Law360, New York ( August 22, 2014, 10:04 AM EDT) -- The Antitrust Division of the U.S. Department of Justice has aggressively pursued international cartel cases in the recent past, including one recent jury trial in San Francisco that resulted in a $500 million fine against AU Optronics Corp. The Ninth Circuit recently affirmed the conviction in United States v. Hui Hsiung, 2014 U.S. LEXIS 13051 (9th Cir. July 10, 2014). However, in a related civil case brought by Motorola Mobility LLC against AU Optronics, the Seventh Circuit adopted a position that would appear at first to make it more difficult for the antitrust enforcement agencies and private plaintiffs to pursue foreign anti-competitive conduct where the court deems the effects of that conduct on U.S. commerce to be too remote....