UNITED STATES INTERNATIONAL TRADE COMMISSION
`WASHINGTON, DC
`
`Honorable Charles E. Bullock
`Chief Administrative Law Judge
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`
`
`
`Investigation No. 337-TA-936
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`
`
`In the Matter of
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`CERTAIN FOOTWEAR PRODUCTS
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`
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`STAFF’S RESPONSE TO THE JOINT MOTION TO TERMINATE AND STAY
`INVESTIGATION AS TO RESPONDENT
`HITCH ENTERPRISES PTY LTD., D/B/A SKEANIE(Mot. Dkt No. 936-025)
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`
`INTRODUCTION
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`On December 22, 2014, Complainant Converse Inc. (“Converse”) and Respondent Hitch
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`I.
`
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`Enterprises Pty Ltd., d/b/a Skeanie (“Skeanie”)1 filed a joint motion to terminate this
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`investigation as to Skeanie based on a settlement agreement and a proposed consent order, under
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`Commission Rules 210.21(b) and (c), 19 C.F.R. §§ 210.21(b) and (c). See Docket No. 936-025
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`(“Motion”). The motion includes a consent order stipulation, a proposed consent order, and the
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`parties’ settlement agreement. See Motion at attached stipulation (“Stipulation”) and proposed
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`consent order (“Consent Order”). The parties also seek to stay the investigation as to Skeanie
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`pending a ruling on the motion to terminate.
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`For the reasons set forth below, the Commission Investigative Staff (the “Staff”) supports
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`the motion to terminate and the request for a stay.
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`1 To date, Respondent Skeanie has not entered an appearance by counsel in this Investigation.
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`II.
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`
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`TERMINATION OF SKEANIE
`BASED UPON A SETTLEMENT AGREEMENT
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`The instant motion was filed under 19 C.F.R § 210.21(b). See Motion at p. 1. Rule
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`210.21(b) provides that in order for an investigation to be terminated as to a respondent on the
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`basis of a licensing or other settlement agreement, the motion for termination must include: (1)
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`copies of the licensing or other settlement agreement, including both a public and a confidential
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`version if necessary; (2) any supplemental agreements; and (3) a statement that there are no other
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`agreements, written or oral, express or implied, between the parties concerning the subject matter
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`of the investigation. 19 C.F.R. § 210.21(b)(1).
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`Here, the Motion includes unredacted copies of the parties’ settlement agreement. Conf.
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`Ex. C. The Motion also states that “[a]side from the Consent Order Stipulation and Settlement
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`Agreement, there are no other agreements, written or oral, express or implied, between
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`Complainant and Skeanie concerning the subject matter of the Investigation.” Motion at pp. 1-2.
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`In addition, the movants have filed both public and confidential versions of the Agreements.
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`EDIS Doc. ID 548275 (confidential version), 548277 (confidential version with consideration
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`redacted) and 548278 (public version).2
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` 2
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` The parties have filed and served on the remaining respondents a version of their settlement
`agreement that has the consideration terms redacted. See Conf. Ex. D. In this respect, Rule
`210.21(b) states, “On motion for good cause shown, the administrative law judge may limit the
`service of the agreements to the settling parties and the Commission investigative attorney.” See
`also Motion at p. 1 (explaining that the redactions are “highly-sensitive details, that, if disclosed
`could affect Complainant’s settlement prospects with other Respondents”); accord, Certain
`Automotive Multimedia Display and Navigation System, Components Thereof, And Products
`Containing Same, Inv. No. 337-TA-657, Order No. 13, pp. 2-4 (March 31, 2009) (withholding
`financial settlement terms from non-settling respondents). The Staff notes that certain
`respondents have opposed receiving only this redacted version, and seek, instead, to receive a
`fully unredacted version of the settlement agreement. See EDIS Doc. ID Nos. 548600 and
`548596.
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`III. TERMINATION OF SKEANIE BASED UPON A CONSENT ORDER
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`STIPULATION AND PROPOSED CONSENT ORDER
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`Converse and Skeanie also seek to terminate this investigation with regard to Skeanie
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`based on a consent order under 19 C.F.R § 210.21(c). See Motion at p. 1. Rule 210.21(c)(1)(ii)
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`provides:
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` a
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` proposal to terminate by consent order shall be submitted as a motion to the
`administrative law judge with a stipulation that incorporates a proposed consent order.
