Slip Op. 26-15
UNITED STATES COURT OF INTERNATIONAL TRADE
BIO-LAB, INC., INNOVATIVE WATER CARE, LLC (F/K/A CLEARON CORP.), AND OCCIDENTAL CHEMICAL CORPORATION,
Plaintiffs,
v. Before: Jennifer Choe-Groves, Judge
UNITED STATES, Court No. 24-00118
Defendant,
and
JUANCHENG KANGTAI CHEMICAL CO., LTD. AND HEZE HUAYI CHEMCIAL CO., LTD.,
Defendant-Intervenors.
OPINION AND ORDER
[Remanding the U.S. Department of Commerce’s final results.]
Dated: February 18, 2026
Chase J. Dunn and James R. Cannon, Jr., Cassidy Levy Kent (USA) LLP, of Washington, D.C., for Plaintiffs Bio-Lab, Inc., Innovative Water Care, LLC (f/k/a Clearon Corp.), and Occidental Chemical Corporation. With them on the brief was Ulrika K. Swanson. Court No. 24-00118 Page 2
Tate N. Walker, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for Defendant United States. With him on the brief were Brett A. Shumate, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Reginald T. Blades, Jr., Assistant Director. Of counsel was Shanni Alon, Attorney, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, D.C.
Alexandra H. Salzman, The Inter-Global Trade Law Group, PLLC, of Washington, D.C., for Defendant-Intervenors Juancheng Kangtai Chemical Co., Ltd. and Heze Huayi Chemical Co., Ltd. With her on the brief were Gregory S. Menegaz and Vivien J. Wang.
Choe-Groves, Judge: This action concerns the U.S. Department of
Commerce’s (“Commerce”) final determination in Chlorinated Isocyanurates from
the People’s Republic of China (“Final Results”), 89 Fed. Reg. 49,149 (Dep’t of
Commerce June 11, 2024) (final results of countervailing duty administrative
review; 2021) and accompanying Decision Memorandum for the Final Results of
Countervailing Duty Administrative Review of Chlorinated Isocyanurates from the
People’s Republic of China; 2021 (Dep’t of Commerce June 4, 2024) (“Final
IDM”), PR 143.1
Before the Court is Plaintiffs Bio-Lab, Inc.’s (“Bio-Lab”), Innovative Water
Care, LLC’s (f/k/a Clearon Corp.) (“IWC”), and Occidental Chemical
Corporation’s (“OxyChem”) (collectively, “Plaintiffs”) Memorandum of Law and
Fact in Support of Plaintiffs’ Rule 56.2 Motion for Judgment on the Agency
1 Citations to the administrative record reflect the public record (“PR”) and confidential record (“CR”) numbers filed in this case, ECF Nos. 36, 37, 38. Court No. 24-00118 Page 3
Record. Mem. Law Fact Supp. Pls.’ R. 56.2 Mot. J. Agency R. (“Plaintiffs’
Motion for Judgment Upon the Agency Record” or “Pls.’ Br.”), ECF Nos. 25, 26,
27. The United States (“Defendant”) filed Defendant’s Response in Opposition to
Plaintiffs’ Motion for Judgment Upon the Agency Record. Def.’s Resp. Opp’n
Pls.’ Mot. J. Agency R. (“Def.’s Resp. Br.”), ECF No. 30. Heze Huayi Chemical
Co., Ltd. (“Heze Huayi”) and Juancheng Kangtai Chemical Co., Ltd. (“Kangtai”)
(collectively, “Defendant-Intervenors”) filed the Response Brief of Defendant-
Intervenors Heze Huayi Chemical Co., Ltd. and Juancheng Kangtai Chemical Co.,
Ltd. Resp. Br. Def.-Intervs. Heze Huayi Chemical Co., Ltd. and Juancheng
Kangtai Chemical Co., Ltd. (“Def.-Intervs.’ Resp. Br.”), ECF No. 31. Plaintiffs
filed Plaintiffs’ Reply Brief. Pls.’ Reply Br., ECF Nos. 32, 33, 34. The Court held
oral argument on December 16, 2025. Confidential Oral Argument (Dec. 16,
2025), ECF No. 52.
For the reasons discussed below, the Court grants Plaintiffs’ Motion for
Judgment Upon the Agency Record and remands Commerce’s Final Results.
