countertop market, suchas DuPont and Caesarstone would continue to supply the U.S. market

with quartz in the event that Respondents' infringingdesigns were excluded. Still further, as

noted above, Respondents can themselves continue to supply the U.S. market with quartz as the

relief sought concernsonly a fraction of the designs offeredby the Respondents. Complainant

and, on information and belief, competitors suchas DuPont and Caesarstonehave the ability to

expand their manufacturing capacitysufficiently to replace the volumeof articles that would be

subject to the requested remedial orders. Indeed, Complainanthas repeatedly and significantly

expanded its manufacturing capacityin recent years, even doublingits capacity in 2013. Thus,


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there isno basis for concern thatthe requested relief would deprive purchasersinthe United

States of reasonable access to quartz slabsforuseas countertops andthe like.

C O N C L U S I O N

Ifthe Commission grantsthe requested remedialorders, the public interestin protecting

Complainant's validand enforceable intellectual propertyrights will be served. In addition, the

accused products arenot necessary to anyhealthor welfare need, andan adequate supplyof

substitute quartz slabswill be available through Complainant and other competitors. As such,

the strong public interest in protecting Complainant's intellectual propertyrights outweighs any

potential adverse impact on the public.

Dated: April 14, 2016

Respectfully submitted,

F I S H & R I C H A R D S O N P.C.

Ahmed J. DâT h o m a s S . F u s c o

Christopher DryerEr in M . B . L e a c h

F I S H & R I C H A R D S O N P.C.1425: K Street, NW, 11th FloorWashington, DC 20005Telephone: (202) 783-5070Facsimile: (202) 783-2331

J o h n S. G o e t z

K r i st e n M c C a l li o nFISH & RICHARDSON P.C.601 Lexington Avenue, 52nd FloorNew York, NY 10022Telephone: (212)-765-5070


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L I S T O F E X H I B I T S

Certified Copy of U.S. Design Patent No. D712,670Certified Copy of U.S. Design Patent No. D713,154

Certified Copy of U.S. Design Patent No. D737,058Certified Copy of U.S. Design Patent No. D737,576

Certified Copy of U.S. Design Patent No. D737,577Certified Copy of U.S. Design Patent No. D738,630Certified Copy of Assignment Records for U.S. Design Patent No.D712,670

Certified Copy of Assignment Records for U.S. Design Patent No.D 7 1 3 J 5 4

Certified Copy of Assignment Records for U.S. Design Patent No.D 7 3 7 . 0 5 8

Certified Copy of Assignment Records for U.S. Design Patent No.D737,576



Wilsonart Guide Specification Section 12 3661.19 Quartz SurfacingCountertopsA N S I / N S F 51-1997 Standard

NSF International Website Excerpt (http://www.nsf.org/consumer-resources/what-is-nsf-certification/) (last accessed Feb. 5, 2016)NSF Product and Service Listings, NSF/ANSI 51 Food EquipmentMaterials. Wilsonar t L L C

Wilsonart Quartz Collection Press Release (January 20, 2015)E.B. Bradley Co. brochureadvertisingall five infringing designs for salein numerous locations, including in Seattle,.Los Angeles, San Francisco,Portland,and San DiegoWurth Wood Groupbrochureadvertisingall five infringing designs forsale in locations in Maryland, Virginia, North Carolina, South Carolina,Tennessee, Alabama, Georgia, and FloridaFalfas Cabinetand Stonewebsite offering all five infringing designs for

sale at location in Sarasota, FloridaQuality Surfaces website excerptsshowing all five infringing designs forsale in Spencer, IndianaDorado Facebook Post Advertising NUSTONE ProductsNUSTONE Website ExcerptsPanjivaImportation Database RecordFor Quartz Slabs Imported byWi l so n a rt L L C


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^lSilNumblS

2 5

26

2 7

2 8

2 9

31

3 2

3 d

3 9

4 0

41

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Panjiva Importation DatabaseRecords For Quartz Slabs ImportedbyDorado Soapstone LLCPhotograph ComparingWilsonart's Arno Design tothe '670 PatentPhotograph ComparingWilsonart's Aurora Design tothe '058 PatentPhotograph ComparingWilsonart's Badaling Design to the '576 PatentPhotograph ComparingWilsonart's Santiago Design to the '577 PatentPhotograph ComparingWilsonart's Murren Design to the '630 PatentPhotograph Comparing Dorado's Tundra Designto the '154 PatentPhotograph Comparing Cambria's Bradshaw™ Designto the '670 PatentPhotograph ComparingCambria's Galloway™ Design to the '154 PatentPhotograph ComparingCambria's Menai™ Design to the '058 PatentPhotograph Comparing Cambria's Castlemartin™ Designto the '576Patent