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`In accordance with Rule 210.21(c)(3)(i) and (ii), the motion includes a Consent Order Stipulation
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`signed by Skeanie and a proposed consent order. See Ex. A, Stipulation, at p. 3 and Ex. B,
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`Consent Order. Because the Staff believes that the Stipulation and proposed Consent Order
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`satisfy Commission Rules 210.21(c)(3) and 210.21(c)(4) respectively, the Staff supports
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`termination of the investigation as to Skeanie on this basis as well.
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`A. The Consent Order Stipulation Satisfies Commission Rule 210.21(c)(3)
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`The Staff is of the view that the Stipulation complies with the requirements of
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`Commission Rule 210.21(c)(3)(i) and (ii). The Stipulation states that the Commission has in rem
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`jurisdiction over Skeanie’s accused products, and personal jurisdiction over Skeanie for the
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`purposes of the consent order. See Commission Rule 210.21(c)(3)(i)(A); Ex. A, Stipulation, ¶ 2.
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`The Stipulation contains statements identifying each asserted trademark registration and
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`states that Skeanie will cease the importation, sale for importation, or sale after importation of
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`the subject articles in the United States, or inducement of such activities “except under consent
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`or license from Converse, or to the extent permitted by the Settlement Agreement.” See
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`Commission Rule 210.21(c)(3)(i)(B); Ex. A, Stipulation, preamble and ¶¶ 3-5.
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`The Stipulation contains an express waiver of all rights to seek judicial review or
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`otherwise challenge or contest the validity of the consent order. See Rule 210.21(c)(3)(i)(C); Ex.
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`A, Stipulation, ¶ 7. The Stipulation also includes a statement that “Skeanie will cooperate with
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`and will not seek to impede by litigation or other means the Commission’s efforts to gather
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`information under Subpart I of the Commission’s Rules of Practice and Procedure, 19 C.F.R.
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`Part 210.” See Commission Rule 210.21(c)(3)(i)(D); Ex. A, Stipulation, ¶ 8. The Stipulation
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`further states that the enforcement, modification, or revocation of the consent order will be
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`carried out pursuant to Subpart I of this part, incorporating by reference the Commission’s Rules
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`of Practice and Procedure. See Commission Rule 210.21(c)(3)(i)(E); Ex. A, Stipulation, ¶ 9.
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`The Stipulation contains a statement that the signing of the Stipulation is for settlement
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`purposes only and does not constitute an admission by Skeanie that an unfair act has been
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`committed. See Commission Rule 210.21(c)(3)(i)(F); Ex. A, Stipulation, ¶ 10.
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`The Stipulation further states that the consent order shall have the same force and effect
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`and may be enforced, modified, or revoked in the same manner as is provided in Section 337 of
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`the Tariff Act of 1930 and 19 C.F.R. Part 210 for other Commission actions, and the
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`Commission may require periodic compliance reports pursuant to Subpart I of 19 C.F.R. Part
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`210 to be submitted by the person entering into the consent order stipulation. See Commission
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`Rule 210.21(c)(3)(i)(G); Ex. A, Stipulation, ¶ 11.
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`The Stipulation also states that the Consent Order shall not apply with respect to any
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`Trademark at Issue that has expired or been found or adjudicated invalid or unenforceable by the
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`Commission or a court or agency of competent jurisdiction, provided that such finding or
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`judgment has become final and non-reviewable. See Commission Rule 210.21(c)(3)(ii)(A); Ex.
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`A, Stipulation, ¶ 12.
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`The Stipulation contains a statement that Skeanie and “their officers, directors,
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`employees, agents, and any entity or individual acting on their behalf and with their authority
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`will not seek to challenge the validity or enforceability of any of the Trademarks at Issue in any
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`administrative or judicial proceeding to enforce the Consent Order.” See Commission Rule
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`210.21(c)(3)(ii)(B); Ex. A, Stipulation, ¶ 13.
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`Based on the above, the Staff believes that the requirements of Commission Rule
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`210.21(c)(3) have been met.
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`B. The Consent Order Satisfies Commission Rule 210.21(c)(4)
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`The proposed Consent Order also satisfies, and does not appear to have terms beyond, or
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`materially inconsistent with, those provided for in Rule 210.21(c)(4). See Commission Rule
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`210.21(c)(4).
