USITC Publication 5289

Gesamter Gesetzestext

In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
Publication 5289 March 2022
U.S. International Trade Commission
Washington, DC 20436

U.S. International Trade Commission
COMMISSIONERS
David S. Johanson, Chairman
Rhonda K. Schmidtlein, Commissioner
Jason E. Kearns, Commissioner
Randolph J. Stayin, Commissioner
Amy A. Karpel, Commissioner
Address all communications to
Secretary to the Commission
United States International Trade Commission
Washington, DC 20436

U.S. International Trade Commission
Washington, DC 20436
www.usitc.gov
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
Publication 5289 March2022

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
NOTICE OF A COMMISSION DETERMINATION TO ISSUE A LIMITED
EXCLUSION ORDER AND CEASE AND DESIST ORDERS AGAINST DEFAULTING
RESPONDENTS; TERMINATION OF THE INVESTIGATION
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
SUMMARY: Notice is hereby given that the U.S. International Trade Commission (the
“Commission”) has determined to issue a limited exclusion order and cease and desist orders
against the following respondents found in default in this investigation: AJ Auto Spare Parts
FZE of Dubai, United Arab Emirates; John Auto Spare Parts Co. LLC of Dubai, United Arab
Emirates; and Cuong Anh Co. Ltd. of Ninh Binh Province, Vietnam (collectively, “the
Defaulting Respondents”). The Commission has also determined to impose a bond equal to one
hundred (100) percent of the entered value of the infringing products imported during the period
of Presidential review. The investigation is hereby terminated.
FOR FURTHER INFORMATION CONTACT: Benjamin S. Richards, Esq., Office of the
General Counsel, U.S. International Trade Commission, 500 E Street S.W., Washington, D.C.
20436, telephone (202) 708-5453. Copies of non-confidential documents filed in connection
with this investigation may be viewed on the Commission’s electronic docket (EDIS) at
https://edis.usitc.gov. For help accessing EDIS, please email EDIS3Help@usitc.gov. General
information concerning the Commission may also be obtained by accessing its Internet server at
https://www.usitc.gov. Hearing-impaired persons are advised that information on this matter can
be obtained by contacting the Commission’s TDD terminal on (202) 205-1810.
SUPPLEMENTARY INFORMATION: On June 7, 2019, the Commission instituted the
above-referenced investigation based on a complaint filed by Hyundai Motor America, Inc. of
Fountain Valley, California and Hyundai Motor Company of Seoul, Republic of Korea
(collectively, “Hyundai”). 84 FR 26703-04 (June 7, 2019). The complaint alleges a violation of
19 U.S.C. 1337, as amended (“Section 337”), in the importation, sale for importation, or sale in
the United States after importation of certain gray market Hyundai parts in the categories of
belts, body exterior and interior parts, brakes, wheel hubs, cooling system parts, drivetrain parts,
electrical parts, emission parts, engine parts, exhaust parts, fuel/air pumps, oil/air/cabin air filters

and parts, heat and A/C parts, ignition parts, steering parts, suspension parts, transmission parts,
wheels and parts, wiper and washer parts, and accessories that infringe one or more of Hyundai’s
U.S. Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195. Id. at 26704.
The complaint further alleges that a domestic industry exists in the United States. Id.
The Commission’s notice of investigation named Direct Technologies International, Inc.
(“DTI”) of North Miami Beach, Florida; AJ Auto Spare Parts FZE (“AJ Auto”) and John Auto
Spare Parts Co. LLC (“John Auto”), both of Dubai, United Arab Emirates; and Cuong Anh Co.
Ltd. (“Cuong Anh”) of Ninh Binh Province, Vietnam as respondents. The Office of Unfair
Import Investigations was not named as a party to this investigation.
On November 25, 2019, the Commission determined not to review an initial
determination (“ID”) granting Hyundai’s unopposed motion to find respondents AJ Auto, John
Auto, and Cuong Anh (collectively, the “Defaulting Respondents”) in default. Order No. 17
(Nov. 5, 2019), not reviewed, Comm’n Notice (Nov. 25, 2019). Thereafter, on January 24, 2020,
Hyundai filed a declaration seeking immediate entry of a limited exclusion order against the
Defaulting Respondents and any of their affiliated companies, parents, subsidiaries, and related
business entities, successors or assigns.
On February 18, 2020, the Commission determined not to review an ID granting
Hyundai’s unopposed motion for summary determination that Hyundai satisfies the domestic
industry requirement of section 337. Order No. 26 (Jan. 16, 2020), not reviewed, Comm’n
Notice (Feb. 18, 2020).
On March 26, 2020, the Commission determined not to review an ID granting a joint
motion by Hyundai and DTI to terminate the investigation as to DTI based on a consent order.
Order No. 36 (Mar. 5, 2020), not reviewed, Comm’n Notice (Mar. 26, 2020). The Commission
concurrently issued a consent order directed to DTI, found that Hyundai’s January 24, 2020
declaration for immediate relief against the Defaulting Respondents was moot, and requested
briefing on the issues of remedy, bonding, and the public interest with respect to the Defaulting
Respondents. Comm’n Notice, 2-3 (Mar. 26, 2020).
On April 9, 2020, Hyundai filed the sole response to the Commission’s request for
briefing. No replies or other submissions were received.
Upon review of the record, and in the absence of any response from the Defaulting
Respondents or from other interested persons or government agencies, and having concluded that
it would not be contrary to the public interest to do so, the Commission has determined to issue a
limited exclusion order and cease and desist orders against the Defaulting Respondents. The
Commission has further determined to set a bond in the amount of one hundred (100) percent of
the entered value of the covered products.
The investigation is hereby terminated.
While temporary remote operating procedures are in place in response to COVID-19, the
Office of the Secretary is not able to serve parties that have not retained counsel or otherwise
provided a point of contact for electronic service. Accordingly, pursuant to Commission Rules
201.16(a) and 210.7(a)(1) (19 CFR 201.16(a), 210.7(a)(1)), the Commission orders that the

Hyundai complete service for any party/parties without a method of electronic service noted on
the attached Certificate of Service and shall file proof of service on the Electronic Document
Information System (EDIS).
The Commission vote for this determination took place on August 18, 2020.
The authority for the Commission’s determination is contained in Section 337 of the
Tariff Act of 1930, as amended (19 U.S.C. 1337), and in part 210 of the Commission’s Rules of
Practice and Procedure (19 CFR part 210).
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: 	August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached NOTICE has been served on the
following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
LIMITED EXCLUSION ORDER
The United States International Trade Commission (“Commission”) has determined that
there is a violation of Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. § 1337), in the
unlawful importation, sale for importation, and sale in the United States after importation of certain
replacement automotive service and collision parts and components thereof that infringe one or
more of U.S. Trademarks, Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195
(collectively, the “Asserted Trademarks”) by respondents AJ Auto Spare Parts FZE of Dubai,
United Arab Emirates; John Auto Spare Parts Co. LLC, of Dubai, United Arab Emirates; and
Cuong Anh Co. Ltd. of Ninh Binh Province, Vietnam (collectively “Defaulting Respondents”).
The Commission previously found the Defaulting Respondents in default pursuant to subsection
(g)(1) of section 337, 19 U.S.C. § 1337(g)(1), and section 210.16 of the Commission’s Rules of
Practice and Procedure, 19 C.F.R. § 210.16, for failing to respond to the Complaint and Notice of
Investigation.
Having reviewed the record of this investigation, including the written submissions of the
parties and the public, the Commission has made its determination on the issues of remedy, public
interest, and bonding. The Commission has determined that the appropriate form of relief is a
limited exclusion order prohibiting the unlicensed entry of certain replacement automotive service

and collision parts and components thereof that infringe one or more of the Asserted Trademarks
(“Covered Articles”) manufactured abroad or imported by or on behalf of Defaulting Respondents,
or any of their affiliated companies, parents, subsidiaries, or other related business entities, or their
successors or assigns, for consumption into the United States, consumption from a foreign trade
zone, or withdrawal from a warehouse for consumption, except under license of the trademark
owner or as provided by law.
The Commission has determined that the public interest factors enumerated in 19 U.S.C.
§ 1337(g)(1) do not preclude the issuance of the limited exclusion order, and that the bond during
the period of Presidential review shall be in the amount of one hundred (100) percent of the entered
value of the Covered Articles.
Accordingly, the Commission hereby ORDERS that:
1. 	Replacement automotive service and collision parts and components thereof that
infringe one or more of the Asserted Trademarks and that are manufactured abroad
or imported by or on behalf of the Defaulting Respondents, or any of their affiliated
companies, parents, subsidiaries, or other related business entities, or their
successors or assigns, are excluded from entry for consumption into the United
States, entry for consumption from a foreign trade zone, or withdrawal from a
warehouse for consumption, except under license of the trademark owner or as
provided by law, until such date as the Asserted Trademarks are abandoned,
canceled, or rendered invalid or unenforceable.
2. 	For the purpose of assisting U.S. Customs and Border Protection (“CBP”) in the
enforcement of this order, and without in any way limiting the scope of this Order,
the Commission has attached to this Order a copy of the relevant trademark

registrations as Exhibits 1-4.
3. 	Notwithstanding paragraph 1 of this Order, the Covered Articles are entitled to
entry into the United States for consumption, entry for consumption from a foreign-
trade zone, or withdrawal from a warehouse for consumption under bond in the
amount of one hundred (100) percent of the entered value of the Covered Articles,
pursuant to subsection (j) of Section 337 (19 U.S.C. § 1337(j)) and the Presidential
Memorandum for the United States Trade Representative of July 21, 2005 (70 Fed.
Reg. 43251), from the day after this Order is received by the United States Trade
Representative until such time as the United States Trade Representative notifies
the Commission that this Order is approved or disapproved but, in any event, not
later than sixty (60) days after the date of receipt of this Order. 	All entries of
Covered Articles made pursuant to this paragraph are to be reported to CBP, in
advance of the date of the entry, pursuant to procedures CBP establishes.
4. 	At the discretion of CBP and pursuant to the procedures it establishes, persons
seeking to import Covered Articles that are potentially subject to this Order may be
required to certify that they are familiar with the terms of this Order, that they have
made appropriate inquiry, and thereupon state that, to the best of their knowledge
and belief, the products being imported are not excluded from entry under
paragraph 1 of this Order. At its discretion, CBP may require persons who have
provided the certification described in this paragraph to furnish such records or
analyses as are necessary to substantiate the certification.
5. 	Complainants shall file a written statement with the Commission, made under oath,
each year on the anniversary of the issuance of this Order stating whether

Complainants continue to use each of the Asserted Trademarks in commerce in the
United States in connection with the products at issue and whether any of the
Asserted Trademarks have been abandoned, canceled, or rendered invalid or
unenforceable.
6. 	The Commission may modify this Order in accordance with the procedures
described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
7. 	The Commission Secretary shall serve copies of this Order upon each party of
record in this investigation and upon CBP. 	While temporary remote operating
procedures are in place in response to COVID-19, the Office of the Secretary is not
able to serve parties that have not retained counsel or otherwise provided a point of
contact for electronic service. 	Accordingly, pursuant to Commission Rules
201.16(a) and 210.7(a)(1) (19 C.F.R §§ 201.16(a), 210.7(a)(1)), the Commission
orders that the Complainant(s) complete service for any party/parties without a
method of electronic service noted on the attached Certificate of Service and shall
file proof of service on the Electronic Document Information System (EDIS).
8. 	Notice of this Order shall be published in the Federal Register.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: 	August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent AJ Auto Spare Parts FZE of
Office/Warehouse No. RA08TC06, Jebel Ali Free Zone, Dubai, United Arab Emirates
(“Respondent”) cease and desist from conducting any of the following activities in the United
States, including via the internet: importing, selling, marketing, advertising, distributing,
transferring (except for exportation), soliciting United States agents or distributors, and aiding or
abetting other entities in the importation, sale for importation, sale after importation, transfer
(except for exportation), or distribution within the United States of certain replacement
automotive service and collision parts and components thereof that infringe one or more of U.S.
Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the
“Asserted Trademarks”) in violation of Section 337 of the Tariff Act of 1930, as amended (19
U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) 	“Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.

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(B) “Commission” shall mean the United States International Trade Commission.
(C) “Complainants” shall mean Hyundai Motor Company of 231 YangJae-Dong,
Seocho-gu Seoul 137-938, Republic of Korea and Hyundai Motor America, Inc.
of 10550 Talbert Avenue, Fountain Valley, CA 92708.
(D) “Respondent” shall mean AJ Auto Spare Parts FZE of Office/Warehouse No.
RA08TС06, Jebel Ali Free Zone, Dubai, United Arab Emirates.
(E) “Person” shall mean an individual, or any non-governmental partnership, firm,
association, corporation, or other legal or business entity other than Respondent or
its majority-owned or controlled subsidiaries, successors, or assigns.
(F) “United States” shall mean the fifty States, the District of Columbia, and Puerto
Rico.
(G) The terms “import” and “importation” refer to importation for entry for
consumption under the Customs laws of the United States.
(H) The term “covered products” shall mean replacement automotive service and
collision parts and components thereof that infringe one or more of the Asserted
Trademarks. Covered products shall not include articles for which a provision of
law or license avoids liability for infringement.
II.
Applicability
The provisions of this Cease and Desist Order shall apply to Respondent and to any of its
principals, stockholders, officers, directors, employees, agents, licensees, distributors, controlled
(whether by stock ownership or otherwise) and majority-owned business entities, successors, and

3
assigns, and to each of them, insofar as they are engaging in conduct prohibited by section III,
infra, for, with, or otherwise on behalf of Respondent.
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order. While the
Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) 	import, sell for importation, or sell after importation into the United States
covered products;
(B) 	market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) 	advertise imported covered products;
(D) 	solicit U.S. agents or distributors for imported covered products; or
(E) 	aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this

4
section shall cover the period from the date of issuance of this Order through December 31,
2020. This reporting requirement shall continue in force until such time as Respondent has
truthfully reported, in two consecutive timely filed reports, that it has no inventory of covered
products in the United States.
Within thirty (30) days of the last day of the reporting period, Respondent shall report to
the Commission: (a) the quantity in units and the value in dollars of covered products that it has
(i) imported and/or (ii) sold in the United States after importation during the reporting period,
and (b) the quantity in units and value in dollars of reported covered products that remain in
inventory in the United States at the end of the reporting period.
When filing written submissions, Respondent must file the original document
electronically on or before the deadlines stated above and submit eight (8) true paper copies to
the Office of the Secretary by noon the next day pursuant to Section 210.4(f) of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.4(f)). Submissions should refer
to the investigation number (“Inv. No. 337-TA-1160”) in a prominent place on the cover pages
and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000. If Respondent desires to submit
a document to the Commission in confidence, it must file the original and a public version of the
original with the Office of the Secretary and must serve a copy of the confidential version on
Complainants’ counsel.1
1 Complainants must file a letter with the Secretary identifying the attorney to receive reports and
bond information associated with this Order. The designated attorney must be on the protective
order entered in the investigation.

5
Persons filing written submissions must file the original document electronically on or
before the deadlines stated above. The Commission’s paper filing requirements in 19 C.F.R.
210.4(f) are currently waived, pending resolution of the COVID-19 crisis. 85 Fed. Reg. 15798
(March 19, 2020).
Any failure to make the required report or the filing of any false or inaccurate report shall
constitute a violation of this Order, and the submission of a false or inaccurate report may be
referred to the U.S. Department of Justice as a possible criminal violation of 18 U.S.C. § 1001.
VI.
Record-Keeping and Inspection
(A) For the purpose of securing compliance with this Order, Respondent shall retain
any and all records relating to the sale, offer for sale, marketing, or distribution in
the United States of covered products, made and received in the usual and
ordinary course of business, whether in detail or in summary form, for a period of
three (3) years from the close of the fiscal year to which they pertain.
(B) For the purposes of determining or securing compliance with this Order and for
no other purpose, subject to any privilege recognized by the federal courts of the
United States, and upon reasonable written notice by the Commission or its staff,
duly authorized representatives of the Commission shall be permitted access and
the right to inspect and copy, in Respondent’s principal offices during office
hours, and in the presence of counsel or other representatives if Respondent so
chooses, all books, ledgers, accounts, correspondence, memoranda, and other
records and documents, in detail and in summary form, that must be retained
under subparagraph VI(A) of this Order.