Photograph ComparingCambria's Berwyn™ Designto the '577 PatentPhotograph ComparingCambria's Fairbourne™ Design to the '630 PatentDeclaration of Jim Ward Regarding Cambria's Domestic IndustryDeclaration of Peter Martin Regarding Importation of Accused ProductsQuartz Slab Importation AnalysisLetter From Peter Martin to Wilsonart Regarding Infringement ofCambria Intellectual Property RightsLetters to DoradoRegarding Infringementof the '154 Patent

u


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Phvsical Exhibi t N o. 1

Physical Exhibit No. 2

Physical Exhibit No . 3

P h ys ic a l E x hi b it N o . 4




P h v s ic a l E x h ib i t N o. 8







Phvsical Exhibi t No. 15




L I S T O F P H Y S IC A L E X H I B I T S

Color Photograph Submitted to the USPTO for U.S. Design PatentNo. D712,670

Color Photograph Submitted to the USPTO for U.S. Design PatentNo. D 7 1 3 J 5 4

Color Photograph Submitted to the USPTO for U.S. Design PatentN o . D737 .058



Color Photograph Submitted to the USPTO for U.S. Design PatentN o . D 7 38 , 63 0

Physical Sample of Accused Wilsonart Arno Product

Physical Sample of Accused Wilsonart Aurora ProductPhysical Sample of Accused Wilsonart Badaling Product

Physical Sample of Accused Wilsonart Santiago Product

Physical Sample of Accused Wilsonart Murren Product

Physical Sample of Accused Dorado Tundra ProductPhysical Sample of Cambria's Bradshaw™ Domestic IndustryP r o d u c t

Physical Sample of Cambria's Galloway™ Domestic IndustryP r o d u c t

Physical Sample of Cambria's Menai™ Domestic Industry ProductPhysical Sample of Cambria's Castlemartin™ Domestic IndustryP r o d u c t

Physical Sample of Cambria's Berwyn™ Domestic IndustryP r o d u c t

Physical Sample of Cambria's Fairbourne™ Domestic IndustryP r o d u c t

m


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_A_

B_

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G

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LIST O F APPENDICES

;;g)i^(a^ jX8HB •Certified Copy of File Wrapper for U.S. Design PatentNo. D712,670Certified Copy of File Wrapper for U.S. Design Patent No. D713,154

Certified Copy of File Wrapper for U.S. Design PatentNo. D737,058Certified Copy of File Wrapper for U.S. Design Patent No. D737,576Certified Copy of File Wrapper for U.S. Design PatentNo. D737,577Certified Copy of File Wrapperfor U.S. Design PatentNo. D738,630Technical References Cited in File Wrapper for U.S. Design Patent No.D712,670Technical References Cited in File Wrapper for U.S. Design Patent No.D712,154Technical References Cited in File Wrapper for U.S. Design PatentNo.D737,058

Technical References Cited in File Wrapper for U.S. Design PatentNo.D737,576Technical References Cited in File Wrapper for U.S. Design PatentNo.D737,577

Technical References Cited in File Wrapper for U.S. Design Patent No.D738,630 .

I V


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I. I N T R O D U C T I O N

1. This Complaint is filed by Cambria CompanyLLC ( Cambria ) under Section337

of the TariffActof 1930, as amended, 19 U.S.C. § 1337, based on the unlawful importationinto

the United States, thesalefor importation into the United States, and/orthe sale within the United

States after importation by proposed Respondentsof certain quartz slabs and portions thereofthat

infringe the claims of United States Design Patent Nos. D712,670 ( the '670 patent ), D713,154

( the '154 patent ), D737,058 ( the '058 patent ), D737,576 ( the '576 patent ), D737,577 ( the

'577 patent ), and D738,630 ( the '630 patent ) (collectively, the Asserted Patents ).

2. Cambria is a leading designer and manufacturer of quartzproducts specializing in

quartz surface products. Foundedin 2000, Cambria has been atthe forefront of the development

of the rapidly-expanding UnitedStates market forquartz surface products. Cambria prides itself

as being the only family-owned,American-made producer of quartz surface products, withits

headquarters locatedin Belle Plaine, Minnesotaand its production facility in Le Sueur, Minnesota.

Since its founding, Cambria has repeatedly and dramatically expanded its production capacity in

order to meet the rising demand for its products. In addition to the superior craftsmanship and

quality control affordedby Cambria's production of quartz surface products in the United States,

much of Cambria's success has been due to its innovative designs, many of which are the subject

of United States patent rights.

3. The success of Cambria's quartz surface products has attracted numerous

competitors to the marketplace, including WilsonartLLC ( Wilsonart ) and Dorado Soapstone

LLC ( Dorado ) (collectively, the proposed Respondents ). The proposed Respondents

manufacture, import, sell for importation into the United States, and/or sell after importationinto

the United States quartz slabsand portions thereof. Manyof the quartz slabs and portions thereof

imported by the proposed Respondents embodyCambria's innovative designs that are protected


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by U.S. design patents owned by Cambria. As set forth in Section VI below, these products

(referred to herein asthe Accused Products ) are manufactured abroad in locations such as China,

India, and Portugal, and are imported for sale into the United States. Cambriais aware of products

imported by the proposed Respondentsthat incorporate at least the designs covered bythe '670

patent, the '154 patent, the '058 patent, the '576 patent, the '577 patent, and the '630 patent.

4. The importation of knock-off quartz slabs, includingthose covered bytheAsserted

Patents, is a substantial and growing problem for the United States domestic industry. For

example, the volume of quartz slabs being imported has increased approximately six-fold in the

past five years. See Exhibit No. 40 (Quartz Slab Importation Analysis). Furthermore, these

imported quartz slabsare typicallyimportedunder subheadings of the Harmonized TariffSchedule

such as 6810.99.00 (Agglomerated quartzslabs of the type used for countertops)which are subject

to no tariff when being imported into the United States, whereas quartz slabs manufactured in the

UnitedStatesby Cambriaare typicallysubject to tariffs when being exportedto othercountries.

