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`UNITED STATES INTERNATIONAL TRADE COMMISSION
`Washington, DC
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`Before the Honorable MaryJoan McNamara
`Administrative Law Judge
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`
`In the Matter of
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`CERTAIN VAPORIZER CARTRIDGES AND
`COMPONENTS THEREOF
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`Investigation No. 337-TA-1211
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`COMMISSION INVESTIGATIVE STAFF’S RESPONSE TO JOINT MOTION TO
`TERMINATE THE INVESTIGATION AS TO RESPONDENT ALL PUFF STORE
`(Mot. Dkt. No. 1211-039)
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`On December 11, 2020, Complainant JUUL Labs, Inc. (“JLI” or “Complainant”) and
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`Respondent All Puff Store (“Respondent” or “All Puff Store”) jointly moved to terminate this
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`investigation as to All Puff Store based on a Consent Order Stipulation and Proposed Consent
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`Order. See Motion Dkt. No. 1211-039 (“Motion”). For the reasons set forth below, the
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`Commission Investigative Staff (“Staff”) supports the Motion for termination as to Respondent
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`All Puff Store.
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`I. LEGAL STANDARDS
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`Under the Commission Rules, “[a]ny party may move at any time to terminate an
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`investigation in whole or in part as to any or all respondents on the basis of a settlement, a
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`licensing or other agreement, … or a consent order[.]” See 19 CFR § 210.21(a)(2).
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`Commission Rule 210.21(c) expressly provides for terminating an investigation based on the
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`entry of a consent order. See 19 C.F.R. § 210.21(c) (termination by consent order). “A motion
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`for termination by consent order shall contain copies of any licensing or other settlement
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`agreement, any supplemental agreements, and a statement that there are no other agreements,
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`written or oral, express or implied between the parties concerning the subject matter of the
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`investigation.” 19 C.F.R. § 210.21(c). “If the licensing or other settlement agreement contains
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`confidential business information within the meaning of § 201.6(a) of this chapter, a copy of the
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`agreement with such information deleted shall accompany the motion.” Id; see also C.F.R. §
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`210.21(b) (same requirement).
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`A motion to terminate by consent order must be submitted “with a stipulation that
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`includes a proposed consent order.” 19 C.F.R. § 210.21(c)(1)(ii). The contents of the consent
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`order stipulation must comply with the requirements set forth in Commission Rules 210.21(c)(3).
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`See 19 C.F.R. § 210.21(c)(3). The Commission will not issue a consent order with terms
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`beyond or inconsistent with those set forth in Commission Rule 210.21(c)(4). See 19 C.F.R. §
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`210.21(c)(4).
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`As a general matter, “public policy supports termination in order to conserve public and
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`private resources.” Certain Insulated Beverage Containers, Components, Labels, And
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`Packaging Materials Thereof, Inv. No. 337-TA-1084, ID at 3 (Jun. 8, 2018) (granting
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`termination based on settlement agreement) (unreviewed). “The Commission has held that, in
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`the absence of extraordinary circumstances, termination of an investigation will be readily
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`granted to a complainant during the prehearing stage of an investigation.” Id. (quotation
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`omitted).
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`II. DISCUSSION
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`As explained below, the Staff is of the view that the Motion, Consent Order Stipulation
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`(Exhibit A), Proposed Consent Order (Exhibit B), and the redactions in the settlement agreement
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`(Exhibit C) provided by Complainant JLI and Respondent All Puff Store substantially comply
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`with the Commission Rules. See 19 C.F.R. § 210.21(c). Therefore, the Staff submits that the
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`2
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`Motion for a Consent Order and termination of the investigation as to Respondent All Puff Store
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`should be granted.
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`A.
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`Consent Order Stipulation
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`The Consent Order Stipulation (Exhibit A) by Respondent All Puff Store appears to
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`comply with the requirements of Commission Rule 210.21(c)(3). See Motion at Ex. A
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`(“Stipulation”); 19 C.F.R. § 210.21(c)(3). With respect to paragraph (c)(3)(i)(A) of the
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`Commission Rule, All Puff Store admits that the Commission has subject matter jurisdiction
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`over this investigation, in rem jurisdiction over its accused articles, and in personam jurisdiction
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`over All Puff Store for purposes of the consent order. See Stipulation at ¶ 1.
