Al Noor Alaili Trading Co., LLC v. U.S. Department of Commerce, et al.

District Court, E.D. Michigan·Decided March 27, 2026·No. 2:23-cv-10084·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

AL NOOR ALAILI TRADING CO., LLC,

Plaintiff, Case No. 2:23-cv-10084

v. Honorable Susan K. DeClercq United States District Judge U.S. DEPARTMENT OF COMMERCE, et al.,

Defendants. _____________________________________/

ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS (ECF No. 25), DISMISSING PLAINTIFF’S AMENDED COMPLAINT (ECF No. 22), AND CLOSING THE CASE

This case involves Plaintiff Al Noor Alaili Trading Co, LLC (“ANATCO”)’s challenge to an agency action that is statutorily exempt from review under the Administrative Procedures Act (APA). So, instead, ANATCO has brought an ultra vires claim against the United States Department of Commerce (Commerce) and Commerce’s subsidiary agency, the U.S. Bureau of Industry and Security (BIS), asserting that the agencies and their employees exceeded their statutory and regulatory authority and acted contrary to law in taking action that adversely impacted ANATCO. Defendants, however, seek dismissal of ANATCO’s complaint, arguing that it has not met the high burden of pleading an ultra vires claim. As explained below, this Court will grant Defendants’ motion and will dismiss ANATCO’s complaint because ANATCO has not plausibly alleged that Defendants acted ultra vires in taking agency action that impacted ANATCO.

I. BACKGROUND A. Statutory and Administrative Framework In 1979, Congress enacted the Export Administration Act of 1979 (EAA),

which “provided significant authority to the President—and to the agencies to which he delegated that authority—to regulate exports to foreign countries and to limit trade ‘determined by the President to be against the national interest.’” Jacob Aaron Pagano, Contrary to National Security: The Rise of the Entity List in U.S. Policy

Towards China and Its Role in the National Security Administrative State, 61 COLUM. J. TRANSNAT’L L. 453, 465–66 (2023) (hereafter “Contrary to National Security”) (quoting the EEA, Pub. L. No. 96–72 §§ 1–4, 93 Stat. 503, 503–06

(1979)). After the passage of the EAA, Commerce implemented the Export Administration Regulations (EAR) to govern exports from the United States to foreign countries. See generally 15 C.F.R. § 730.1 et seq. When the EAA lapsed in 2001, the President implemented Executive Order

13,222 on August 17, 2001, which “continued the EAR under the International Economic Powers Act.” Shannon Moloney, BIS Meets Loper Bright: Rethinking “National Security,” 10 ALR ACCORD 143, 148 (2025) (citing 66 Fed. Reg. 44025);

see also Micei Int’l v. Dep’t of Com., 613 F.3d 1147, 1150 (D.C. Cir. 2010) (explaining that the President issued the executive order after finding that “the expiration of the EAA and the resulting absence of an operative export control law”

qualified as a national emergency to warrant issuing the executive order). Then, in 2018, Congress provided a more permanent statutory basis for the regulation and control of exports by passing the Export Controls Reform Act of 2018

(ECRA), which requires BIS to control the export of emerging and foundational technologies “essential to the national security of the United States.” 50 U.S.C. § 4817(a)(1)(A). To that end, the ECRA empowers the Secretary of Commerce to control the export of items that can be used for the following purposes:

(i) the proliferation of weapons of mass destruction or of conventional weapons; (ii) the acquisition of destabilizing numbers or types of conventional weapons; (iii) acts of terrorism; (iv) military programs that could pose a threat to the security of the United States or its allies; or (v) activities undertaken specifically to cause significant interference with or disruption of critical infrastructure.

50 U.S.C. § 4811(2)(A). The ECRA also “requires the Secretary to take various other substantive, licensing, and compliance actions related to export controls,” and grants the Secretary broad authority to “undertake any other action as is necessary to carry out this subchapter that is not otherwise prohibited by law.” Changji Esquel Textile Co. v. Raimondo, 40 F.4th 716, 720 (D.C. Cir. 2022), aff’d, 40 F.4th 716 (D.C. Cir. 2022) (quoting 50 U.S.C. § 4813(a)(16)); see also 50 U.S.C. § 4813(a)(5)–(15).

As most relevant to this case, the ECRA also directs Commerce, “in consultation with the Secretary of State, the Secretary of Defense, the Secretary of Energy,” and the President, to “establish and maintain a list of foreign persons and

end-uses that are determined to be a threat to the national security and foreign policy of the United States pursuant to the policy set forth in [50 U.S.C. §] 4811(2)(A).” 50 U.S.C. § 4813(a)(2). The list of foreign persons that are determined to be a threat to national security and foreign policy is often referred to as “the Entity List.” See

Changji, 573 F. Supp. 3d at 108 (explaining the function and purpose of the Entity List). As it relates to the Entity List, the EAR articulates “[c]riteria for revising the

Entity List,” and permit Commerce and BIS to add a foreign party to the Entity List “if there is reasonable cause to believe, based on specific and articulable facts” that a foreign party to an export transaction poses a “significant risk of being or becoming involved in activities that are contrary to the national security or foreign policy

interests of the United States.” 15 C.F.R. § 744.11(b). The EAR outlines five categories of activities “that could be or represent a significant risk of being contrary to the national security or foreign policy interests of the United States.” Id. These

five categories of activities are: (1) Supporting persons engaged in acts of terror.

(2) Actions that could enhance the military capability of, or the ability to support terrorism of governments that have been designated by the Secretary of State as having repeatedly provided support for acts of international terrorism.

(3) Transferring, developing, servicing, repairing or producing conventional weapons in a manner that is contrary to United States national security or foreign policy interests or enabling such transfer, service, repair, development, or production by supplying parts, components, technology, or financing for such activity.

(4) Prevention of the accomplishment of an end use check conducted by or on behalf of BIS or the Directorate of Defense Trade Controls of the Department of State by:

(i) The entity or persons that own or control an address that presents a high diversion risk precluding access to; refusing to provide information about; or providing false or misleading information about parties to the transaction or the item to be checked.

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Al Noor Alaili Trading Co., LLC v. U.S. Department of Commerce, et al., (E.D. Mich. 2026).

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