5. Certified copies of Cambria's Asserted Patents are included as Exhibit Nos. 1-6. In

addition, because coloris an essential elementof Cambria's patenteddesigns, Cambria submitted

color photographs representative of its claimed designs during the prosecution- of each of the

Asserted Patents. See Appendix Nos. A-F (CertifiedCopiesof the File Wrapper foreachAsserted

Patent); 37 C.F.R. §§ 1.152,1.84 (authorizing the submissionof color photographsin design patent

applications). High-quality colorcopies of the photographsfiled withthe United States Patentand

Trademark Office for each of the Asserted Patents are included with this Complaint as Physical

ExhibitNos. 1-6. Cambria owns all rights and title in each of the Asserted Patents, including the

right to sue for infringement. Certified copies of the assignment records for each of Cambria's

AssertedPatents are included as Exhibit Nos. 7-12. Certified copies of the file histories of each


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of the AssertedPatentsand technicalreferencescited therein are includedas Appendices A-Fand

G-L, respectively.

6. A domestic industryas required by 19 U.S.C. §§ 1337(a)(2) and (3) exists in the

United States relating to articles protected by Cambria's Asserted Patents, including significant

investment in plant and equipment, significantemployment of labor and capital, and substantial

investment in the exploitation of the designs claimed in Cambria's Asserted Patents, including

through engineering, research, and development.

7. Cambria seeksreliefin the formof a permanent general exclusion order forbidding

entry into the United States all quartz slabs and portions thereof thatinfringe any of the AssertedPatents. Alternatively, Cambriaseeks a permanent limited exclusionorder barring entry into the

United States all quartz slabs and portions thereof made by or on behalf of Respondents, that

infringe any of the Asserted Patents. Cambria further seeks permanent cease and desist orders

under 19 U.S.C. § 1337(f) prohibiting proposed Respondents from importing, marketing,

advertising, demonstrating, distributing, warehousing inventoryfor distribution, selling, offering

for sale, or using quartz slabs or portions thereofthat infringe any of the Asserted Patents.

II. T H E P A RT IE S

A. Complainant

8. Complainant Cambriais a limited liabilitycompany organized under the laws of

Minnesota and having its principal placeof business at 805 Enterprise Drive East, Suite H, Belle

Plaine, Minnesota, 56011. Cambria owns the Asserted Patents and the right to sue for all

infringement thereof.

9. Cambria is a leading supplier and innovator inthe area of quartz surface products

and has significant operationsin the United States, includingwith respect to the designsprotected

by Cambria's Asserted Patents. Cambria's innovative, patented designs are the product of


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extensive engineering, research, and development in the United States, and Cambria's commercial

surfaceproducts embodying its designs aremanufactured entirelyin theUnitedStatesat Cambria's

production plant in Le Sueur, Minnesota.

B. Proposed Respondents

10. Oninformation and belief, proposed respondent WilsonartLLC is a limited liability

company organized under the laws of Delaware and having its principal place of business at 2501

Wilsonart Dr., Temple, Texas, 76504. On information and belief, Wilsonart develops,

manufactures, imports, sells for importation, and/or sells after importation into the United States

quartz slabs and portions thereof under the trade name Wilsonart Quartz.

11. On information and belief, proposed respondent Dorado Soapstone LLC is a limited

liabilitycompany organizedunder the laws of Colorado with its principalplace of business at 940

S. Jason St. Unit 9, Denver, Colorado, 80223. On information and belief, Dorado develops,

manufactures, imports, sells for importation, and/or sells after importation into the United States

quartz slabs and portions thereof under the trade name NUSTONE quartz.

T H E T E H N O L O G Y N D P R O D U T S T S S U

12. The products at issue are quartz slabs and portions thereof. The Accused Products

are engineered to embody a specific visualdesign. At issue inthis proceeding is the visual designs

of the Accused Products, which infringe the asserted United Statesdesign patents owned by

Cambria. The Accused Products are imported into the United States after manufacture abroad and

are in turn used by businesses and individuals in the United States for use in surfaces such as

countertops. The Accused Products are sold for importation into, imported into, and sold after

importation intothe United States by or on behalfof the proposed Respondents.


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IV . T H E A S SE RT E D PAT E N TS

13. The Asserted Patents protect the ornamental features of Cambria's quartz designs.

Cambria owns by assignment the entire right, title, and interest in and to each of Cambria's

Asserted Patents. E x h ib i t N o s. 7-12.

14. Pursuant to Commission Rule 210.12(c), Cambria has filed certified copies of the

prosecution historiesof each of Cambria's Asserted Patents with this Complaint as Appendices 1-

6.

A. Nontechnical Description of th e 670 Patent

15. United States Design PatentNo. D712,670, entitled Portion of a Slab issued to

Jon Louis Grzeskowiak et al. on September 9, 2014. The '670 patent issued from U.S. Design

Patent Application SerialNo. 29/442,513, filed March15, 2013. The '670 patent has one (1)

claim. A certified copyofthe '670 patent is attached to the Complaintas Exhibit No. 1.