JURISDICTION AND STANDARD OF REVIEW
The Court has jurisdiction pursuant to Section 516A(a)(2)(B)(iii) of the
Tariff Act of 1930, as amended, 19 U.S.C. § 1516a(a)(2)(B)(iii), and 28 U.S.C.
§ 1581(c). The Court shall hold unlawful any determination found to be Court No. 24-00118 Page 4
unsupported by substantial evidence on the record or otherwise not in accordance
with law. 19 U.S.C. § 1516a(b)(1)(B)(i).
DISCUSSION
I. Statutory Framework for Commerce’s Application of Facts Otherwise Available
Pursuant to the Tariff Act, Commerce has the authority to conduct
countervailing duty investigations and determine whether “the government of a
country or any public entity within the territory of a country is providing, directly
or indirectly, a countervailable subsidy with respect to the manufacture,
production, or export of a class or kind of merchandise imported, or sold (or likely
to be sold) for importation, into the United States.” 19 U.S.C. § 1671(a)(1). The
Court of Appeals for the Federal Circuit (“CAFC”) has said that countervailing
subsidies “exist when (1) a foreign government provides a financial
contribution (2) to a specific industry and (3) a recipient within the industry
receives a benefit as a result of that contribution.” Fine Furniture (Shanghai) Ltd.
v. United States (“Fine Furniture”), 748 F.3d 1365, 1369 (Fed. Cir. 2014) (citing
19 U.S.C. § 1677(5)(B)).
Section 776 of the Tariff Act states that if “necessary information is not
available on the record,” then the agency shall “use the facts otherwise available in
reaching” its determination. 19 U.S.C. § 1677e(a)(1). 19 U.S.C. § 1677e(a)(2)
permits Commerce to select from facts otherwise available if an interested Court No. 24-00118 Page 5
party: (A) withholds information; (B) fails to provide such information by the
deadlines for submission, or in the form and manner requested; (C) significantly
impedes a proceeding; or (D) provides such information but the information cannot
be verified. 19 U.S.C. § 1677e(a)(2).
Commerce’s authority to use facts otherwise available under 19 U.S.C.
§ 1677e(a) is subject to 19 U.S.C. § 1677m(d), which states that:
If the administering authority or the Commission determines that a response to a request for information under this subtitle does not comply with the request, the administering authority or the Commission (as the case may be) shall promptly inform the person submitting the response of the nature of the deficiency and shall, to the extent practicable, provide that person with an opportunity to remedy or explain the deficiency in light of the time limits established for the completion of investigations or reviews under this subtitle. 19 U.S.C. § 1677m(d).
If Commerce determines that “an interested party has failed to cooperate by
not acting to the best of its ability to comply with a request for information” from
the agency, then Commerce “may use an inference that is adverse to the interests
of that party in selecting from among the facts otherwise available.” Id.
§ 1677e(b)(1)(A). The CAFC has interpreted these two subsections to have
different purposes. See Mueller Comercial de Mexico, S. de R.L. De C.V. v.
United States, 753 F.3d 1227, 1232 (Fed. Cir. 2014). Subsection (a) applies
“whether or not any party has failed to cooperate fully with the agency in its
inquiry.” Id. (citing Zhejiang DunAn Hetian Metal Co. v. United States, 652 F.3d Court No. 24-00118 Page 6
1333, 1346 (Fed. Cir. 2011)). Subsection (b) applies only when Commerce makes
a separate determination that the respondent failed to cooperate “by not acting to
the best of its ability. Id. (quoting Zhejiang DunAn Hetian Metal Co., 652 F.3d at
1346).
When determining whether a respondent has complied to the “best of its
ability,” Commerce “assess[es] whether [a] respondent has put forth its maximum
effort to provide Commerce with full and complete answers to all inquiries in an
investigation.” Nippon Steel v. United States, 337 F.3d 1373, 1382 (Fed. Cir.
2003). This determination requires both an objective and subjective showing. Id.
Commerce must determine objectively “that a reasonable and responsible
[respondent] would have known that the requested information was required to be
kept and maintained under the applicable statutes, rules, and regulations.” Id.
