Bonney Forge Corp. v. United States

2025 CIT 56
CourtUnited States Court of International Trade
DecidedMay 6, 2025
Docket20-03837
StatusPublished

This text of 2025 CIT 56 (Bonney Forge Corp. 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
Bonney Forge Corp. v. United States, 2025 CIT 56 (cit 2025).

Opinion

Slip Op. No. 25-56

UNITED STATES COURT OF INTERNATIONAL TRADE

BONNEY FORGE CORPORATION and UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS INTERNATIONAL UNION,

Plaintiffs, Before: Stephen Alexander Vaden, v. Judge

UNITED STATES, Court No. 1:20-cv-03837 (SAV)

Defendant,

and

SHAKTI FORGE INDUSTRIES PVT LTD.,

Defendant-Intervenor.

OPINION

[Sustaining Commerce’s Remand Determination.]

Dated: May 6, 2025

William A. Fennell, Schagrin Associates of Washington, DC, for Plaintiffs Bonney Forge Corporation and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union. With him on the brief were Roger B. Schagrin and Elizabeth J. Drake.

Kara M. Westercamp, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice of Washington, DC, for Defendant United States. With her on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia McCarthy, Director, Claudia Burke, Deputy Director, and Court No. 1:20-cv-03837 (SAV) Page 2

JonZachary Forbes, Attorney, U.S. Department of Commerce, Office of the Chief Counsel for Trade Enforcement & Compliance.

Sezi Erdin, Trade Pacific PLLC of Washington, DC, for Defendant-Intervenor Shakti Forge Industries Pvt Ltd. With her on the brief were Robert G. Gosselink and Aqmar Rahman.

Vaden, Judge: Before the Court is the third installment in a case about

Indian forged steel fittings. This saga began at the end of 2019 when the Department

of Commerce (Commerce) initiated an antidumping investigation and selected an

Indian producer, Defendant-Intervenor Shakti Forge Industries Pvt Ltd. (Shakti), as

a mandatory respondent. Domestic petitioners Bonney Forge Corporation (Bonney

Forge) and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied

Industrial and Service Workers International Union (collectively, Plaintiffs)

challenged Commerce’s decision not to conduct an in-person verification of Shakti’s

information. This Court found merit in Plaintiffs’ objections and remanded to

Commerce. Bonney Forge Corp. v. United States (Bonney Forge I), 46 CIT __, 560 F.

Supp. 3d 1303, 1316 (2022). On remand, Commerce claimed to take new agency

action but failed to follow the necessary procedural steps. This Court remanded for

a second time. Bonney Forge Corp. v. United States (Bonney Forge II), 47 CIT __,

Court No. 1:20-cv-03837, 2023 Ct. Intl. Trade LEXIS 125, at *16 (Aug. 21, 2023).

Commerce then completed an in-person verification at Shakti’s factory in India. The

agency found no discrepancies in Shakti’s reported costs. Plaintiffs now argue that,

if Commerce had searched further, it would have found an error demonstrating

Shakti’s costs were inaccurate. The Court disagrees. Commerce’s Second Remand

Determination will be SUSTAINED. Court No. 1:20-cv-03837 (SAV) Page 3

BACKGROUND The Court presumes familiarity with this case’s facts as described in its two

previous opinions. See Bonney Forge I, 46 CIT __, 560 F. Supp. at 1305–09; Bonney

Forge II, 47 CIT __, 2023 Ct. Intl. Trade LEXIS 125, at *2–6. This opinion recounts

only those facts relevant to the Court’s review of the Second Remand Determination.

I. Procedural History

This case concerns Commerce’s Final Determination in its antidumping

investigation of Indian forged steel fittings. See Forged Steel Fittings from India:

Final Affirmative Determination of Sales at Less Than Fair Value (Final

Determination), 85 Fed. Reg. 66,306, 66,307–08 (Dep’t of Com. Oct. 19, 2020).

Commerce selected Shakti as a mandatory respondent. Decision Memorandum for

the Preliminary Determination in the Less-Than-Fair-Value Investigation of Forged

Steel Fittings from India (PDM) at 3, J.A. at 11,667, ECF No. 46. Shakti produces

finished and unfinished fittings and sells them in both India and the United States.

Shakti Section A Questionnaire Resp. at A-14–A-16, J.A. at 81,699–701, ECF No. 104.

It has two types of customers: end users and traders or distributors. Id. at A-16, J.A.

at 81,701. End users are retail consumers, while traders and distributors are

middlemen that resell the merchandise to retail consumers.

Commerce sent questionnaires to Shakti asking for data about its production

processes and costs. Request for Information, J.A. at 2,906, ECF No. 45. Shakti

described its multi-step production process as occurring in two stages — the forging

stage and the machining and packaging stage. Shakti Section A Questionnaire Resp.,

Ex. A-10(a), J.A. at 81,905–09, ECF No. 104. Shakti reported that it uses different Court No. 1:20-cv-03837 (SAV) Page 4

machining processes depending on a product’s intended customer. Id. at 81,908–09.

It said:

In process of Machining there is major difference in Domestic trader’s order and export orders. There will be no boring after drilling and socket preparation will be done in conventional laths in domestic orders. However in export orders each fitting[] will be machined 100% Boring and end preparation with [computer numerical control] Machines.

Id. at 81,908 (grammatical errors in original). In short, Shakti stated that it uses its

most sophisticated machines — known as computer numerical control machines — to

complete the finishing on products sold in the United States. Id. It uses less

sophisticated conventional lathes to complete the finishing on products sold to traders

in India. Id. Computer numerical control machines require greater labor and energy

costs than conventional lathe machines. Oral Arg. Tr. at 12:1-13, ECF No. 113.

Shakti also reported that it does not usually perform heat treatment and surface

finishing on products sold to traders in India. Shakti Section A Questionnaire Resp.,

Ex. A-10(a), J.A. at 81,907, ECF No. 104. These processes add costs, as well.

Shakti submitted cost sheets for its merchandise at Commerce’s request. Pls.’

R. 56.2 Br. at 4, ECF No. 25. For certain products sold to Indian traders, Shakti

reported costs for time spent on computer numerical control machines. Id. at 8.

Shakti similarly reported surface finishing and heat treatment costs for domestic

Indian sales despite earlier stating that it does not usually perform these processes

on products sold to traders in India. Shakti Section A Questionnaire Resp., Ex. A-

10(a), J.A. at 81,908, ECF No. 104. Court No. 1:20-cv-03837 (SAV) Page 5

Commerce originally chose not to verify Shakti’s questionnaire responses

because of the COVID-19 pandemic. Cancellation of Verification and Briefing

Schedule, J.A. at 13,906, ECF No. 46. Plaintiffs suggested that Commerce perform a

virtual verification in place of a traditional on-site verification. Pls.’ Administrative

Br. at 19–20, J.A. at 91,588–89, ECF No. 45. Commerce did not respond to this

request. Issue and Decision Memorandum for the Final Determination in the Less-

Than-Fair-Value Investigation of Forged Steel Fittings from India (Final IDM) at 1–

23, J.A. at 14,126–48, ECF No. 46; Oral Arg. Tr. 25:7–8, ECF No. 53 (Ms.

Westercamp: “There is no discussion [in the record] about why a virtual verification

would not have been feasible.”). Instead, it issued a series of supplemental

questionnaires to Shakti. See, e.g., Suppl. Questionnaire (Mar. 20, 2020), J.A. at

6,022, ECF No. 46; Sections A–D Suppl.

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