Forrest Xu v. United States

United States Court of International Trade·Decided September 16, 2026·No. 26-03403·Published

Opinion

Slip Op. 26-115

UNITED STATES COURT OF INTERNATIONAL TRADE

FORREST XU, Plaintiff,

v.

Before: Lisa W. Wang, Judge U.S. CUSTOMS AND BORDER PROTECTION, U.S. DEPARTMENT OF Court No. 26-03403

HOMELAND SECURITY, and SUSAN S. THOMAS, EXECUTIVE ASSISTANT COMMISSIONER, OFFICE OF TRADE,

Defendants.

OPINION AND ORDER

[Denying Plaintiff’s motion for a preliminary injunction.]

Dated: September 16, 2026

Christopher J. Duncan, Squire Patton Boggs (US) LLP, of Los Angeles, CA, for Plaintiff Forrest Xu.

David N. Heitner, Trial Attorney, U.S. Department of Justice, Commercial Litigation Branch, of New York, NY, for Defendants U.S. Customs and Border Protection, et al. With him on the brief were Brett A. Shumate, Assistant Attorney General, Patricia M. McCarthy, Director, Justin R. Miller, Attorney-In-Charge, International Trade Field Office, and Aimee Lee, Assistant Director. Of counsel on the brief were Marc Matthews, Alexandra Khrebtukova, Lisa Ross, and Robert Mathai, Office of Chief Counsel, U.S. Customs and Border Protection.

Wang, Judge: Before the court is Plaintiff Forrest Xu’s motion for a preliminary injunction. Pl.’s Emergency Mot. for Prelim. Inj., ECF No. 13; Pl.’s Mem. in Supp. of Emergency Mot. for Prelim. Inj. (“Pl.’s Mot.”), ECF No. 13-1. Plaintiff seeks to enjoin Defendants U.S. Customs and Border Protection (“Customs”), U.S. Department of

Court No. 26-03403 Page 2

Homeland Security, and Susan S. Thomas, Executive Assistant Commissioner, Office of Trade, from deactivating Plaintiff’s entry filer code, which allows him to file entries with Customs electronically.1 Id. at 1. Plaintiff argues that injunctive relief is warranted because: (1) Plaintiff is likely to succeed on the merits; (2) Plaintiff faces an immediate and continuing threat of irreparable harm; (3) the balance of hardships favors Plaintiff; and (4) the public interest is best served by the issuance of a preliminary injunction. See generally id.

For the following reasons, Plaintiff’s motion for a preliminary injunction is denied.

BACKGROUND

Plaintiff Forrest Xu “is a licensed customs broker.” Compl. ¶ 4, ECF No. 5.

Plaintiff was assigned an entry filer code: “a unique, three character code that Customs … assigns to a licensed customs broker.” Lizarraga Customs Broker v. Bureau of Customs & Border Prot., 34 CIT 1309, 1310 (2010). An active entry filer code is required to file entries electronically with Customs.2 Id. (“In order to file electronically, the broker must have an active entry filer code and be approved for participation in the [Automated Broker Interface (‘ABI’)] system.”).

1 Plaintiff refers to the entry filer code at issue as an “electronic entry filer code” at times.

See, e.g., Pl.’s Mot. at 1. 2 As the court has explained, “[f]iling ‘entries’ means the filing of documentation required

to ensure the release of imported merchandise from Customs’ custody or the act of filing that documentation.” Lizarraga, 34 CIT at 1310.

On August 7, 2024, Customs conducted an on-site review at Plaintiff’s office and found violations of Customs regulations and other customs broker requirements. Letter from Susan S. Thomas to Forrest Xu (June 1, 2026) (“Suspension Letter”) at 8, ECF No. 4-1; Letter from Alan Aprea to Forrest Xu (Feb. 5, 2025) at Exhibit A-26–27, ECF No. 21-2; Broker Visit Interview Questions at Exhibit A-3–16, ECF No.21-2. At that time, Customs notified Plaintiff that his operation under the name of “Eton Customs Broker Inc.” (“Eton”) was impermissible and instructed Plaintiff “to cease conducting customs business” as Eton. Suspension Letter at 8. Two additional written communications were sent by Customs regarding Plaintiff’s impermissible use of the corporate name Eton, on February 5, 2025, and on June 6, 2025. Id. at 8–9; Letter from Miyoshi M. Feliciano to Forrest Xu (June 6, 2025) at Exhibit A-36, ECF No. 21-2. Customs also sent several “informed compliance letters” to Plaintiff during the period between December 19, 2025, and March 27, 2026, regarding certain “misuse” of Plaintiff’s entry filer code. Suspension Letter at 9.