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`With respect to paragraph (c)(3)(i)(B), the Stipulation identifies the asserted patent claims
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`and All Puff Store stipulates that:
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`it will not sell for importation, import into the United States or sell in the United
`States after importation, directly or indirectly, or aid, abet, encourage, participate
`in, or induce the sale for importation, importation into the United States or sale in
`the United States after importation of vaporizer cartridges and components thereof
`that infringe any of the claims of the Asserted Claims, except under consent or
`license from JLI.
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`Id. at ¶ 2; see also id. at Introductory ¶ 1 (“with respect to the sole claim of each of U.S. Patent
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`Nos. D842,536 (‘’536’), D858,870 (‘’870’), D858,869 (‘’869’), D858,868 (‘’868’) (collectively
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`the ‘Asserted Claims’”)). The Stipulation states that “All Puff Store does not have any existing
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`U.S. inventories of vaporizer cartridges and components thereof.” Id. at ¶ 3.
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`With respect to paragraph (c)(3)(i)(C), All Puff Store expressly waives all rights to seek
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`judicial review or otherwise challenge the validity of the consent order. Id. at ¶ 4. With respect
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`to paragraph (c)(3)(i)(D), All Puff Store stipulates that it will cooperate with and will not seek to
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`impede by litigation or other means the Commission’s efforts to gather information under
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`Subpart I of the Commission’s Rules. Id. at ¶ 5. With respect to paragraph (c)(3)(i)(E), All
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`Puff Store stipulates that the enforcement, modification, or revocation of the consent order will
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`be carried out pursuant to Subpart I of the Commission’s Rules of Practice and Procedure. Id. at
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`¶ 6.
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`With respect to paragraph (c)(3)(i)(F), All Puff Store states that the signing of the
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`Stipulation is for settlement purposes only and does not constitute an admission by All Puff Store
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`that an infringement of the Asserted Claims and/or an unfair act has been committed. Id. at ¶ 7.
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`With respect to paragraph (c)(3)(i)(G), All Puff Store stipulates that the consent order shall have
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`the same force and effect and may be enforced, modified, or revoked in the same manner as is
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`provided in section 337 of the Tariff Act of 1930 and 19 C.F.R. Part 210 for other Commission
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`actions, and that the Commission may require periodic compliance reports pursuant to Subpart I
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`of 19 C.F.R. Part 210 to be submitted by All Puff Store. Id. at ¶ 8.
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`With respect to paragraph (c)(3)(ii)(A), All Puff Store stipulates that the consent order
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`shall not apply with respect to any asserted patent claim that has expired or is held invalid or
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`unenforceable by a court or agency of competent jurisdiction or if any article has been found or
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`adjudicated not to infringe the asserted right in a final decision, no longer subject to appeal, the
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`Consent Order shall become null and void as to such expired, invalid, or unenforceable claim or
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`as to any adjudicated article. Id. at ¶ 9. With respect to paragraph (c)(3)(ii)(B), All Puff Store
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`states that it will not seek to challenge the validity or enforceability of the asserted patents in any
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`administrative or judicial proceeding to enforce the consent order. Id. at ¶ 10.1 In sum, the
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`Stipulation appears to satisfy the Commission Rule.
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`1 The Stipulation also includes a statement that the Stipulation and Consent Order are in the
`public interest. See Stipulation at ¶ 11. While this statement in the Stipulation is not provided
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`B.
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`Proposed Consent Order
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`The Proposed Consent Order also appears to comply with and to not have terms beyond,
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`or materially inconsistent with, those set forth in Commission Rule 210.21(c)(4). See Motion at
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`Ex. B (“Proposed Order”); 19 C.F.R. § 210.21(c)(4). With respect to paragraph (c)(4)(i) of the
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`Commission Rule, the Proposed Consent Order includes statements identifying Complainant JLI,
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`Respondent All Puff Store, and the allegations in the Complaint that All Puff Store has engaged
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`in importation into the United States, sale for importation into the United States, and/or sale
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`within the United States after importation of certain vaporizer cartridges and components thereof
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`in violation of Section 337 with respect to the sole claim of each of U.S. Patent Nos. D842,536
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`(“’536”), D858,870 (“’870”), D858,869 (“’869”), D858,868 (“’868”) (collectively the “Asserted
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`Claims”). See Proposed Order at Introductory ¶ 1.
