Law360, New York (July 26, 2011, 1:59 PM ET) -- In a highly anticipated decision, the U.S. International Trade Commission again clarified what constitutes a “domestic industry” under Section 337 of the Tariff Act of 1930.

In Multimedia Display and Navigation Devices and Systems (ITC Inv. No. 337-TA-694) — an action brought by Pioneer Corporation and Pioneer Electronics (USA) Inc. (collectively, "Pioneer") alleging infringement by Garmin International Inc. and Garmin Corporation (collectively, "Garmin") of Pioneer’s GPS navigation patents — the ITC determined that Pioneer’s U.S. licensing activities were insufficient to establish a domestic industry. The commission...