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`The proposed Consent Order identifies the Complainant, the Respondent, the subject
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`articles,3 and includes a statement of the allegations in the complaint that Skeanie sells for
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`importation, imports, and sells after importation the subject articles in violation of Section 337
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`by reason of infringement of the asserted Registrations. See Commission Rule 210.21(c)(4)(i);
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`Ex. B, Consent Order, ¶¶ 1-4. The Consent Order further states Skeanie has executed a consent
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`order stipulation, and the consent order does not contain the terms of the stipulation. See
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`Commission Rule 210.21(c)(4)(ii); Ex. B, Consent Order, ¶ 5.
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`The Consent Order contains statements identifying each asserted trademark registration
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`and states that “Skeanie shall not sell for importation, import, or sell after importation Subject
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`Articles, directly or indirectly, and shall not aid, abet, encourage, participate in, or induce the
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`sale for importation, the importation, or the sale after importation of Subject Articles except
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`under consent or license from Converse, or to the extent permitted by the Settlement Agreement
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`3 The subject articles are defined as “footwear products that were previously imported into the
`United States, sold for importation into the United States, and/or sold within the United States
`after importation and that are alleged to infringe one or more of the ‘753, ‘103, and ‘960
`Registrations.” See Ex. B, Consent Order at ¶ 3.
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`between Converse and Skeanie.” See Commission Rule 210.21(c)(4)(iii) and (iv)4; Ex. B,
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`Consent Order, p. 1, ¶¶ 3, 6. Further, the Consent Order would order Skeanie to “cease and
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`desist from importing and distributing Subject Articles in the United States.” See Commission
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`Rule 210.21(c)(4)(v); Ex. B, Consent Order, ¶ 7
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`The Consent Order contains a statement that Skeanie shall be precluded from seeking
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`judicial review or otherwise challenging or contesting the validity of the consent order. See Rule
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`210.21(c)(4)(vi); Ex. B, Consent Order ¶ 8. The Consent Order also includes a statement that
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`Skeanie shall cooperate with and shall not seek to impede by litigation or other means the
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`Commission’s efforts to gather information under Subpart I of the Commission’s Rules of
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`Practice and Procedure, 19 C.F.R. Part 210. See Commission Rule 210.21(c)(4)(vii); Ex. B,
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`Consent Order, ¶ 9.
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`The Consent Order contains a statement that Skeanie and “its officers, directors,
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`employees, agents, and any entity or individual acting on its behalf and its their authority shall
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`not seek to challenge the validity or enforceability of any of the Trademarks at Issue in any
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`administrative or judicial proceeding to enforce the Consent Order.” See Commission Rule
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`210.21(c)(4)(viii); Ex. B, Consent Order, ¶ 10.
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`The Consent Order contains statements that “[i]f the ‘753, ‘l03 and ‘960 Registrations
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`expire, this Consent Order shall become null and void as to such expired trademarks” and “[t]he
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`Consent Order shall become null and void with respect to any of the Trademarks at Issue that has
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`been held invalid or unenforceable by a court or agency of competent jurisdiction or as to any
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`4 Rule 210.21(c)(4)(iv) requires “a statement, if applicable, regarding the disposition of existing
`U.S. inventories of the subject articles.” The Consent Order does not have such a statement,
`although the settlement agreement states that “[a]s of the Effective Date, Skeanie does not have
`any Accused Products in inventory in the United States or in transit to the United States.” See
`Ex. E, at p. 4.
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`articles that have been found or adjudicated not to infringe the Trademarks at Issue in a final
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`decision, no longer subject to appeal.” See Rule 210.21(c)(4)(ix) and (c)(4)(x); Ex. B, Consent
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`Order, ¶¶ 11, 12.
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`Finally, the Consent Order contains a statement that the “Investigation is hereby
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`terminated with respect to Skeanie; provided, however, that enforcement, modification, or
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`revocation of the Consent Order shall be carried out pursuant to Subpart I of the Commission’s
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`Rules of Practice and Procedure, 19 CFR, Part 210.” See Rule 210.21(c)(4)(xi); Consent Order,
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`¶ 13.