6
VII.
Service of Cease and Desist Order
The Secretary shall serve copies of this Order upon each party of record in this
investigation that has retained counsel or otherwise provided a point of contact for electronic
service and upon CBP. While temporary remote operating procedures are in place in response to
COVID-19, the Office of the Secretary is not able to serve parties that have not retained counsel
or otherwise provided a point of contact for electronic service. Accordingly, pursuant to
Commission Rules 201.16(a) and 210.7(a)(1) (19 C.F.R. §§ 201.16(a), 210.7(a)(1)), the
Commission orders that the Complainant complete service of this Order for any party without a
method of electronic service noted on the attached Certificate of Service and shall file proof of
service on the Electronic Document Information System (EDIS).
Respondent is ordered and directed to:
(A) 	Serve, within fifteen (15) days after the effective date of this Order, a copy of this
Order upon each of its respective officers, directors, managing agents, agents, and
employees who have any responsibility for the importation, marketing,
distribution, or sale of imported covered products in the United States;
(B) 	Serve, within fifteen (15) days after the succession of any persons referred to in
subparagraph VII(A) of this Order, a copy of the Order upon each successor; and
(C) 	Maintain such records as will show the name, title, and address of each person
upon whom the Order has been served, as described in subparagraphs VII(A) and
VII(B) of this Order, together with the date on which service was made.
The obligations set forth in subparagraphs VII(B) and VII(C) shall remain in effect
indefinitely, unless the Asserted Trademarks are held invalid and unenforceable.

7
VIII.
Confidentiality
Any request for confidential treatment of information obtained by the Commission
pursuant to Sections V and VI of this Order should be made in accordance with Section 201.6 of
the Commission’s Rules of Practice and Procedure (19 C.F.R. § 201.6). For all reports for which
confidential treatment is sought, Respondent must provide a public version of such report with
confidential information redacted.
IX.
Enforcement
Violation of this Order may result in any of the actions specified in Section 210.75 of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.75), including an action for
civil penalties under Section 337(f) of the Tariff Act of 1930 (19 U.S.C. § 1337(f)), as well as
any other action that the Commission deems appropriate. In determining whether Respondent is
in violation of this Order, the Commission may infer facts adverse to Respondent if it fails to
provide adequate or timely information.
X.
Modification
The Commission may amend this Order on its own motion or in accordance with the
procedure described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
XI.
Bonding
The conduct prohibited by Section III of this Order may be continued during the sixty
(60) period in which this Order is under review by the United States Trade Representative, as

8
delegated by the President (70 Fed. Reg. 43,251 (Jul. 21, 2005)), subject to Respondent posting a
bond in the amount of one hundred (100) percent of the entered value of each covered products.
This bond provision does not apply to conduct that is otherwise permitted by Section IV of this
Order. Covered products imported after the date of issuance of this Order are subject to the entry
bond as set forth in the exclusion order issued by the Commission and are not subject to this
bond provision.
The bond is to be posted in accordance with the procedures established by the
Commission for the posting of bonds by complainants in connection with the issuance of
temporary exclusion orders. See 19 C.F.R. § 210.68. The bond and any accompanying
documentation are to be provided to and approved by the Commission prior to the
commencement of conduct which is otherwise prohibited by Section III of this Order. Upon the
Secretary’s acceptance of the bond, (a) the Secretary will serve an acceptance letter on all parties
and (b) Respondent must serve a copy of the bond and any accompanying documentation on
Complainants’ counsel.2
The bond is to be forfeited in the event that the United States Trade Representative
approves this Order (or does not disapprove within the review period), unless (i) the U.S. Court
of Appeals for the Federal Circuit, in a final judgment, reverses any Commission final
determination and order as to a Respondent on appeal, or (ii) Respondent exports or destroys the
products subject to this bond and provides certification to that effect that is satisfactory to the
Commission.
The bond is to be released in the event the United States Trade Representative
disapproves this Order and no subsequent order is issued by the Commission and approved (or
2 See note 1 above.

9
not disapproved, or no action is taken) by the United States Trade Representative, upon service
on Respondent of an order issued by the Commission based upon application therefore made by
Respondent to the Commission.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: 	August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent Cuong Anh Co. Ltd. of Lot 5, Gian
Khau Industrial Parks, Gia Tran Village, Gia Vien District, Ninh Binh Province, Vietnam
(“Respondent”) cease and desist from conducting any of the following activities in the United
States, including via the internet: importing, selling, marketing, advertising, distributing,
transferring (except for exportation), soliciting United States agents or distributors, and aiding or
abetting other entities in the importation, sale for importation, sale after importation, transfer
(except for exportation), or distribution within the United States of certain replacement
automotive service and collision parts and components thereof that infringe one or more of U.S.
Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the
“Asserted Trademarks”) in violation of Section 337 of the Tariff Act of 1930, as amended (19
U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) 	“Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.

2
(B) “Commission” shall mean the United States International Trade Commission.
(C) “Complainants” shall mean Hyundai Motor Company of 231 YangJae-Dong,
Seocho-gu Seoul 137-938, Republic of Korea and Hyundai Motor America, Inc.
of 10550 Talbert Avenue, Fountain Valley, CA 92708.
(D) “Respondent” shall mean Cuong Anh Co. Ltd. of Lot 5, Gian Khau Industrial
Parks, Gia Tran Village, Gia Vien District, Ninh Binh Province, Vietnam .
(E) “Person” shall mean an individual, or any non-governmental partnership, firm,
association, corporation, or other legal or business entity other than Respondent or
its majority-owned or controlled subsidiaries, successors, or assigns.
(F) “United States” shall mean the fifty States, the District of Columbia, and Puerto
Rico.
(G) The terms “import” and “importation” refer to importation for entry for
consumption under the Customs laws of the United States.
(H) The term “covered products” shall mean replacement automotive service and
collision parts and components thereof that infringe one or more of the Asserted
Trademarks. Covered products shall not include articles for which a provision of
law or license avoids liability for infringement.
II.
Applicability
The provisions of this Cease and Desist Order shall apply to Respondent and to any of its
principals, stockholders, officers, directors, employees, agents, licensees, distributors, controlled
(whether by stock ownership or otherwise) and majority-owned business entities, successors, and

3
assigns, and to each of them, insofar as they are engaging in conduct prohibited by section III,
infra, for, with, or otherwise on behalf of Respondent.
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order.
While the Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) 	import, sell for importation, or sell after importation into the United States
covered products;
(B) 	market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) 	advertise imported covered products;
(D) 	solicit U.S. agents or distributors for imported covered products; or
(E) 	aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this

4
section shall cover the period from the date of issuance of this Order through December 31,
2020. This reporting requirement shall continue in force until such time as Respondent has
truthfully reported, in two consecutive timely filed reports, that it has no inventory of covered
products in the United States.
Within thirty (30) days of the last day of the reporting period, Respondent shall report to
the Commission: (a) the quantity in units and the value in dollars of covered products that it has
(i) imported and/or (ii) sold in the United States after importation during the reporting period,
and (b) the quantity in units and value in dollars of reported covered products that remain in
inventory in the United States at the end of the reporting period.
When filing written submissions, Respondent must file the original document
electronically on or before the deadlines stated above and submit eight (8) true paper copies to
the Office of the Secretary by noon the next day pursuant to Section 210.4(f) of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.4(f)). Submissions should refer
to the investigation number (“Inv. No. 337-TA-1160”) in a prominent place on the cover pages
and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000. If Respondent desires to submit
a document to the Commission in confidence, it must file the original and a public version of the
original with the Office of the Secretary and must serve a copy of the confidential version on
Complainants’ counsel.1
1 Complainants must file a letter with the Secretary identifying the attorney to receive reports and
bond information associated with this Order. The designated attorney must be on the protective
order entered in the investigation.

6
VII.
Service of Cease and Desist Order
The Secretary shall serve copies of this Order upon each party of record in this
investigation that has retained counsel or otherwise provided a point of contact for electronic
service and upon CBP. While temporary remote operating procedures are in place in response to
COVID-19, the Office of the Secretary is not able to serve parties that have not retained counsel
or otherwise provided a point of contact for electronic service. Accordingly, pursuant to
Commission Rules 201.16(a) and 210.7(a)(1) (19 C.F.R. §§ 201.16(a), 210.7(a)(1)), the
Commission orders that the Complainant complete service of this Order for any party without a
method of electronic service noted on the attached Certificate of Service and shall file proof of
service on the Electronic Document Information System (EDIS).
Respondent is ordered and directed to:
(A) 	Serve, within fifteen (15) days after the effective date of this Order, a copy of this
Order upon each of its respective officers, directors, managing agents, agents, and
employees who have any responsibility for the importation, marketing,
distribution, or sale of imported covered products in the United States;
(B) 	Serve, within fifteen (15) days after the succession of any persons referred to in
subparagraph VII(A) of this Order, a copy of the Order upon each successor; and
(C) 	Maintain such records as will show the name, title, and address of each person
upon whom the Order has been served, as described in subparagraphs VII(A) and
VII(B) of this Order, together with the date on which service was made.
The obligations set forth in subparagraphs VII(B) and VII(C) shall remain in effect
indefinitely, unless the Asserted Trademarks are held invalid and unenforceable.

7
VIII.
Confidentiality
Any request for confidential treatment of information obtained by the Commission
pursuant to Sections V and VI of this Order should be made in accordance with Section 201.6 of
the Commission’s Rules of Practice and Procedure (19 C.F.R. § 201.6). For all reports for which
confidential treatment is sought, Respondent must provide a public version of such report with
confidential information redacted.
IX.
Enforcement
Violation of this Order may result in any of the actions specified in Section 210.75 of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.75), including an action for
civil penalties under Section 337(f) of the Tariff Act of 1930 (19 U.S.C. § 1337(f)), as well as
any other action that the Commission deems appropriate. In determining whether Respondent is
in violation of this Order, the Commission may infer facts adverse to Respondent if it fails to
provide adequate or timely information.
X.
Modification
The Commission may amend this Order on its own motion or in accordance with the
procedure described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
XI.
Bonding
The conduct prohibited by Section III of this Order may be continued during the sixty
(60) period in which this Order is under review by the United States Trade Representative, as

9
not disapproved, or no action is taken) by the United States Trade Representative, upon service
on Respondent of an order issued by the Commission based upon application therefore made by
Respondent to the Commission.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: 	August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent John Auto Spare Parts Co. LLC, of
Building 15 – Jafza 15, Dubai, United Arab Emirates (“Respondent”) cease and desist from
conducting any of the following activities in the United States, including via the internet:
importing, selling, marketing, advertising, distributing, transferring (except for exportation),
soliciting United States agents or distributors, and aiding or abetting other entities in the
importation, sale for importation, sale after importation, transfer (except for exportation), or
distribution within the United States of certain replacement automotive service and collision
parts and components thereof that infringe one or more of U.S. Trademark Registration Nos.
1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the “Asserted Trademarks”) in
violation of Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) 	“Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.
(B) 	“Commission” shall mean the United States International Trade Commission.

2
(C) “Complainants” shall mean Hyundai Motor Company of 231 YangJae-Dong,
Seocho-gu Seoul 137-938, Republic of Korea and Hyundai Motor America, Inc.
of 10550 Talbert Avenue, Fountain Valley, CA 92708.
(D) “Respondent” shall mean John Auto Spare Parts Co. LLC, of Building 15 – J afza
15, Dubai, United Arab Emirates .
(E) “Person” shall mean an individual, or any non-governmental partnership, firm,
association, corporation, or other legal or business entity other than Respondent or
its majority-owned or controlled subsidiaries, successors, or assigns.
(F) “United States” shall mean the fifty States, the District of Columbia, and Puerto
Rico.
(G) The terms “import” and “importation” refer to importation for entry for
consumption under the Customs laws of the United States.
(H) The term “covered products” shall mean replacement automotive service and
collision parts and components thereof that infringe one or more of the Asserted
Trademarks. Covered products shall not include articles for which a provision of
law or license avoids liability for infringement.
II.
Applicability
The provisions of this Cease and Desist Order shall apply to Respondent and to any of its
principals, stockholders, officers, directors, employees, agents, licensees, distributors, controlled
(whether by stock ownership or otherwise) and majority-owned business entities, successors, and
assigns, and to each of them, insofar as they are engaging in conduct prohibited by section III,
infra, for, with, or otherwise on behalf of Respondent.

3
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order.
While the Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) 	import, sell for importation, or sell after importation into the United States
covered products;
(B) 	market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) 	advertise imported covered products;
(D) 	solicit U.S. agents or distributors for imported covered products; or
(E) 	aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this
section shall cover the period from the date of issuance of this Order through December 31,
2020. This reporting requirement shall continue in force until such time as Respondent has

4
truthfully reported, in two consecutive timely filed reports, that it has no inventory of covered
products in the United States.
Within thirty (30) days of the last day of the reporting period, Respondent shall report to
the Commission: (a) the quantity in units and the value in dollars of covered products that it has
(i) imported and/or (ii) sold in the United States after importation during the reporting period,
and (b) the quantity in units and value in dollars of reported covered products that remain in
inventory in the United States at the end of the reporting period.
When filing written submissions, Respondent must file the original document
electronically on or before the deadlines stated above and submit eight (8) true paper copies to
the Office of the Secretary by noon the next day pursuant to Section 210.4(f) of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.4(f)). Submissions should refer
to the investigation number (“Inv. No. 337-TA-1160”) in a prominent place on the cover pages
and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000. If Respondent desires to submit
a document to the Commission in confidence, it must file the original and a public version of the
original with the Office of the Secretary and must serve a copy of the confidential version on
Complainants’ counsel.1
Persons filing written submissions must file the original document electronically on or
before the deadlines stated above. The Commission’s paper filing requirements in 19 C.F.R.
1 Complainants must file a letter with the Secretary identifying the attorney to receive reports and
bond information associated with this Order. The designated attorney must be on the protective
order entered in the investigation.

5
210.4(f) are currently waived, pending resolution of the COVID-19 crisis. 85 Fed. Reg. 15798
(March 19, 2020).
Any failure to make the required report or the filing of any false or inaccurate report shall
constitute a violation of this Order, and the submission of a false or inaccurate report may be
referred to the U.S. Department of Justice as a possible criminal violation of 18 U.S.C. § 1001.
VI.
Record-Keeping and Inspection
(A) For the purpose of securing compliance with this Order, Respondent shall retain
any and all records relating to the sale, offer for sale, marketing, or distribution in
the United States of covered products, made and received in the usual and
ordinary course of business, whether in detail or in summary form, for a period of
three (3) years from the close of the fiscal year to which they pertain.
(B) For the purposes of determining or securing compliance with this Order and for
no other purpose, subject to any privilege recognized by the federal courts of the
United States, and upon reasonable written notice by the Commission or its staff,
duly authorized representatives of the Commission shall be permitted access and
the right to inspect and copy, in Respondent’s principal offices during office
hours, and in the presence of counsel or other representatives if Respondent so
chooses, all books, ledgers, accounts, correspondence, memoranda, and other
records and documents, in detail and in summary form, that must be retained
under subparagraph VI(A) of this Order.

