`WASHINGTON D.C.
`
`Before the Honorable MaryJoan McNamara
`Administrative Law Judge
`
`In The Matter Of
`
`CERTAIN SURFACE CLEANING
`DEVICES AND COMPONENTS THEREOF
`
`Inv. No. 337-TA-1404
`
`COMPLAINANTS’ NOTICE OF PATENT PRIORITY DATES
`
`Pursuant to Ground Rule 4 and the Adopted Procedural Schedule (Order No. 5) in this
`
`Investigation, Complainants SharkNinja Operating LLC, Omachron Alpha Inc., and Omachron
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`Intellectual Property Inc. (collectively, “Complainants”) hereby provide their Notice of Patent
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`Priority Dates/Dates of Conception.
`
`The inventions in the relevant1 claims of U.S. Patent No. 7,776,120 (“the ’120 Patent”)
`
`were conceived by March 3, 2003, and reduced to practice by April 20, 2006. The earliest-filed
`
`application to which relevant claims of the ʼ120 Patent are entitled to claim priority is provisional
`
`application no. 60/780,824, filed on March 10, 2006.
`
`The inventions in the relevant claims of U.S. Patent No. 10,219,661 (“the ’661 Patent”)
`
`were conceived by August 21, 2014, and reduced to practice by October 14, 2014. The earliest-
`
`filed application to which relevant claims of the ʼ661 Patent are entitled to claim priority is
`
`provisional application no. 62/093,189, filed on December 17, 2014.
`
`The inventions in the relevant claims of U.S. Patent No. 11,903,546 (“the ’546 Patent”)
`
`were conceived by August 21, 2014, and reduced to practice by October 14, 2014. The earliest-
`
`
` 1 The “relevant” claims include (1) the claims Complainants assert Respondents infringe, and
`(2) the claims Complainants assert are practiced by one or more domestic industry products.
`
`
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`
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`Complainants’ Notice of Patent Priority Dates
`
`1
`
`
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`filed application to which relevant claims of the ʼ546 Patent are entitled to claim priority is
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`provisional application no. 62/093,189, filed on December 17, 2014.
`
`The inventions in the relevant claims of U.S. Patent No. 11,910,983 (“the ’983 Patent”)
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`were conceived by August 21, 2014, and reduced to practice by October 14, 2014. The earliest-
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`filed application to which relevant claims of the ʼ983 Patent are entitled to claim priority is
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`provisional application no. 62/093,189, filed on December 17, 2014.
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`The inventions in the relevant claims of U.S. Patent No. 11,910,984 (“the ’984 Patent”)
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`were conceived by January 31, 2016, and reduced to practice by January 31, 2016. The earliest-
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`filed application to which relevant claims of the ʼ984 Patent are entitled to claim priority is
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`application no. 15/642,781, filed on July 6, 2017.
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`Complainants’ Notice of Patent Priority Dates
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`
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`2
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`
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`Dated: July 18, 2024
`
`
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`
`
`Brian M. Buroker
`Shuo Josh Zhang
`1050 Connecticut Avenue NW
`Washington, DC 20036
`Telephone: (202) 955-8541
`bburoker@gibsondunn.com
`szhang@gibsondunn.com
`
`Neema Jalali
`One Embarcadero Center
`Suite 2600
`San Francisco, CA 94111
`Telephone: (415) 393-8200
`njalali@gibsondunn.com
`
`Jennifer Rho
`333 South Grand Avenue
`Los Angeles, CA 90071
`Telephone: (213) 229-7000
`jrho@gibsondunn.com
`
`David Glandorf
`1801 California Street, Suite 4200
`Denver, CO 80202
`Telephone: (303) 298-5700
`dglandorf@gibsondunn.com
`
`
`
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`Respectfully submitted,
`
`/s/ Mark Reiter
`
`GIBSON, DUNN & CRUTCHER LLP
`
`Mark Reiter
`Robert Vincent
`Nathan Curtis
`Julia Tabat
`Monica Lin
`2001 Ross Avenue, Suite 2100
`Dallas, TX 75201
`Telephone: (214) 698-3400
`mreiter@gibsondunn.com
`rvincent@gibsondunn.com
`ncurtis@gibsondunn.com
`jtabat@gibsondunn.com
`mlin2@gibsondunn.com
`
`Brian Rosenthal
`Sung Bin Lee
`Vivian Lu
`200 Park Avenue
`New York, NY 10166
`Telephone: (212) 351-4000
`brosenthal@gibsondunn.com
`slee3@gibsondunn.com
`vlu@gibsondunn.com
`
`
`Counsel for Complainants
`
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`Complainants’ Notice of Patent Priority Dates
`
`
`
`3
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`
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`CERTIFICATE OF SERVICE
`
`
`I, Michael Delaney, certify that on July 18, 2024, a copy of COMPLAINANTS’ NOTICE
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`OF PATENT PRIORITY DATES was served, pursuant to Commission regulations, on the
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`following interested parties in the manner so indicated:
`
`
`The Honorable Lisa Barton
`Secretary to the Commission
`U.S. International Trade Commission
`500 E Street, S.W., Room 112A
`Washington, DC 20436
`
`
`
`The Honorable MaryJoan McNamara
`Administrative Law Judge
`U.S. International Trade Commission
`500 E Street, S.W.
`Washington, DC 20436
`
`
`Counsel for Respondents Dyson, Inc.,
`Dyson Technology Limited, and Dyson
`Canada Limited:
`
`Jay Emerick
`Kirkland & Ellis
`333 West Wolf Point Plaza
`Chicago, IL 60654
`Telephone: (312) 862-3772
`
`
`
`
`
`DATE: July 18, 2024
`
`
`
`
`Via EDIS
`
`
`Via EDIS
`Via Email:
`McNamara337@usitc.gov
`
`
`
`Via E-mail:
`
`jay.emerick@kirkland.com
`KE-ITC-1404-Dyson_Respondents@kirkland.com
`
`/s/ Michael Delaney
`Michael Delaney
`GIBSON, DUNN & CRUTCHER LLP
`
`
`Certificate of Service
`
`
`
`1
`
`
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