16. The '670 patent claims an ornamental designfor a portion of a slab, as shown and

described in the figures ofthe patent.1

r a g — T

1M


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A high-quality color copy of the photograph filed with the United States Patent and Trademark

Office for the '670 Patent is included with this Complaint as Physical ExhibitNo. 1.

B. Nontechnical Description of th e 154 Patent

17. United States Design Patent No. D713,154 entitled Portion of a Slab issued to

Jon Louis Grzeskowiak and Marin E. Davis on September 11, 2014. The '154 patent issuedfrom

U.S. Design PatentApplication Serial No. 29/463,747, filed February 20, 2014. The '154 patent

has one (1) claim. A certified copy of the '154 patent is attached to the Complaint as Exhibit No.

2 .

18. The '154 patent claims an ornamental design for a portion of a slab, as shown and

described in the figures of the patent.


Office for the ' 154patent is includedwith this Complaintas Physical ExhibitNo. 2.

C. Nontechnical Description of th e 058 Patent

19. United States Design Pa tent No. D737,058 entitled Portion of a Slab issued to

Martin E. Davis et al. on August 25, 2015. The '058 patent issued from U.S. Design Patent


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ApplicationSerial No. 29/474,410, filed September 12, 2014. The '058 patent has one (1) claim.

A certified copy of the '058 patent is attached to the Complaintas ExhibitNo. 3.

20. The '058 patentclaims an ornamental design for a portion of a slab, as shown and


A high-quality colorcopy of the photograph filed with the United States Patent and Trademark

Office for the '058 patent is included with this Complaint as Physical Exhibit No. 3.

D. Nontechnical Description of the 576 Patent

21. United States DesignPatentNo. D737,576, entitled Portion of a Slab issued to

Martin E. Davis et al. on September 1, 2015. The '576 patent issued from U.S. Design Patent

Application Serial No. 29/474,414,filed September 12, 2014. The '576 patenthas one (1) claim.

A certified copy of the '576 patent is attached to the Complaintas ExhibitNo. 4.

22. The '576 patent claims an ornamental designfor a portion ofa slab, as shown and



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E. Nontechnical Description of th e 577 Patent

23. United States Design Patent No. D737,577, entitled Portion of a Slab issued to

Martin E. Davis et al. on September 1, 2015. The '577 patent issued from U.S. Design Patent

Application Serial No. 29/474,415, filed September 12, 2014. The '577 patenthas one (1) claim.

A certified copy of the '577 patent is attached to the Complaint as Exhibit No. 5.

24. The 577 patent claims an ornamental design for a portion of a slab, as shown and



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*

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A high-quality colorcopy of the photograph filed with the United States Patent and Trademark

Office for the '577 patent is included with this Complaint as Physical ExhibitNo. 5.

F. Nontechnical Description of th e 630 Patent

25. United States DesignPatentNo. D738,630, entitled Portion of a Slab issued to

Jon Louis Grzeskowiak et al. on September 15, 2014. The '630 patent issued from U.S. Design

Patent ApplicationSerial No. 29/442,516,filed March 15,2013.The '630 patenthas one (1)claim.

A certified copy of the '630 patent is attached tothe Complaint as ExhibitNo. 6.

26. The '630 patent claims an ornamental design fora portion ofa slab, as shown and



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G. Foreign Counterparts

27. Cambria is aware of the following foreign counterparts to Cambria's Asserted

Patents: CanadaIndustrial Design Registration No. 148599. Cambria is aware ofthe following

foreign counterpart applications corresponding to Cambria's Asserted Patents: Canada Industrial

Design Application Nos. 161482, 161483, and 161488.

H . L i c e n s e e s

28. Cambria has not licensed any of the Asserted Patents.

V. U N L AW F U L AN D UNFAIR A C T S OF T H E P R O P OS E D R E S PO N D E N TS

29. ProposedRespondents have engaged in unlawfuland unfairacts including the sale

for importation into the United States, importation into the United States, and/or sale within the

United States after importation of Accused Products that infringe one or more of the Asserted

Patents. The following table illustrates which proposed Respondent infringeseach of the Asserted

Pa t en t s :

A s s e r t e d P a t e n t Infringing Respondent s)T h e 6 7 Pa ten t Wi l s o n a r t

T h e 1 5 4 Pa ten t D o r a d o

T h e 5 8 Pa ten t Wi l s o n a r t

T h e 5 7 6 Pa ten t Wi l s o n a r t

T h e 5 7 7 P a t e n t Wi l s o n a r t

T h e 6 3 P a t e n t W i l s o n a r t

A. Proposed Respondent Wilsonart

30. On information and belief, proposed Respondent Wilsonart and/or persons actina

on behalfof Wilsonart imports,sells for importation, and/orsellsafter importation into the United

1 0


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1. Wilsonart s Infringement of the 670 Patent

33. On information and belief, Wilsonart sells for importation into the United States,

imports into the United States, and/orsells after importation into the United States certain quartz

slabs and portions thereof that infringe the '670 patent, including at least its Arno quartz

products. A physical sample of Wilsonart's Arno product is included with this Complaint as

Physical Exhibit No. 7.2

34. Wilsonart's Arno products directly infringe the '670 patent. Wilsonart directly

infringes the '670 patent by importing, selling for importation, and/or selling after importation into

the United States its Arno products. Wilsonart's Arno products infringe the design claimed

in the '670 patentbecause,in the eye of an ordinaryobserver giving such attention as a purchaser

usually gives, the design of Wilsonart's Arno products are substantially the same as the design

embodied and claimed in the 670 patent, such that an ordinary observer would be deceived into

believing that Wilsonart's Arno design is the same as the design embodied and claimed in the

'670 patent. Review of Wilsonart's Arno products demonstrates that the products literally

infringe the '670 patent. See Exhibit No. 26 (photograph comparing Wilsonart's Arno design

to the '670 patent). On informationand belief, Wilsonart's Arno productsare imported at least

as quartz slabs, portions of which directly infringe the '670 patent at the time of importation.