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`With respect to paragraph (c)(4)(ii), the Proposed Order states that All Puff Store has
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`executed a consent order stipulation in which it agrees to entry of the Consent Order. See
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`Proposed Order at Introductory ¶ 2. With respect to paragraphs (c)(4)(iii) and (v), the language
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`in the Proposed Order mirrors the language that was included in All Puff Store’s Consent Order
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`Stipulation. See id. at ¶ 1. The Proposed Order states that it “shall be applicable to and binding
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`upon All Puff Store, their officers, agents, servants, attorneys, employees, affiliates, and all
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`persons, firms, or corporations acting or claiming to act on its behalf or under its direction or
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`authority.” Id. at ¶ 2. With respect to paragraph (c)(4)(iv), the Proposed Order states that All
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`for by the Rules, the Staff is of the view that it is not problematic because the Rules otherwise
`require the Administrative Law Judge (“ALJ”) to consider the effect of termination on the public
`interest.
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`Puff Store does not have any existing U.S. inventories of vaporizer cartridges and components
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`thereof. Id. at ¶ 6.
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`With respect to paragraph (c)(4)(vi), the Proposed Order provides that All Puff Store will
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`be precluded from seeking judicial review or otherwise challenging or contesting the validity of
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`the Consent Order. Proposed Order at ¶ 3. With respect to paragraph (c)(4)(vii), the Proposed
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`Order provides that All Puff Store shall cooperate with and shall not seek to impede by litigation
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`or other means the Commission’s efforts to gather information under Subpart I of the
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`Commission’s Rules of Practice and Procedure. Id. at ¶ 4.
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`With respect to paragraph (c)(4)(viii), the Proposed Order provides that All Puff Store
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`and its officers, directors, employees, agents, and any entity or individual acting on its behalf and
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`with its authority shall not seek to challenge the validity or enforceability of the Asserted Claims
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`in any administrative or judicial proceeding to enforce the Consent Order. Proposed Order at ¶
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`5. With respect to paragraph (c)(4)(ix), the Proposed Order provides that, when an Asserted
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`Patent expires, the Consent Order shall become null and void as to such expired patent. Id. at ¶
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`7.
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`With respect to paragraph (c)(4)(x), the Proposed Order provides that the Consent Order
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`shall become null and void as to any claim of any intellectual property right that is held invalid
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`or unenforceable by a court or agency of competent jurisdiction or as to any article that has been
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`found or adjudicated not to infringe the asserted right in a final decision, no longer subject to
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`appeal. Id. at ¶ 8.
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`With respect to paragraph (c)(4)(xi), the Proposed Order includes an admission of
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`jurisdictional facts. See id. at ¶ 9. Specifically, with respect to paragraph (c)(4)(xii), the
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`Proposed Consent Order states that the Investigation is hereby terminated with respect to All
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`Puff Store; provided, however, that enforcement, modification, or revocation of the Consent
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`Order shall be carried out pursuant to Subpart I of the Commission’s Rules of Practice and
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`Procedure. Id. at ¶ 10. In sum, the Proposed Order also appears to satisfy the Commission
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`Rule.
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`C.
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`Settlement Agreement
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`In addition to the Consent Order Stipulation and Proposed Consent Order, the parties
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`have also entered into a settlement agreement (Exhibit C). See Motion at Ex. C. The parties
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`have provided both confidential and public versions of their settlement agreement, as required by
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`the Rules. See EDIS Doc. ID No. 727843 (Dec. 11, 2020) (public settlement agreement); 19
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`C.F.R. § 210.21(c) (“If the licensing or other settlement agreement contains confidential business
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`information within the meaning of § 201.6(a) of this chapter, a copy of the agreement with such
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`information deleted shall accompany the motion.”). The redactions to the public settlement
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`agreement are limited to a single section – section 2.3. See Ex. C at § 2.3. The Staff is of the
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`view that the redactions to the public version of the settlement agreement are appropriately
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`tailored and consistent with the scope of Commission Rule 201.6(a). See 19 C.F.R. § 201.6(a).