6
VII.
Service of Cease and Desist Order
The Secretary shall serve copies of this Order upon each party of record in this
investigation that has retained counsel or otherwise provided a point of contact for electronic
service and upon CBP. While temporary remote operating procedures are in place in response to
COVID-19, the Office of the Secretary is not able to serve parties that have not retained counsel
or otherwise provided a point of contact for electronic service. Accordingly, pursuant to
Commission Rules 201.16(a) and 210.7(a)(1) (19 C.F.R. §§ 201.16(a), 210.7(a)(1)), the
Commission orders that the Complainant complete service of this Order for any party without a
method of electronic service noted on the attached Certificate of Service and shall file proof of
service on the Electronic Document Information System (EDIS).
Respondent is ordered and directed to:
(A) 	Serve, within fifteen (15) days after the effective date of this Order, a copy of this
Order upon each of its respective officers, directors, managing agents, agents, and
employees who have any responsibility for the importation, marketing,
distribution, or sale of imported covered products in the United States;
(B) 	Serve, within fifteen (15) days after the succession of any persons referred to in
subparagraph VII(A) of this Order, a copy of the Order upon each successor; and
(C) 	Maintain such records as will show the name, title, and address of each person
upon whom the Order has been served, as described in subparagraphs VII(A) and
VII(B) of this Order, together with the date on which service was made.
The obligations set forth in subparagraphs VII(B) and VII(C) shall remain in effect
indefinitely, unless the Asserted Trademarks are held invalid and unenforceable.

7
VIII.
Confidentiality
Any request for confidential treatment of information obtained by the Commission
pursuant to Sections V and VI of this Order should be made in accordance with Section 201.6 of
the Commission’s Rules of Practice and Procedure (19 C.F.R. § 201.6). For all reports for which
confidential treatment is sought, Respondent must provide a public version of such report with
confidential information redacted.
IX.
Enforcement
Violation of this Order may result in any of the actions specified in Section 210.75 of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.75), including an action for
civil penalties under Section 337(f) of the Tariff Act of 1930 (19 U.S.C. § 1337(f)), as well as
any other action that the Commission deems appropriate. In determining whether Respondent is
in violation of this Order, the Commission may infer facts adverse to Respondent if it fails to
provide adequate or timely information.
X.
Modification
The Commission may amend this Order on its own motion or in accordance with the
procedure described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
XI.
Bonding
The conduct prohibited by Section III of this Order may be continued during the sixty
(60) period in which this Order is under review by the United States Trade Representative, as

9
not disapproved, or no action is taken) by the United States Trade Representative, upon service
on Respondent of an order issued by the Commission based upon application therefore made by
Respondent to the Commission.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: 	August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
NOTICE OF COMMISSION DETERMINATION NOT TO REVIEW AN INITIAL
DETERMINATION TERMINATING RESPONDENT DIRECT TECHNOLOGIES
INTERNATIONAL, INC. BASED ON CONSENT ORDER; ISSUANCE OF CONSENT
ORDER; FINDING DECLARATION FOR IMMEDIATE RELIEF IS MOOT; REQUEST
FOR WRITTEN SUBMISSIONS ON REMEDY, THE PUBLIC INTEREST, AND
BONDING
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
SUMMARY: Notice is hereby given that the U.S. International Trade Commission (the
“Commission”) has determined not to review an initial determination (“ID”) (Order No. 36)
terminating Direct Technologies International, Inc. on the basis of consent order. The
Commission has determined to issue a consent order. The Commission has further determined to
find that the complainants’ declaration seeking immediate relief against certain respondents
previously found to be in default is moot. The Commission also requests written submissions
from the complainants, interested government agencies, and interested persons on the issues of
remedy, the public interest, and bonding concerning certain respondents found in default.
FOR FURTHER INFORMATION CONTACT: Benjamin S. Richards, Office of the General
Counsel, U.S. International Trade Commission, 500 E Street SW, Washington, DC 20436,
telephone (202) 708-5453. Copies of non-confidential documents filed in connection with this
investigation are or will be available for inspection during official business hours (8:45 a.m. to
5:15 p.m.) in the Office of the Secretary, U.S. International Trade Commission, 500 E Street SW,
Washington, DC 20436, telephone (202) 205-2000. General information concerning the
Commission may also be obtained by accessing its Internet server (https://www.usitc.gov). The
public record for this investigation may be viewed on the Commission’s Electronic Docket
Information System (“EDIS”) (https://edis.usitc.gov). Hearing-impaired persons are advised that
information on this matter can be obtained by contacting the Commission’s TDD terminal,
telephone (202) 205-1810.
SUPPLEMENTARY INFORMATION: On June 7, 2019, the Commission instituted the
above-referenced investigation based on a complaint filed by Hyundai Motor America, Inc. of
Fountain Valley, California and Hyundai Motor Company of Seoul, Republic of Korea
(collectively, “Hyundai”). 84 FR 26703-04 (June 7, 2019). The complaint alleges a violation of

2
19 U.S.C. 1337, as amended (“Section 337”), in the importation, sale for importation, or sale in
the United States after importation of certain gray market Hyundai parts in the categories of
belts, body exterior and interior parts, brakes, wheel hubs, cooling system parts, drivetrain parts,
electrical parts, emission parts, engine parts, exhaust parts, fuel/air pumps, oil/air/cabin air filters
and parts, heat and A/C parts, ignition parts, steering parts, suspension parts, transmission parts,
wheels and parts, wiper and washer parts, and accessories that infringe one or more of Hyundai’s
U.S. Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195. Id. at 26704.
The complaint further alleges that a domestic industry exists in the United States. Id.
The Commission’s notice of investigation named Direct Technologies International, Inc.
(“DTI”) of North Miami Beach, Florida; AJ Auto Spare Parts FZE (“AJ Auto”) and John Auto
Spare Parts Co. LLC (“John Auto”), both of Dubai, United Arab Emirates; and Cuong Anh Co.
Ltd. (“Cuong Anh”) of Ninh Binh Province, Vietnam as respondents. The Office of Unfair
Import Investigations was not named as a party to this investigation.
On November 25, 2019, the Commission determined not to review an initial
determination (Order No. 17) granting Hyundai’s unopposed motion to find respondents AJ
Auto, John Auto, and Cuong Anh (collectively, the “Defaulting Respondents”) in default. Order
No. 17 (Nov. 5, 2019), not rev’d, Comm’n Notice (Nov. 25, 2019).
On January 24, 2020, Hyundai filed a declaration seeking immediate entry of a limited
exclusion order against the Defaulting Respondents and any of their affiliated companies,
parents, subsidiaries, and related business entities, successors or assigns.
On March 5, 2020, the presiding administrative law judge (“ALJ”) issued an initial
determination (Order No. 36) granting a joint motion by Hyundai and DTI to terminate the
investigation as to DTI on the basis of a consent order. The ALJ found that the consent order
stipulation and proposed consent order complied with Commission Rule 210.21(c)(3) and (4)
(19 CFR 210.21(c)(3) and (4)). The ALJ also found that termination of this investigation does
not impose any undue burdens on the public health and welfare, competitive conditions in the
United States economy, production of like or directly competitive articles in the United States, or
United States consumers. No petitions for review of the ID were received.
The Commission has determined not to review the subject ID and has determined to issue
a consent order. The Commission has further determined that Hyundai’s declaration is now
moot given the termination of DTI, the final remaining respondent in this investigation. Finally,
the Commission has determined to request briefing on the issues of remedy, bonding, and the
public interest.
Section 337(g)(1) (19 U.S.C. 1337(g)(1)) and Commission Rule 210.16(c) (19 CFR
210.16(c)) authorize the Commission, upon request, to issue a limited exclusion order or a cease
and desist order or both against a respondent found in default, unless after consideration of the
public interest factors in Section 337(g)(1), it finds that such relief should not issue.
Accordingly, in connection with the final disposition of this investigation, the Commission is
interested in receiving written submissions that address the form of remedy, if any, that should
be ordered with respect to the Defaulting Respondents, identified above. If a party seeks
exclusion of an article from entry into the United States for purposes other than entry for

3
consumption, the party should so indicate and provide information establishing that activities
involving other types of entry either are adversely affecting it or likely to do so. For background,
see Certain Devices for Connecting Computers via Telephone Lines, Inv. No. 337-TA-360,
USITC Pub. No. 2843, Comm’n Op. at 7-10 (December 1994).
The statute requires the Commission to consider the effects of that remedy upon the
public interest. The public interest factors the Commission will consider include the effect that
an exclusion order and/or cease and desist orders would have on (1) the public health and
welfare, (2) competitive conditions in the U.S. economy, (3) U.S. production of articles that are
like or directly competitive with those that are subject to investigation, and (4) U.S. consumers.
The Commission is therefore interested in receiving written submissions that address the
aforementioned public interest factors in the context of this investigation.
If the Commission orders some form of remedy, the U.S. Trade Representative, as
delegated by the President, has 60 days to approve, disapprove, or take no action on the
Commission’s action. See Presidential Memorandum of July 21, 2005, 70 FR 43251 (July 26,
2005). During this period, the subject articles would be entitled to enter the United States under
bond, in an amount determined by the Commission and prescribed by the Secretary of the
Treasury. The Commission is therefore interested in receiving submissions concerning the
amount of the bond that should be imposed if a remedy is ordered.
Written Submissions: Complainants, interested government agencies, and any other
interested persons are encouraged to file written submissions on the issues of remedy, the public
interest, and bonding.
In their initial submission, complainants are requested to identify the form of the remedy
sought and to submit proposed remedial orders for the Commission’s consideration.
Complainants are also requested to state the date that the asserted patents expire, the HTSUS
subheadings under which the products at issue are imported, and to supply the identification
information for all known importers of the products at issue in this investigation. Initial written
submissions regarding remedy, bonding, and the public interest and proposed remedial orders
must be filed no later than close of business on April 9, 2020. Reply submissions must be filed
no later than the close of business on April 16, 2020. No further submissions on these issues
will be permitted unless otherwise ordered by the Commission.
Persons filing written submissions must file the original document electronically on or
before the deadlines stated above. The Commission’s paper filing requirements are currently
waived. Submissions should refer to the investigation number (“Inv. No. 337-TA-1160”) in a
prominent place on the cover page and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000.
Any person desiring to submit a document to the Commission in confidence must request
confidential treatment unless the information has already been granted such treatment during the
proceedings. All such requests should be directed to the Secretary of the Commission and must
include a full statement of the reasons why the Commission should grant such treatment. See 19
CFR 210.6. Documents for which confidential treatment by the Commission is sought will be

4
treated accordingly. A redacted non-confidential version of the document must also be filed
simultaneously with any confidential filing. All information, including confidential business
information and documents for which confidential treatment is properly sought, submitted to the
Commission for purposes of this Investigation may be disclosed to and used: (i) By the
Commission, its employees and Offices, and contract personnel (a) for developing or
maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission
including under 5 U.S.C. Appendix 3; or (ii) by U.S. government employees and contract
personnel1 solely for cybersecurity purposes. All non-confidential written submissions will be
available for public inspection at the Office of the Secretary and on EDIS.
The authority for the Commission’s determination is contained in Section 337 of the
Tariff Act of 1930, as amended (19 U.S.C. 1337), and in part 210 of the Commission’s Rules of
Practice and Procedure (19 CFR part 210).
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: March 26, 2020
1 All contract personnel will sign appropriate nondisclosure agreements.

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached NOTICE has been served on the
following parties as indicated, on 3/26/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International, Inc.
d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download

UNITED STATES INTERNATIONAL TRADE COMMISSION
I' 	Washington, D.C.
In the Matter of 	‘
CERTAIN REPLACEMENT
AUTOMOTIVE SERVICE AND 	Inv. No. 337-TA-1160
COLLISION PARTS AND COMPONENTS
THEREOF
ORDER NO. 36: INITIAL DETERMINATION GRANTING JOINT MOTION TO
TERMINATE RESPONDENT DIRECT TECHNOLOGIES
INTERNATIONAL, INC. BASED ON CONSENT ORDER;
TERMINATING THE INVESTIGATION IN ITS ENTIRETY
_ (March 5, 2020)
On February 20, 2020, Complainants Hyundai Motor Company and Hyundai Motor
America, Inc. (collectively, “Hyundai”) and Respondent Direct Technologies Intemational, Inc.
(“DTI”) filed a joint motion (1160-O31)to tenninate this Investigation based on a consent order
l
stipulation and a proposed consent order.
In accordance with Connnission Rule 210.21(c)(l)(ii), Hyundai and DTI have entered into
a “Consent Order Stipulation” and a proposed “Consent Order,” attached hereto as Attachments A
and B. Hyundai and DTI submit that all agreements between them conceming the subject matter
of this Investigation are attached as confidential exhibits to their motion. Mem. at 6-7. Consistent
with 19 C.F.R. § 21O.2l(c), they confirm that “[t]here are no other agreements, written or oral,
express or implied, . . . conceming the subject matter of this Investigation.” Id. at 7.
Commission Rule 210.2 l(c)(3) sets forth certain requirements for the contents of a consent
order stipulation. See 19 C.F.R. § 210.2l(c)(3). The Consent Order Stipulation submitted by the
parties complies with the requirements of Commission Rule 2l0.21(c)(3). See Attachment A.
‘ DTI is the only remaining respondent in this Investigation. The other named respondents have been found in default.

Specifically, DTI agrees that upon entry of the Consent Order:
DTI . . . will not sell for importation, import into the United States, sell after
importation, distribute, or otherwise transfer (other than exportation) the
Accused Parts that infringe the Asserted Trademarks in the United States,
directly or indirectly, and shall not aid, abet, encourage, participate in, or
induce the sale for importation, the importation, the sale after importation,
distribution, or otherwise transfer the Accused Parts, except under consent,
license from Complainants, or to the extent permitted by a settlement
agreement between Hyundai and DTI.‘
Consent Order Stip. 1l3. Pursuant to Commission Rule 210.21(c)(3)(i), DTI also agrees to
(1) admit that the Commission has in rem jurisdiction over the subject
matter of this Investigation, and in personam jurisdiction over
Respondents (see Consent Order Stip. 1i1);
(2) ‘ expressly waive all rights to seek judicial review or otherwise
challenge or contest the validity of the Consent Order (id at fil5);
(3) cooperate with and not seek to impede by litigation or other means
. the Cornmission’s efforts to gather information under Subpart I of
the C0mmission’s Rules of Practice and Procedure (id. at 1[6); and
(4') the enforcement, modification, or revocation of the Consent Order
being carried out pursuant to Subpart I of Part 210 of 19 C.F.R. §
210 (id. at {I7).
Because this is an intellectual property-based investigation and in accordance with
Commission Rule 2lO.2l(c)(3)(ii), the Consent Order Stipulation also states thatz.
(1) the Consent Order shall not apply with respect to any claims of any
intellectual property right that has expired or been foimd or
adjudicated invalid or unenforceable by the Commission or a comt
or agency of competent jurisdiction, provided that such finding or
judgment has become final and non-reviewable (id. at 1i9); and
(2) DTI (including DTI’s officers, directors, employees, agents, or any
entity or individual acting on DTI’s behalf and with DTl’s authority)
will not seek to challenge the validity of the intellectual property
rights of the Asserted Trademarks in any administrative or judicial
proceeding to enforce the Consent Order (id. at 1]10).
-2

Additionally, Commission Rule 2l0.2l(c)(4) sets forth certain requirements for the
contents of the consent order. See 19 C.F.R. § 2l0.2l(c)(4). The Consent Order submitted by the
parties complies with the requirements of Commission Rule 2l0.2l(c)(4). See Attachment B.
V In any initial determination tenninating an investigation by settlement agreement or
consent order, the administrative law judge is directed to consider and make appropriate findings
regarding the effect of the proposed settlement on the public health and welfare, competitive
conditions in the United States economy, production of like or directly competitive articles in the
United States, and United States consumers. 19 C.F.R. § 2l0.50(b)(2). Hyundai and DTI assert
that granting the joint motion is “in the public interest as it conserves judicial and private party
resources.” Mem. at 9. The undersigned finds that tennination of this Investigation does not impose
any undue burdens on the public health and welfare, competitive conditions in the United States
economy, production of like or directly competitive articles in the United States, or United States
consumers.
Accordingly, for good cause shown, it is the undersigned’s Initial Determination that the
joint motion (1160-031) to terminate this Investigation in its entirety based on a consent order
stipulation and proposed consent order be granted. '
This Initial Determination, along with supporting “documentation,is hereby certified to the
Commission. Pursuant to 19 C.F.R. § 2lO.42(h), this Initial Determination shall become the
determination of the Commission Lmless a party files a petition for review of the Initial
Determination pursuant to l9 C.F.R. § 2l0.43(a), or the Commission;pursuant to 19 C.F.R. §
210.44, orders, on its own motion, a review of the Initial Determination or.certain issues, herein.
éarles Bullock /
Chief Administrative Law Judge
_ 3 _ 	_
SO ORDERED. 	’

