Exhibit 3

Case: 1:20-cv-03542 Document #: 1-1 Filed: 06/17/20 Page 1 of 6 PageID #:12
Prepared by

U.S. Customs and Border Protection 

Office of Trade

Intellectual 

Property Rights 

Fiscal Year 2018 Seizure Statistics 

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Table of Contents 

Executive Summary...............................................................6 

Year in Review.......................................................................7 

IPR & E-Commerce......................................................................15 

Fiscal Year 2018 IPR Seizure Statistics .......................................16 

Number of Seizures by Product ...................................................20 

Products Seized by MSRP ...........................................................22 

Total MSRP for Products Seized by Economy .............................24 

Seizures by Economy...................................................................26 

Seizures by Shipping Environment...............................................28 

Health, Safety, and Security .........................................................30 

Exclusion Orders ..........................................................................32 

Centers of Excellence and Expertise............................................33 

IPR Points of Contact ...................................................................34 

Disclaimer: The information contained in this report does not 

constitute the official trade statistics of the United States. The 

statistics, and the projections based upon those statistics, are 

not intended to be used for economic analysis, and are provided 

for the purpose of establishing U.S. Department of Homeland 

Security workload. 

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EXECUTIVE SUMMARY 

Products that infringe U.S. trademarks and copyrights are subject 

to exclusion orders issued by the United States International 

Trade Commission threaten the health and safety of American 

consumers and pose risks to our national interests. U.S. Customs 

and Border Protection (CBP) and U.S. Immigration and Customs 

Enforcement (ICE) Homeland Security Investigations’ (HSI) 

enforcement of intellectual property rights (IPR) mitigates the 

financial and welfare risks posed by imports of illicit products.

Each year, more than 11 million maritime containers arrive at 

our seaports. At our land borders, another 10 million arrive by 

truck and 3 million arrive by rail. An additional quarter billion 

more cargo, postal, and express consignment packages arrive 

through air travel. The Department of Homeland Security (DHS) 

remains vigilant in targeting shipments containing IPR-infringing 

goods, levying civil fines and criminally investigating those who 

seek to violate our trade laws, harm consumers, and damage our 

economy. 

In fiscal year (FY) 2018, the number of IPR seizures decreased 

by 333 seizures to 33,810 from 34,143 in FY 2017. The total 

estimated manufacturer’s suggested retail price (MSRP) of the 

seized goods, had they been genuine, increased to nearly $1.4 

billion from over $1.2 billion in FY 2017. 

In FY 2018, ICE-HSI arrested 381 individuals, obtained 296 

indictments, and received 260 convictions related to intellectual 

property crimes. 

6 EXECUTIVE SUMMARY 

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Mail Shipment 

Express Bills 

Growth of Small Shipment (in millions) 

500 

400 

300 

200 

100 

0 

76 82 

170 

91 

222 

96 

275 

110 

502 

475 

150 161 

2013 2014 2015 2016 2017 2018 

 

IPR & E-Commerce 

E-commerce sales, including those through third-party platforms, have 

resulted in a sharp increase in the shipment of small packages into the 

United States. In FY 2018, there were 161 million express shipments, 

and 475 million packages shipped through the international mail 

environment. 

Over 90% of all intellectual property seizures occur in the international

mail and express environments. A majority of those fall under the de

minimis threshold of $800. 

In March 2018, CBP released its CBP E-Commerce Strategy. The

strategy strengthens CBP’s ability to protect the public and U.S.

economy from noncompliant goods. The strategy drives compliance

and enforcement, and promotes coordination. CBP is working toward 

implementation. 

More e-commerce related information can be found at 

https://www.cbp.gov/trade/basic-import-export/e-commerce 

IPR & E-COMMERCE 15 

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FISCAL YEAR 2018 IPR SEIZURE STATISTICS 

BY NUMBER OF SEIZURES 

46 

% 41 

% 

2 

%

1 

% 

1 

% 

9 

% 

China (Mainland) 

Hong Kong

Turkey

India

 Taiwan

All Other Countries 

FY 2018 TOTALS: 

33,810 - NUMBER OF SEIZURES 

$1,399,873,842 - MSRP 

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