Aloha Pencil Co. v. United States

United States Court of International Trade·Decided May 6, 2026·No. 25-00102·Published

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.

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 Commerce rescinded the review after determining that Aloha Pencil did not qualify as a domestic interested party able to request the review of foreign producers and exporters and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

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). 5 Both provisions of section 1516a pertain to Commerce’s determinations pursuant to 19

U.S.C. § 1675. Section 1516a(a)(2)(B)(iii) governs judicial review of “[a] final determination . . . by the administering authority [i.e., Commerce] . . . under section

allegations of jurisdiction and the absence of any objection thereto, see Joint Status Report (Sept. 17, 2025) at 2, ECF No. 34, this case initially proceeded pursuant to section 1581(c). The court granted motions to intervene as of right on the side of defendant filed by China First and Dixon. Order (Aug. 14, 2025), ECF No. 29; Order (Aug. 14, 2025), ECF No. 30. Upon further review and briefing by the parties, the court determined that it exercised jurisdiction over Commerce’s Rescission Notice pursuant to 28 U.S.C. § 1581(i)(1)(D). Jurisdiction Mem. at 5–8. Section 1581(i) vests the court with “exclusive jurisdiction of any civil action commenced against the United States . . . providing for-- . . . (D) administration and enforcement with respect to the matters referred to in subparagraphs (A) through (C) of this paragraph and subsections (a)-(h) of this section.” 28 U.S.C. § 1581(i)(1)(D).

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