PUBLIC VERSION
ATTACHMENT A

PUBLIC VERSION
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, DC
Before the Honorable Charles E. Bullock
Chief Administrative Law Judge
In the Matter of
E‘l[3J1%;‘V1I§11f}'€,1:3L§*]5C§\l/‘11('§Il;I1/;ND Investigation No. 337-TA-1 160
COUJMONPARTSANDCOMPONENTS
THEREOF
DTI’S CONSENT ORDER STIPULATION
WHEREAS, Hyundai Motor Company and Hyundai Motor America, Inc. (collectively
“Complainants”) filed a Complaint before the United States International Trade Commission (the
“Commission”) on May 3, 2019, and a supplement to the complaint was filed on May 21 and
May 23, 2019. The complaint, "assupplemented, alleges violations of Section 337 in the alleged
importation into the United States, sale for importation into the United States, and/or sale within
the United States after importation of certain replacement automotive service and collision parts
and components thereof that allegedly infringe U.S. Registered Trademark Nos. 1104727,
3991863, 1569538, and 4065195 (“Asserted Trademarks”).
WHEREAS, Complainants allege that Respondents DTI, AJ Auto Spare Parts FZE (“AJ
Auto”), John Auto Spare Parts Co. LLC (“John Auto”), and Cuong Anh Co. Ltd. (Cuong Anh”)
(collectively “Respondents”) infringe the Asserted Trademarks by way of selling for importation,
importing, and selling after importation Hyundai-branded replacement automotive service and
collision parts and components thereof (“Accused Parts”).
WHEREAS, DTI acknowledges that Respondents AJ Auto and Cuong Anh supplied

PUBLIC VERSION
DTI with Accused Parts;
WHEREAS, DTI has commercially significant inventory of Accused Parts in the United
States;
WHEREAS, Respondents AJ Auto, Cuong Anh, and John Auto have defaulted;
WHEREAS, DTI enters into this Consent Order Stipulation and agrees to entry of a
Consent Order from the Commission to settle this dispute with Hyundai and terminate this
'~
Investigation as to DTI; 	_
WHEREAS, DTI agrees to the entry of a Consent Order by the Commission in the form
attached hereto as Attachment B in order to terminate this Investigation as to DTI;
NOW THEREFORE, pursuant to Commission Rule 2l0.21(c)(l)(ii) and (c)(3) (19
CA.F.R.§ 2l0.21(c)(l)(ii) and (c)(3)), DTI stipulates and agrees as follows:
" l. The Commission has in rem jurisdiction over the Accused Parts that are the basis of this
Investigation, subject matterjurisdiction over this Investigation, and personal jurisdiction over
DTI for purposes of this Consent Order.
2. Complainants allege that DTI imports and sells the Accused Parts and that infringe the
Asserted Trademarks. 	- t
3. Upon entry of the Consent Order, DTI (including DTI’s officers, directors, employees,
agents, or any entity or individual acting on DTI’s behalf and with DTI’s authority) will not sell
for importation, import into the United States, sell afier importation, distribute, or otherwise
transfer (other than exportation) the Accused Parts that infringe the Asserted Trademarks in the
United States, directly or indirectly, and shall not aid, abet, encourage, participate in, or induce
the sale for importation, the importation, the_sale after importation, distribution, or otherwise
transfer the Accused Parts , except under consent, license from Complainants, or to the extent

PUBLIC VERSION
permitted by a settlement agreement between Hyundai and DTI.
4. DTI has commercially significant inventory in the United States of Accused Parts that
infringe the Asserted Trademarks, and DTI (including DTl’s officers, directors, employees,
agents, or any entity or individual acting on DTl’s behalf and with DTI’s authority), except
under consent, license from Complainants, or to the extent permitted by a settlement agreement
between Hyundai and DTI, shall cease and desist from importing and distributing articles
covered by the Asserted Trademarks. _ '
5. DTI and its officers, directors, employees, agents, and any entity or individual acting on
its behalf and with its authority expressly waive all rights to seek judicial review or otherwise i
challenge or contest the validity of the Consent Order.
6. DTI will cooperate with and will not seek to impede by litigation or other means the
Commission’s efforts to gather information under subpart I of the Commission’s Rules of
Practice and Procedure, 19 C.F.R. Part 210. '
7. The enforcement, modification, and revocation of the Consent Order will be carried out
pursuant to Subpart I of Part 210, Title 19 Code of Federal Regulations, incorporating by
reference the Commission’s Rules of Practice and Procedure.
8. The Consent Order shall have the same force and effect and may be enforced, modified
or revoked in the same manner as is provided in Section 337 of the Tariff Act of 1930 and Part
210, Title 19 of the Code of Federal Regulations for other Commission actions, and the
Cornrnission may require periodic compliance reports pursuant to subpart I of Part 210, Title 19
of the Code of Federal Regulations to be submitted by DTI. ii
9. If any of the Asserted Trademarks has expired or is held invalid or unenforceable by a
court or agency of competentjurisdiction, or if any articles has been found or adjudicated not to

PUBLIC VERSION
infringe the Asserted Trademark in a final decision, no longer subject to appeal, this Consent
Order shall become null and void as to such expired, invalid, or unenforceable trademark or as o
any adjudicated article. 	,
10. DTI (including DTI’s officers, directors, employees, agents, or any entity or individual
acting on DTI’s behalf and with DTI’s authority) will not seek to challenge the validity of the
intellectual property rights of the Asserted Trademarks in any administrative or judicial
proceeding to enforce the Consent Order.
Attested to and signed on thisl day of February, 2020 in Miami Gardens. Florida ,
USA. V
Dmitriy Yur enko
On behalf of Respondent Direct
TechnologiesInternational, Inc. d/b/a
DTI Inc.

PUBLIC VERSION
ATTACHMENT B

PUBLIC VERSION
1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, DC
Before the Honorable Charles E. Bullock
Chief Administrative Law Judge
In the Matter of
ga%g‘;%%'3;L€‘§§%gg;ND 	InvestigationNo. 337-TA-1160
COLLISION PARTS AND COMPONENTS
THEREOF
[PROPOSED] CONSENT ORDER
The U.S. International Trade Commission (“Commission”) has instituted an investigation
at the request of Complainants Hyundai Motor Company and Hyundai Motor America, Inc.
(collectively “Hyundai” or “Complainants”) against Respondent Direct Teclmologies
International, Inc. d/b/a DTI, Inc. (“DTI” or “Rcspondent”). The Complaint, as supplemented,
alleges violations of 19 U.S.C. § 1337 based upon the sale for importation into the United States,
importation into the United States, and/or sale after importation into the United States of
Hyundai-branded replacement automotive service and collision parts and components thereof
(“Accused Parts”) that infringement U.S. Trademark Reg. Nos. l 104727, 3991863, 1569538, and
4065195 (“Asserted Trademarks”). The Commission instituted this investigation on June 3,
2019, and the Notice of Institution was published in the Federal Register on June 7, 2019. 84
Fed. Reg. 26703. 	i
DTI has executed a Consent Order Stipulation and moved with Complainants for an
Initial Determination terminating this investigation by entry of a Consent Order.
Upon entry of the Consent Order, DTI (including DTI’s officers, directors, employees,

PUBLIC VERSION
agents, or any entity or individual acting on DTI’s behalf and with DTI’s authority) shall not
directly or indirectly sell for importation, import into the United States, sell after importation,
distribute, or otherwise transfer the Accused Parts that infringe the Asserted Trademarks, except
under consent, license from Complainants, or to the extent permitted by a settlement agreement
between Hyundai and DTI. DTI (including DTI’s officers, directors, employees, agents, or any
entity or individual acting on DTI’s behalf and with DTI’s authority) shall not aid, abet,
encourage, participate in, or induce the sale fof importation, the importation, the sale after
importation, distribution, or otherwise transfer the Accused Parts except under consent, license
from Complainants, or to the extent permitted by a settlement agreement between Hyundai and
DTI.
DTI stipulates that it has commercially significant. inventory of the Accused Parts in the
United States. DTI (including DTI’s officers, directors, employees, agents, or any entity or
individual acting on DTI’s behalf and with DTI’s authority) shall cease and desist from
importing and distributing the Accused Parts, except under consent, license from Complainants,
or to the extent permitted by a settlement agreement between Hyundai and DTI.
' DTI (including DTI’s officers, directors, employees, agents, or any entity or individual
acting on DTI’s behalf and with DTI’s authority) shall be precluded from seekingjudicial review
or otherwise challenging or contesting the validity of the Consent Order.
DTI shall cooperate with and shall not seek to impede by litigation or other means the
Commission’s efforts to gather information under subpart Iiof the Comrnission’s Rules of
Practice and Procedure, 19 C.li .R. Part 210. 	ii
DTI and its officers, directors, employees, agents, and any entity or individual acting on
its behalf and with its authority shall not seek to challenge the validity or enforceability of the
l

PUBLIC VERSION
Asserted Trademarks in any administrative or judicial proceeding to enforce the Consent Order.
When an Asserted Trademark expires the Consent Order shall become null and void as to
such trademark. If any trademark is held invalid or unenforceable by a court or agency of
competent jurisdiction or as to any article has been found or adjudicated not to infringe the
Asserted Trademarks in a final decision, no longer subject to appeal, this Consent Order shall
become null and void as to such invalid or unenforceable claim. 	'
All jurisdictional facts are admitted by stipulation. The Commission has in rem
jurisdiction and personal jurisdiction.
This investigation is hereby terminated with respect to DTI; provided, however, that
enforcement, modification, or revocation of the Consent Order shall be carried out pursuant to
Subpartl of the Commission's Rules of Practice and Procedure, 19 CPR part 210.
This motion is hereby GRANTED and it is SO ORDERED on this __ day of
, 2020.
Charles E. Bullock
Chief Administrative Law Judge
J

@PU 111111111ON
EXHIBIT
A

PUBLIC VERSION
17

PUBLIC VERSION
I8

PUBLIC VERSION
18

PUBLIC VERSION
EXHIBIT
B

PUBLIC VERSION

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE 	Inv. N0. 337-TA-1160
AND COLLISION PARTS AND COMPONENTS THEREOF ' 	.
Certifieate of Serviee —Page 1 ,
»
I, Lisa R.-Barton, hereby certify that the attached ORDER NO. 36 has been served upon
the following parties as indicated, on March 5, 2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hvundai Motor America,
Inc. and Hvundai Motor Compang l
Kecia Reynolds, Esq.
1200 Seventeenth Street, NW 	- '
Washington, DC 20036
PILLSBURY WINTI-IROP SHAW PITTMAN LLP U Via Hand Delivery 	x
fiVia ExpressDelivery
U Via First Class Mail
III Other:
On Behalf of Respondent Direct Technologies
International, Inc. d/b/a DTI. Inc.:
Andrew R. Kopsidas
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Washington, DC 20024
El Via Hand Delivery
iVia ExpressDelivery
El Via First Class Mail V
III Other:

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE Investigation N0. 337-TA-1160
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
NOTICE OF COMMISSION DETERMINATION NOT TO REVIEW AN INITIAL.
DETERMINATION ENTERING SUMMARY DETERMINATION THAT THE
DOMESTIC INDUSTRY REQUIREMENT IS SATISFIED
AGENCY: U.S. International Trade Commission.
ACTION: Notice.
SUMMARY: Notice is hereby given that the U.S. International Trade Commission (the
“Comnrission”) has determined not to review an initial determination (“ID”) (Order No. 26)
granting complainants’ unopposed motion for stmnnary determination that complainants satisfy
both the technical and economic prongs of the domestic industry requirement.
FOR FURTHER INFORMATION CONTACT: Carl P. Bretscher, Office of the General
Counsel, U.S. Intemational Trade Commission, 500 E Street SW, Washington, DC 20436,
telephone (202) 205-2382. Copies of non-confidential documents filed in connection with this
investigation are or will be available for inspection during official business hours (8:45 a.m. to
5:15 p.m.) in the Office of the Secretary, U.S. Intemational Trade Commission, 500 E Street SW,
Washington, DC 20436, telephone (202) 205-2000. General information concerning the
Commission may also be obtained by accessing its Intemet server (httgs://www.usi!c.gov). The
public record for this investigation may be viewed on the Comrnission’s Electronic Docket
Information System (“EDIS”) (ht_tQs.'//edis.usitc. gov). Hearing-impaired persons are advised that
information on this matter can be obtained by contacting the Commission’s TDD terminal,
telephone (202) 205-1810. '
SUPPLEMENTARY INFORMATION: On Jmre 17, 2019, the Commission instituted the
above-referenced investigation based on a complaint,filed by Hyundai Motor America, Inc. of
Fountain Valley, California and Hyundai Motor Company of Seoul, Republic of Korea
(collectively, “Hyundai”). 84 FR 267030-04 (June 7, 2019). The complaint alleges a violation
of 19 U.S.C. 1337, as amended (“Section 337”), in the importation, sale for importation, or sale
in the United States after importation of certain gray market Hyundai parts in the categories of
belts, body exterior and interior parts, brakes, wheel hubs, cooling system parts, drivetrain parts,
electrical parts, emission parts, engine parts, exhaust parts, fuel/air pumps, oil/air/cabin air filters
and parts, heat and A/C parts, ignition parts, steering parts, suspension parts, transmission parts,
wheels and parts, wiper and washer parts, and accessories that infringe one or more of Hyundai’s

U.S. Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195. Id. at 26704.
The complaint further alleges that a domestic industry exists in the United States. Id.
The Commission’s notice of investigation named Direct Technologies Intemational, Inc.
(“DTI”) of North Miami Beach, Florida; AJ Auto Spare Parts FZE (“AJ Auto”) and John Auto
Spare Parts Co. (“John Auto”) of Dubai, United Arab Emirates; and Cuong Anh Co. (“Cuong
Anh”) ofNinh Binh Province, Vietnam as respondents. The Office of Unfair Import
Investigations was not named as a party to this investigation.
On November 25, 2019, the Commission determined not to review an ID (Order No. 17)
granting Hyundai’s unopposed motion to find respondents AJ Auto, John Auto, and Cuong Anh
in default. Order No. 17 (Nov. 5, 2019), not rev ’d, Cornrn’n Notice (Nov. 25, 2019). As a
result, DTI is presently the only respondent still active in this investigation.
On January 16, 2020, the presiding administrative law judge entered the subject ID
(Order No. 26), pursuant to Commission Rule 210.18 (19 CFR 210.18), granting Hyundai’s
Lmopposedmotion for summary determination that it satisfies both the technical and economic
prongs of Section 337’s domestic industry requirement. DTI did not oppose Hyundai’s motion
or file a petition for review of the subject ID.
The Commission has determined not to review the subject ID. The authority for the
Commission’s detennination is contained in Section 337 of the Tariff Act of 1930, as amended
(19 U.S.C. 1337), and in part 210 of the Commission’s Rules of Practice and Procedure (19 CFR
part 210). 	\
p 	Lisa R. Barton
Secretary to the Commission
Issued: February 18, 2020
By order of the Commission.

