![Wrapped Package](/-/media/images/publications/2019/10/returns-count-as-sales-under-section-337/articleimage/wrapped-package.jpeg?rev=31cd95d5f3ac4b1480f340003522317f&la=en&h=675&w=1080&hash=90123B6DB25E7B7C625F097E56E95D24)
Returns Count as Sales under Section 337, ITC Section 337
From a conceptual standpoint, one might think there is a difference between selling an item and charging for a leased item that was never returned. However, a recent decision from the ITC held that charging fees for unreturned rental equipment qualifies as a sale, either contractually or through conversion, for purposes of Section 337. Certain Digital Video Receivers and Related Hardware and Software Components, Inv. No. 337-TA-1103, Order No. 47 (June 3, 2019).