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October 9, 2018 

PUBLIC VERSION 

Submitted via regulations.gov 

The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

600 17th Street Northwest 

Washington, D.C. 20508 

Subject: Docket Number USTR-2018-0025 

Elo Touch Solutions Inc.’s Request for Exclusion of Certain Glass Panels Classified under HTS 

Subheading 8537.10.8000 from the Determination of Action Pursuant to Section 301: China’s Acts, 

Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation 

Dear Ambassador Lighthizer, 

 We appreciate the opportunity to submit comments pursuant to your findings of the Investigation into China’s 

Acts, Policies, and Practices Related to Technology Transfer, Intellectual Property, and Innovation under Section 301 of 

the Trade Act of 1974. Elo Touch Solutions (Elo) respectfully requests the exclusion of the glass panels specifically 

classified under HTS subheading 8537.10.8000. from the 8-digit line of products targeted by Section 301 tariffs. We have 

provided a formal description of this item in the product exclusion request form. 

Elo is a global leader in touchscreen solutions including point of sale systems and interactive signage displays 

from 10 to 70 inches. The inventor of the touchscreen, Elo now has 20+ million retail and hospitality installations in 80+ 
The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 9, 2018 

PUBLIC VERSION 

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countries with products designed in California and three locations within the United States.1 Elo intellectual property is 

protected by global patent, trademark and design registrations. 

The following discussion addresses specific information that is requested in the Federal Register on July 11, 2018 

(83 Fed. Reg. 32181) concerning the three questions provided and responded to below. 

I. Whether the particular product is available only from China? In addressing this factor, requestors should 

address specifically whether the particular product and/or comparable product is available from sources in 

the United States and/or in third countries.

 [ 

 

1

 Elo locations in the United States include: California: Milpitas; New York: Rochester; Tennessee: Knoxville. 
The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 9, 2018 

PUBLIC VERSION 

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The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 9, 2018 

PUBLIC VERSION 

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 ] 

II. Whether the imposition of additional duties on the particular product would cause severe economic harm 

to the requestor or other U.S. interests.

[ 

] 
The Honorable Robert E. Lighthizer 

United States Trade Representative 

Office of the United States Trade Representative 

October 9, 2018 

PUBLIC VERSION 

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III. Whether the particular product is strategically important or related to ‘‘Made in China 2025’’ or other 

Chinese industrial programs. 

[ 

 

] 

IV. Conclusion 

[ 

] Should any additional information be needed to complete your assessment, we remain at your assistance. I 

certify that the information provided is complete and correct to the best of my knowledge. 

Respectfully submitted, 

Patrick Smith 

Senior Manager of Global Logistics 

Elo Touch Solutions, Inc. 

445 S. Gay Street, Suite 406 

Knoxville, TN 37902 

865-235-8166