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND Inv. No. 337-TA-1160
COLLISION PARTS AND COMPONENTS THEREOF
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached NOTICE has been served on the
following parties as indicated, on 2/18/2020.
Lisa Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America. Inc.
and Hyundai Motor Company_:
Kecia Reynolds, Esq.
PILLSBURY VVINTHROPSHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
El Via Hand Delivery
El Via Express Delivery
IZIVia First Class Mail
El Other:
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
El Via Hand Delivery
III Via Express Delivery
Via\First Class Mail
III Other:

UNITED STATES INTERNATIONAL TRADE COMMISSION
1 	. 	Washington, D.C.
In the Matter of 	'
CERTAIN REPLACEMENT _
- AUTOMOTIVE SERVICE AND . , 	Inv- N0- 337—TA-1160
COLLISION PARTS AND COMPONENTS 	' 	*
THEREOF 	- 	A
_ ORDER NO.26: .INITIAL DETERMINATION GRANTING COMPLAINANTS’
_ ' UNOPPOSED MOTION FOR SUMMARY DETERMINATION
THAT THE DOMESTIC INDUSTRY REQUIREMENT IS
SATISFIED ‘ ‘ Y ‘
. 	(January 16, 2020)
On December 3, 20,19, Complainants Hyundai Motor Company (“HMC”) and Hyundai
Motor America, Inc. (“HMA”) (collectively, “Hyundai”) filed a motion (1 160-017) for summary
determination that the technical and economic prongs of the domestic industry requirement are
satisfied. Respondent Direct Technologies International, Inc. (“DTI”) does not oppose the motion.
Mot. at 3. . ‘
I. ~ ‘BACKGROUND
A. Asserted Trademarks‘ 	" »
_ Hyundai is asserting the following trademarks against DTI in this Investigation:
U.S. 'l"rndexnark 	_ 	'
‘ Re-;lstn'atlo||N0s. Reglstn-ailunDnfie 	Design ,
1104727 	October 24, 1978 	_
HYI-IIIDRI
l569538 	'Dccen|be1‘5, I989 ' 	'
I *§§91s6§::7 I E OT July’l§. 2011 7 E I I J A	I-lYl.|fIDfll\ 	I
4065195 December6,2011 	®
L__._n_________At_

1. _ Technical Prong_ 	. 	f
The technical prong of the domestic industry requirement is satisfied when the complainant
establishes that the articles relating to the domestic industry are protected by the intellectual
property at issue in the investigation. See Certain Personal Transporters, Components Thereof
and Packaging and Manuals Therefor, Inv. No. 337-TA-1007, Order No. 32 (Initial
Determination) at 2-3 (Apr. 6, 2017), a]j"d, Commission Decision Not to Review an Initial
Determination Granting Complainants’ Motion for Summary Determination on the Technical
Prong of the Domestic Industry Requirement (May 14, 2010). Where registered trademark rights
are asserted, “[t]he test for determining whether the technical prong is met through the practice of
a trademark is plain use of the trademark on products and packaging.” Certain Protective Cases
and Components Thereof, Inv. No. 337-TA-780, Initial Determination at 90 (June 29, 2012).
. 2. Economic Prong 	'
Section 337(a)(3) sets forth the following economic criteria for determining the existence
of a domestic industry in such investigations: .
- (3) For purposes of paragraph (2), an industry in the United States
shall be considered to exist if there is in the United States, with
respect to the articles protected by the patent, copyright, trademark,
mask Work, or design concerned — \
(A) significant investment in plant and equipment;
(B) significant employment of labor or capital; or
(C) substantial investment in its exploitation, including engineering,
1 	research and development, or licensing.
Given that these criteria are listed in the disjunctive, satisfaction of any one of them will be
sufficient to meet the economic prong of the domestic industry requirement. Certain Integrated
Circuit Chipsets and Prods. Containing Same, Inv. No. 337-TA-428, Order No. 10, Initial
Detennination (unreviewed) (May 4, 2000).
_ 3 _

III. DISCUSSION _
A. Technical Prong . .
Hyundai asserts that all the Domestic Industry Products satisfy the technical prong of the
domestic industry requirement. Mem. at 17. Hyundai offers the testimony of James Carter, a Senior
Group Manager, Financial Planning and Analysis for HMA, who testified that the Domestic
Industry Vehicles bear the Asserted Trademarks. SUMF at 1]70; SUMF Eit. 5, Carter Decl., at 1|1I
3, 54. Mr. Carter also testified that the Domestic Industry Parts bear the Asserted Trademarks.
SUMF at 111]80, 83; SUMF Ex. 5 at 1|1[44, 56.
The evidence confirms that the Asserted Trademarks are “plainly used” on the Domestic
Industry Products. SUMF at 1]17; SUMF Ex. 5 at 1H[3, 44, 54, 56; see also Protective Cases, 337
TA-780, Initial \Determination at 90. Hyundai submits that the following examples are
representative of how the Asserted Trademarks are displayed on the Domestic Industry Products:
REGISTERED DOMESTIC INDUSTRY PRODUCT
TRADEMARKS
Smarter
. 	tttesyeit.
:4'Ki1:|‘§.§III.F21i-3 	t!.ilL~‘L\‘.-J1;1.) 	, -. 5,7 ,(4_'_,
(u.s. Reg. Nos. ~
1,569,538 and 	f - --—
4,065,19s) 	_ g
g 	| 	"';-.~.
-4

REGISTERED D IN P
TRADE S OMESTIC DUSTRY RODUCT
“HYUNDAI,”
(U.S. Reg. -Nos.
1,104,727 and
3,991,863) » 	0' 	r //"‘
,I I, 	.... 	I‘Q 	<1.	l 	~
(U.S. Reg. Nos. , 	:7"? D
1,569,538 and
4,065,195)
See SUMF E54.7 at 23-24; see also Mem. at 3-4; Mot. Ex. l at 111]42, 46. The evidence also shows
that the Domestic Industry Vehicles are manufactured and assembled in the United States using
Domestic Industry Parts. SUMF at 111]16, 18; SUMF Ex. 5 at 1|1l3, 44, 54.
Additionally, there is no evidence of record to contradict Hyundai’s assertion that the
Domestic Industry Products prominently feature the Asserted Trademarks. ‘
.The undersigned therefore finds that the undisputed facts demonstrate that Hyundai has
satisfied the technical prong of the domesticiindustry requirement: I 	.
B. Economic Prong
Hyundai asserts that it satisfies the economic prong under 19 U.S.C. § l337(a)(3)(A) and
(B) because it has: “(A) significantly invested in plants and equipment . . . and (B) significantly
invested in labor and capi_tal.” Mem. at 17. DTI does not dispute that Hyundai satisfies the
economic prong. DTI also does not dispute that Hyundai’s investments are significant, both
qualitatively and quantitatively. See Certain Carburetors and Products Containing Such
Carburetors, Inv. No. 337-TA-1123, Comm’n Op. at 17 (Oct. 28, 2019) (citing Certain Printing
& Imaging Devices & Components Thereofl Inv. No. 337-TA-690, Comm’n Op. at 27 (Feb. 17,
2011).) 	.
_ 5 _

1. - Significant Investment in Plant and Equipment
The evidence demonstrates that Hyundai has made significant investments in plant and
equipment to support manufacturing, service, and commercialization of the Domestic Industry
Products in the United States. For example, Hyundai Motor Manufacturing Alabama, LLC
(“HMMA”), awholly-owned subsidiary ofHMA,invested— tocreateadomestic
vehicle manufacturing plant in Montgomery, Alabama (the “HMMA Facility”). The HMMA
Facility isapproximately —, with approximately— dedicated
to storing the Domestic Industry Parts and using them in the manufacture of the Domestic Lndustry
Vehicles. SUMF at 1]23-24; SUMF Ex. 5 at 1[5. The HMMA facility is capable of manufacturing
up to - Domestic Industry Vehicles per year. SUMF at 111] 20-21; SUMF Ex. 5 at 1]3. From
2016 to Q2 2019, the HMMA Facility produced approximatelyI Domestic Industry
Vehicles. SUMF at 1|1]69-74; SUMF Ex. 5 at 111]43-48. HMMA utilizes machinery and other
equipment at the HMMA Facility for the manufacture of Domestic Industry Vehicles with
depreciatedassetvaluesfor the years2016,2017,2018,and 2019(estimated)of—
respectively. SUMF at 111152-53; SUMF EX. 5 at
112s.
HMAalso investedapproximately — to purchaseland for its corporate
headquarters in Fountain Valley, California (“Fountain Valley Headquarters”), and approximately
— in building and land improvements.SUMF at 1[1]30, 43; SUMFEx. 5 at 1l1[9, 20.
The Fountain Valley Headquarters administers and manages multiple activities relating to the
Domestic Industry Products in the United States, such as Warranty programs, parts and service
operations, customer “callcenters, and marketing and advertising. SUMF at 111]32-42; SUMF Ex.
5 at 111]9-19. In addition, Hyundai has invested significantly in its seven regional offices located
_6

across the United States, and in facilities located in California and Michigan for engineering and
R&D. SUMF at 111145-51; SUMF Ex. 5 at 111121-26 (detailing Hyundai’s investment of
approximately in domestic R&D facilities and per year for its re ional 8
office lease expenses). Hyundai utilizes office, computer, service, and demonstration equipment
at its Fountain Valley Headquarters and regional offices to support and manage activities directly
related to the Domestic Industry Products. SUMF at 1]55; SUMF Ex. at 1129. This equipment
hasdepreciatedassetvaluesfortheyears2016,2017,2018,and2019(estimated)of
respectively. SUMF at 1 54-55; SUMF Ex. 5 at
1 29. I
Given that the facilities and equipment described above are used in the manufacturing,
. /
“research and development, and operations for Hyundai’s Domestic Industry Products, the
undisputed facts demonstrate that Hyundai has satisfied the economic prong under 19 U.S.C. §
1337(a)(3)(A). , »
2. Significant Employment of Labor or Capital
The evidence shows that Hyundai has made significant investments in the employment of
labor and capital in connection with the manufacture, distribution, sales, marketing, advertising,
and service-related functions related to the Domestic Industry Products.
HMMAemployedan approximateaverageof-employees in Montgomery,Alabama
from2016throughthe firsthalfof 2019,withan averagepayrollof over— peryear.
SUMF at 1111 57-60; SUMF Ex. 5 at 111130-34. All HMMA employees work directly or indirectly
on the manufacture of Domestic Industry Vehicles, and are responsible for “sourcing component
parts, and operating HMMA’s stamping shop, welding facility, paint shop, general assembly
facility, and engine shops” at the HMMA Facility. SUMF at 1156; SUMF Ex. 5 at 1130.
_7_

HMA’s employees at its Fountain Valley Headquarters and regional offices are responsible
for “operations, marketing, customer service, parts distribution, dealer support, and facilitating
HMA’s warrantyyprograms for [the] Domestic Industry Vehicles and Domestic Industry Parts.”
SUMF at 1]'61;SUMF Ex. 5 at 1]35. From 2016 to June 2019, HMA employed an average of
employees at its Fountain Valley Headquarters, and an average of. employees at its regional
offices. SUMF at 1]1I61-65; SUMF Ex. 5 at 1|1I35-39. From 2016 to 2018, the average payroll for
HMA’s employees at its Fountain Valley Headquarters and its regional offices combined Was
approximately — peryear.Id.
The evidence also shows that Hyundai has made significant capital expenditures in the
United States associated with the Domestic Industry Products. In 2018, HMMA invested
- to build a facility at the HMMA Facility for manufacturingengine
components and enhancing existing operations for new models of Domestic Industry Vehicles.
SUMF at 1| 27; SUMF Ex. 5 at 116. This facility opened in May 2019. SUMF at 1127; Mot. Ex. 1
at 1]137. Additionally, Hyundai has expended significant capital under HMA’s vehicle warranty
program.SUMFat1]92; SUMFEx.5 at1165.From2016to 2018,Hyundaipaidover
per year to Hyundai dealers for repairs and services made imder HMA’s vehicle warranty program.
SUMF at 1192; SUMF ‘Ex.5 at 1165. And, through the first half of 2019, Hyundai has paid dealers
roughly_ in cormectionwithHMA’svehiclewarrantyprogram.SUMFat1]92;SUMF
Ex.5 at1]65.Roughly- oftheseexpensesareattributableto thecostofDomesticIndustry
Parts. Mot. Ex. 1 at111]81, 115. I .
Given the labor and capital expenditures described above, the undisputed facts demonstrate
that Hyundai has made significant investments towards labor and capital in the United States
_3_

related to the Domestic Industry Products that satisfy the economic prong under 19 U.S.C.
§ 1337(a)(3)(B).
IV. CONCLUSION 	, 	_ .
For the reasons discussed above, the undersigned finds that a summary determination thatQ
the domestic industry requirement is satisfied is appropriate. Accordingly, Hyundai’s rmopposed
motion (1 167-017) for summary determination that the domestic industry requirement is satisfied
is hereby granted. . . _.
Pursuant to 19 C.F.R. § 210.42(h), this Initial Determination shall be the determination of
the Commission unless a party files a petition for review of the Initial Determination pursuant to
19 C.F.R. § 2l0.43(a), or the Commission, pursuant to 19 C.F.R. § 210.44, orders, on its own
motion, a review of the Initial Determination or certain issues herein.
Within seven days of the date of this document, the parties shall submit to the Office of the
Administrative Law Judges a joint statement as to whether or not they seek to have any portion of
this document deleted from the public version. If the parties do seek to have portions of this
document deleted fi'om the public version, they mustsubmit to this office a copy of this document
with red brackets indicating the portion or portions asserted to contain confidential business
information. The submission may be made by email and/or hard copy by the aforementioned date
and need not be filed with the Commission Secretary. i
so ORDERED 	“
U 	@4471”harles E Bullock
Chief Administrative Law Judge ,
-9

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE 	Inv. No. 337-TA-1160
AND COLLISION PARTS AND COMPONENTS THEREOF
Certificate of Service —Page 1
I, Lisa R. Barton, hereby certify that the attached PUBLIC VERSION ORDER NO 26
has been sewed upon the following parties as indicated, on February 4, 2020.
"' 	V I 1.‘ 	..¢v@"'4:3“’?M 	,.
‘_/ " //_./'1 	" ~__‘.‘_‘_:.’-/"_ \ 	T‘
I "" /' 5;’ 111.,“ V./~s____,-L
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street SW, Room 112
. Washington, DC 20436
On Behalf of Complainants Hvundai Motor America,
Inc. and Hvundai Motor C0mpany_:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW V
Washington, DC 20036 	»
El Vi Hand Delivery
III/& ExpressDelivery
III Via First Class Mail
II] Other: I _
On Behalf of Respondent Direct Technologies
International, Inc. d/b/a DTI, Inc.:
Andrew R. Kopsidas
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Washington, DC 20024 I
C] Via Hand Delivery
Efia ExpressDelivery
El Via First Class Mail
El Other: A
)

30 printed pages contain little extracted OCR body text; searchable legal-body completeness has not been established for those pages.