(citing Ta Chen Stainless Steel Pipe, Inc. v. United States, 298 F.3d 1330, 1336
(Fed. Cir. 2002)). Next, Commerce must demonstrate subjectively that the
respondent’s “failure to fully respond is the result of the respondent’s lack of
cooperation in either: (a) failing to keep and maintain all required records, or (b)
failing to put forth its maximum efforts to investigate and obtain the requested
information from its records.” Id. at 1382–83. Adverse inferences are not
warranted “merely from a failure to respond,” but rather in instances when
Commerce reasonably expected that “more forthcoming responses should have Court No. 24-00118 Page 7
been made[.]” Id. at 1383. “The statutory trigger for Commerce’s consideration of
an adverse inference is simply a failure to cooperate to the best of respondent’s
ability, regardless of motivation or intent.” Id. In the event that a respondent
possesses relevant information but does not provide it, such behavior “cannot be
considered ‘maximum effort to provide Commerce with full and complete
answers.’” Maverick Tube Corp. v. United States, 857 F.3d 1353, 1361 (Fed. Cir.
2017) (quoting Nippon Steel, 337 F.3d at 1382).
A. Commerce’s Use of Facts Otherwise Available
1. Necessary Information Not Available on the Record Pursuant to 19 U.S.C. § 1677e(a)(1)
Commerce determined that the use of facts otherwise available was
appropriate because necessary information was missing from the record regarding
the price paid by Heze Huayi and Kangtai for the land-use rights. Final IDM at
11–13. Commerce determined that “the record does not have the land-use rights
purchase contracts with the price paid for the land-use rights, which . . . is
information necessary to [Commerce’s] determination.” Id. at 13. Commerce
reasoned that “the land-use rights purchase contracts normally provide information
regarding the owner of the land, the terms and duration of the contract, the
location, the type of land-use right, the area, and, crucially, the price.” Id.
Commerce requested that the Government of China provide “all government
laws or regulations (at all levels of government) pertaining to the provision of land Court No. 24-00118 Page 8
or land-use rights.” Decision Memorandum for the Preliminary Results of the
Countervailing Duty Administrative Review of Chlorinated Isocyanurates from the
People’s Republic of China and Rescission of Administrative Review, in Part;
2021 (Dept. of Commerce Nov. 20, 2023) (“PDM”) at 15, PR 107; see
Administrative Review of the Countervailing Duty Order on Chlorinated
Isocyanurates from the People’s Republic of China: New Subsidy Allegations
Questionnaire for the Government of China (Nov. 2, 2023) at 4, PR 90. The
Government of China failed to provide “any provincial or local laws or regulations
governing land-use rights . . . nor did it provide any explanation of how [Heze
Huayi and Kangtai] acquired land-use rights and whether any local laws or
regulations would have governed such transactions.” PDM at 15. Commerce
made a preliminary determination that “necessary information . . . is not on the
record of this review” and Commerce “must rely on facts otherwise available in
making [its] preliminary determination.” Id. at 16.
Without the land-use rights purchase contracts themselves and without the
Government of China’s response to the New Subsidy Allegations Questionnaire,
there was no documentation on the record confirming the price paid for the land-
use rights as reported by Heze Huayi and Kangtai. Final IDM at 11–13.
Commerce based its determination that necessary information was missing from
the record pursuant to 19 U.S.C. § 1677e(a)(1) based on the missing land-use Court No. 24-00118 Page 9
rights purchase contracts. Id. As discussed below, however, the Court concludes
that the documents on which Commerce relied as facts otherwise available are
inaccurate and faulty because they were mostly written in Chinese and were not
translated into English, showed only sporadic payments, and failed to clearly
provide the information sought by Commerce regarding the owner of the land, the
terms and duration of the contract, the location, the type of land-use right, the area,
and the price.
2. Information Pursuant to 19 U.S.C § 1677e(a)(2)
Even though Commerce determined that the application of facts otherwise
available was warranted pursuant to 19 U.S.C. § 1677e(a)(1) because necessary
information was missing from the record, Commerce also made a determination
pursuant to 19 U.S.C. § 1677e(a)(2)(D) that Heze Huayi and Kangtai did not
“[withhold] information requested by Commerce or [provide] information that
could not be verified within the meaning of [19 U.S.C. § 1677e(a)(2)(A) and (B)].”