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`In view of the foregoing, the Staff believes that the requirements of Commission Rule
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`210.21(c)(4) have also been satisfied. Accordingly, the Staff supports termination of the
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`investigation as to Skeanie by the entry of the proposed Consent Order.
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`IV.
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`PUBLIC INTEREST
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`Pursuant to the Commission’s rules, the Commission, when ruling on a proposed consent
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`order, shall consider the effect of consent order “upon the public health and welfare, competitive
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`conditions in the U.S. economy, the production of like or directly competitive articles in the
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`United States, and U.S. consumers.” See 19 C.F.R. § 210.21(c)(2)(ii). Here, the Staff is not
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`aware of any information that would indicate that termination of this investigation as to Skeanie
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`on the basis of the proposed Consent Order or as a result of the parties’ settlement agreement
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`would be contrary to the public health and welfare, competitive conditions in the U.S. economy,
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`the production of like or directly competitive articles in the United States, or U.S. consumers.
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`See 19 U.S.C. § 1337(d).
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`In addition, the public interest generally favors termination of an investigation when it
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`will avoid needless litigation and conserve public and private resources. See, e.g., Certain
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`Electronic Paper Towel Dispensing Devices and Components Thereof, Inv. No. 337-TA-718,
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`Order No. 25, at 4 (Dec. 1, 2010); Certain Compact Disc and DVD Holders, Inv. No. 337-TA-
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`482, Order No. 11, at 3 (Mar. 7, 2003) (“termination of litigation under these circumstances as an
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`alternative method of dispute resolution is generally in the public interest.”); accord Certain Gel-
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`Filled Wrist Rests and Products Containing Same, Inv. No. 337-TA-456, Order No. 16, at 5
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`(May 21, 2002).
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`Finally, the Administrative Procedure Act states that agencies should consider
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`termination of disputes by the involved parties where “the public interest permit[s].” See 5
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`U.S.C. §554(c)(l). In sum, the Staff is of the view that the public interest would be served by
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`granting the motion to terminate Skeanie from this investigation.
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`V.
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`REQUEST FOR STAY AS TO SKEANIE
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`Converse and Skeanie also move to stay this investigation as to Skeanie “pending final
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`resolution of the instant motion as to all events and Procedural Schedule deadlines related to
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`Skeanie.” See Memo at p. 4. The Staff submits that the procedural schedule should be stayed as
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`to Skeanie pending the Chief ALJ and Commission’s rulings on the Motion to Terminate to
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`conserve the parties’ and the Commission’s resources. See Certain Sleep-Disordered Breathing
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`Treatment Systems and Components Thereof, Inv. No. 337-TA-879, Order No. 11, at p. 6 (July
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`17, 2013) (staying investigation as to terminated respondent pending final disposition of motion
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`to terminate).
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`VI. CONCLUSION
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`For the foregoing reasons, the Staff supports termination of Respondent Skeanie from
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`this investigation based on a settlement agreement as well as a consent order stipulation and
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`consent order, and further supports the motion to stay the investigation as to Skeanie pending
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`final resolution of this motion to terminate.
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`Respectfully submitted,
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`/s/Sarah J. Sladic
`Margaret MacDonald, Director
`David O. Lloyd, Supervisory Attorney
`Sarah J. Sladic, Investigative Attorney
`OFFICE OF UNFAIR IMPORT INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street SW, Suite 401
`Washington, DC 20436
`(202) 205-2202
`(202) 205-2158 (facsimile)
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`January 2, 2015
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`Certain Footwear Products
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`337-TA-936
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`CERTIFICATE OF SERVICE
`
` I
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` hereby certify that on January 2, 2015 I caused the foregoing STAFF’S RESPONSE TO THE
`JOINT MOTION TO TERMINATE AND STAY INVESTIGATION AS TO
`RESPONDENT HITCH ENTERPRISES PTY LTD., D/B/A SKEANIE to be filed with the
`Commission, served by hand upon Chief Administrative Law Judge Charles Bullock (two paper
`copies plus a pdf copy served on Irina.Kuschner@usitc.gov), and served as indicated below:
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`BY E-MAIL:
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`COUNSEL FOR COMPLAINANT CONVERSE, INC.:
`V. James Adduci, Esq.
