Section 1 - Conflict Minerals Disclosure
Item 1.01 Conflict Minerals Disclosure and Report
Introduction
This Form SD is filed pursuant to Rule
13p-1
under the Securities Exchange Act of 1934, as amended, for the reporting period January 1, 2018 to December 31, 2018 (the
Reporting Period
).
InterDigital, Inc. (the
Company
) designs and develops advanced technologies that enable and enhance wireless communications and
capabilities. Since our founding in 1972, our engineers have designed and developed a wide range of innovations that are used in digital cellular and wireless products and networks, including 2G, 3G, 4G and IEEE
802-related
products and networks, as well as video processing, coding and display technology. Given our long history and focus on advanced research and development, we have one of the most significant patent
portfolios in the wireless and video industries. We derive revenues primarily from patent licensing, with contributions from patent sales, product sales, technology solutions licensing and sales and engineering services.
As part of the Companys compliance with the rules of the U.S. Securities and Exchange Commission (the
SEC
) concerning conflict
minerals, we evaluated the products that we manufacture or contract to manufacture to determine whether any such products contain conflict minerals that are necessary to the functionality or production of those products. The SEC defines the term
conflict mineral
to mean columbite-tantalite (coltan), cassiterite, gold, wolframite, or their derivatives, which are limited to tantalum, tin, and tungsten. In connection with such evaluation, we determined that one of our
wholly-owned subsidiaries, Hillcrest Laboratories, Inc., manufactured or contracted to manufacture a small number of products during the Reporting Period that included components containing conflict minerals that are necessary to the functionality
or production of those products (the
Covered Products
). The Covered Products represent an extremely small fraction of the Companys revenue base, generating less than one percent of our total revenues for the Reporting
Period.
Reasonable Country of Origin Inquiry (
RCOI
)
Following our initial determination that the Covered Products contain conflict minerals, we conducted a good faith RCOI reasonably designed to determine
whether such conflict minerals may have originated in the Democratic Republic of Congo or an adjoining country (the
Covered Countries
). As part of this process, we obtained Conflict Minerals Reporting Templates
(
CMRTs
) from suppliers who supplied components to us during the Reporting Period that contained one or more conflict minerals. The CMRT is regarded as the most common reporting tool for conflict minerals content and sourcing
information worldwide, developed by several of the worlds leading consumer electronics companies.
CMRTs were reviewed for completeness and
consistency, and, to the extent possible, we determined the specific conflict minerals that were supplied to us by each supplier in order to analyze each suppliers CMRT more precisely. If a supplier did not provide a CMRT, we contacted such
supplier for information about its conflict minerals policy and sourcing and reviewed such suppliers conflict minerals disclosure on its public website, to the extent made available. After reviewing the CMRTs and other information provided or
otherwise made available to us, we requested additional supplier information and followed up with suppliers as necessary.