Final IDM at 13, n.55.2
2 It is apparent that the Final IDM erroneously cited to 19 U.S.C. § 1677e(a)(2)(B) rather than 19 U.S.C. § 1677e(a)(2)(D) because the provided citation to 19 U.S.C. § 1677e(a)(2)(B) does not correspond to the Final IDM statement and 19 U.S.C. § 1677e(a)(2)(D) appears to be the appropriate citation. Compare 19 U.S.C. § 1677e(a)(2)(B) (“fails to provide such information by the deadlines for submission, or in the form and manner requested”) with 19 U.S.C. § 1677e(a)(2)(D) (“provides such information but the information cannot be verified”). Court No. 24-00118 Page 10
In its New Subsidy Allegations Questionnaires, Commerce requested the
following information from Heze Huayi and Kangtai for each instance in which
they acquired or leased land-use rights: (1) date of acquisition; (2) identity of
seller; (3) location of land; (4) area of land; (5) price paid for land-use rights; (6)
terms of payment; (7) duration of lease; (8) translated copy of the land-use
contract; and (9) land-use certificates and land-use agreements issued by the local
land-use bureau. See Administrative Review of the Countervailing Duty Order on
Chlorinated Isocyanurates from the People’s Republic of China: New Subsidy
Allegations Questionnaire for Heze Huayi (Nov. 2, 2023) (“New Subsidy
Allegations Questionnaire for Heze Huayi”) at 4–5, PR 91; Administrative Review
of the Countervailing Duty Order on Chlorinated Isocyanurates from the People’s
Republic of China: New Subsidy Allegations Questionnaire for Kangtai (Nov. 2,
2023) (“New Subsidy Allegations Questionnaire for Kangtai”) at 4–5, PR 92.
Heze Huayi and Kangtai provided Land-use Right Certificates and Land-use Right
Purchase Charts, which purportedly established the date of acquisition, identity of
seller, location of land, area of land, price paid for land-use rights, terms of
payment, and duration of lease. See Chlorinated Isocyanurates from the People’s
Republic of China: Heze Huayi New Subsidy Allegations Questionnaire Response
(Nov. 14, 2023) (“Heze Huayi New Subsidy Allegations Questionnaire Resp.”) at
Exs. NSA-1, NSA-2, PR 96, CR 76–77; Chlorinated Isocyanurates from the Court No. 24-00118 Page 11
People’s Republic of China: Kangtai New Subsidy Allegations Questionnaire
Response (Nov. 14, 2023) (“Kangtai New Subsidy Allegations Questionnaire
Resp.”) at Exs. NSA-1, NSA-2, PR 97, CR 78–79. Heze Huayi and Kangtai stated
that they could not locate the actual land-use rights purchase contracts due to the
length of time that had elapsed since they signed the contracts. Heze Huayi New
Subsidy Allegations Questionnaire Resp. at 1–2; Kangtai New Subsidy Allegations
Questionnaire Resp. at 1–2.
In accordance with 19 U.S.C. § 1677m(d), Commerce issued supplemental
questionnaires to Heze Huayi and Kangtai, notified them that the land-use rights
purchase contracts were necessary for Commerce’s determination, and requested
that Heze Huayi and Kangtai provide the land-use rights purchase contracts for
each land-use rights purchase identified in Exhibit 1 of each company’s New
Subsidy Allegations Response. See Countervailing Duty Administrative Review
of Chlorinated Isocyanurates from the People’s Republic of China: Heze Huayi’s
Supplemental Questionnaire (Apr. 3, 2024) (“Heze Huayi Supplemental
Questionnaire”) at 4–5, PR 128; Countervailing Duty Investigation of Chlorinated
Isocyanurates from the People’s Republic of China: New Subsidy Allegations
Supplemental Questionnaire (Apr. 4, 2024) (“Kangtai Supplemental
Questionnaire”) at 4–5, PR 129; see also Heze Huayi New Subsidy Allegations
Questionnaire Resp. at Ex. NSA-1; Kangtai New Subsidy Allegations Court No. 24-00118 Page 12
Questionnaire Resp. at Ex. NSA-1. In the absence of the land-use rights purchase
contracts, Commerce requested that Heze Huayi and Kangtai: (1) explain the steps
each company took to determine the price paid for the land-use rights and submit
official documentation that each used in the course of its normal business activities
supporting its response; (2) explain how each company’s accounting system
records and maintains information relating to each land-use rights purchase, and
provide documentation supporting its response; (3) indicate the manner of payment
for each land-use rights purchase and provide a summary of the terms for each
land-use rights purchase, and provide documentation supporting the response;
and (4) tie each of the land-use rights purchases to each company’s 2021 financial
statements, including screenshots of the applicable ledger(s). See Heze Huayi
Supplemental Questionnaire at 4–5; Kangtai Supplemental Questionnaire 4–5.
