Bridgestone Americas Tire Operations, LLC v. United States

United States Court of International Trade·Decided July 22, 2026·No. 24-00263·Published

Opinion

Slip Op. 26- UNITED STATES COURT OF INTERNATIONAL TRADE

BRIDGESTONE AMERICAS TIRE OPERATIONS, LLC,

Plaintiff,

v.

UNITED STATES,

Defendant, Before: Gary S. Katzmann, Judge Court No. 24-00263 and

UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS INTERNATIONAL UNION, AFL CIO, CLC,

Defendant-Intervenor.

OPINION

[ Plaintiff’s Motion for Judgment on the Agency Record is denied. ] Dated: July 22, 2026

Daniel J. Cannistra, Crowell & Moring LLP, of Washington, D.C., argued for Plaintiff Bridgestone Americas Tire Operations, LLC. Also on the brief were Pierce J. Lee and Valerie Ellis.

Sosun Bae, Senior Trial Counsel, Commercial Litigation Branch, U.S. Department of Justice, of Washington, D.C. argued 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 were Ayat Mujais, Assistant Chief Counsel and Samuel Childerson, Attorney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce.

Saad Y. Chalchal, Schagrin Associates, of Washington, D.C., argued for Defendant-Intervenor United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Court No. 24-00263 Page 2

Workers International Union, AFL-CIO, CLC. Also on the briefs were Roger B. Schagrin, Luke A. Meisner, and Elizabeth J. Drake.

Katzmann, Judge: Plaintiff Bridgestone Americas Tire Operations, LLC (“Bridgestone”),

a U.S. importer of truck and bus tires from Thailand, brings this action against Defendant the

United States (“the Government”) to challenge the U.S. Department of Commerce’s

(“Commerce”) final determination in the antidumping duty administrative investigation of truck

and bus tires from Thailand. See Truck and Bus Tires From Thailand: Final Affirmative

Determination of Sales at Less Than Fair Value and Final Affirmative Determination of Critical

Circumstances, in Part, 89 Fed. Reg. 83636 (Dep’t Com. Oct. 17, 2024), P.R. 297 (“Final

Determination”). This case raises two issues: (1) whether Commerce’s determination to apply

total adverse facts available is supported by substantial evidence and in accordance with the law

and (2) whether Commerce’s corroboration of Bridgestone’s dumping margin is supported by

substantial evidence and in accordance with the law. Because the errors throughout Bridgestone’s

reporting were pervasive and because Commerce lawfully corroborated Bridgestone’s dumping

margin, the court denies Bridgestone’s motion and sustains Commerce’s Final Determination.

LEGAL BACKGROUND

I. Antidumping Duties

“Dumping occurs when a foreign company sells a product in the United States at a lower

price than” the company charges for the “same product in its home market.” Sioux Honey Ass’n

v. Hartford Fire Ins. Co., 672 F.3d 1041, 1046 (Fed. Cir. 2012). This practice constitutes unfair

competition because it enables foreign producers to undercut domestic companies by selling

products below fair market value. Id. To address the impact of such unfair competition, Congress

enacted the Tariff Act of 1930, as amended, which empowers Commerce to investigate potential

dumping and, if necessary, to issue orders instituting duties on subject merchandise. Id. at Court No. 24-00263 Page 3

1046–47.

Under 19 U.S.C. § 1673, Commerce may impose antidumping duties on “foreign

merchandise [that] is being, or is likely to be, sold in the United States at less than its fair value.”

“Sales at less than fair value are those sales for which the ‘normal value’ (the price a producer

charges in its home market) exceeds the ‘export price’ (the price of the product in the United States)

. . . .” U.S. Steel Corp. v. United States, 621 F.3d 1351, 1353 (Fed. Cir. 2010) (quoting 19 U.S.C.

§ 1677(35)(A)). “Commerce then calculates a ‘dumping margin’ for a particular product subject

to review, equal to ‘the amount by which the normal value exceeds the export price or constructed

export price.’ ” 1 Id. (quoting 19 U.S.C. § 1677(35)(A)). Commerce makes various adjustments

when calculating normal value and constructed export price. As relevant here, Commerce adjusts

the normal value and/or constructed export price where the producer or exporter makes “a change

in the price charged for subject merchandise or the foreign like product, such as a discount, rebate,

or other adjustment.” 19 C.F.R. § 351.102(b)(38); see also id. § 351.401(c). Additionally,

Commerce reduces the constructed export price by the amount “attributable to any additional costs,

charges, or expenses, and United States import duties, which are incident to bringing the subject

merchandise from the original place of shipment in the exporting country to the place of delivery

1 “The term ‘constructed export price’ means the price at which the subject merchandise is first sold (or agreed to be sold) in the United States . . . by a seller affiliated with the producer or exporter, to a purchaser not affiliated with the producer or exporter, as adjusted under [19 U.S.C. §§ 1677a(c), (d)].” 19 U.S.C. § 1677a(b) (emphasis added). By contrast, ‘export price’ is the “price at which the subject merchandise is first sold (or agreed to be sold) before the date of importation by the producer or exporter of the subject merchandise outside of the United States to an unaffiliated purchaser in the United States.” Id. § 1677a(a) (emphasis added). Here, Commerce calculated a constructed export price for Bridgestone because “the subject merchandise was first sold in the United States . . . by a U.S. seller affiliated with the producer or exporter, to a purchaser not affiliated with the producer or exporter.” See Mem. from J. Maeder to R. Majerus, re: Decision Memorandum for the Preliminary Affirmative Determination in the Less-Than-Fair-Value Investigation of Truck and Bus Tires from Thailand at 9 (Dep’t Com. May 14, 2024), P.R. 218 (“Prelim. IDM”). Court No. 24-00263 Page 4

in the United States,” including warehousing, freight, and packing expenses. 19 U.S.C.

§ 1677a(c)(2)(A).

II. Verification and Use of Facts Otherwise Available

In antidumping proceedings, Commerce “obtains most of its factual information . . . from

submissions made by interested parties during the course of the proceeding.” 19 C.F.R.

§ 351.301(a). Verification is the process by which Commerce “verif[ies] all information relied

upon in making . . . a final determination” in an antidumping investigation. 19 U.S.C. § 1677m(i).

“The purpose of verification is to test information provided by a party for accuracy and

completeness.” Goodluck India Ltd. v.

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