2. Wilsonart s Infringement of th e 058 Patent


imports into the United States, and/or sells afterimportation into the United States certain quartz

2The included physical samplesof the Accused and Domestic IndustryProducts are illustrative ofthe practice of Cambria's Asserted Patents. However,because they represent onh a small portionof a slab, these samples may not exhibit all the characteristics of each product and are not fullvrepresentative of the Accused and Domestic IndustryProducts,other portions of whichmayevenmore clearly practice the Asserted Patents.

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slabs and portions thereof that infringe the '058 patent, including at least its Aurora quartz

products. A physical sampleof Wilsonart's Aurora product is included with this Complaintas

Physical Exhibit No. 8.

36. Wilsonart's Aurora products directly infringe the '058 patent. Wilsonart directly

infringes the '058 patentby importing, selling for importation,and/or selling after importationinto

. the United States its Aurora products. Wilsonart's Aurora products infringe the design

claimed in the '058 patentbecause, in the eye of an ordinary observer giving such attention as a

purchaserusually gives, the design of Wilsonart's Aurora products are substantially the same as

the design embodied and claimed in the '058 patent, such that an ordinary observerwould bedeceived into believing that Wilsonart's Aurora design isthe same as the design embodiedand

claimed in the '058 patent. Review of Wilsonart's Aurora products demonstrates that the

products literally infringethe '058 patent. See ExhibitNo. 27 (photographcomparing Wilsonart's

Aurora design to the '058 patent). On information and belief, Wilsonart's Aurora products

are imported at least as quartz slabs, portionsof which directly infringe the '058 patent at the time

of importation.



imports into the United States, and/or sells after importation into the United States certain quartz

slabs and portions thereof that infringe the '576 patent, including at least its Badaling quartz

products. A physical sampleof Wilsonart's Badaling product is included with this Complaint

as Physical Exhibit No. 9.

38. Wilsonart's Badaling products directly infringe the '576 patent. WTilsonart

directly infringes the '576 patent by importing, selling for importation, and/or selling after

importation into the United States its Badaling products. Wilsonart's Badaling products

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infringe the design claimed in the '576 patent because, in the eye of an ordinary observer giving

such attention as a purchaser usually gives, the design of Wilsonart's Badaling products are

substantially the sameas thedesignembodied and claimedin the '576 patent, suchthatan ordinary

observer would be deceived into believing that Wilsonart's Badaling design is the same as the

design embodied and claimed in the '576 patent. Review of Wilsonart's Badaling products

• demonstrates that the products literallyinfringe the '576 patent. See ExhibitNo. 28 (photograph

comparing Wilsonart's Badaling design to the '576 patent). On information and belief,

Wilsonart's Badaling products are imported at least as quartz slabs,portions of which directly

infringe the '576 patent at the timeof

importation.

4. Wilsonar t s Infr ingement of th e 577 Patent



slabs and portions thereof that infringe the '576 patent, including at least its Santiago quartz

products. A physical sample of Wilsonart's Santiago product is included with this Complaint

as Physical Exhibit No. 10.

40. Wilsonart's Santiago products directly infringe the '577 patent. Wilsonart

directly infringes the '577 patent by importing, selling for importation, and/or selling after

importation into the United States its Santiago products. Wilsonart's Santiago products

infringe the design claimed in the '577 patent because, in the eye of an ordinary observer giving

such attention as a purchaser usually gives, the design of Wilsonart's Santiago products are

substantiallythe same asthe design embodiedand claimed inthe '577 patent, such that an ordinary-

observer would be deceived into believing that Wilsonart's Santiago design is the same as the

design embodied and claimed in the '577 patent. Review of Wilsonart's Santiago products

demonstrates thatthe products literally infringe the '577 patent. See Exhibit No. 29 (photograph

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comparing Wilsonart's Santiago design to the '577 patent). On information and belief,

Wilsonart's Santiago products are imported at least as quartz slabs, portionsof which directly

infringe the '577patentat the time of importation.



imports into the United States, and/orsells after importation into the United States certain quartz

slabs and portions thereof that infringe the '630 patent, including at least its Murren quartz

products. A physical sampleof Wilsonart's Murren product is included with this Complaint as

Physical Exhibit No. 11.

42. Wilsonart's Murren products directly infringethe'630 patent. Wilsonartdirectly

infringes the '630 patentby importing, sellingfor importation,and/or selling after importationinto

the United States its Murren products. Wilsonart's Murren products infringe the design

claimed in the '630 patent because, in the eye of an ordinary observergiving such attention as a

purchaser usually gives, the design of Wilsonart's Murren products are substantially the same

as the design embodied andclaimed in the '630 patent, such that an ordinary observerwould be

deceived into believing that Wilsonart's Murren design is the same as the design embodiedand

claimed in the '630 patent. Review of Wilsonart's Murren products demonstrates that the

products literally infringethe '630 patent. See ExhibitNo. 30 (photographcomparingWilsonart's

Murren design to the '630 patent). On information and belief, Wilsonart's Murren products

are imported at least as quartz slabs, portionsofwhich directly infringethe '630 patent at the time

of importation.