Heze Huayi and Kangtai were still unable to provide the necessary land-use rights
purchase contracts. Final IDM at 12; see Chlorinated Isocyanurates from the
People’s Republic of China: Heze Huayi 3rd Supplemental Questionnaire
Response (Apr. 17, 2024) (“Heze Huayi Supplemental Questionnaire Resp.”) at 1–
2, PR 134, CR 96–98; Chlorinated Isocyanurates from the People’s Republic of
China: Kangtai Supplemental Questionnaire Response (Apr. 18, 2024) (“Kangtai
Supplemental Questionnaire Resp.”), at 1–2, PR 135, CR 99–100. Court No. 24-00118 Page 13
Commerce accepted the supplemental information submitted by Heze Huayi
and Kangtai as facts otherwise available, reasoning that although the information
provided by Heze Huayi and Kangtai was not a substitute for the land-use rights
purchase contracts themselves, “there is no evidence on the record that undermines
[the provided information’s] probative value.” Final IDM at 13. Plaintiffs argue
that Commerce’s use of facts otherwise available should be remanded because
Commerce’s determination is not supported by substantial evidence and is not in
accordance with law. Pls.’ Br. at 25–26. Plaintiffs contend that the record
evidence does not adequately support the prices paid alleged by Heze Huayi and
Kangtai. Id. at 16–17, 23. Specifically, Plaintiffs challenge the information
provided by Heze Huayi and Kangtai, arguing that the documents that Commerce
accepted as facts otherwise available were incomplete, inaccurate, and otherwise
not an acceptable substitute for the missing information in the land-use rights
purchase contracts. Id. at 17–22.
The Court reviewed the documents cited by Commerce in the Final IDM.
See Heze Huayi New Subsidy Allegations Questionnaire Resp. at Exs. NSA-1,
NSA-2; Kangtai New Subsidy Allegations Questionnaire Resp. at Exs. NSA-1,
NSA-2; Heze Huayi Supplemental Questionnaire Resp. at Exs. SQ3-1–SQ3-5;
Kangtai Supplemental Questionnaire Resp. at Exs. SQ4-1–SQ4-5. The Court
agrees with Plaintiff that the documents provided by Heze Huayi and Kangtai were Court No. 24-00118 Page 14
deficient because the documents were written in Chinese and were largely
untranslated into English, showed sporadic payments to various seemingly
irrelevant entities, and failed to clearly provide the information sought by
Commerce regarding the owner of the land, the terms and duration of the contract,
the location, the type of land-use right, the area, and the price. Moreover,
Commerce did not explain sufficiently why the documents provided by Heze
Huayi and Kangtai were adequate substitutes for the missing information on the
record. See Donald J. Kochan, Reason-Giving, Rulemaking, and the Rule of Law,
87 UMKC L. Rev. 525, 548 (2018) (noting that agencies should be encouraged to
provide reasons in order to increase credibility and legitimacy).
Substantial evidence relied upon by Commerce must be accurate, which has
been defined by the CAFC as mathematically and factually correct. Nan Ya
Plastics Corp. v. United States (“Nan Ya Plastics Corp.”), 810 F.3d 1333, 1344
(Fed. Cir. 2016) (“[C]ase law and the statute thus teach that a Commerce
determination . . . is ‘accurate’ if it is correct as a mathematical and factual matter,
thus supported by substantial evidence[.]”).
Despite Commerce’s acceptance of the documents submitted by Heze Huayi
and Kangtai as substitutes for the missing land-use rights purchase contracts, it is
apparent to the Court that the record evidence cited by Commerce does not Court No. 24-00118 Page 15
establish that the prices alleged by Heze Huayi and Kangtai are accurate or an
acceptable substitute for the land-use rights purchase contracts.
