King Maker Mktg., Inc. v. United States

2025 CIT 58
CourtUnited States Court of International Trade
DecidedMay 15, 2025
Docket24-00134
StatusPublished

This text of 2025 CIT 58 (King Maker Mktg., 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
King Maker Mktg., Inc. v. United States, 2025 CIT 58 (cit 2025).

Opinion

Slip Op.

UNITED STATES COURT OF INTERNATIONAL TRADE

KING MAKER MARKETING INC.,

Plaintiff, Before: Timothy M. Reif, Judge v. Court No. 24-00134 UNITED STATES,

Defendant.

OPINION

[Granting defendant’s motion to dismiss with prejudice.]

Dated: May 15, 2025

John M. Peterson and Patrick B. Klein, Neville Peterson, LLP, of New York, N.Y., argued for plaintiff King Maker Marketing Inc. With them on the brief were Richard F. O’Neill and Maria E. Celis.

Beverly A. Farrell, Senior Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of New York, N.Y., argued for defendant United States. With her on the briefs were Brett A. Shumate, Acting Assistant Attorney General, Patricia M. McCarthy, Director and Justin R. Miller, Attorney-in-Charge, International Trade Field Office. Of counsel were Sabahat Chaudhary, Office of the Chief Counsel, U.S. Customs and Border Protection, of Washington, D.C., and Alexandra Khrebtukova, Office of Chief Counsel, International Trade Litigation, U.S. Customs and Border Protection, of New York, N.Y.

Reif, Judge: Before the court is the motion to dismiss of the United States

(“defendant”). King Maker Marketing Inc. (“plaintiff”) brings the instant action to contest

the deemed denial of administrative protest 1001-22-101163 (the “Protest”). The

Protest challenged the decision of U.S. Customs and Border Protection (“Customs”) to

deny as untimely plaintiff’s various claims for substitution unused merchandise Court No. 24-00134 Page 2

drawback submitted pursuant to 19 U.S.C. § 1313(j)(2). Compl. ¶ 1, ECF No. 5; Am.

Summons, ECF No. 15.

Defendant moves to dismiss plaintiff’s complaint and argues that “the plain terms

of the drawback statute have not been met.” Def.’s Mot. Dismiss for Failure to State a

Claim Upon Which Relief Can Be Granted (“Def. Br.”) at 1, ECF No. 20. For the

reasons discussed below, the court grants defendant’s motion to dismiss with prejudice.

BACKGROUND

Plaintiff was the importer of 21 shipments of certain paper-wrapped cigarettes

(the “merchandise”) that arrived in the United States and were admitted into a foreign-

trade zone (“FTZ”) between September 4, 2012, and February 6, 2014. Compl. ¶¶ 4, 6;

Def. Br. at 4. No entry for consumption was filed, and no duties were paid, at the time

that the merchandise was admitted into the FTZ. Compl. ¶ 7.

Plaintiff withdrew the various shipments of the merchandise from the FTZ for

domestic consumption between May 6, 2013, and September 3, 2018. Compl. ¶¶ 6, 8;

Def. Br. at 5. At the time of withdrawal of each shipment, plaintiff filed entries for

consumption with Customs and paid applicable duties, taxes and fees. 1 Compl. ¶ 8;

Def. Br. at 5.

The merchandise was classified under Harmonized Tariff Schedule of the United

States (“HTSUS”) subheading 2404.20.80, which covers “Cigarettes containing tobacco

. . . Other [than containing clove]; paper wrapped.” Compl. ¶ 8; Def. Br. at 5. After entry

1 Each of the entries was a Type 06 entry, which means that the merchandise was

withdrawn from the FTZ for consumption. Compl. ¶ 9; see U.S. Customs and Border Prot., ACE Transaction Details (last modified Jan. 23, 2024), https://www.cbp.gov/trade/automated/ace-transaction-details. Court No. 24-00134 Page 3

of the merchandise from the FTZ, plaintiff came into possession of, and exported,

certain other cigarettes that were classified also under HTSUS subheading 2404.20.80.

Compl. ¶ 10; Def. Br. at 5. Plaintiff identified these other cigarettes as substitution

merchandise that qualified for substitution unused merchandise drawback pursuant to

19 U.S.C. § 1313(j)(2). Compl. ¶ 10; Def. Br. at 5.

Plaintiff filed its various substitution unused merchandise drawback claims

between May 5, 2018, and February 15, 2019. Compl. ¶¶ 6, 11; Def. Br. at 5. Customs

denied the various drawback claims on March 18, 2022. Compl. ¶ 14; Def. Br. at 5.

Customs concluded that the claims were untimely because they were not filed before

the close of the five-year period beginning on the date of importation of the imported

merchandise. Compl. ¶ 14; Def. Br. at 5-6.

On September 6, 2022, plaintiff filed timely the Protest of the denial of its various

drawback claims. Def. Br. at 6; see Protests and Entries, ECF No. 12-1. On June 26,

2024, plaintiff requested accelerated disposition of the Protest pursuant to 19 U.S.C. §

1515(b). Compl. ¶ 17; Def. Br. at 6.

Customs did not decide the Protest within 30 days following the mailing of

plaintiff’s request. Compl. ¶ 18; Def. Br. at 6. For that reason, the Protest was deemed

denied by operation of law on July 27, 2024. Compl. ¶ 18; Def. Br. at 6.

On August 2, 2024, plaintiff filed the instant action by filing summons and

complaint. Summons, ECF No. 1; Compl.

On November 27, 2024, defendant filed its motion to dismiss the complaint. Def.

Br. On April 17, 2025, the Court heard oral argument. Oral Arg. Tr., ECF No. 34. Court No. 24-00134 Page 4

JURISDICTION AND STANDARD OF REVIEW

The Court exercises exclusive jurisdiction over all civil actions commenced under

section 515 of the Tariff Act of 1930, 19 U.S.C. § 1515, to contest protests denied by

Customs, 28 U.S.C. § 1581(a), 2 and reviews such actions de novo. 28 U.S.C. §

2640(a)(1) (“The Court of International Trade shall make its determinations upon the

basis of the record made before the court . . . .”).

In a USCIT Rule 12(b)(6) motion to dismiss for failure to state a claim, “any

factual allegations in the complaint are assumed to be true and all inferences are drawn

in favor of the plaintiff.” Env’t One Corp. v. United States, 47 CIT __, __, 627 F. Supp.

3d 1349, 1355 (2023) (quoting Amoco Oil Co. v. United States, 234 F.3d 1374, 1376

(Fed. Cir. 2000)); see USCIT R. 12(b)(6). In deciding a Rule 12(b)(6) motion, the court

may consider documents “incorporated by reference or integral to the claim, items

subject to judicial notice, [and] matters of public record.” A & D Auto Sales, Inc. v.

United States, 748 F.3d 1142, 1147 (Fed. Cir. 2014) (alteration in original) (quoting 5B

Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 1357 (3d ed.

2004)).

“A court may properly dismiss a claim pursuant to [USCIT] Rule 12(b)(6) only if

Plaintiffs’ allegations of fact are not ‘enough to raise a right to relief above the

speculative level.’” VoestAlpine USA Corp. v. United States, 46 CIT __, __, 578 F.

Supp. 3d 1263, 1276 (2022) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555

(2007)). To survive a motion to dismiss, plaintiff’s complaint must contain sufficient

2 References to the U.S. Code are to the 2018 edition. Further citations to the Tariff Act of 1930, as amended, are to the relevant portions of Title 19 of the U.S. Code. Court No. 24-00134 Page 5

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