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`The Motion states “that there are no other agreements, written or oral, express or implied,
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`relating to the subject matter of this Investigation.” Motion at 1; see also 19 C.F.R. § 210.21(c)
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`(requirement for same). The Motion thus appears to comply with the requirements for
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`termination. See 19 C.F.R. § 210.21(c).
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`D.
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`Public Interest Considerations
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`Pursuant to Commission Rule 210.50(b)(2), the Administrative Law Judge, in ruling on a
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`motion to terminate on the basis of a settlement agreement and/or a consent order, is to consider
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`and make appropriate findings regarding the effect of the proposed termination on the public
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`interest. 19 C.F.R. § 210.59(b)(2). Generally, the public interest tends to favor early
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`termination of investigations by settlement or consent order to conserve public and private
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`resources. See, e.g., Certain Electronic Paper Towel Dispensing Devices and Components
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`Thereof, Inv. No. 337-TA-718, Order No. 25 at 4 (Dec. 1, 2010) (termination by consent order
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`granted); Certain Semiconductor Chips with Minimized Chip Package Size and Prods.
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`Containing Same (III), Inv. No. 337-TA-630, Order No. 25 at 4 (Sept. 4, 2008) (termination
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`based on settlement and consent order granted); accord Certain Beverage Brewing Capsules,
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`Components Thereof, and Prods. Containing the Same, Inv. No. 337-TA-929, Order No. 10 at 6
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`(Nov. 19, 2014) (same). There is also a public interest in “the recognition of presumptively
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`valid patents and their exclusive rights.” Certain Recombinantly Produced Hepatitis B
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`Vaccines and Prods. Containing Same, Inv. No. 337-TA-408, Order No. 7 at 5 (Aug. 17, 1998).
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`Here, the Staff is not aware of any information to indicate that termination of this
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`investigation as to Respondent All Puff Store and the entry of the Proposed Order would be
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`contrary to any of the public health and welfare, competitive conditions in the U.S. economy, the
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`production of like or directly competitive articles in the United States, or U.S. consumers. See
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`19 U.S.C. § 1337(d). The Motion and Stipulation also state that termination is in the public
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`interest. See Motion at 2-3; Stipulation at ¶ 11. Therefore, the Staff submits that termination of
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`the investigation as to Respondent All Puff Store and issuance of the Proposed Consent Order is
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`not contrary to the public interest.
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`III. CONCLUSION
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`For the reasons set forth above, the Staff submits that the Motion for termination as to
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`Respondent All Puff Store should be granted.
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`Dated: December 23, 2020
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`Respectfully submitted,
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`/s/ Claire K. Comfort
`Margaret D. Macdonald, Director
`Anne Goalwin, Supervisory Attorney
`Claire K. Comfort, Investigative Attorney
`OFFICE OF UNFAIR IMPORT INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street SW, Suite 401
`Washington, DC 20436
`(202) 205-2160
` (202) 205-2158 (fax)
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`Certain Vaporizer Cartridges and Components Thereof
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`Inv. No. 337-TA-1211
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on December 23, 2020, the foregoing Commission Investigative
`Staff’s Response to Joint Motion to Terminate the Investigation as to Respondent All Puff Store