`ADDUCI, MASTRIANI & SCHAUMBERG, LLP
`1133 Connecticut Ave, NW
`12th Floor
`Washington, DC, 20036
`
`Converse@adduci.com
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`COUNSEL FOR RESPONDENT A-LIST, INC.:
`Gregory S. Cordrey, Esq.
`JEFFER MANGELS BUTLER & MITCHELL, LLP
`3 Park Plaza, Suite 1100
`Irvine, CA 92614
`
`gcordrey@jmbm.com
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`COUNSEL FOR RESPONDENT ESQUIRE
`FOOTWEAR LLC:
`Darren Oved, Esq.
`OVED & OVED LLP
`401 Greenwich Street
`New York, NY 10013
`
`darren@ovedlaw.com
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`COUNSEL FOR RESPONDENT FORTUNE DYNAMIC,
`INC.:
`Gary J. Rinkerman, Esq.
`DRINKER BIDDLE & REATH LLP
`1500 K Street, NW, Suite 1100
`Washington, DC 20005
`
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`
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`COUNSEL FOR RESPONDENT ALDO GROUP:
`Jeffrey L. Eichen, Esq.
`DRINKER BIDDLE & REATH LLP
`222 Delaware Avenue, Suite 1410
`Wilmington, DE 19801
`
`aldo-itc@dbr.com
`
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`COUNSEL FOR RESPONDENT FILA U.S.A.,
`INC.:
`Ross Q. Panko, Esq.
`ARENT FOX LLP
`1717 K Street, NW
`Washington, DC 20006-5344
`
`ross.panko@arentfox.com
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`COUNSEL FOR RESPONDENT GINA GROUP,
`LLC:
`Gregory F. Ahrens, Esq.
`WOOD, HERRON & EVANS, L.L.P.
`441 Vine Street
`Cincinnati, OH 45202
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`

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`FortuneDynamic-ITC@dbr.com
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`COUNSEL FOR RESPONDENT H & M HENNES &
`MAURTIZ L.P:
`Staci Jennifer Riordan, Esq.
`NIXON PEABODY LLP
`555 West Fifth Street, 46th Floor
`Los Angeles, CA 90013
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`936_ITC_H&M@nixonpeabody.com
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`COUNSEL FOR RESPONDENT HIGHLINE UNITED
`LLC d/b/a ASH Footwear USA :
`Gerard P. Norton, Esq.
`FOX ROTHSCHILD LLP
`Princeton Pike Corporate center
`997 Lennox Drive, Building 3
`Lawrenceville, NJ 08648-2311
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`ASH-ITC@foxrothschild.com
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`COUNSEL FOR RESPONDENT MAMIYE IMPORTS
`LLC (d/b/a Lilly of New York) AND SHOE SOX:
`Bruce R. Ewing, Esq.
`DORSEY & WHITNEY LLP
`51 West 52nd Street
`New York, NY 10019-6119
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`ewing.bruce@dorsey.com
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`COUNSEL FOR RESPONDENT OPPO ORIGINAL
`CORP.:
`Joanna Y. Tsai, Esq.
`JYTLAW
`12636 High Bluff Drive
`Suite 400
`San Diego, CA 92130
`
`JYT@jytlaw.com
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`COUNSEL FOR RESPONDENT OSITOS SHOES, INC.
`(d/b/a Collection 'O):
`Mitchell S. Feller, Esq.
`GOTTLIEB, RACKMAN & RESIMAN, PC
`270 Madison Avenue
`New York, NY 10016
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`
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`1
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`Gina_ITC@whe-law.com
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`COUNSEL FOR RESPONDENT ICONIX
`BRAND GROUP INC. d/b/a Ed Hardy:
`Kieran G. Doyle, Esq.
`COWAN, LIEBOWITZ & LATMAN, P.C.
`1133 Avenue of the Americas
`New York, NY 10036-6799
`
`KGD@cll.com
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`COUNSEL FOR RESPONDENT KMART
`CORPORATION:
`Eric S. Namrow, Esq.
`MORGAN, LEWIS & BOCKIUS LLP
`1111 Pennsylvania Avenue, NW
`Washington, DC 20004
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`MLInv337TA936@morganlewis.com
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`COUNSEL FOR RESPONDENT NOWHERE
`CO., LTD. (d/b/a Bape):
`Gary J. Rinkerman, Esq.