On April 24, 2026, Customs sent Plaintiff a letter informing him that the agency was “conducting a compliance review of the accuracy of the CBP Form 5106 data that [he] certified and transmitted to the Automated Commercial Environment” (“ACE”) for over thirty specific Importer of Record (“IOR”) numbers.3 Letter from Judy Staudt to

3 Per Customs, “CBP Form 5106, also known as the Importer Identity Form, is used to

collect and maintain essential identification information for individuals and businesses involved in importing goods into the United States. This form serves several critical purposes: it establishes or updates an importer's identity within [Custom’s] systems, assigns a unique importer number (often linked to an IRS Employer Identification

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Forrest Xu (Apr. 24, 2026) (“Apr. 24, 2026 Letter”) at Exhibit A-81–82, ECF No. 21-2. The letter requested that Plaintiff respond and provide the agency with specific documentation and answers to a set of questions. Id. at A-82–83. The letter further specified that “[f]ailure to respond … and/or provide a sufficient explanation and supporting written or electronic records or documents may result in [Customs] taking action to disable [Plaintiff’s] ability to transmit CBP Form 5106s electronically in ACE.” Id. at A-83.

Plaintiff sent a response to Customs on April 29, 2026. Letter From Forrest Xu to Customs (Apr. 29, 2026), Exhibit C, ECF No. 21-4. In his response, Plaintiff stated that the importers at issue were “legitimate operating business entities”, but acknowledged that there was “still room for improvement in our importer verification procedures.” Id. Plaintiff listed several corrective measures that he proposed to take regarding these procedures. Id.

In a letter dated May 4, 2026, Customs informed Plaintiff “that [Customs] … disabled [his] ability to transmit CBP Form 5106s electronically to the Automated Commercial Environment (ACE) ….” Letter from Judy Staudt to Forrest Xu (May 4, 2026) (“May 4, 2026 Letter”) at Exhibit A-77, ECF No. 21-2. In a subsequent letter, Customs informed Plaintiff that the agency was “no longer allowing [him] to use [his]

Number, Social Security Number, or a CBP-assigned ID), and is a prerequisite for becoming an Importer of Record.” CBP Form 5106 – Create/Update Importer Identity Form, U.S. Customs and Border Protection, https://www.cbp.gov/document/forms/cbpform -5106-createupdate-importer-identity-form (last visited Sept. 10, 2026).

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assigned entry filer code” and that the “action extends to both electronic filing in … ACE … through … ABI and paper filing utilizing [his] assigned entry filer code ….” Suspension Letter at 8. The letter also informed Plaintiff of an alternate method he could use to file entries and the steps that Plaintiff would have to take “[f]or [Customs] to consider reinstating the use of [his] entry filer code after a minimum of 180 calendar days from the date of [the] letter ….” Id. at 9–10.

On July 30, 2026, Plaintiff filed a complaint challenging the deactivation of his entry filer code. See generally Compl. Before filing his complaint, Plaintiff filed a motion for a temporary restraining order “enjoining [Defendants] … from deactivating [P]laintiff’s customs broker electronic entry filer code ….” Pl.’s Mot. for Temp. Restraining Order at 1, ECF No. 4. Defendants filed their response on August 3, 2026. Defs.’ Opp. to Pl.’s Mot. for a Temp. Restraining Order, ECF No. 8 (superseded by ECF No. 21).

The court denied Plaintiff’s motion for a temporary restraining order on August 4, 2026. Order Denying Pl.’s Mot. for Temp. Restraining Order, ECF No. 9. On August 6, 2026, Plaintiff filed a motion for reconsideration. Pl.’s Emergency Mot. for Reconsideration, ECF No. 10. The court denied the motion the same day. Order Denying Pl.’s Emergency Mot. for Reconsideration, ECF No. 12.

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