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B. Proposed Respondent Dorado

43. On information and belief, proposedRespondent Dorado and/or persons acting on

behalf of Dorado imports, sells for importation, and/or sells after importation into the United States

certain quartz slabs and portions thereof that infringe at least the '154 patent.

44. On May 22, 2015, Cambria informed Dorado of its infringement of Cambria's' 154

.-patent. See Exhibit No. 42 (Letters to Dorado Regarding Infringement of the '154 Patent).

However, Doradohas continuedto import, sell for importation,and/or sell after importation into

the United States quartz slabs and portions thereof embodying at least its Tundra design, that

infringe one or more of the Asserted Patents.

1. Dorado s Infringement o f th e 154 Patent

45. On information and belief, Dorado sells for importation into the United States,


slabs and portions thereof that infringe the '154 patent, including at least its Tundra quartz

products. A physical sample of Dorado's Tundra product is included with this Complaint as


46. Dorado's Tundra products directly infringe the '154 patent. Dorado directly

infringes the' 154 patentby importing,selling for importation, and/or selling after importationinto

the United States its Tundra products. Dorado's Tundra products infringe the design claimed

inthe'154 patent because, in the eye ofan ordinary observergiving suchattention as a purchaser

usually gives, the design of Dorado's Tundra products are substantially the same as the design

embodied and claimed in the ' 154 patent, such that an ordinary observerwould be deceived into

believing that Dorado's Tundra design is the same as the design embodied and claimed in the

'154 patent. Review of Dorado's Tundra products demonstrates that the products literal]v

infringe the ' 154 patent. See ExhibitNo. 31 (photographcomparing Dorado's Tundra design to

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the '154 patent). On information and belief, Dorado's Tundra products are importedat least as

quartz slabs, portions of which directly infringe the '154 patent at the time of importation.

VI. SPECIFIC A C T S OF UNFAIR IMPORTATION AND SALE

47. On information and belief, proposed Respondents, either themselves or through

subsidiaries and/or third parties acting on behalf of proposed Respondents, are engaged in the

importation, salefor importation, and/or saleafter importation intothe United States of infringing

quartz slabs and portions thereof.

A. Proposed Respondent Wilsonart

48. Wilsonart's infringing quartz slabs and portions thereof are manufactured abroad

and imported for sale into the United States. For example, Wilsonart's publicly-availableguide

specification for quartz surfacing countertops represents that its quartz products conform to

NSF/ANSI Standard 51. Exhibit 13 (Wilsonart Guide Specification Section 123661.19Quartz

Surfacing Countertops)at 2, 5. The NSF/ANSI 51 standard, titled Food Equipment Materials,

is published by NSF International and approved bythe American National Standards Institute and

generally establishes safety requirements for products that may have contact with food. See

Exhibit 14 (ANSI/NSF 51-1997) at ii-viii, 1. The certification process under, NSF/ANSI 51

involves regular on-site inspections of manufacturing facilities. Exhibit 15 (NSF International

Website Excerpts). The location of each such manufacturing facility is publicly listed on NSF

International's website, along with a list of the specific products manufactured at that facility.

Exhibit 16 (NSF Product and Service Listings, NSF/ANSI 51 Food Equipment Materials,

Wilsonart LLC). The NSF International certification listings for Wilsonart indicate that

Wilsonart's infringing Badaling, Murren, Arno, and Santiago designs are manufactured

ina facility in India and that its infringing Aurora design is manufacturedina facility in Portugal.

Id The listings, current as of Friday, February 05, 2016 at 12:15 a.m., further indicate that

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Wilsonart does not have any certified manufacftiring facilities for quartz products in the United

States. Id. Furthermore, importation records show that Wilsonart has been importing quartz slabs

into the United States from both India and Portugal, including over 150 shipments of quartz slabs

from November 5, 2014, through February 20, 2016. Exhibit 24 (Panjiva Importation Record For

Quartz Slabs Imported by Wilsonart LLC).

49. After manufacture abroad, Wilsonart 's infringing designs are imported, sold for

importation, and/or sold after importation into the United States. For example, numerous

distributors of Wilsonart 's quartz products currently offer the infringing designs for sale in the

United States after importation by Wilsonart. See, e.g., Exhibit 18 (E.B. Bradley Co. brochure

advertising all five infringing Wilsonart designs for sale in numerous locations, including in

Seattle, Los Angeles, San Francisco, Portland, and San Diego); Exhibit 19 (Wurth Wood Group

brochure advertising all five infringing Wilsonart designs for sale in locations in Maryland,

Virginia, North Carolina, South Carolina, Tennessee, Alabama, Georgia, and Florida); Exhibit 20

(Falfas Cabinet and Stone website offering all five infringing Wilsonart designs for sale at location

in Sarasota, Florida); Exhibit 21 (Quality Surfaces website excerpts showing all five infringing

Wilsonart designs for sale in Spencer, Indiana). In addition, Wilsonart issued a press release dated

January 20, 2015, stating that the infringing Aurora, Badaling, Murren, Arno, and

Santiago designs wouldbe on display at the2015Kitchen& BathIndustry Show in Las Vegas,

Nevada. Exhibit 17 (Wilsonart Quartz Collection Press Release). Finally, Cambria employees

have personally seen the Wilsonart Aurora, Badaling, Murren, Arno, and Santiago

quartz products for sale in the United States and have obtained samples of the each of those

Wilsonart quartz products in the United States. See Exhibit 39 (Declaration of Peter Martin

Regarding Importation of Accused Products).

