U.S. International Trade Commission Ends Solar Panel Investigation
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On February 13, 2026, the U.S. International Trade Commission (USITC) announced it will not review an initial determination to end a trade investigation. This decision terminates Investigation Nos. 337-TA-1422 and 337-TA-1425.
The investigations focused on certain TOPCon solar cells, modules, panels, and related products. These products were alleged to infringe U.S. Patent No. 9,722,104 and U.S. Patent No. 10,230,009.
The complaints were filed by Trina Solar (U.S.), Inc. of Fremont, California; Trina Solar US Manufacturing Module 1, LLC of Wilmer, Texas; and Trina Solar Co., Ltd. of Xinbei District, China.
The complaints claimed patent infringement and said that a domestic industry existed. USITC officially opened Investigation No. 337-TA-1422 on November 5, 2024, and Investigation No. 337-TA-1425 on December 9, 2024.
The investigations named several companies as respondents. These included:
- Runergy USA Inc., Pleasanton, CA
- Runergy Alabama Inc., Huntsville, AL
- Jiangsu Runergy New Energy Technology Co., Ltd., Yangcheng City, China
- Adani Solar USA Inc., Irving, TX
- Adani Green Energy Ltd., Ahmedabad, India
- CSI Solar Co., Ltd., Suzhou, China
- Canadian Solar Inc., West Guelph, Canada
- Canadian Solar (USA) Inc., Walnut Creek, CA
- Canadian Solar Manufacturing (Thailand) Co., Ltd., Bo Win, Thailand
- Canadian Solar US Module Manufacturing Corporation, Mesquite, TX
- Recurrent Energy Development Holdings, LLC, Austin, TX
The Commission’s Office of Unfair Import Investigations took part in the investigations.
On January 21, 2025, the Commission combined the two investigations.
On January 31, 2025, the Commission approved removing Adani Green Energy Ltd. from the case and added Mundra Solar PV Ltd. as a respondent.
On February 12, 2025, the target date for completing the investigation was changed to May 20, 2026.
On February 13, 2025, the Commission approved ending the case against Recurrent Energy Development Holdings LLC.
On June 17, 2025, the Commission updated the name of Trina Solar US Manufacturing Module 1, LLC to T1 G1 Dallas Solar Module (Trina) LLC.
On August 26, 2025, the investigation was partially ended for claims 11 of the ‘104 patent and claim 14 of the ‘009 patent.
On December 8, 2025, the deadline for completing the investigation was extended to August 18, 2026.
On December 9, 2025, more claims were withdrawn: claims 2–5 and 9–10 of the ‘104 patent, and claims 2, 3, 5, 7, 11–13, and 16 of the ‘009 patent.
On January 15, 2026, the Administrative Law Judge approved the parties’ joint motion to end the investigation entirely. The judge found the motion followed Rule 210.21(a)(1) and said that ending the investigation was in the public interest.
No party reviewed the judge’s decision. As a result, the USITC chose not to review the decision.
The investigation is now officially closed.
This action is taken under Section 337 of the Tariff Act of 1930, as amended (19 U.S.C. 1337), and Part 210 of the Commission’s rules (19 CFR part 210).
The Commission made its decision on February 10, 2026.
The document was issued by Lisa Barton, Secretary to the Commission, on February 11, 2026. It is filed under Federal Register Document number 2026-02949.
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