`(Motion Dkt. No. 1211-039) was filed with the Commission, served upon the Administrative Law Judge
`(by email to McNamara337@usitc.gov and jae.lee@usitc.gov), and served upon the parties in the manner
`indicated below:
`
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`BY EMAIL:
`qe-juullabs@quinnemanuel.com
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`BY EMAIL:
`mreeder@cadwellclontsreeder.com
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`BY EMAIL:
`#Carytown-ITCGroup@freeborn.com
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`For Complainant JUUL Labs, Inc.:
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`S. Alex Lasher
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
`1300 I Street, NW, Suite 900
`Washington, DC 20005
`Tel: (202) 538-8000
`Fax: (202) 538-8100
`
`Kevin P.B. Johnson
`Victoria F. Maroulis
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
`555 Twin Dolphin Dr., 5th Floor
`Redwood Shores, CA 94065
`Tel: (650) 801-5000
`Fax: (650) 801-5100
`
`Andrew M. Holmes
`QUINN EMANUEL URQUHART & SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, CA 94111
`Tel: (415) 875-6600
`Fax: (415) 875-6700
`
`For Respondents Aqua Haze LLC, Texas E. Cigarette
`d/b/a EZFumes, and Vapeonline LLC d/b/a 2nd Wife
`Vape:
`
`Michael F. Reeder II
`CADWELL CLONTS & REEDER LLP
`One Riverway, Suite 1700
`Houston, TX 77056
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`For Respondent Tobacco Club & Gifts Inc. d/b/a
`Carytown Tobacco:
`
`Jeffrey J. Catalano
`Troy D. Smith
`FREEBORN & PETERS LLP
`311 S. Wacker Drive, Suite 3000
`Chicago, IL 60606
`Tel: (312) 360-6000
`Fax: (312) 360-6520
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`1
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`Certain Vaporizer Cartridges and Components Thereof
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`Inv. No. 337-TA-1211
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`Theodore I. Brenner
`FREEBORN & PETERS LLP
`901 East Byrd Street, Suite 950
`Richmond, VA 23219
`Tel: (804) 799-7777
`Fax: (804) 644-1354
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`For Respondent VR Products I LLC d/b/a eJuiceDB:
`
`Robert L. Epstein
`Brieanne Scully
`EPSTEIN DRANGEL LLP
`60 East 42nd Street, Suite 2520
`New York, NY 10165
`Tel: (212) 292-5390
`Fax: (212) 292-5391
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`For Respondent Price Point Distributors Inc. d/b/a
`Price Point NY:
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`Evan H. Langdon
`NIXON PEABODY LLP
`799 9th Street NW, Suite 500
`Washington, DC 20001-5327
`Tel: (202) 585-8000
`Fax: (202) 585-8080
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`For Respondent Bansidhar Inc. d/b/a Smoker’s
`Express:
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`Marc Lorelli
`BROOKS KUSHMAN P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, MI 48075
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`For Respondent Three Mini Calvins, LLC d/b/a
`Tobacco Alley of Midland:
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`Nathan C. Brunette
`Elliott J. Williams
`STOEL RIVES LLP
`760 SW Ninth Avenue, Suite 3000
`Portland, OR 97205
`Tel: (503) 224-3380
`Fax: (503) 220-2480
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`BY EMAIL:
`repstein@ipcounselors.com
`bscully@ipcounselors.com
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`BY EMAIL:
`elangdon@nixonpeabody.com
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`BY EMAIL:
`mlorelli@brookskushman.com
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`BY EMAIL:
`DG_337-1211@stoel.com
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`Certain Vaporizer Cartridges and Components Thereof
`
`Inv. No. 337-TA-1211
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`For Respondent Vaperistas, LLC:
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`Siddhesh V. Pandit
`Timothy J. Maier
`Christopher J. Maier
`MAIER & MAIER PLLC
`345 S. Patrick Street
`Alexandria, VA 22314
`
`For Respondent Wireless N Vapor Citi LLC:
`
`Steven Susser
`Alex Szypa
`CARLSON GASKEY & OLDS P.C.
`400 West Maple Rd. Suite 350
`Birmingham, MI
`
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`Service on the Following Respondents Is to Be
`Completed by Complainant:
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`Dongguan Hengtai Biotechnology Co., Ltd. d/b/a Mr. Fog
`Room 5028, No. 915,
`Chang’an Section, Tai'an Road,
`Dongguan, Guangdong
`CHINA 523857
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`Limitless Accessories, Inc. d/b/a Valgous
`8712 Kathleen Lane
`Tinley Park, IL 60487
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`Shenzhen Azure Tech USA LLC f/k/a DS Vaping P.R.C.
`1267 Willis St., STE 200,
`Redding, CA 96001
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`Shenzhen Yark Technology Co., Ltd.
`3rd Floor of No. 14 SongShang West Road
`BoGang Community Xinsha Road of Shajing
`District Bao’an, Shenzhen
`CHINA 518125
`
`101 Smoke Shop, Inc.