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products accused of infringement in this Complaint. It is not intended, norshould it be interpreted,

to limit the scopeproducts accused of infringement and subject to the requested Investigation.

V I I I . T H E D O M E S T I C I N D U S T R Y

53. A domestic industry exists, as defined under 19 U.S.C. §§ 1337(a)(3)(A), (B),

and/or (C), comprising substantial investments in plant and equipment, labor and capital, and

substantial investment in the exploitationof the Asserted Patents, including through engineering,

research, and development.

A. The Technical Prong

54. Cambria practices each of the Asser ted Patents. Each of the Asserted Patents

corresponds with one of the designs of quartz products manufactured and sold by Cambria in the

United States. The following table sets forth the specific Cambria design corresponding to each

of the Asserted Patents (collectively referred to as Cambria's Domestic Industry Products ):

A s s er te d P a te n t ; Cambria DesignT h e 6 7 Pa ten t B r a d s h a w ™

T h e 1 5 4 Pa ten t Galloway™

T h e 5 8 P a t e n t M e n a i ™

T he 5 7 6 Pa ten t Cas t l emar t i n™

T he 5 7 7 Pa ten t Berwyn™

T he 6 3 P a t e n t Fa i rbourne™

55. Cambria's Bradshaw™ design practices the '670 patent. A physical sample of

Cambria's Bradshaw™ design is included with this Complaint as Physical Exhibit No. 13. A

photograph comparing Cambria'sBradshaw™ designto the designclaimed in the '670 patentand

demonstrating its substantial similarity is attached as Exhibit No. 32.

56. Cambria's Galloway™ design practices the '154 patent. A physical sample of

Cambria's Galloway™ design is included with this Complaint as Physical Exhibit No. 114. A

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photographcomparing Cambria's Galloway™ design to the designclaimed in the '154 patent and

demonstratingits substantial similarity is attached as ExhibitNo. 33.

57. Cambria's Menai™ design practices the '058 patent. A physical sample of

Cambria's Menai™ design is included with this Complaint as Physical Exhibit No. 15. A

photograph comparingCambria's Menai™ design to the design claimed in the '058 patent and

demonstrating its substantial similarity is attachedas Exhibit No. 34.

58. Cambria's Castlemartin™ design practices the '576 patent. A physical sampleof

Cambria's Castlemartin™ design is includedwith this Complaint as Physical ExhibitNo. 16. A

photograph comparingCambria's Castlemartin™ designto the design claimed in the '576 patentand demonstrating its substantial similarity is attached as ExhibitNo. 35.

59. Cambria's Berwyn™ design practices the '577 patent. A physical sample of

Cambria's Berwyn™ design is included with this Complaint as Physical Exhibit No. 17. A

photograph comparing Cambria's Berwyn™ design to the design claimed in the '577 patent and

demonstrating its substantial similarity is attached as ExhibitNo. 36.

60. Cambria's Fairbourne™ design practices the '630 patent. A physical sample of

Cambria's Fairboume™ design is included with this Complaint as Physical ExhibitNo. 18. A

photograph comparingCambria's Fairbourne™ designto the design claimed in the '630 patent

and demonstrating its substantial similarity is attached as ExhibitNo. 37.

B. The Economic Prong

61. Cambria conducts extensive activities in the United States, including the entirety of

its manufacturing and research and development with respect to Cambria's Domestic Industry

Products. For example, as detailed in Confidential Exhibit No. 38 and discussed in more detail

below, from 2014 to 2015 Cambria manufactured a significant number of each of Cambria's

Domestic Industry Products in the United States.

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62. Cambria's activities and investments relating to Cambria's Domestic Industry

Products constitute a domestic industry under 19 U.S.C. § 1337(a)(3)(A) at least because Cambria

has made significant investments in plant and equipment in the United States used in conjunction

with manufacturing, engineering, and research and development. Cambria's activities and

investments relating to Cambria's Domestic Industry Products constitute a domestic industryunder

19 U.S.C. § 1337(a)(3)(B) at least because Cambria has made significant investments in the

employment of labor and capital in the United States in connection with its manufacturing,

engineering, and research and development. Cambria's activities and investments relating to

Cambria's Domestic Industry Products constitute a domestic industry under 19 U.S.C. §1337(a)(3)(C) at least because Cambria ha s further made substantial investments in the

exploitation of Cambria's Asserted Patents through engineering and research and development

directed to each of these products in the United States.

