Atlas Power LLC v. United States

2026 CIT 04
CourtUnited States Court of International Trade
DecidedJanuary 27, 2026
Docket23-00084
StatusPublished

This text of 2026 CIT 04 (Atlas Power LLC 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
Atlas Power LLC v. United States, 2026 CIT 04 (cit 2026).

Opinion

Slip Op. 26-4

UNITED STATES COURT OF INTERNATIONAL TRADE

ATLAS POWER LLC,

Plaintiff, Before: Lisa W. Wang, Judge v. Court No. 23-00084 UNITED STATES,

Defendant.

Opinion and Order

[Granting in part and denying in part Plaintiff’s motion for summary judgment and granting in part and denying in part Defendant’s cross motion for summary judgment.]

Dated: January 27, 2026

J. Kevin Horgan, deKieffer & Horgan, PLLC, of Washington, D.C., argued for Plaintiff Atlas Power LLC. With him on the brief was Merisa A. Horgan.

Mathias Rabinovitch, Trial Attorney, U.S. Department of Justice, Civil Division, Commercial Litigation Branch, of New York, NY, argued for Defendant United States. With him on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Aimee Lee, Assistant Director. Of Counsel on the brief was Sabahat Chaudhary, Office of the Assistant Chief Counsel, International Trade Litigation, U.S. Customs and Border Protection.

Wang, Judge: Before the court are cross motions for summary judgment. Pl.’s

Mot. for Summ. J. (“Pl.’s Mot.”), ECF No. 45; Def.’s Cross Mot. for Summ. J. and Resp.

in Opp. to Pl.’s Mot. for Summ. J. (“Def.’s Mot.”), ECF No. 49. Plaintiff Atlas Power LLC

(“Plaintiff” or “Atlas”) challenges U.S. Customs and Border Protection’s (“Customs”)

denial of its protest against the assessment of duties imposed under section 301 of the

Trade Act of 1974 (“section 301 duties”) on NVIDIA Crypto Mining Processor (“CMP”) Court No. 23-00084 Page 2

170HX printed circuit assemblies (“imported merchandise” or “CMP Boards”), which

were imported by Plaintiff from October 5, 2021, through November 1, 2021. Third Am.

Compl. ¶ 1, ECF No. 39; see Trade Act of 1974, Pub. L. No. 93-618, 88 Stat. § 301,

1978, 2041 (1974) (codified as amended at 19 U.S.C. § 2411). Plaintiff argues that the

imported merchandise was properly classified by Customs under subheading

8473.30.1180 of the Harmonized Tariff Schedule of the United States (“HTSUS”) and

meets the definitions of the exclusions from the assessment of section 301 duties

provided in U.S. Notes 20(ttt)(iii)(108) through (110). Pl.’s Mot. at 16; see also HTSUS

8473.30.1180 (2021). The United States (“Defendant” or “government”) cross moves for

summary judgment, arguing that the imported merchandise is properly classified under

HTSUS subheading 8543.90.68 and, alternatively, even if the imported merchandise is

properly classified under HTSUS subheading 8473.30.1180, it does not meet the

definitions of the exclusions provided for in U.S. Notes 20(ttt)(iii)(108) through (110). 1

Def.’s Mot. at 9; see also HTSUS 8543.90.68 (2021).

For the following reasons, the court finds that the imported merchandise is:

(1) properly classified under HTSUS subheading 8473.30.1180; and (2) does not meet

1 Defendant further claims that even if the CMP Boards fall within HTSUS subheading

8473.30.1180, a portion of the entries of imported merchandise are not covered by the retroactive application of the exclusions from section 301 duties. Def.’s Mot. at 10.

Because the court concludes that the imported merchandise does not meet the definitions of the exclusions set forth in U.S. Notes 20(ttt)(iii)(108) through (110) to be excluded from the assessment of section 301 duties, it need not consider the effective date of the retroactive exclusions. Court No. 23-00084 Page 3

the definitions of the exclusions provided in U.S. Notes 20(ttt)(iii)(108) through (110) as

articles excluded from section 301 duties.