OCR transcription for search; preserved printed pages are authoritative

In the Matter of

CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF

Investigation No. 337-TA-1160

Publication 5289 March 2022

U.S. International Trade Commission

| ;
| : ange
7 CTT

Washington, DC 20436

U.S. International Trade Commission
COMMISSIONERS
David S. Johanson, Chairman
Rhonda K. Schmidtlein, Commissioner
Jason E. Kearns, Commissioner
Randolph J. Stayin, Commissioner
Amy A. Karpel, Commissioner
Address all communications to
Secretary to the Commission
United States International Trade Commission
Washington, DC 20436

U.S. International Trade Commission
Washington, DC 20436
www.usitc.gov
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
Publication 5289 March2022

Hyundai complete service for any party/parties without a method of electronic service noted on
the attached Certificate of Service and shall file proof of service on the Electronic Document
Information System (EDIS).
The Commission vote for this determination took place on August 18, 2020.
The authority for the Commission’s determination is contained in Section 337 of the
Tariff Act of 1930, as amended (19 U.S.C. 1337), and in part 210 of the Commission’s Rules of
Practice and Procedure (19 CFR part 210).
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached NOTICE has been served on the
following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE
AND COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
Certificate of Service – Page 2
John Auto Spare Parts Co. LLC
Building 15 — Jafza 15
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
Cuong Anh co. Ltd.
Lot 5, Gian 'Chau Industrial Parks
Gia Tran village, Gia Vien District
Ninh Bing Province Viet Nam
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS AND
COMPONENTS THEREOF
Investigation No. 337-TA-1160
LIMITED EXCLUSION ORDER
The United States International Trade Commission (“Commission”) has determined that
there is a violation of Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. § 1337), in the
unlawful importation, sale for importation, and sale in the United States after importation of certain
replacement automotive service and collision parts and components thereof that infringe one or
more of U.S. Trademarks, Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195
(collectively, the “Asserted Trademarks”) by respondents AJ Auto Spare Parts FZE of Dubai,
United Arab Emirates; John Auto Spare Parts Co. LLC, of Dubai, United Arab Emirates; and
Cuong Anh Co. Ltd. of Ninh Binh Province, Vietnam (collectively “Defaulting Respondents”).
The Commission previously found the Defaulting Respondents in default pursuant to subsection
(g)(1) of section 337, 19 U.S.C. § 1337(g)(1), and section 210.16 of the Commission’s Rules of
Practice and Procedure, 19 C.F.R. § 210.16, for failing to respond to the Complaint and Notice of
Investigation.
Having reviewed the record of this investigation, including the written submissions of the
parties and the public, the Commission has made its determination on the issues of remedy, public
interest, and bonding. The Commission has determined that the appropriate form of relief is a
limited exclusion order prohibiting the unlicensed entry of certain replacement automotive service

and collision parts and components thereof that infringe one or more of the Asserted Trademarks
(“Covered Articles”) manufactured abroad or imported by or on behalf of Defaulting Respondents,
or any of their affiliated companies, parents, subsidiaries, or other related business entities, or their
successors or assigns, for consumption into the United States, consumption from a foreign trade
zone, or withdrawal from a warehouse for consumption, except under license of the trademark
owner or as provided by law.
The Commission has determined that the public interest factors enumerated in 19 U.S.C.
§ 1337(g)(1) do not preclude the issuance of the limited exclusion order, and that the bond during
the period of Presidential review shall be in the amount of one hundred (100) percent of the entered
value of the Covered Articles.
Accordingly, the Commission hereby ORDERS that:
1. Replacement automotive service and collision parts and components thereof that
infringe one or more of the Asserted Trademarks and that are manufactured abroad
or imported by or on behalf of the Defaulting Respondents, or any of their affiliated
companies, parents, subsidiaries, or other related business entities, or their
successors or assigns, are excluded from entry for consumption into the United
States, entry for consumption from a foreign trade zone, or withdrawal from a
warehouse for consumption, except under license of the trademark owner or as
provided by law, until such date as the Asserted Trademarks are abandoned,
canceled, or rendered invalid or unenforceable.
2. For the purpose of assisting U.S. Customs and Border Protection (“CBP”) in the
enforcement of this order, and without in any way limiting the scope of this Order,
the Commission has attached to this Order a copy of the relevant trademark

registrations as Exhibits 1-4.
3. Notwithstanding paragraph 1 of this Order, the Covered Articles are entitled to
entry into the United States for consumption, entry for consumption from a foreign-
trade zone, or withdrawal from a warehouse for consumption under bond in the
amount of one hundred (100) percent of the entered value of the Covered Articles,
pursuant to subsection (j) of Section 337 (19 U.S.C. § 1337(j)) and the Presidential
Memorandum for the United States Trade Representative of July 21, 2005 (70 Fed.
Reg. 43251), from the day after this Order is received by the United States Trade
Representative until such time as the United States Trade Representative notifies
the Commission that this Order is approved or disapproved but, in any event, not
later than sixty (60) days after the date of receipt of this Order. All entries of
Covered Articles made pursuant to this paragraph are to be reported to CBP, in
advance of the date of the entry, pursuant to procedures CBP establishes.
4. At the discretion of CBP and pursuant to the procedures it establishes, persons
seeking to import Covered Articles that are potentially subject to this Order may be
required to certify that they are familiar with the terms of this Order, that they have
made appropriate inquiry, and thereupon state that, to the best of their knowledge
and belief, the products being imported are not excluded from entry under
paragraph 1 of this Order. At its discretion, CBP may require persons who have
provided the certification described in this paragraph to furnish such records or
analyses as are necessary to substantiate the certification.
5. Complainants shall file a written statement with the Commission, made under oath,
each year on the anniversary of the issuance of this Order stating whether

Complainants continue to use each of the Asserted Trademarks in commerce in the
United States in connection with the products at issue and whether any of the
Asserted Trademarks have been abandoned, canceled, or rendered invalid or
unenforceable.
6. The Commission may modify this Order in accordance with the procedures
described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
7. The Commission Secretary shall serve copies of this Order upon each party of
record in this investigation and upon CBP. While temporary remote operating
procedures are in place in response to COVID-19, the Office of the Secretary is not
able to serve parties that have not retained counsel or otherwise provided a point of
contact for electronic service. Accordingly, pursuant to Commission Rules
201.16(a) and 210.7(a)(1) (19 C.F.R §§ 201.16(a), 210.7(a)(1)), the Commission
orders that the Complainant(s) complete service for any party/parties without a
method of electronic service noted on the attached Certificate of Service and shall
file proof of service on the Electronic Document Information System (EDIS).
8. Notice of this Order shall be published in the Federal Register.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent AJ Auto Spare Parts FZE of
Office/Warehouse No. RA08TC06, Jebel Ali Free Zone, Dubai, United Arab Emirates
(“Respondent”) cease and desist from conducting any of the following activities in the United
States, including via the internet: importing, selling, marketing, advertising, distributing,
transferring (except for exportation), soliciting United States agents or distributors, and aiding or
abetting other entities in the importation, sale for importation, sale after importation, transfer
(except for exportation), or distribution within the United States of certain replacement
automotive service and collision parts and components thereof that infringe one or more of U.S.
Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the
“Asserted Trademarks”) in violation of Section 337 of the Tariff Act of 1930, as amended (19
U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) “Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.

3
assigns, and to each of them, insofar as they are engaging in conduct prohibited by section III,
infra, for, with, or otherwise on behalf of Respondent.
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order. While the
Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) import, sell for importation, or sell after importation into the United States
covered products;
(B) market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) advertise imported covered products;
(D) solicit U.S. agents or distributors for imported covered products; or
(E) aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this

4
section shall cover the period from the date of issuance of this Order through December 31,
2020. This reporting requirement shall continue in force until such time as Respondent has
truthfully reported, in two consecutive timely filed reports, that it has no inventory of covered
products in the United States.
Within thirty (30) days of the last day of the reporting period, Respondent shall report to
the Commission: (a) the quantity in units and the value in dollars of covered products that it has
(i) imported and/or (ii) sold in the United States after importation during the reporting period,
and (b) the quantity in units and value in dollars of reported covered products that remain in
inventory in the United States at the end of the reporting period.
When filing written submissions, Respondent must file the original document
electronically on or before the deadlines stated above and submit eight (8) true paper copies to
the Office of the Secretary by noon the next day pursuant to Section 210.4(f) of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.4(f)). Submissions should refer
to the investigation number (“Inv. No. 337-TA-1160”) in a prominent place on the cover pages
and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000. If Respondent desires to submit
a document to the Commission in confidence, it must file the original and a public version of the
original with the Office of the Secretary and must serve a copy of the confidential version on
Complainants’ counsel.1
1 Complainants must file a letter with the Secretary identifying the attorney to receive reports and
bond information associated with this Order. The designated attorney must be on the protective
order entered in the investigation.

6
VII.
Service of Cease and Desist Order
The Secretary shall serve copies of this Order upon each party of record in this
investigation that has retained counsel or otherwise provided a point of contact for electronic
service and upon CBP. While temporary remote operating procedures are in place in response to
COVID-19, the Office of the Secretary is not able to serve parties that have not retained counsel
or otherwise provided a point of contact for electronic service. Accordingly, pursuant to
Commission Rules 201.16(a) and 210.7(a)(1) (19 C.F.R. §§ 201.16(a), 210.7(a)(1)), the
Commission orders that the Complainant complete service of this Order for any party without a
method of electronic service noted on the attached Certificate of Service and shall file proof of
service on the Electronic Document Information System (EDIS).
Respondent is ordered and directed to:
(A) Serve, within fifteen (15) days after the effective date of this Order, a copy of this
Order upon each of its respective officers, directors, managing agents, agents, and
employees who have any responsibility for the importation, marketing,
distribution, or sale of imported covered products in the United States;
(B) Serve, within fifteen (15) days after the succession of any persons referred to in
subparagraph VII(A) of this Order, a copy of the Order upon each successor; and
(C) Maintain such records as will show the name, title, and address of each person
upon whom the Order has been served, as described in subparagraphs VII(A) and
VII(B) of this Order, together with the date on which service was made.
The obligations set forth in subparagraphs VII(B) and VII(C) shall remain in effect
indefinitely, unless the Asserted Trademarks are held invalid and unenforceable.

7
VIII.
Confidentiality
Any request for confidential treatment of information obtained by the Commission
pursuant to Sections V and VI of this Order should be made in accordance with Section 201.6 of
the Commission’s Rules of Practice and Procedure (19 C.F.R. § 201.6). For all reports for which
confidential treatment is sought, Respondent must provide a public version of such report with
confidential information redacted.
IX.
Enforcement
Violation of this Order may result in any of the actions specified in Section 210.75 of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.75), including an action for
civil penalties under Section 337(f) of the Tariff Act of 1930 (19 U.S.C. § 1337(f)), as well as
any other action that the Commission deems appropriate. In determining whether Respondent is
in violation of this Order, the Commission may infer facts adverse to Respondent if it fails to
provide adequate or timely information.
X.
Modification
The Commission may amend this Order on its own motion or in accordance with the
procedure described in Section 210.76 of the Commission’s Rules of Practice and Procedure
(19 C.F.R. § 210.76).
XI.
Bonding
The conduct prohibited by Section III of this Order may be continued during the sixty
(60) period in which this Order is under review by the United States Trade Representative, as

9
not disapproved, or no action is taken) by the United States Trade Representative, upon service
on Respondent of an order issued by the Commission based upon application therefore made by
Respondent to the Commission.
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: August 18, 2020

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent Cuong Anh Co. Ltd. of Lot 5, Gian
Khau Industrial Parks, Gia Tran Village, Gia Vien District, Ninh Binh Province, Vietnam
(“Respondent”) cease and desist from conducting any of the following activities in the United
States, including via the internet: importing, selling, marketing, advertising, distributing,
transferring (except for exportation), soliciting United States agents or distributors, and aiding or
abetting other entities in the importation, sale for importation, sale after importation, transfer
(except for exportation), or distribution within the United States of certain replacement
automotive service and collision parts and components thereof that infringe one or more of U.S.
Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the
“Asserted Trademarks”) in violation of Section 337 of the Tariff Act of 1930, as amended (19
U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) “Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.

2
(B) “Commission” shall mean the United States International Trade Commission.
(C) “Complainants” shall mean Hyundai Motor Company of 231 YangJae-Dong,
Seocho-gu Seoul 137-938, Republic of Korea and Hyundai Motor America, Inc.
of 10550 Talbert Avenue, Fountain Valley, CA 92708.
(D) “Respondent” shall mean Cuong Anh Co. Ltd. of Lot 5, Gian Khau Industrial
Parks, Gia Tran Village, Gia Vien District, Ninh Binh Province, Vietnam .
(E) “Person” shall mean an individual, or any non-governmental partnership, firm,
association, corporation, or other legal or business entity other than Respondent or
its majority-owned or controlled subsidiaries, successors, or assigns.
(F) “United States” shall mean the fifty States, the District of Columbia, and Puerto
Rico.
(G) The terms “import” and “importation” refer to importation for entry for
consumption under the Customs laws of the United States.
(H) The term “covered products” shall mean replacement automotive service and
collision parts and components thereof that infringe one or more of the Asserted
Trademarks. Covered products shall not include articles for which a provision of
law or license avoids liability for infringement.
II.
Applicability
The provisions of this Cease and Desist Order shall apply to Respondent and to any of its
principals, stockholders, officers, directors, employees, agents, licensees, distributors, controlled
(whether by stock ownership or otherwise) and majority-owned business entities, successors, and

3
assigns, and to each of them, insofar as they are engaging in conduct prohibited by section III,
infra, for, with, or otherwise on behalf of Respondent.
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order.
While the Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) import, sell for importation, or sell after importation into the United States
covered products;
(B) market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) advertise imported covered products;
(D) solicit U.S. agents or distributors for imported covered products; or
(E) aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, D.C.
In the In the Matter of
CERTAIN REPLACEMENT AUTOMOTIVE
SERVICE AND COLLISION PARTS
AND COMPONENTS THEREOF
Investigation No. 337-TA-1160
CEASE AND DESIST ORDER
IT IS HEREBY ORDERED THAT Respondent John Auto Spare Parts Co. LLC, of
Building 15 – Jafza 15, Dubai, United Arab Emirates (“Respondent”) cease and desist from
conducting any of the following activities in the United States, including via the internet:
importing, selling, marketing, advertising, distributing, transferring (except for exportation),
soliciting United States agents or distributors, and aiding or abetting other entities in the
importation, sale for importation, sale after importation, transfer (except for exportation), or
distribution within the United States of certain replacement automotive service and collision
parts and components thereof that infringe one or more of U.S. Trademark Registration Nos.
1,104,727; 3,991,863; 1,569,538; and 4,065,195 (collectively, the “Asserted Trademarks”) in
violation of Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. § 1337).
I.
Definitions
As used in this Order:
(A) “Asserted Trademarks” shall mean U.S. Trademark Registration Nos. 1,104,727;
3,991,863; 1,569,538; and 4,065,195.
(B) “Commission” shall mean the United States International Trade Commission.

3
III.
Conduct Prohibited
The following conduct of Respondent in the United States is prohibited by this Order.
While the Asserted Trademarks remain valid and enforceable, Respondent shall not:
(A) import, sell for importation, or sell after importation into the United States
covered products;
(B) market, distribute, offer for sale, or otherwise transfer (except for exportation), in
the United States imported covered products;
(C) advertise imported covered products;
(D) solicit U.S. agents or distributors for imported covered products; or
(E) aid or abet other entities in the importation, sale for importation, sale after
importation, transfer, or distribution of covered products.
IV.
Conduct Permitted
Notwithstanding any other provision of this Order, specific conduct otherwise prohibited
by the terms of this Order shall be permitted if in a written instrument, the owner of the Asserted
Trademarks licenses or authorizes such specific conduct.
V.
Reporting
For purposes of this requirement, the reporting periods shall commence on January 1 of
each year and shall end on the subsequent December 31. The first report required under this
section shall cover the period from the date of issuance of this Order through December 31,
2020. This reporting requirement shall continue in force until such time as Respondent has

4
truthfully reported, in two consecutive timely filed reports, that it has no inventory of covered
products in the United States.
Within thirty (30) days of the last day of the reporting period, Respondent shall report to
the Commission: (a) the quantity in units and the value in dollars of covered products that it has
(i) imported and/or (ii) sold in the United States after importation during the reporting period,
and (b) the quantity in units and value in dollars of reported covered products that remain in
inventory in the United States at the end of the reporting period.
When filing written submissions, Respondent must file the original document
electronically on or before the deadlines stated above and submit eight (8) true paper copies to
the Office of the Secretary by noon the next day pursuant to Section 210.4(f) of the
Commission’s Rules of Practice and Procedure (19 C.F.R. § 210.4(f)). Submissions should refer
to the investigation number (“Inv. No. 337-TA-1160”) in a prominent place on the cover pages
and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000. If Respondent desires to submit
a document to the Commission in confidence, it must file the original and a public version of the
original with the Office of the Secretary and must serve a copy of the confidential version on
Complainants’ counsel.1
Persons filing written submissions must file the original document electronically on or
before the deadlines stated above. The Commission’s paper filing requirements in 19 C.F.R.
1 Complainants must file a letter with the Secretary identifying the attorney to receive reports and
bond information associated with this Order. The designated attorney must be on the protective
order entered in the investigation.

