Aloha Pencil Co. v. United States

CourtUnited States Court of International Trade
DecidedMay 6, 2026
Docket25-00102
StatusPublished

This text of Aloha Pencil Co. v. United States (Aloha Pencil Co. v. United States) is published on Counsel Stack Legal Research, covering United States Court of International Trade primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Aloha Pencil Co. v. United States, (cit 2026).

Opinion

Slip Op. 26-46

UNITED STATES COURT OF INTERNATIONAL TRADE

ALOHA PENCIL COMPANY, LLC,

Plaintiff,

v.

UNITED STATES, Before: Mark A. Barnett, Chief Judge Defendant, Court No. 25-00102

and

CHINA FIRST PENCIL CO., LTD., and DIXON TICONDEROGA COMPANY,

Defendant-Intervenors.

OPINION AND ORDER

[Granting Defendant’s motion to dismiss for lack of subject-matter jurisdiction.]

Dated: May 6, 2026

Mark B. Lehnardt, Davis & Leiman, of Washington, DC, for Plaintiff Aloha Pencil Company, LLC.

Nelson Kuan, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, for Defendant United States. Also on the brief were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director, and Franklin E. White, Jr., Assistant Director. Of counsel on the brief was Samuel E. Childerson, U.S. Department of Commerce, of Washington, DC.

Ned H. Marshak, Francis J. Sailer, Jordan C. Kahn, and Michael S. Holton, Grunfeld Desiderio Lebowitz Silverman & Klestadt LLP, of Washington, DC, and New York, NY, for Defendant-Intervenor China First Pencil Co., Ltd.

Michael J. Larson, Felicia Leborgne Nowels, and Li X. Massie, Akerman LLP, of Tallahassee, FL, for Defendant-Intervenor Dixon Ticonderoga Company. Court No. 25-00102 Page 2

Barnett, Chief Judge: Plaintiff Aloha Pencil Company, LLC (“Aloha Pencil”)

commenced this case to challenge the U.S. Department of Commerce’s (“Commerce”

or “the agency”) notice of rescission, in its entirety, of the 2023–2024 administrative

review of the antidumping duty order on cased pencils from the People’s Republic of

China (“China”), Certain Cased Pencils From the People’s Republic of China, 90 Fed.

Reg. 19,268 (Dep’t Commerce May 7, 2025) (rescission of antidumping duty admin.

rev.; 2023–2024) (“Rescission Notice”). See Compl. ¶ 1, ECF No. 9. Commerce

rescinded the review after determining that Aloha Pencil did not qualify as a domestic

interested party able to request the review of foreign producers and exporters and that

the remaining companies subject to the review had no reviewable entries. Rescission

Notice, 90 Fed. Reg. at 19,269. This matter is before the court on Defendant United

States’ (“the Government”) motion to dismiss for lack of subject-matter jurisdiction.

Def.’s Mot. to Dismiss for Lack of Subject Matter Jurisdiction (“Def.’s Mot.”), ECF No.

44; see also Def.’s Reply in Supp. of its Mot. to Dismiss for Lack of Subject Matter

Jurisdiction (“Def.’s Reply”), ECF No. 49. The Government argues that Plaintiff has not

demonstrated Article III standing. See generally Def.’s Mot. Aloha Pencil opposes the

Government’s motion. Resp. to Mot. to Dismiss (“Pl.’s Resp.”), ECF No. 48. Because,

as discussed below, Aloha Pencil made no factual allegations in its complaint to support

its claim to be a manufacturer, producer, or wholesaler of the domestic like product, the

court will grant the Government’s motion. 1

1 Also pending are Defendant-Intervenors China First Pencil Co., Ltd.’s (“China First”)

and Dixon Ticonderoga Company’s (“Dixon”) responses to the court’s order to show Court No. 25-00102 Page 3

BACKGROUND

I. Factual Background 2

In 1994, Commerce published an antidumping duty order on certain cased

pencils from China. Am. Compl. ¶ 22 (citing Certain Cased Pencils from the People’s

