Daikin America, Inc. v. United States

2025 CIT 22
CourtUnited States Court of International Trade
DecidedMarch 7, 2025
Docket22-00122
StatusPublished

This text of 2025 CIT 22 (Daikin America, Inc. 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
Daikin America, Inc. v. United States, 2025 CIT 22 (cit 2025).

Opinion

Slip Op. 25-22

UNITED STATES COURT OF INTERNATIONAL TRADE

Court No. 22-00122

DAIKIN AMERICA, INC., Plaintiff, v. UNITED STATES, Defendant, and GUJARAT FLUOROCHEMICALS LIMITED, Defendant-Intervenor.

Before: M. Miller Baker, Judge

OPINION

[The court sustains Commerce’s redetermination.]

Dated: March 7, 2025

Roger B. Schagrin, Luke A. Meisner, and Nicholas C. Phillips, Schagrin Associates, Washington, DC, on the comments for Plaintiff.

Brian M. Boynton, Principal Deputy Assistant Attor- ney General; Patricia M. McCarthy, Director; Claudia Burke, Deputy Director; and Collin T. Mathias, Trial Attorney, Commercial Litigation Branch, Civil Divi- sion, U.S. Department of Justice, Washington, DC, on Ct. No. 22-00122 Page 2

the comments for Defendant. Of counsel on the com- ments was Leslie M. Lewis, Attorney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce, Washington, DC.

Jessica R. DiPietro, Matthew M. Nolan, and John M. Gurley, ArentFox Schiff LLP, Washington, DC, on the comments for Defendant-Intervenor.

Baker, Judge: This case involving a challenge to the Department of Commerce’s calculation of the dumping rate assigned to a chemical imported from India re- turns after remand. See Daikin Am., Inc. v. United States, Slip Op. 24-32, 2024 WL 1171736 (CIT Mar. 14, 2024). Both domestic producer Daikin America, Inc., and Indian manufacturer Gujarat Fluorochemicals Limited are unhappy with the agency’s redetermina- tion, although for different reasons. This time, the court concludes that the Department got it right.

I

First, a quick refresher on the relevant (and some- what abstruse) background principles. Generally, Commerce determines a respondent’s dumping mar- gin by comparing the relevant merchandise’s export price or constructed export price in the United States with its normal value. Hung Vuong Corp. v. United States, 483 F. Supp. 3d 1321, 1334 (CIT 2020) (citing 19 U.S.C. § 1673). Normal value is the “home market” price. Id. at 1334 n.6. Ct. No. 22-00122 Page 3

“The ‘export price’ is the price the producer or ex- porter charges to an unaffiliated customer either within, or for exportation to, the United States, while the ‘constructed export price’ is the price the affiliated purchaser charges within the United States to a pur- chaser not affiliated with the producer or exporter.” Id. at 1353 n.34 (CIT 2020) (emphasis in original) (citing Mid Continent Steel & Wire, Inc. v. United States, 203 F. Supp. 3d 1295, 1298–99 (CIT 2017)); see also 19 U.S.C. § 1677a(a) (defining “export price”), (b) (de- fining “constructed export price”).

“Commerce makes certain statutory adjustments to the price of goods to reflect various costs involved in preparing the goods for sale in the United States, and the adjustments to ‘constructed export price’ are more extensive than the adjustments to ‘export price.’୻” Hung Vuong, 483 F. Supp. 3d at 1353 n.34 (citing 19 U.S.C. § 1677a(c), (d)). One of the adjustments rel- evant here, which the Department makes to both prices, is the cost of transporting the products to the place of delivery in the United States. See 19 U.S.C. § 1677a(c)(2)(A).

The relevant regulation directs that respondents report such expenses on a “transaction-specific” basis. See 19 C.F.R. § 351.401(g)(1). If such reporting is “not feasible,” Commerce may “consider allocated Ct. No. 22-00122 Page 4

expenses[1] . . . , provided [it] is satisfied that the allo- cation method used does not cause inaccuracies or dis- tortions.” 19 C.F.R. § 351.401(g)(1); see also id. § 351.401(g)(2) (“Any party seeking to report an ex- pense or a price adjustment on an allocated basis must demonstrate to the Secretary’s satisfaction that the al- location is calculated on as specific a basis as is feasi- ble” and that “the allocation methodology used does not cause inaccuracies or distortions.”). In making these determinations, the Department “will take into account the records maintained by the party . . . in the ordinary course of its business,” id. § 351.401(g)(3), as well as certain other factors, id.

Along with adjusting the U.S. price, Commerce must sometimes also adjust the home-market price. This is because the statute directs the agency to deter- mine the latter “to the extent practicable” by looking to sales “at the same level of trade as” the former. 19 U.S.C. § 1677b(a)(1)(B)(i). Although neither the

1 “Transaction-specific” reporting means providing the De-

partment with the shipping costs linked to each sale. “Al- located” disclosure of such spending means some method- ology that apportions gross outlays among sales. That is why Commerce prefers “transaction-specific” figures—they represent the actual amounts, while “allocated expenses” inherently involve estimates. Cf. Shikoku Chems. Corp. v. United States, 795 F. Supp. 417, 420 (CIT 1992) (referring to “the standard Commerce practice of preferring actual ex- penses over allocated expenses”). Ct. No. 22-00122 Page 5

statute nor the SAA 2 defines “same level of trade,” see Micron Tech., Inc. v. United States, 243 F.3d 1301, 1305 (Fed. Cir. 2001), binding precedent holds it “to mean comparable marketing stages in the home and United States markets, e.g., a comparison of wholesale sales in [the home market] to wholesale sales in the United States,” id. (citing 19 C.F.R. § 351.412(c)(2)). This “ensures . . . that a [home-market] wholesale price will not be compared to a United States . . . retail price.” Id. (emphasis added).

But the Department may be “unable to find sales in the foreign market at the same level of trade as the sales in the United States.” Id. In those cases, it “com- pare[s] sales in the United States and foreign markets at a different level of trade.” Id. Based on that compar- ison, it must

increase or decrease the [home-market price] to account for the difference in the level of trade, if that difference:

(i) involves the performance of different sell- ing activities; and

2 Statement of Administrative Action Accompanying the Uruguay Round Agreements Act, H.R. Rep. No. 103–316, vol. 1, 1994 U.S.C.C.A.N. 4040. The SAA is an “authorita- tive expression” of the statute’s meaning. 19 U.S.C. § 3512(d). Ct. No. 22-00122 Page 6

(ii) is demonstrated to affect price compara- bility, based on a pattern of consistent price differences between sales at different levels of trade in the country in which normal value is determined.

Id. (quoting 19 U.S.C. § 1677b(a)(7)(A)). This is what the statute refers to as a “level of trade” adjustment.

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2025 CIT 22, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daikin-america-inc-v-united-states-cit-2025.