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND
COLLISION PARTS AND COMPONENTS THEREOF
Inv. No. 337-TA-1160
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached Order, Commission has been served
on the following parties as indicated, on 8/18/2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America, Inc.
and Hyundai Motor Company:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
Email: kecia.reynolds@pillsburylaw.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification of
Availability for Download
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
Email: kopsidas@fr.com
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Email Notification
of Availability for Download
Respondents:
AJ Auto Spare Parts FZE
Office/Warehouse No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants
AJ Auto Spare Parts FZE
Office/Warehous No. RAO8TC06
Jebel Ali Free Zone
Dubai, United Arab Emirates
☐ Via Hand Delivery
☐ Via Express Delivery
☐ Via First Class Mail
☒ Other: Service to Be
Completed By Complainants

2
19 U.S.C. 1337, as amended (“Section 337”), in the importation, sale for importation, or sale in
the United States after importation of certain gray market Hyundai parts in the categories of
belts, body exterior and interior parts, brakes, wheel hubs, cooling system parts, drivetrain parts,
electrical parts, emission parts, engine parts, exhaust parts, fuel/air pumps, oil/air/cabin air filters
and parts, heat and A/C parts, ignition parts, steering parts, suspension parts, transmission parts,
wheels and parts, wiper and washer parts, and accessories that infringe one or more of Hyundai’s
U.S. Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195. Id. at 26704.
The complaint further alleges that a domestic industry exists in the United States. Id.
The Commission’s notice of investigation named Direct Technologies International, Inc.
(“DTI”) of North Miami Beach, Florida; AJ Auto Spare Parts FZE (“AJ Auto”) and John Auto
Spare Parts Co. LLC (“John Auto”), both of Dubai, United Arab Emirates; and Cuong Anh Co.
Ltd. (“Cuong Anh”) of Ninh Binh Province, Vietnam as respondents. The Office of Unfair
Import Investigations was not named as a party to this investigation.
On November 25, 2019, the Commission determined not to review an initial
determination (Order No. 17) granting Hyundai’s unopposed motion to find respondents AJ
Auto, John Auto, and Cuong Anh (collectively, the “Defaulting Respondents”) in default. Order
No. 17 (Nov. 5, 2019), not rev’d, Comm’n Notice (Nov. 25, 2019).
On January 24, 2020, Hyundai filed a declaration seeking immediate entry of a limited
exclusion order against the Defaulting Respondents and any of their affiliated companies,
parents, subsidiaries, and related business entities, successors or assigns.
On March 5, 2020, the presiding administrative law judge (“ALJ”) issued an initial
determination (Order No. 36) granting a joint motion by Hyundai and DTI to terminate the
investigation as to DTI on the basis of a consent order. The ALJ found that the consent order
stipulation and proposed consent order complied with Commission Rule 210.21(c)(3) and (4)
(19 CFR 210.21(c)(3) and (4)). The ALJ also found that termination of this investigation does
not impose any undue burdens on the public health and welfare, competitive conditions in the
United States economy, production of like or directly competitive articles in the United States, or
United States consumers. No petitions for review of the ID were received.
The Commission has determined not to review the subject ID and has determined to issue
a consent order. The Commission has further determined that Hyundai’s declaration is now
moot given the termination of DTI, the final remaining respondent in this investigation. Finally,
the Commission has determined to request briefing on the issues of remedy, bonding, and the
public interest.
Section 337(g)(1) (19 U.S.C. 1337(g)(1)) and Commission Rule 210.16(c) (19 CFR
210.16(c)) authorize the Commission, upon request, to issue a limited exclusion order or a cease
and desist order or both against a respondent found in default, unless after consideration of the
public interest factors in Section 337(g)(1), it finds that such relief should not issue.
Accordingly, in connection with the final disposition of this investigation, the Commission is
interested in receiving written submissions that address the form of remedy, if any, that should
be ordered with respect to the Defaulting Respondents, identified above. If a party seeks
exclusion of an article from entry into the United States for purposes other than entry for

3
consumption, the party should so indicate and provide information establishing that activities
involving other types of entry either are adversely affecting it or likely to do so. For background,
see Certain Devices for Connecting Computers via Telephone Lines, Inv. No. 337-TA-360,
USITC Pub. No. 2843, Comm’n Op. at 7-10 (December 1994).
The statute requires the Commission to consider the effects of that remedy upon the
public interest. The public interest factors the Commission will consider include the effect that
an exclusion order and/or cease and desist orders would have on (1) the public health and
welfare, (2) competitive conditions in the U.S. economy, (3) U.S. production of articles that are
like or directly competitive with those that are subject to investigation, and (4) U.S. consumers.
The Commission is therefore interested in receiving written submissions that address the
aforementioned public interest factors in the context of this investigation.
If the Commission orders some form of remedy, the U.S. Trade Representative, as
delegated by the President, has 60 days to approve, disapprove, or take no action on the
Commission’s action. See Presidential Memorandum of July 21, 2005, 70 FR 43251 (July 26,
2005). During this period, the subject articles would be entitled to enter the United States under
bond, in an amount determined by the Commission and prescribed by the Secretary of the
Treasury. The Commission is therefore interested in receiving submissions concerning the
amount of the bond that should be imposed if a remedy is ordered.
Written Submissions: Complainants, interested government agencies, and any other
interested persons are encouraged to file written submissions on the issues of remedy, the public
interest, and bonding.
In their initial submission, complainants are requested to identify the form of the remedy
sought and to submit proposed remedial orders for the Commission’s consideration.
Complainants are also requested to state the date that the asserted patents expire, the HTSUS
subheadings under which the products at issue are imported, and to supply the identification
information for all known importers of the products at issue in this investigation. Initial written
submissions regarding remedy, bonding, and the public interest and proposed remedial orders
must be filed no later than close of business on April 9, 2020. Reply submissions must be filed
no later than the close of business on April 16, 2020. No further submissions on these issues
will be permitted unless otherwise ordered by the Commission.
Persons filing written submissions must file the original document electronically on or
before the deadlines stated above. The Commission’s paper filing requirements are currently
waived. Submissions should refer to the investigation number (“Inv. No. 337-TA-1160”) in a
prominent place on the cover page and/or the first page. (See Handbook on Filing Procedures,
https://www.usitc.gov/documents/handbook_on_filing_procedures.pdf). Persons with questions
regarding filing should contact the Secretary at (202) 205-2000.
Any person desiring to submit a document to the Commission in confidence must request
confidential treatment unless the information has already been granted such treatment during the
proceedings. All such requests should be directed to the Secretary of the Commission and must
include a full statement of the reasons why the Commission should grant such treatment. See 19
CFR 210.6. Documents for which confidential treatment by the Commission is sought will be

4
treated accordingly. A redacted non-confidential version of the document must also be filed
simultaneously with any confidential filing. All information, including confidential business
information and documents for which confidential treatment is properly sought, submitted to the
Commission for purposes of this Investigation may be disclosed to and used: (i) By the
Commission, its employees and Offices, and contract personnel (a) for developing or
maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission
including under 5 U.S.C. Appendix 3; or (ii) by U.S. government employees and contract
personnel1 solely for cybersecurity purposes. All non-confidential written submissions will be
available for public inspection at the Office of the Secretary and on EDIS.
The authority for the Commission’s determination is contained in Section 337 of the
Tariff Act of 1930, as amended (19 U.S.C. 1337), and in part 210 of the Commission’s Rules of
Practice and Procedure (19 CFR part 210).
By order of the Commission.
Lisa R. Barton
Secretary to the Commission
Issued: March 26, 2020
1 All contract personnel will sign appropriate nondisclosure agreements.

UNITED STATES INTERNATIONAL TRADE COMMISSION
I' Washington, D.C.
In the Matter of ‘
CERTAIN REPLACEMENT
AUTOMOTIVE SERVICE AND Inv. No. 337-TA-1160
COLLISION PARTS AND COMPONENTS
THEREOF
ORDER NO. 36: INITIAL DETERMINATION GRANTING JOINT MOTION TO
TERMINATE RESPONDENT DIRECT TECHNOLOGIES
INTERNATIONAL, INC. BASED ON CONSENT ORDER;
TERMINATING THE INVESTIGATION IN ITS ENTIRETY
_ (March 5, 2020)
On February 20, 2020, Complainants Hyundai Motor Company and Hyundai Motor
America, Inc. (collectively, “Hyundai”) and Respondent Direct Technologies Intemational, Inc.
(“DTI”) filed a joint motion (1160-O31)to tenninate this Investigation based on a consent order
l
stipulation and a proposed consent order.
In accordance with Connnission Rule 210.21(c)(l)(ii), Hyundai and DTI have entered into
a “Consent Order Stipulation” and a proposed “Consent Order,” attached hereto as Attachments A
and B. Hyundai and DTI submit that all agreements between them conceming the subject matter
of this Investigation are attached as confidential exhibits to their motion. Mem. at 6-7. Consistent
with 19 C.F.R. § 21O.2l(c), they confirm that “[t]here are no other agreements, written or oral,
express or implied, . . . conceming the subject matter of this Investigation.” Id. at 7.
Commission Rule 210.2 l(c)(3) sets forth certain requirements for the contents of a consent
order stipulation. See 19 C.F.R. § 210.2l(c)(3). The Consent Order Stipulation submitted by the
parties complies with the requirements of Commission Rule 2l0.21(c)(3). See Attachment A.
‘ DTI is the only remaining respondent in this Investigation. The other named respondents have been found in default.

Specifically, DTI agrees that upon entry of the Consent Order:
DTI . . . will not sell for importation, import into the United States, sell after
importation, distribute, or otherwise transfer (other than exportation) the
Accused Parts that infringe the Asserted Trademarks in the United States,
directly or indirectly, and shall not aid, abet, encourage, participate in, or
induce the sale for importation, the importation, the sale after importation,
distribution, or otherwise transfer the Accused Parts, except under consent,
license from Complainants, or to the extent permitted by a settlement
agreement between Hyundai and DTI.‘
Consent Order Stip. 1l3. Pursuant to Commission Rule 210.21(c)(3)(i), DTI also agrees to
(1) admit that the Commission has in rem jurisdiction over the subject
matter of this Investigation, and in personam jurisdiction over
Respondents (see Consent Order Stip. 1i1);
(2) ‘ expressly waive all rights to seek judicial review or otherwise
challenge or contest the validity of the Consent Order (id at fil5);
(3) cooperate with and not seek to impede by litigation or other means
. the Cornmission’s efforts to gather information under Subpart I of
the C0mmission’s Rules of Practice and Procedure (id. at 1[6); and
(4') the enforcement, modification, or revocation of the Consent Order
being carried out pursuant to Subpart I of Part 210 of 19 C.F.R. §
210 (id. at {I7).
Because this is an intellectual property-based investigation and in accordance with
Commission Rule 2lO.2l(c)(3)(ii), the Consent Order Stipulation also states thatz.
(1) the Consent Order shall not apply with respect to any claims of any
intellectual property right that has expired or been foimd or
adjudicated invalid or unenforceable by the Commission or a comt
or agency of competent jurisdiction, provided that such finding or
judgment has become final and non-reviewable (id. at 1i9); and
(2) DTI (including DTI’s officers, directors, employees, agents, or any
entity or individual acting on DTI’s behalf and with DTl’s authority)
will not seek to challenge the validity of the intellectual property
rights of the Asserted Trademarks in any administrative or judicial
proceeding to enforce the Consent Order (id. at 1]10).
-2

Additionally, Commission Rule 2l0.2l(c)(4) sets forth certain requirements for the
contents of the consent order. See 19 C.F.R. § 2l0.2l(c)(4). The Consent Order submitted by the
parties complies with the requirements of Commission Rule 2l0.2l(c)(4). See Attachment B.
V In any initial determination tenninating an investigation by settlement agreement or
consent order, the administrative law judge is directed to consider and make appropriate findings
regarding the effect of the proposed settlement on the public health and welfare, competitive
conditions in the United States economy, production of like or directly competitive articles in the
United States, and United States consumers. 19 C.F.R. § 2l0.50(b)(2). Hyundai and DTI assert
that granting the joint motion is “in the public interest as it conserves judicial and private party
resources.” Mem. at 9. The undersigned finds that tennination of this Investigation does not impose
any undue burdens on the public health and welfare, competitive conditions in the United States
economy, production of like or directly competitive articles in the United States, or United States
consumers.
Accordingly, for good cause shown, it is the undersigned’s Initial Determination that the
joint motion (1160-031) to terminate this Investigation in its entirety based on a consent order
stipulation and proposed consent order be granted. '
This Initial Determination, along with supporting “documentation,is hereby certified to the
Commission. Pursuant to 19 C.F.R. § 2lO.42(h), this Initial Determination shall become the
determination of the Commission Lmless a party files a petition for review of the Initial
Determination pursuant to l9 C.F.R. § 2l0.43(a), or the Commission;pursuant to 19 C.F.R. §
210.44, orders, on its own motion, a review of the Initial Determination or.certain issues, herein.
éarles Bullock /
Chief Administrative Law Judge
_ 3 _ _
SO ORDERED. ’

PUBLIC VERSION
ATTACHMENT A

PUBLIC VERSION
DTI with Accused Parts;
WHEREAS, DTI has commercially significant inventory of Accused Parts in the United
States;
WHEREAS, Respondents AJ Auto, Cuong Anh, and John Auto have defaulted;
WHEREAS, DTI enters into this Consent Order Stipulation and agrees to entry of a
Consent Order from the Commission to settle this dispute with Hyundai and terminate this
'~
Investigation as to DTI; _
WHEREAS, DTI agrees to the entry of a Consent Order by the Commission in the form
attached hereto as Attachment B in order to terminate this Investigation as to DTI;
NOW THEREFORE, pursuant to Commission Rule 2l0.21(c)(l)(ii) and (c)(3) (19
CA.F.R.§ 2l0.21(c)(l)(ii) and (c)(3)), DTI stipulates and agrees as follows:
" l. The Commission has in rem jurisdiction over the Accused Parts that are the basis of this
Investigation, subject matterjurisdiction over this Investigation, and personal jurisdiction over
DTI for purposes of this Consent Order.
2. Complainants allege that DTI imports and sells the Accused Parts and that infringe the
Asserted Trademarks. - t
3. Upon entry of the Consent Order, DTI (including DTI’s officers, directors, employees,
agents, or any entity or individual acting on DTI’s behalf and with DTI’s authority) will not sell
for importation, import into the United States, sell afier importation, distribute, or otherwise
transfer (other than exportation) the Accused Parts that infringe the Asserted Trademarks in the
United States, directly or indirectly, and shall not aid, abet, encourage, participate in, or induce
the sale for importation, the importation, the_sale after importation, distribution, or otherwise
transfer the Accused Parts , except under consent, license from Complainants, or to the extent

PUBLIC VERSION
infringe the Asserted Trademark in a final decision, no longer subject to appeal, this Consent
Order shall become null and void as to such expired, invalid, or unenforceable trademark or as o
any adjudicated article. ,
10. DTI (including DTI’s officers, directors, employees, agents, or any entity or individual
acting on DTI’s behalf and with DTI’s authority) will not seek to challenge the validity of the
intellectual property rights of the Asserted Trademarks in any administrative or judicial
proceeding to enforce the Consent Order.
Attested to and signed on thisl day of February, 2020 in Miami Gardens. Florida ,
USA. V
Dmitriy Yur enko
On behalf of Respondent Direct
TechnologiesInternational, Inc. d/b/a
DTI Inc.

