Chandan Steel Ltd. v. United States

729 F. Supp. 3d 1357, 2024 CIT 105
CourtUnited States Court of International Trade
DecidedOctober 2, 2024
Docket21-00540
StatusPublished

This text of 729 F. Supp. 3d 1357 (Chandan Steel Ltd. 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
Chandan Steel Ltd. v. United States, 729 F. Supp. 3d 1357, 2024 CIT 105 (cit 2024).

Opinion

Slip Op. No. 24-105

UNITED STATES COURT OF INTERNATIONAL TRADE

CHANDAN STEEL LIMITED,

Plaintiff, Before: Timothy C. Stanceu, Judge v. Court No. 21-00540 UNITED STATES,

Defendant.

OPINION

[Denying relief on plaintiff’s motion for reconsideration of the court’s previous decision sustaining an antidumping duty rate of 145.25%]

Dated: October 2, 2024

Peter J. Koenig, Squire Patton Boggs (US) LLP, of Washington, D.C., for plaintiff Chandan Steel Limited.

Geoffrey M. Long, Senior Trial Counsel, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for defendant. With him on the response were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Tara K. Hogan, Assistant Director. Of counsel on the response were Collin T. Mathias, Trial Attorney, and Ashlande Gelin, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce, of Washington, D.C.

Stanceu, Judge: The court previously sustained an antidumping duty rate of

145.25% ad valorem assigned by the International Trade Administration, U.S.

Department of Commerce (“Commerce” or the “Department”) to plaintiff Chandan

Steel Limited (“Chandan”) in the final results of a review of an antidumping duty Court No. 21-00540 Page 2

order. Kisaan Die Tech Private, Ltd. v. United States, 47 CIT __, 665 F. Supp. 3d 1364 (2023)

(“Kisaan Die Tech”). Chandan has filed a “Motion for Reconsideration” of the court’s

decision, arguing that the court did not address certain arguments Chandan made in

the litigation. Chandan Rule 59(a)/(e) and 60 Mot. for Reconsideration (Jan. 8, 2024),

ECF No. 63 (“Mot. for Reconsideration”). The court will deny relief on the Motion for

Reconsideration and enter judgment in favor of defendant.

I. BACKGROUND

Background is set forth in the court’s prior opinion and is summarized briefly

herein. See Kisaan Die Tech, 47 CIT at __, 665 F. Supp. 3d at 1367–68. 1

Chandan contested the published final determination (the “Final Results”)

Commerce issued to conclude the first periodic administrative review (“first review”) of

an antidumping duty order on stainless steel flanges from India. See Stainless Steel

Flanges from India: Final Results of Antidumping Duty Administrative Review; 2018–2019,

86 Fed. Reg. 47,619 (Int’l Trade Admin. Aug. 26, 2021) (“Final Results”); Stainless Steel

Flanges from India: Issues and Decision Memorandum for the Final Results of the Antidumping

1 This action has been deconsolidated from Kisaan Die Tech et al. v. United States, Court No. 21-00512. Order of Judgment by Stipulation, Kisaan Die Tech et al. v. United States, Court No. 21-512 (Sept. 30, 2024), ECF No. 85. All filings in Court No. 21-00512 pertinent to Court No. 21-00540 have been incorporated by reference on the docket of this action. Order of Judgment by Stipulation (Sept. 30, 2024), Chandan Steel Limited v. United States, Court No. 21-00540, ECF No. 25. All ECF citations herein refer to the filings on the docket of Court No. 21-00512, unless otherwise indicated. Court No. 21-00540 Page 3

Duty Administrative Review; 2018–2019 (Int’l Trade Admin. Aug. 20, 2021), P.R. Doc. 169

(“Final I&D Mem.”). 2

In the first review, Chandan was the sole mandatory respondent, i.e., the only

exporter or producer Commerce selected for individual examination. Kisaan Die Tech,

47 CIT at __, 665 F. Supp. 3d at 1368. Commerce assigned Chandan the antidumping

duty rate of 145.25% as an application of what it termed “total adverse facts available,”

referring to the use of “the facts otherwise available” under section 776(a) of the Tariff

Act of 1930, as amended (“Tariff Act”), 19 U.S.C. § 1677e(a) 3, and an “adverse inference”

under section 776(b) of the Tariff Act, id. § 1677e(b). Commerce found that Chandan

repeatedly misreported its foreign sales information and also misreported its cost of

production information, and certain other information, that Commerce requested in

questionnaires it sent Chandan in the first review. Kisaan Die Tech, 47 CIT at __,

665 F. Supp. 3d at 1369–70.

In the Final Results, Commerce applied facts otherwise available and an adverse

inference rather than calculate a dumping margin based on Chandan’s sales. Refusing

2 Documents in the Joint Appendix (Jan. 31, 2023), ECF. Nos. 61 (public), 60 (conf.) are cited herein as “P.R. Doc. __.” All citations to record documents are to the public versions.

Citations to the United States Code herein are to the 2018 edition. Citations to 3

the Code of Federal Regulations are to the 2021 edition. Court No. 21-00540 Page 4

to use record information on these sales, Commerce instead applied “the highest rate

alleged in the petition.” Final I&D Mem. 33.

In a motion for judgment on the agency record brought before the court under

USCIT Rule 56.2, Chandan challenged the 145.25% rate generally on the ground that it

made no material errors in its submissions meriting the application of the facts

otherwise available and adverse inference provisions in the Tariff Act, and, in the

alternative, argued that Commerce unlawfully failed to limit its application of those

provisions according to the information—which it alleges could only have been

insignificant—that may have been missing from the record. Kisaan Die Tech, 47 CIT at

__, 665 F. Supp. 3d at 1370. Chandan argued, specifically, that: (1) there was no gap in

information that needed to be filled with facts otherwise available, (2) Commerce failed

to notify Chandan of any deficiencies in the submitted information and to allow

Chandan the opportunity to address them, (3) Chandan acted to the best of its ability in

responding to the Department’s information requests, and any errors were insufficient

for the use of adverse inferences, and (4) the adverse inferences Commerce used were

unlawfully punitive in light of Commerce having at its disposal information sufficient

to calculate a weighted-average dumping margin for the vast majority of Chandan’s

sales. Id.; see Pl. Chandan’s Mot. for J. on the Agency R. (June 30, 2022), ECF No. 37

(“56.2 Mot.”); Pl. Chandan’s Reply Br. (Jan. 17, 2023), ECF No. 59. Court No. 21-00540 Page 5

The court rejected Chandan’s arguments in sustaining the Department’s

assigning Chandan the “adverse inference” rate of 145.25%. Specifically, the court

sustained the Department’s application of facts otherwise available and an adverse

inference based on the Department’s finding that Chandan failed to provide Commerce

a comparison market sales database that complied fully with reporting instructions

even though Commerce brought the reporting errors to Chandan’s attention and

allowed two opportunities for resubmission. Kisaan Die Tech, 47 CIT at __, 665 F. Supp.

3d at 1370–74. The court stated that it “need not resolve the disagreements between the

parties that arise from” the Department’s other findings upon which it based its

application of facts otherwise available and an adverse inference. Id. at __, 665 F. Supp.

3d at 1376–77.

After the court issued its Opinion and Order in Kisaan Die Tech on December 8,

2023, Chandan filed the instant Motion for Reconsideration, in which Chandan argues

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