63. Cambria takes pride in manufacturing all of its quartz surface products entirely in

the United States. As a result, Cambria has made extensive investments in constructing and

repeatedly expanding its state-of-the-art production facility in Le Sueur, Minnesota, which also

employs numerous workers in the United States. See Confidential Exhibit No. 38 (Declaration of

Jim Ward) at^ 5,13. While Cambriamanufactures many versions of quartz productsatits facility

in Le Sueur, a portion of its investment in its plant is attributable to the Cambria Domestic Industrv

Products. See Confidential ExhibitNo. 38 at ffl[ 7-8. Cambria's vast domestic manufacturing also

requires a large quantity of expensive equipment, a portion of which is attributable to the

manufacture of the Cambria Domestic IndustryProducts. See Confidential Exhibit No. 38at ^ 6-

8.

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64. Cambria also conducts all of its research and development activities with respectto

its designs, including the designsof the Cambria Domestic Industry Products,in the United States.

These activities also take place in Cambria's Le Sueur, Minnesota facility and require additional

equipmentand materials above and beyond that used for commercialproduction. See Confidential

Exhibit No. 38 at 119-11. Cambria's investments with respect to research and development

regarding the designs of the Cambria Domestic Industry Products have been significant. See

Confidential Exhibit No. 38 at H 9-12.

IX . R E L AT ED L I TI G ATI O N

65. Contemporaneous withthe filing of this Complaint, Cambriafiled a Complaint in

the United States District Court for the District of Minnesota alleging patent infringement by the

Respondents. Apart from that filing, neither the Asserted Patentsnor the quartz designs that they

protect have beenthe subject of any other court or agency litigation.

X. REQUESTED RELIEF

66. WHEREFORE,by reason of the foregoing, Cambriarespectfully requests that the

United States In te rna t ional Trade Commission:

a) Institute an immediate investigation, pursuantto Section 337 of the Tariff

Act of 1930, as amended, 19 U.S.C. § 1337(a)(l)(B)(i), regarding violations by Respondents of

Section 337 based upon the importation,sale for importation, and/or sale after importationinto the

United Statesof Respondents' quartz slabs andportions thereof that infringe the '670, '154, '058,

576, 577, and/or 630 patents;

b) Schedule and conduct a hearing pursuant to 19 U.S.C. § 1337 for the

purposes of receiving evidence and hearing argument concerning whether there has been a

violation of Section 337, and, following the hearing, determinethat there has been a violation of

Sect ion 337;

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c) Issue apermanent general exclusion order, pursuant to 19U.S.C. § 1337(d),

forbidding entry into the United States all quartz slabs and portions thereof that infringethe '670,

'154, '058, '576, '577, and/or 630 patents;

d) In the alternative, issue a permanent limited exclusion order, pursuant to 19

U.S.C. § 1337(d)(1), forbidding entry into the United States all quartz slabs and portions thereof

made by or on behalf of Respondents, that infringe the '670, '154, '058, '576, '577, and/or '630

patents;

e) Issue permanent cease and desist orders, pursuant to 19 U.S.C. § 1337(f),

directing each Respondent, or others acting on its behalf, to cease and desist from importing,

marketing, advertising, demonstrating, distributing, warehousing inventory for distribution,

selling, offering for sale, or using quartz slabs and portions thereof that infringe the '670, '154,

'058, '576, '577, and/or 630 patents;

f) Impose a bond, pursuant to 19 U.S.C. § 1337(j), upon importation of any

quartzslabs and portionsthereof that infringethe '670, '154, '058, '576, '577, and/or '630 patents

during the Presidential Review period; and

g) Grant all suchother and further reliefas the Commissiondeemsappropriate

based upon the facts complained of herein and as determined by the investigation.

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Dated: April 14, 2016

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Respectfully submitted,

F I S H R I C H A R D S O N P.C.

Ahmed J. DaVisT h o m a s S. F u s c o

Christopher DryerE ri n M .B . L e ac h

FISH & RICHARDSON P.C.1425 K Street, NW, 11th FloorWashington, DC 20005Telephone: (202) 783-5070Facsimile: (202) 783-2331

J o h n S . Goetz

Kris ten McCal l ion

F I S H & R I C H A R D S O N P.C.

601 Lexington Avenue, 52nd FloorNew York, NY 10022Telephone: (212)-765-5070


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V E R I F I C AT I O N O F C O M P L A I N T

I, Peter Martin, declare, in accordance with 19 C.F.R. §§ 210.4(c) and 210.12(a), under

penalty of perjury, that the following statements are true:

1. I am currently the Executive Vice President of Sales, Marketing, and Business

Partner Services at Cambria Company LLC. I am duly authorized by Complainant Cambria

Company LLC to verify the foregoing Complaint.

2. I have read the Complaint and am aware of its contents.

3. The Complaint is not being filed for any improper purpose, such as to harass or to

cause unnecessary delay or needless increase in the cost of litigation.

4. To the best of my knowledge, information, and belief, formed after a reasonable

inquiry,the claims and other legal contentions set forth in the Complaint are warranted by

existinglaw or by a good faith, non-frivolous argument for extension, modification, or reversal

of existing law, or by the establishment of new law.

5. To the best of my knowledge, information, and belief, formed after a reasonable

inquiiy, theallegations of theComplaint are well grounded in fact andhave evidentiary support,

or, where specifically identified, are likely to have evidentiary support after a reasonable

opportunity for further investigation or discovery.

Executed on April 13, 2016P e t e r M a r t i n

Executive Vice President,Cambria Company LLC

cambria itc request

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