Law360, New York ( May 18, 2015, 10:10 AM EDT) -- It is axiomatic that before a patent owner can take advantage of U.S. International Trade Commission remedies against unfair imports under Section 337 (19 U.S.C. § 1337), the patent owner must show that a "domestic industry" exists with respect to the asserted patent. That showing in turn requires proof of "significant" or "substantial" domestic investment connected to the patent. In Lelo Inc. v. International Trade Commission, Case No. 2013-1582 (Fed. Cir. May 11, 2015) the Federal Circuit has provided important guidance regarding the record a patent owner must develop in order to demonstrate the significance of the domestic investment at issue — the court rejected the notion that showing the "qualitative" significance of a patent owner's domestic investments can overcome an absence of evidence as to the "quantitative" significance of those investments....