Honeywell Aerospace Files an ITC Complaint Against Lucid and Rivian Over Electronic Control Units (DN 3947).

The notice

The Commission's notice of receipt of complaint and solicitation of comments relating to the public interest was issued November 6, 2026. It says the Commission received a complaint and a submission under section 210.8(b) of its Rules of Practice and Procedure, filed on behalf of Honeywell Aerospace US LLC on November 5, 2026. The complaint alleges violations of section 337 of the Tariff Act of 1930, 19 U.S.C. 1337, in the importation into the United States, the sale for importation, and the sale within the United States after importation of certain electronic control units and products containing the same.

The complaint names five respondents: Lucid Group, Inc. of Newark, California; Lucid USA, Inc. of Casa Grande, Arizona; Lucid Group USA, Inc. of Newark, California; Rivian Automotive, Inc. of Irvine, California; and Rivian Automotive, LLC of Wittman, Arizona. Honeywell Aerospace asks for a limited exclusion order, cease and desist orders, and a bond on the respondents' alleged infringing articles during the 60-day Presidential review period under 19 U.S.C. 1337(j).

Public interest comments

The notice invites proposed respondents, other interested parties, members of the public, and interested government agencies to comment on whether the requested relief would affect the public health and welfare in the United States, competitive conditions in the U.S. economy, the production of like or directly competitive articles in the United States, or U.S. consumers. It asks in particular how the articles are used in the United States, whether there are public health, safety, or welfare concerns, whether like or directly competitive articles made in the United States by Honeywell Aerospace, its licensees, or third parties could replace them, whether those suppliers could replace the volume of articles within a commercially reasonable time, and how the requested orders would affect U.S. consumers. Written submissions are due by close of business eight calendar days after the notice is published in the Federal Register, and the complainant may reply within three calendar days after the date the submissions are due. Submissions and replies are limited to five pages and should refer to Docket No. 3947.

The Arizona and Texas cases

Honeywell Aerospace is already suing both companies in district court. On September 18, 2026, it sued Rivian Automotive, LLC and Rivian Automotive, Inc. in the District of Arizona, Honeywell Aerospace US LLC v. Rivian Automotive, LLC, No. 2:26-cv-06694, and Lucid Group, Inc. and Lucid Group USA, Inc. in the Eastern District of Texas, Honeywell Aerospace US LLC v. Lucid Group, Inc., No. 2:26-cv-00841. Each complaint asserts the same seven U.S. patents: 7,088,264, 7,286,062, 7,840,352, 8,314,816, 8,364,334, 9,355,567, and 10,133,856. The Arizona complaint accuses Rivian vehicles operating Driver+, the Rivian Autonomy Platform, and Autonomy+. The Texas complaint accuses Lucid Air and Lucid Gravity vehicles operating versions of the Lucid DreamDrive platform. Both complaints allege willful infringement and demand a jury.

Both dockets show requests in October 2026 to extend the defendants' time to answer.

Receipt is not institution

Under 19 CFR 210.10(a)(1), the Commission determines whether to institute an investigation within 30 days after a complaint is filed, unless an exception applies, such as exceptional circumstances, a request by the complainant to postpone the determination, or withdrawal of the complaint. Under 19 CFR 210.10(b)(1), an investigation is instituted by publication of a notice in the Federal Register.

What to watch next

Watch for Federal Register publication of the receipt notice, which starts the eight-day comment period, any public interest submissions and replies, and the Commission's decision on institution, which would define the scope of any investigation. In Arizona and Texas, watch for the defendants' responses to the complaints and, if an investigation is instituted, any request under 28 U.S.C. 1659 by a party that is also a Respondent to stay claims involving the same issues. Any of these matters can end at any time, including by settlement or withdrawal.