PUBLIC VERSION
ATTACHMENT B
1
1

PUBLIC VERSION
1
UNITED STATES INTERNATIONAL TRADE COMMISSION
Washington, DC
Before the Honorable Charles E. Bullock
Chief Administrative Law Judge
In the Matter of
ga%g‘;%%'3;L€‘§§%gg;ND InvestigationNo. 337-TA-1160
COLLISION PARTS AND COMPONENTS
THEREOF
[PROPOSED] CONSENT ORDER
The U.S. International Trade Commission (“Commission”) has instituted an investigation
at the request of Complainants Hyundai Motor Company and Hyundai Motor America, Inc.
(collectively “Hyundai” or “Complainants”) against Respondent Direct Teclmologies
International, Inc. d/b/a DTI, Inc. (“DTI” or “Rcspondent”). The Complaint, as supplemented,
alleges violations of 19 U.S.C. § 1337 based upon the sale for importation into the United States,
importation into the United States, and/or sale after importation into the United States of
Hyundai-branded replacement automotive service and collision parts and components thereof
(“Accused Parts”) that infringement U.S. Trademark Reg. Nos. l 104727, 3991863, 1569538, and
4065195 (“Asserted Trademarks”). The Commission instituted this investigation on June 3,
2019, and the Notice of Institution was published in the Federal Register on June 7, 2019. 84
Fed. Reg. 26703. i
DTI has executed a Consent Order Stipulation and moved with Complainants for an
Initial Determination terminating this investigation by entry of a Consent Order.
Upon entry of the Consent Order, DTI (including DTI’s officers, directors, employees,

PUBLIC VERSION
agents, or any entity or individual acting on DTI’s behalf and with DTI’s authority) shall not
directly or indirectly sell for importation, import into the United States, sell after importation,
distribute, or otherwise transfer the Accused Parts that infringe the Asserted Trademarks, except
under consent, license from Complainants, or to the extent permitted by a settlement agreement
between Hyundai and DTI. DTI (including DTI’s officers, directors, employees, agents, or any
entity or individual acting on DTI’s behalf and with DTI’s authority) shall not aid, abet,
encourage, participate in, or induce the sale fof importation, the importation, the sale after
importation, distribution, or otherwise transfer the Accused Parts except under consent, license
from Complainants, or to the extent permitted by a settlement agreement between Hyundai and
DTI.
DTI stipulates that it has commercially significant. inventory of the Accused Parts in the
United States. DTI (including DTI’s officers, directors, employees, agents, or any entity or
individual acting on DTI’s behalf and with DTI’s authority) shall cease and desist from
importing and distributing the Accused Parts, except under consent, license from Complainants,
or to the extent permitted by a settlement agreement between Hyundai and DTI.
' DTI (including DTI’s officers, directors, employees, agents, or any entity or individual
acting on DTI’s behalf and with DTI’s authority) shall be precluded from seekingjudicial review
or otherwise challenging or contesting the validity of the Consent Order.
DTI shall cooperate with and shall not seek to impede by litigation or other means the
Commission’s efforts to gather information under subpart Iiof the Comrnission’s Rules of
Practice and Procedure, 19 C.li .R. Part 210. ii
DTI and its officers, directors, employees, agents, and any entity or individual acting on
its behalf and with its authority shall not seek to challenge the validity or enforceability of the
l

PUBLIC VERSION
Asserted Trademarks in any administrative or judicial proceeding to enforce the Consent Order.
When an Asserted Trademark expires the Consent Order shall become null and void as to
such trademark. If any trademark is held invalid or unenforceable by a court or agency of
competent jurisdiction or as to any article has been found or adjudicated not to infringe the
Asserted Trademarks in a final decision, no longer subject to appeal, this Consent Order shall
become null and void as to such invalid or unenforceable claim. '
All jurisdictional facts are admitted by stipulation. The Commission has in rem
jurisdiction and personal jurisdiction.
This investigation is hereby terminated with respect to DTI; provided, however, that
enforcement, modification, or revocation of the Consent Order shall be carried out pursuant to
Subpartl of the Commission's Rules of Practice and Procedure, 19 CPR part 210.
This motion is hereby GRANTED and it is SO ORDERED on this __ day of
, 2020.
Charles E. Bullock
Chief Administrative Law Judge
J

PUBLIC VERSION
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SETTLEMENT TERM SHEET

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CERTAIN REPLACEMENT AUTOMOTIVE SERVICE Inv. N0. 337-TA-1160
AND COLLISION PARTS AND COMPONENTS THEREOF ' .
Certifieate of Serviee —Page 1 ,
»
I, Lisa R.-Barton, hereby certify that the attached ORDER NO. 36 has been served upon
the following parties as indicated, on March 5, 2020.
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hvundai Motor America,
Inc. and Hvundai Motor Compang l
Kecia Reynolds, Esq.
1200 Seventeenth Street, NW - '
Washington, DC 20036
PILLSBURY WINTI-IROP SHAW PITTMAN LLP U Via Hand Delivery x
fiVia ExpressDelivery
U Via First Class Mail
III Other:
On Behalf of Respondent Direct Technologies
International, Inc. d/b/a DTI. Inc.:
Andrew R. Kopsidas
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Washington, DC 20024
El Via Hand Delivery
iVia ExpressDelivery
El Via First Class Mail V
III Other:

U.S. Trademark Registration Nos. 1,104,727; 3,991,863; 1,569,538; and 4,065,195. Id. at 26704.
The complaint further alleges that a domestic industry exists in the United States. Id.
The Commission’s notice of investigation named Direct Technologies Intemational, Inc.
(“DTI”) of North Miami Beach, Florida; AJ Auto Spare Parts FZE (“AJ Auto”) and John Auto
Spare Parts Co. (“John Auto”) of Dubai, United Arab Emirates; and Cuong Anh Co. (“Cuong
Anh”) ofNinh Binh Province, Vietnam as respondents. The Office of Unfair Import
Investigations was not named as a party to this investigation.
On November 25, 2019, the Commission determined not to review an ID (Order No. 17)
granting Hyundai’s unopposed motion to find respondents AJ Auto, John Auto, and Cuong Anh
in default. Order No. 17 (Nov. 5, 2019), not rev ’d, Cornrn’n Notice (Nov. 25, 2019). As a
result, DTI is presently the only respondent still active in this investigation.
On January 16, 2020, the presiding administrative law judge entered the subject ID
(Order No. 26), pursuant to Commission Rule 210.18 (19 CFR 210.18), granting Hyundai’s
Lmopposedmotion for summary determination that it satisfies both the technical and economic
prongs of Section 337’s domestic industry requirement. DTI did not oppose Hyundai’s motion
or file a petition for review of the subject ID.
The Commission has determined not to review the subject ID. The authority for the
Commission’s detennination is contained in Section 337 of the Tariff Act of 1930, as amended
(19 U.S.C. 1337), and in part 210 of the Commission’s Rules of Practice and Procedure (19 CFR
part 210). \
p Lisa R. Barton
Secretary to the Commission
Issued: February 18, 2020
By order of the Commission.

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE AND Inv. No. 337-TA-1160
COLLISION PARTS AND COMPONENTS THEREOF
PUBLIC CERTIFICATE OF SERVICE
I, Lisa R. Barton, hereby certify that the attached NOTICE has been served on the
following parties as indicated, on 2/18/2020.
Lisa Barton, Secretary
U.S. International Trade Commission
500 E Street, SW, Room 112
Washington, DC 20436
On Behalf of Complainants Hyundai Motor America. Inc.
and Hyundai Motor Company_:
Kecia Reynolds, Esq.
PILLSBURY VVINTHROPSHAW PITTMAN LLP
1200 Seventeenth Street, NW
Washington, DC 20036
El Via Hand Delivery
El Via Express Delivery
IZIVia First Class Mail
El Other:
On Behalf of Respondents Direct Technologies International,
Inc. d/b/a DTI, Inc.
Andrew R. Kopsidas Esq.
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Suite 1000
Washington, DC 20024
El Via Hand Delivery
III Via Express Delivery
Via\First Class Mail
III Other:

UNITED STATES INTERNATIONAL TRADE COMMISSION
1 . Washington, D.C.
In the Matter of '
CERTAIN REPLACEMENT _
- AUTOMOTIVE SERVICE AND . , Inv- N0- 337—TA-1160
COLLISION PARTS AND COMPONENTS ' *
THEREOF - A
_ ORDER NO.26: .INITIAL DETERMINATION GRANTING COMPLAINANTS’
_ ' UNOPPOSED MOTION FOR SUMMARY DETERMINATION
THAT THE DOMESTIC INDUSTRY REQUIREMENT IS
SATISFIED ‘ ‘ Y ‘
. (January 16, 2020)
On December 3, 20,19, Complainants Hyundai Motor Company (“HMC”) and Hyundai
Motor America, Inc. (“HMA”) (collectively, “Hyundai”) filed a motion (1 160-017) for summary
determination that the technical and economic prongs of the domestic industry requirement are
satisfied. Respondent Direct Technologies International, Inc. (“DTI”) does not oppose the motion.
Mot. at 3. . ‘
I. ~ ‘BACKGROUND
A. Asserted Trademarks‘ " »
_ Hyundai is asserting the following trademarks against DTI in this Investigation:
U.S. 'l"rndexnark _ '
‘ Re-;lstn'atlo||N0s. Reglstn-ailunDnfie Design ,
1104727 October 24, 1978 _
HYI-IIIDRI
l569538 'Dccen|be1‘5, I989 ' '
I *§§91s6§::7 I E OT July’l§. 2011 7 E I I J A I-lYl.|fIDfll\ I
4065195 December6,2011 ®
L__._n_________At_

1. _ Technical Prong_ . f
The technical prong of the domestic industry requirement is satisfied when the complainant
establishes that the articles relating to the domestic industry are protected by the intellectual
property at issue in the investigation. See Certain Personal Transporters, Components Thereof
and Packaging and Manuals Therefor, Inv. No. 337-TA-1007, Order No. 32 (Initial
Determination) at 2-3 (Apr. 6, 2017), a]j"d, Commission Decision Not to Review an Initial
Determination Granting Complainants’ Motion for Summary Determination on the Technical
Prong of the Domestic Industry Requirement (May 14, 2010). Where registered trademark rights
are asserted, “[t]he test for determining whether the technical prong is met through the practice of
a trademark is plain use of the trademark on products and packaging.” Certain Protective Cases
and Components Thereof, Inv. No. 337-TA-780, Initial Determination at 90 (June 29, 2012).
. 2. Economic Prong '
Section 337(a)(3) sets forth the following economic criteria for determining the existence
of a domestic industry in such investigations: .
- (3) For purposes of paragraph (2), an industry in the United States
shall be considered to exist if there is in the United States, with
respect to the articles protected by the patent, copyright, trademark,
mask Work, or design concerned — \
(A) significant investment in plant and equipment;
(B) significant employment of labor or capital; or
(C) substantial investment in its exploitation, including engineering,
1 research and development, or licensing.
Given that these criteria are listed in the disjunctive, satisfaction of any one of them will be
sufficient to meet the economic prong of the domestic industry requirement. Certain Integrated
Circuit Chipsets and Prods. Containing Same, Inv. No. 337-TA-428, Order No. 10, Initial
Detennination (unreviewed) (May 4, 2000).
_ 3 _

III. DISCUSSION _
A. Technical Prong . .
Hyundai asserts that all the Domestic Industry Products satisfy the technical prong of the
domestic industry requirement. Mem. at 17. Hyundai offers the testimony of James Carter, a Senior
Group Manager, Financial Planning and Analysis for HMA, who testified that the Domestic
Industry Vehicles bear the Asserted Trademarks. SUMF at 1]70; SUMF Eit. 5, Carter Decl., at 1|1I
3, 54. Mr. Carter also testified that the Domestic Industry Parts bear the Asserted Trademarks.
SUMF at 111]80, 83; SUMF Ex. 5 at 1|1[44, 56.
The evidence confirms that the Asserted Trademarks are “plainly used” on the Domestic
Industry Products. SUMF at 1]17; SUMF Ex. 5 at 1H[3, 44, 54, 56; see also Protective Cases, 337
TA-780, Initial \Determination at 90. Hyundai submits that the following examples are
representative of how the Asserted Trademarks are displayed on the Domestic Industry Products:
REGISTERED DOMESTIC INDUSTRY PRODUCT
TRADEMARKS
Smarter
. tttesyeit.
:4'Ki1:|‘§.§III.F21i-3 t!.ilL~‘L\‘.-J1;1.) , -. 5,7 ,(4_'_,
(u.s. Reg. Nos. ~
1,569,538 and f - --—
4,065,19s) _ g
g | "';-.~.
-4

REGISTERED D IN P
TRADE S OMESTIC DUSTRY RODUCT
“HYUNDAI,”
(U.S. Reg. -Nos.
1,104,727 and
3,991,863) » 0' r //"‘
,I I, .... I‘Q <1. l ~
(U.S. Reg. Nos. , :7"? D
1,569,538 and
4,065,195)
See SUMF E54.7 at 23-24; see also Mem. at 3-4; Mot. Ex. l at 111]42, 46. The evidence also shows
that the Domestic Industry Vehicles are manufactured and assembled in the United States using
Domestic Industry Parts. SUMF at 111]16, 18; SUMF Ex. 5 at 1|1l3, 44, 54.
Additionally, there is no evidence of record to contradict Hyundai’s assertion that the
Domestic Industry Products prominently feature the Asserted Trademarks. ‘
.The undersigned therefore finds that the undisputed facts demonstrate that Hyundai has
satisfied the technical prong of the domesticiindustry requirement: I .
B. Economic Prong
Hyundai asserts that it satisfies the economic prong under 19 U.S.C. § l337(a)(3)(A) and
(B) because it has: “(A) significantly invested in plants and equipment . . . and (B) significantly
invested in labor and capi_tal.” Mem. at 17. DTI does not dispute that Hyundai satisfies the
economic prong. DTI also does not dispute that Hyundai’s investments are significant, both
qualitatively and quantitatively. See Certain Carburetors and Products Containing Such
Carburetors, Inv. No. 337-TA-1123, Comm’n Op. at 17 (Oct. 28, 2019) (citing Certain Printing
& Imaging Devices & Components Thereofl Inv. No. 337-TA-690, Comm’n Op. at 27 (Feb. 17,
2011).) .
_ 5 _

related to the Domestic Industry Products that satisfy the economic prong under 19 U.S.C.
§ 1337(a)(3)(B).
IV. CONCLUSION , _ .
For the reasons discussed above, the undersigned finds that a summary determination thatQ
the domestic industry requirement is satisfied is appropriate. Accordingly, Hyundai’s rmopposed
motion (1 167-017) for summary determination that the domestic industry requirement is satisfied
is hereby granted. . . _.
Pursuant to 19 C.F.R. § 210.42(h), this Initial Determination shall be the determination of
the Commission unless a party files a petition for review of the Initial Determination pursuant to
19 C.F.R. § 2l0.43(a), or the Commission, pursuant to 19 C.F.R. § 210.44, orders, on its own
motion, a review of the Initial Determination or certain issues herein.
Within seven days of the date of this document, the parties shall submit to the Office of the
Administrative Law Judges a joint statement as to whether or not they seek to have any portion of
this document deleted from the public version. If the parties do seek to have portions of this
document deleted fi'om the public version, they mustsubmit to this office a copy of this document
with red brackets indicating the portion or portions asserted to contain confidential business
information. The submission may be made by email and/or hard copy by the aforementioned date
and need not be filed with the Commission Secretary. i
so ORDERED “
U @4471”harles E Bullock
Chief Administrative Law Judge ,
-9

CERTAIN REPLACEMENT AUTOMOTIVE SERVICE Inv. No. 337-TA-1160
AND COLLISION PARTS AND COMPONENTS THEREOF
Certificate of Service —Page 1
I, Lisa R. Barton, hereby certify that the attached PUBLIC VERSION ORDER NO 26
has been sewed upon the following parties as indicated, on February 4, 2020.
"' V I 1.‘ ..¢v@"'4:3“’?M ,.
‘_/ " //_./'1 " ~__‘.‘_‘_:.’-/"_ \ T‘
I "" /' 5;’ 111.,“ V./~s____,-L
Lisa R. Barton, Secretary
U.S. International Trade Commission
500 E Street SW, Room 112
. Washington, DC 20436
On Behalf of Complainants Hvundai Motor America,
Inc. and Hvundai Motor C0mpany_:
Kecia Reynolds, Esq.
PILLSBURY WINTHROP SHAW PITTMAN LLP
1200 Seventeenth Street, NW V
Washington, DC 20036 »
El Vi Hand Delivery
III/& ExpressDelivery
III Via First Class Mail
II] Other: I _
On Behalf of Respondent Direct Technologies
International, Inc. d/b/a DTI, Inc.:
Andrew R. Kopsidas
FISH & RICHARDSON P.C.
1000 Maine Avenue, SW
Washington, DC 20024 I
C] Via Hand Delivery
Efia ExpressDelivery
El Via First Class Mail
El Other: A
)

Certain Replacement Automotive Service and Collision Parts and Components Thereof, Inv. 337-TA-1160

Gesamter Gesetzestext

OCR transcription for search; preserved printed pages are authoritative

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