`3266 Cahuenga Blvd. West
`Los Angeles, CA 90068
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`All Puff Store
`6801 Engle Road, Suite E
`Middleburg Heights, OH 44130
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`BY EMAIL:
`svp@maierandmaier.com
`tjm@maierandmaier.com
`cjm@maierandmaier.com
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`BY EMAIL:
`ssusser@cgolaw.com
`aszypa@cgolaw.com
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`3
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`Certain Vaporizer Cartridges and Components Thereof
`
`Inv. No. 337-TA-1211
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`Alternative Pods
`4860 Rhiannon Court
`Palatine, IL 60067
`
`Ana Equity LLC
`6550 International Drive, Suite 103
`Orlando, FL 32819
`
`Cali Pods
`PO Box 41387
`Houston, TX 77241
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`Canal Smoke Express, Inc.
`383 Canal Street
`New York, NY 10013
`
`Cigar Road, Inc.
`23315 Mulholland Drive
`Woodland, CA 91364
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`Cloud 99 Vapes
`50 2nd Avenue
`New York, NY 10003
`
`Cork & Twist, Inc. d/b/a Vape ’N Glass
`283 N. Barrington Road
`Streamwood, IL 60107
`
`DripTip Vapes LLC
`151 N. Nob Hill Road #115
`Plantation, FL 33325
`
`eCig-City
`1400 University Avenue, Suite A107
`Riverside, CA 92507
`
`Eon Pods LLC
`155 Washington Street
`Jersey City, NJ 07302
`
`Evergreen Smokeshop
`3221 Foothill Boulevard
`Oakland, CA 94601
`
`Guangdong Cellular Workshop Electronic Technology
`Co., Ltd.
`888 BBK Avenue, Jiangbei Village
`Wusha Community, Changan Town, Dongguan City
`Guangdong, CHINA 523068
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`4
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
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`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`
`
`
`
`

`

`Certain Vaporizer Cartridges and Components Thereof
`
`Inv. No. 337-TA-1211
`
`JC Pods
`1410 Kirk Street
`Elk Grove Village, IL 60007
`
`Jem Pods, U.S.A.
`8411 Lake Drive
`Snellville, GA 30039
`
`JUULSite Inc.
`411 Country Club Drive
`Bensenville, IL 60106
`
`Keep Vapor Electronic Tech. Co., Ltd.
`Block D, XinLong Techno Park
`Shaling Town, Bao’an District, Shenzhen
`CHINA 518101
`
`Modern Age Tobacco
`1122 W. University Avenue
`Gainesville, FL 32601
`
`Nilkant 167 Inc.
`167 Newbury Street
`Boston, MA 02116
`
`OMID Holdings, Inc. d/b/a Naturally Peaked Health Co.
`16 Mr. Ebo Road S, Suite 13
`Brewster, NY 10509
`
`Perfect Vape LLC
`2305 S Agnew Avenue
`Oklahoma City, OK 73108
`
`Shango Distribution LLC d/b/a Puff E-Cig
`3 Mountain Drive
`Imlay City, MI 48444
`
`Sky Distribution LLC
`P.O. Box 1325
`Addison, IL 60101
`
`The Kind Group LLC
`1808 Brielle Avenue
`Ocean, NJ 07712
`
`Vape Central Group
`203 NE 1st Avenue
`Hallandale, FL 33009
`
`
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`
`5
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`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`
`
`
`

`

`Certain Vaporizer Cartridges and Components Thereof
`
`Inv. No. 337-TA-1211
`
`Vapers&Papers, LLC
`714 Stanley Street
`Schenectady, NY 12307
`
`WeVapeUSA
`1479 E. 15th Street
`Brooklyn, NY 11230
`
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`
`OTHER METHOD:
`To Be Completed by Complainant
`
`/s/ Claire K. Comfort
`Claire K. Comfort
`Investigative Attorney
`OFFICE OF UNFAIR IMPORT INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street, SW, Suite 401
`Washington, DC 20436
`(202) 205-2160
`(202) 205-2158 (fax)
`
`6
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`