Cornerstone Chem. Co. v. United States

CourtUnited States Court of International Trade
DecidedJune 17, 2026
Docket25-00005
StatusPublished

This text of Cornerstone Chem. Co. v. United States (Cornerstone Chem. Co. 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
Cornerstone Chem. Co. v. United States, (cit 2026).

Opinion

Slip Op. 26-64

UNITED STATES COURT OF INTERNATIONAL TRADE

Court No. 25-00005

CORNERSTONE CHEMICAL COMPANY, Plaintiff, v. UNITED STATES, Defendant, and QATAR MELAMINE COMPANY (A QATARI PRIVATE SHAREHOLDING COMPANY) and QATARENERGY MARKETING (1) (A QATARI PRIVATE SHAREHOLDING COMPANY), Defendant-Intervenors.

Before: M. Miller Baker, Judge

OPINION

[Sustaining Commerce’s negative dumping determi- nation in part and remanding in part.]

Dated: June 17, 2026

Stephen J. Orava, Patrick J. McLain, and Nicholas K. Paster, King & Spalding LLP, Washington, DC, on the briefs for Plaintiff. Ct. No. 25-00005 Page 2

Kristin E. Olson, Trial Attorney, Commercial Litiga- tion Branch, Civil Division, U.S. Department of Jus- tice, Washington, DC, on the brief for Defendant. Of counsel for Defendant was JonZachary Forbes, Attor- ney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce, Wash- ington, DC.

Jay C. Campbell, Richard G. King, and Matthew W. Solomon, White & Case LLP, Washington, DC, on the brief for Defendant-Intervenors.

Baker, Judge: A domestic petitioner challenges the Department of Commerce’s determination that mela- mine from Qatar is not dumped in the American mar- ket. The court holds that the agency failed to ade- quately explain its selection of Turkey as a proxy for determining the home-market price and therefore re- mands for reconsideration.

Insofar as Commerce sticks by its decision to use Turkey or instead employs some other third country for comparison purposes, the court sustains the De- partment’s refusal to adjust the cost of natural gas in- puts from an affiliated supplier reported by a Qatari producer, even though the transactions were at less than the global market rate. When the agency uses ei- ther the home market or a third country to determine the price of the foreign like merchandise, it only looks to the producing country to determine whether trans- actions between affiliated entities were valued below Ct. No. 25-00005 Page 3

the market price. Here, it is undisputed the natural gas inputs traded above the Qatari-market price.

I

The question Commerce must answer in an anti- dumping investigation is whether imported goods are being sold in the United States at “less than fair value.” 19 U.S.C. § 1677b(a). To do that, the Tariff Act of 1930, as amended, instructs the Department to make “a fair comparison” between the export price— i.e., the U.S. sales price—and the “normal value” of the subject merchandise. Id. This case is about how the agency determines “normal value.”

As relevant here, “normal value of the subject mer- chandise” means “the price at which the foreign like product is first sold . . . in the exporting country.” Id. § 1677b(a)(1)(B)(i). 1 In plain English, Commerce is to use sales charges in the producer’s home market. See Smith-Corona Grp. v. United States, 713 F.2d 1568, 1573 (Fed. Cir. 1983).

1 “୻‘[S]ubject merchandise’ means the class or kind of mer-

chandise that is within the scope of an investigation, a re- view, . . . [or] an order” imposing antidumping or counter- vailing duties. Id. § 1677(25). “୻‘[F]oreign like product’ means merchandise in the first” of three categories which is usable, starting with subject merchandise but also in- cluding other goods from the same country that are similar enough for enumerated reasons. Id. § 1677(16). Ct. No. 25-00005 Page 4

But the statute makes certain exceptions to using the home-market price. One of them is when there are insufficient sales of the foreign like merchandise in that country. See 19 U.S.C. § 1677b(a)(1)(C)(i), (ii). An- other is when “the particular market situation in the exporting country does not permit a proper compari- son with the export price,” id. § 1677b(a)(1)(C)(iii)—a sales-based particular market situation. 2

If the home market is disqualified, Commerce uses sales charges from a third country if available. 19 U.S.C. § 1677b(a)(1)(B)(ii). 3 Eligibility for selection as such a proxy requires, among other things, that the Department “not determine that the particular mar- ket situation prevents a proper comparison with the export price,” 19 U.S.C. § 1677b(a)(1)(B)(ii)(III)—once again, a sales-based particular market situation. See note 2.

2 See 19 C.F.R. § 351.416(c), (e) for the criteria the Depart-

ment uses to determine whether such a situation exists. 3 The statute allows the Department to immediately turn

to “constructed value” (discussed below) if the home market is not available. See id. § 1677b(a)(4). But a regulation es- tablishes an agency preference for using third-country sales “if adequate information is available and verifiable.” 19 C.F.R. § 351.404(f). “[W]here prices in more than one third country satisfy” the relevant statutory criteria, Com- merce considers various factors in deciding which proxy to use. See id. § 351.404(e). Ct. No. 25-00005 Page 5

If Commerce finds that normal value cannot be de- termined from charges in either the home market or a third-country proxy, as a last resort it will calculate the product’s “constructed value.” See 19 U.S.C. § 1677b(a)(4); see also note 2; Saha Thai Steel Pipe Pub. Co. v. United States, 87 F.4th 1328, 1330 (Fed. Cir. 2023) (“If the agency cannot determine the normal value of the subject merchandise based on price, then § 1677b(e) authorizes [it] to calculate a constructed value based on costs.”). This term represents the esti- mated total cost of materials, processing, overhead, profit, and packing expenses in the producing nation. See 19 U.S.C. § 1677b(e)(1)–(3). Where a “particular market situation exists such that the cost of materials and . . . processing . . . does not accurately reflect the cost of production in the ordinary course of trade,” id. § 1677b(e)—a cost-based particular market situation,4 cf. Hyundai Steel Co. v. United States, 19 F.4th 1346, 1355 n.10 (Fed. Cir. 2021) (distinguishing the “differ- ent standards” for cost-based versus sales-based par- ticular market situations)—the agency “may use . . . any other . . . methodology” to figure such costs. 19 U.S.C. § 1677b(e). 5

4 See 19 C.F.R. § 351.416(d), (e) for the criteria the Depart-

ment uses to determine whether such a situation exists. 5 “The statute therefore does not direct Commerce to a par-

ticular calculation methodology where [it] uses constructed value and finds a [cost-based particular market situation].” (footnote continues on next page) Ct. No. 25-00005 Page 6

Other statutory roads may also lead to constructed value.

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Cornerstone Chem. Co. v. United States, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cornerstone-chem-co-v-united-states-cit-2026.