BACKGROUND

I. Procedural Background

Plaintiff entered four shipments of the imported merchandise from the People’s

Republic of China (“PRC”) into a foreign trade zone as privileged foreign merchandise in

October and November of 2021. Summons, ECF No.1. Plaintiff subsequently entered

the merchandise for consumption under cover of: (1) entry number 8GF-2000360-5 on

October 5, 2021; (2) entry number 8GF-2000378-7 on November 1, 2021; (3) entry

number 8GF-2000380-3 on November 12, 2021; and (4) entry number 8GF-2000384-5

on November 17, 2021. Id. On August 12, 2022, the entries auto liquidated at the

classification and rate of duty asserted at the time of entry under HTSUS subheading

8473.30.1180, which provides for “Parts and accessories (other than covers, carrying

cases and the like) suitable for use solely or principally with machines of headings 8470

to 8472 … parts and accessories of the machines of heading 8471 [i.e., automatic data

processing machines].” Third Am. Compl. ¶ 12.

At the time of entry, PRC-origin merchandise classified under HTSUS

subheading 8473.30.1180 was subject to section 301 duties of 25 percent ad valorem.

See Notice of Modification of Section 301 Action: China’s Acts, Policies, and Practices

Relating to Technology Transfer, Intellectual Property, and Innovation, 83 Fed. Reg.

47,974, 47,975 (USTR Sept. 21, 2018). On March 28, 2022, the Office of the United

States Trade Representative (“USTR”) reinstated certain exclusions from section 301

duties that had previously been rescinded, making them retroactive to October 12, Court No. 23-00084 Page 4

2021. See Notice of Reinstatement of Certain Exclusions: China’s Acts, Policies, and

Practices Related to Technology Transfer, Intellectual Property, and Innovation, 87 Fed.

Reg. 17,380, 17,382 (USTR Mar. 28, 2022) (“Reinstatement Notice”). 2

Plaintiff filed a timely protest 3 concerning the imported merchandise on October

26, 2022, which Customs denied on November 21, 2022. Third Am. Compl. ¶ 14. In its

protest decision, Customs did not alter the tariff classification of the imported

merchandise under HTSUS subheading 8473.30.1180 and found that the CMP Boards

did not meet the descriptions for the exclusions from the assessment of section 301

duties. Pl.’s Ex. In Supp. of Mot. for Summ. J., Ex. 2, ECF No. 45-3 at 1, Appx000063

(“Atlas Protest Decision”).

On April 19, 2023, Plaintiff commenced this action. Summons. Plaintiff filed a

motion for summary judgment on November 12, 2024. Pl.’s Mot. Defendant filed a cross

motion for summary judgment and response to Plaintiff’s motion for summary judgment

on January 17, 2025. Def.’s Mot. On April 15, 2025, Plaintiff filed a reply in support of its

motion for summary judgment and a response to Defendant’s cross motion for summary

judgment. Pl.’s Reply in Supp. of Mot. for Summ. J. & Resp. to Def.’s Cross Mot. for

Summ. J. (“Pl.’s Reply Br.”), ECF No. 55. On May 20, 2025, Defendant filed a reply in

2 The USTR announced that “the reinstated exclusions will apply to goods entered for

consumption ... on or after ... October 12, 2021, that are not liquidated [or for which liquidation is not final].” Reinstatement Notice, 87 Fed. Reg. at 17,380 (USTR Mar. 28, 2022). 3 In its protest, Plaintiff asserted that the imported merchandise was excluded from the

assessment of section 301 duties as a result of the retroactive nature of the announced exclusions. Third Am. Compl. ¶ 14. Court No. 23-00084 Page 5

support of its cross motion for summary judgment. Def.’s Reply in Supp. of Cross Mot.

for Summ. J. (“Def.’s Reply Br.”), ECF No. 58. On June 4, 2025, the court granted

Plaintiff’s motion for leave to file a sur-reply and accepted Defendant’s response to

Plaintiff’s motion for leave to file a sur-reply. Pl.’s Mot.

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