USITC opens patent investigation into imported recliner mechanisms and seating units

The U.S. International Trade Commission (USITC) has instituted investigation No. 337-TA-1524 into alleged patent infringement in powered rocker-recliner and glider-recliner mechanisms and the seating units containing them. The Commission ordered the institution on September 22, 2026, and the notice was published in the Federal Register of Monday, September 28, 2026 (Vol. 91, No. 186, p. 61249), under document FR Doc. 2026-19713.

The case originates in a complaint filed on August 21, 2026 on behalf of Ultra-Mek, Incorporated of Denton, North Carolina; Leggett & Platt, Incorporated of Carthage, Missouri; and L&P Property Management Company of Carthage, Missouri. Letters supplementing the complaint were filed on September 9 and September 10, 2026. The proceeding rests on section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and on section 210.10 of the Commission’s Rules of Practice and Procedure (19 CFR 210.10 (2025)).

Patents at issue and relief requested

The complaint alleges violations of section 337 in the importation into the United States, the sale for importation, and the sale within the United States after importation of the accused products, by reason of infringement of:

• U.S. Patent No. 8,398,165 (the ‘165 patent), claims 1–7 and 15–18
• U.S. Patent No. 8,398,168 (the ‘168 patent), claims 1–7 and 15–18
• U.S. Patent No. 8,016,348 (the ‘348 patent), claims 1–4 and 6–9
• U.S. Patent No. 8,297,693 (the ‘693 patent), claims 1–7 and 11–14

The complainants also allege that an industry in the United States exists as required by the applicable Federal Statute, and ask the Commission to issue a limited exclusion order and cease and desist orders.

Respondents named in the investigation

The notice names eleven entities as respondents alleged to be in violation of section 337:

• Jiangsu Carya Smart Home Hardware Co., Ltd., of Yangzhou, China
• Living Style Group Ltd., of Hong Kong
• True Innovations & Design (USA) LLC, of Irvine, California
• Living Style (Singapore) Pte. Ltd., of Singapore
• Living Style (Vietnam) Ltd., of Vietnam
• Henglin Home Furnishings Co., Ltd., of Huzhou, China
• Nanjing Hengning Home Furnishings Co., Ltd., of Nanjing, China
• Zhejiang Hengjian Home Furnishing Co., Ltd., of Hangzhou, China
• Colamy, Inc., of Fontana, California
• Aurora Maison, Inc., of Arvada, Colorado
• Aerisnexus Innovations, Inc., of Oklahoma City, Oklahoma

Scope of the investigation and procedural calendar

The plain-language description defining the scope of the investigation is “powered glider-recliner mechanisms; powered rocker-recliner mechanisms; and finished seating units incorporating those mechanisms”. The Chief Administrative Law Judge will designate the presiding Administrative Law Judge, and the Office of Unfair Import Investigations will not participate as a party.

• Responses to the complaint and the notice of investigation: within 20 days of service by the Commission
• Prehearing briefs: November 27, 2026
• Prehearing conference: 9:30 a.m., Monday, November 30, 2026
• Written testimony and presentation slides: noon, December 2, 2026
• Posthearing briefs and written statements of information: December 11, 2026
• Information released to parties: December 28, 2026
• Final comments: December 30, 2026

The Commission states that it is interested in the development of a thorough record on domestic industry, including the extent to which the complainants’ allegations rely on expenditures by third parties or on expenditures made outside the United States. Failure by a respondent to file a timely response may be deemed a waiver of the right to contest the allegations and may result in an exclusion order, a cease and desist order, or both.

The institution of 337-TA-1524 opens a formal adversarial track that can end in orders blocking the entry of the accused mechanisms and finished seating units into the United States. For importers, retailers and furniture suppliers, the case signals months of litigation risk over a product category built on patented reclining hardware, with the first hard deadlines falling in late November and December 2026.

Source: Federal Register, Vol. 91, No. 186, September 28, 2026, Notices, p. 61249 (official reference: FR Doc. 2026-19713).