For example, Heze Huayi’s “Payment Slips for Land Purchases” indicates
payments to four different Chinese government agencies: (1) Juancheng Bureau of
Land Resources; (2) Juancheng Bureau of Finance; (3) Juancheng Bureau of Local
Taxation; and (4) the Non-Taxable Revenues for Local Finance. See Heze Huayi
Supplemental Questionnaire Resp. at Ex. SQ3-3. The only government entity
associated with Heze Huayi’s Land-use Right Certificates is Juancheng County
Bureau of Land Resources. See id. at Ex. SQ3-1. It is not clear from the record
that the payments reported by Heze Huayi relate to the purchase of land-use rights.
Heze Huayi’s payment slips submitted to Commerce do not show a pattern
consistent with typical installment contracts in terms of the amount of the
payments or the payment schedule. See id. at Ex. SQ3-2.
Similarly, Kangtai’s “Supporting Documentation for Land-use Right
Payment” indicates payments to multiple government entities, such as payments to
Juancheng County Finance Second Budget Fund Management Office and
Juancheng County Finance Settlement. See Kangtai Supplemental Questionnaire
Resp. at Ex. SQ4-1. The only government entity associated with Kangtai’s Land-
use Right Certificates is Juancheng County Bureau of Land Resources. See
Kangtai New Subsidy Allegations Questionnaire Resp. at Exs. NSA-1, NSA-2. As Court No. 24-00118 Page 16
with Heze Huayi, Kangtai’s “Supporting Documentation for Land-use Right
Payment” does not show a pattern consistent with typical installment contracts in
terms of the amount of the payments or the payment schedule. See Kangtai
Supplemental Questionnaire Resp. at Ex. SQ4-1.
Much of the information submitted by Heze Huayi and Kangtai in lieu of the
land-use rights purchase contracts (the facts otherwise available on which
Commerce relied) are in Chinese and are not translated into English. Commerce’s
regulations establish that questionnaire responses submitted in a foreign language
“must be accompanied by an English translation of the entire document or of only
pertinent portions, where appropriate, unless the Secretary waives this requirement
for an individual document.” 19 C.F.R. § 351.303(e). Prior to submitting the
response, “[a] party must obtain the Department’s approval for submission of an
English translation of only portions of a document[.]” Id. There is no evidence on
the record before the Court that Heze Huayi and Kangtai requested or received
approval from Commerce to submit only portions of the documents in English.
In the interest of accuracy and obtaining factually correct information on the
record, the Court concludes that Commerce’s reliance on facts otherwise available
is unreasonable because the supplemental documents consisted of faulty records
with incomplete translations and a lack of correlation with the missing information
on the record. The Court remands for Commerce to reconsider the record, at a Court No. 24-00118 Page 17
minimum to request that the documents relied upon as facts otherwise available are
translated from Chinese into English. If Commerce decides to re-open the record
to accept newly translated documents, the Court suggests that Commerce should
consider accepting the land-use rights purchase contracts on the record. During
oral argument, it was brought to the Court’s attention that the land-use rights
purchase contracts are now available. This would allow Commerce to make a new
determination on remand and to verify the information regarding the prices paid by
Heze Huayi and Kangtai. Because Commerce based its determination of facts
otherwise available on the missing land-use rights purchase contracts and the faulty
supplemental information provided by Heze Huayi and Kangtai, the Court
concludes that Commerce’s determination is not in accordance with law and is not
supported by substantial evidence.
CONCLUSION
The Court concludes that Commerce’s application of facts otherwise
available in the Final Results is neither in accordance with law nor supported by
substantial evidence, and the Court remands the Final Results for further
consideration in accordance with this Opinion. Accordingly, it is hereby
ORDERED that this case shall proceed according to the following schedule:
(1) Commerce shall file its remand redetermination on or before April
20, 2026; Court No. 24-00118 Page 18
(2) Commerce shall file the administrative record on or before May 4,
2026;
(3) Comments in opposition to the remand redetermination shall be
filed on or before May 20, 2026;
(4) Comments in support of the remand redetermination shall be filed
on or before June 22, 2026; and
(5) The joint appendix shall be filed on or before June 29, 2026.
/s/ Jennifer Choe-Groves Jennifer Choe-Groves, Judge
Dated: February 18, 2026 New York, New York