ITC Seeks Public Comment on Potential Import Ban of Dell and Lenovo Wireless Devices

The International Trade Commission (ITC) has announced it is soliciting public interest submissions in connection with Investigation No. 337-TA-1429, which concerns certain wireless communications devices and components thereof. The solicitation follows an Initial Determination on Violation of Section 337 issued by the presiding administrative law judge (ALJ) on August 14, 2026, along with a Recommended Determination on remedy and bonding should a violation be found.

Recommended Remedial Orders

The ALJ's Recommended Determination calls for a limited exclusion order directed to certain wireless communications devices and components thereof imported, sold for importation, and/or sold after importation by respondents Dell Technologies Inc., Dell Products L.P. (collectively, "Dell"), and Lenovo (United States) Inc. ("Lenovo"). The recommended relief also includes cease and desist orders directed to both Lenovo and Dell. The Commission is now inviting comment specifically on the public interest implications of these recommended orders, should the Commission ultimately find a violation.

Statutory Framework

Section 337 of the Tariff Act of 1930 provides that if the Commission finds a violation, it shall exclude the articles concerned from the United States unless, after considering the effect of such exclusion upon the public health and welfare, competitive conditions in the United States economy, the production of like or directly competitive articles in the United States, and United States consumers, it finds that such articles should not be excluded from entry, as set out at 19 U.S.C. 1337(d)(1). A similar provision applies to cease and desist orders under 19 U.S.C. 1337(f)(1). The Commission states it is interested in further development of the record on the public interest in this investigation.

Scope of Requested Comments

The Commission is inviting submissions from members of the public and interested government agencies only — not parties to the investigation. Comments are to be filed pursuant to 19 CFR 210.50(a)(4) and must be no more than five pages, inclusive of attachments. The Commission has identified five specific areas it is particularly interested in: how the potentially subject articles are used in the United States; any public health, safety, or welfare concerns relating to the recommended orders; the availability of like or directly competitive articles made in the United States that could replace the subject articles if excluded; whether complainant, complainant's licensees, and/or third-party suppliers have the capacity to replace the volume of articles potentially subject to the recommended orders within a commercially reasonable time; and how the recommended orders would impact consumers in the United States.

Filing Requirements

Written submissions must be filed no later than the close of business on September 15, 2026. All documents must be filed electronically in accordance with 19 CFR 210.4(f) and must reference the investigation number ("Inv. No. 337-TA-1429") prominently on the cover page and/or first page. Persons with questions regarding filing may contact the Secretary at 202-205-2000. Any party seeking confidential treatment must mark each document with a header indicating it contains confidential information, satisfying the procedure set forth in Rules 201.6(b) and 210.5(e)(2) (19 CFR 201.6(b) & 210.5(e)(2)). Non-parties submitting confidential comments must also serve those comments on the parties to the investigation pursuant to the applicable Administrative Protective Order, and must simultaneously file a redacted non-confidential version in accordance with Commission Rule 210.4(f)(7)(ii)(A).

What to Watch

• September 15, 2026: Deadline for public interest submissions from the public and interested government agencies in Inv. No. 337-TA-1429.

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