`DRINKER BIDDLE & REATH LLP
`1500 K Street, NW, Suite 1100
`Washington, DC 20005
`
`NCLtd-ITC@dbr.com
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`COUNSEL FOR RESPONDENT ORANGE
`CLUBWEAR, INC. (d/b/a Demonia Deviant)
`Maurice N. Ross, Esq.
`BARTON LLP
`420 Lexington Avenue
`Suite 1830
`New York, NY 10170
`
`mross@bartonesq.com
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`COUNSEL FOR RESPONDENT PW SHOES,
`INC.:
`Joseph A. Ruta, Esq.
`RUTA SOULIOS & STRATIS LLP
`1500 Broadway – 21st Floor
`New York, NY 10036
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`

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`jruta@lawnynj.com
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`COUNSEL FOR RESPONDENT SKECHERS
`U.S.A., INC.:
`Barbara A. Murphy
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1899 L Street, NW, Suite 1150
`Washington, DC 20036
`
`Morgan Chu, Esq.
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
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`
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`FM-Skechers-36@fostermurphy.com
`skechers-ITC@irell.com
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`COUNSEL FOR RESPONDENT WAL-MART
`STORES, INC.:
`Mareesa A. Frederick, Esq.
`FINNEGAN, HENDERSON, FARABOW,
` GARRET & DUNNER LLP
`901 New York Avenue, NW
`Washington, DC 20001
`Walmart-service@finnegan.com
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`
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`msfeller@grr.com
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`COUNSEL FOR RESPONDENT RALPH LAUREN
`CORPORATION:
`Neil J. McNabnay, Esq.
`FISH & RICHARDSON P.C.
`1717 Main Street
`Suite 5000
`Dallas, TX 75201
`
`ConverseITC-F&RTeam@fr.com
`
`
`COUNSEL FOR RESPONDENT TORY BURCH, LLC:
`Daniel E. Yonan, Esq.
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue
`Washington, DC 20005
`
`ToryBurch-ITC@skgf.com
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`COUNSEL FOR RESPONDENT ZULILY, INC.:
`Susan Koegel, Esq.
`FOSTER, MURPHY, ALTMAN & NICKEL, PC
`1899 L Street, NW, Suite 1150
`Washington, DC 20036
`
`FM-zulily-936@fostermurphy.com
`
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`2
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`BY FIRST CLASS MAIL:
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`RESPONDENTS:
`Brian Lichtenberg, LLC
`825 1/2 Silver Lake Boulevard
`Los Angeles, CA 90026
`
`Dioniso SRL
`via Pievaiola 166-f2
`06132 Perugia Italy
`
`
`Hitch Enterprises Pty Ltd d/b/a Skeanie
`Unit 3
`13 Lyell Street
`Mittagong, New South Wales 2575
`Australia
`
`
`Fujian Xinya I&E Trading Co. Ltd.
`Floor 4
`Building A
`China Shoes Capital
`ChendaiTown, Jinjiang
`Fujian Province
`China 362200
`
`Zhejiang Ouhai International Trade Co. Ltd.
`Jinzhou Mansion
`Wenzhou Road
`Wenzhou
`Zhejiang 325014 China
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`Cmerit USA, Inc., d/b/a Gotta Flurt
`4841 East Airport Drive
`Ontario, CA 91761
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`Edamame Kids, Inc.
`1911-34 Avenue SW
`Calgary, Alberta
`T2T 2C2 Canada
`
`Shenzhen Foreversun Industrial Co., Ltd
`(a/k/a Shenzhen Foreversun Shoes Co., Ltd)
`Room 1109-1112 F11
`Yousong Science &Technology Bldg.
`1st Road of Donghuan, Longhua
`Bao’an, Shenzhen
`Guangdong Province
`China 518109
`
`Wenzhou Cereals Oils & Foodstuffs
`Foreign Trade Co. Ltd.
`24th Floor
`International Trade Centre
`236 Liming West Road, Wenzhou
`Zhejiang Province
`China 325003
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`/s/ Sarah J. Sladic
`Sarah J. Sladic
`Investigative Attorney
`OFFICE OF UNFAIR IMPORT
` INVESTIGATIONS
`U.S. International Trade Commission
`500 E Street, S.W., Suite 401
`Washington, D.C. 20436
`(202) 205-2202
`(202) 205-2158 (fax)
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