Republic of China, 59 Fed. Reg. 66,909 (Dep’t Commerce Dec. 28, 1994) (antidumping

duty order) (“AD Order”)). Aloha Pencil alleges it is a “U.S manufacturer, producer, or

wholesaler” of cased pencils. Id. ¶ 11. Aloha Pencil requested an administrative review

of the AD Order for the 2023 to 2024 period of review (“POR”). See id. ¶¶ 9, 24. Before

initiating the administrative review, Commerce issued to Aloha Pencil a domestic

standing questionnaire. Id. ¶ 23. On January 27, 2025, prior to receiving Aloha Pencil’s

response, Commerce published its notice of initiation of the administrative review. Id.

¶ 24 (citing Initiation of Antidumping and Countervailing Duty Admin. Revs., 90 Fed.

Reg. 8,187 (Dep’t Commerce Jan. 27, 2025) (“Initiation Notice”)). The review covered

39 companies, Initiation Notice, 90 Fed. Reg. at 8,190, many, but not all, of which

Commerce included based on Aloha Pencil’s request for review, id. at 8,194 n.5. 3

cause why they should remain in this action following the court’s determination that this action must proceed under the court’s 28 U.S.C. § 1581(i) jurisdiction. See Mem. and Order at 8–9 (“Jurisdiction Mem.”), ECF No. 39; China First’s Resp. to Ct. Order to Show Cause and Mot. to Intervene (“China First’s Resp.”), ECF No. 45; [Dixon’s] Resp. to Ct.’s Mem. and Order and, Alternatively, Mot. to Intervene as Def.-Intervenor (“Dixon’s Resp.”), ECF No. 47. Because the court is dismissing this action, the court need not address these arguments. 2 The facts are taken primarily from Aloha Pencil’s Amended Complaint, ECF No. 41. 3 Commerce noted that because the agency concluded in the preceding review that

Aloha Pencil did not have standing to request an administrative review, Commerce “intend[ed] to reexamine its standing in this administrative review.” Initiation Notice, 90 Fed. Reg. at 8,194 n.5. Court No. 25-00102 Page 4

Aloha Pencil responded to Commerce’s initial and supplemental standing

questionnaires. Am. Compl. ¶¶ 25–27.

On March 26, 2025, Commerce determined that Aloha Pencil lacked standing to

request an administrative review because Aloha Pencil “did not qualify as a domestic

interested party.” Id. ¶ 32. 4 Commerce issued a notice of intent to rescind the

administrative review of the AD Order and, thereafter, published its notice of the

rescission. Id. ¶ 34; see also id. ¶ 1 (citing Rescission Notice). Commerce explained

that Aloha Pencil was not a “bona fide producer, manufacturer, or wholesaler of a

domestic like product during the POR” and thus was ineligible to request a review.

Rescission Notice, 90 Fed. Reg. at 19,269. Additionally, because Aloha Pencil “was the

sole requestor” for 34 companies subject to the review and “there were no reviewable,

suspended entries of subject merchandise from the five remaining companies,”

Commerce rescinded the review in its entirety. Id.

II. Procedural History

Aloha Pencil commenced this case challenging the Rescission Notice. Compl.

¶ 1. Plaintiff initially alleged jurisdiction pursuant to 28 U.S.C. § 1581(c), further citing

19 U.S.C. § 1516a(a)(2)(A)(i)(I) and (a)(2)(B)(iii). Id. ¶¶ 3, 8. 5 Based on Plaintiff’s

4 Commerce defines “domestic interested party” in reference to 19 U.S.C. § 1677(9)(C)–

(G). See 19 C.F.R. § 351.102(b)(17); id. § 351.213(b)(1) (authorizing domestic interested parties to request an administrative review). Relevant here, section 1677(9)(C) defines “interested party” as “a manufacturer, producer, or wholesaler in the United States of a domestic like product.” 19 U.S.C. § 1677(9)(C).

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