Kumar Industries v. United States

665 F. Supp. 3d 1355, 2023 CIT 166
CourtUnited States Court of International Trade
DecidedNovember 22, 2023
Docket21-00622
StatusPublished

This text of 665 F. Supp. 3d 1355 (Kumar Industries 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.

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Kumar Industries v. United States, 665 F. Supp. 3d 1355, 2023 CIT 166 (cit 2023).

Opinion

Slip Op. 23-166

UNITED STATES COURT OF INTERNATIONAL TRADE

KUMAR INDUSTRIES,

Plaintiff, Before: Timothy C. Stanceu, Judge v. Court No. 21-00622 UNITED STATES,

Defendant.

OPINION

[Sustaining an agency decision concluding an administrative review of an antidumping duty order]

Dated: November 22, 2023

Lizbeth R. Levinson, Fox Rothschild LLP, of Washington, D.C., for plaintiff. With her on the briefs were Ronald M. Wisla and Brittney R. Powell.

Kelly Geddes, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, D.C., for defendant United States. With her on the brief were Brian M. Boynton, Principal Deputy Assistant Attorney General, Patricia M. McCarthy, Director, and Claudia Burke, Assistant Director, Commercial Litigation Branch. Of counsel on the brief was Jared M. Cynamon, Attorney, Office of the Chief Counsel for Trade Enforcement & Compliance, U.S. Department of Commerce.

Stanceu, Judge: Plaintiff contests a determination the International Trade

Administration, U.S. Department of Commerce (“Commerce” or the “Department”)

issued to conclude the first administrative review of an antidumping duty (“AD”) order Court No. 21-00622 Page 2

on imported glycine from India. In the contested determination, Commerce assigned

Kumar an antidumping duty rate of 13.61%.

Before the court is Kumar’s motion for judgment on the agency record,

submitted under USCIT Rule 56.2. The court denies the motion and sustains the

Department’s determination.

I. BACKGROUND

A. The Parties to this Action

Kumar, an Indian manufacturer and exporter of glycine, was a mandatory

respondent in the underlying antidumping duty investigation and in the first

administrative review. Summons 1 (Dec. 10, 2021), ECF No. 1; Compl. ¶ 4 (Jan. 10,

2022), ECF No. 8. Defendant is the United States.

B. The Contested Determination

Commerce published the determination at issue (the “Final Results”) in 2021 to

conclude an antidumping duty administrative review on glycine from India (the

“subject merchandise”). Glycine From India: Final Results of Antidumping Duty

Administrative Review; 2018–2020, 86 Fed. Reg. 62,508 (Int’l Trade Admin. Nov. 10, 2021)

(“Final Results”).

The Final Results incorporated by reference an explanatory document, the “Final

Issues and Decision Memorandum.” Glycine from India: Issues and Decision Memorandum Court No. 21-00622 Page 3

for Final Results of Antidumping Duty Administrative Review; 2018–2020 (Int’l Trade

Admin. Nov. 4, 2021), P.R. Doc. 200 (“Final I&D Mem.”).1

C. Proceedings before Commerce

Commerce concluded an antidumping duty investigation of glycine from India

in 2019, determining that the subject merchandise was being sold in the United States at

less than fair value. Glycine From India: Final Determination of Sales at Less Than Fair

Value, 84 Fed. Reg. 18,487 (Int’l Trade Admin. May 1, 2019). After the U.S. International

Trade Commission (the “ITC”) determined that imports of glycine were injuring the

domestic glycine industry, Glycine from China, India, and Japan; Determinations, 84 Fed.

Reg. 29,238 (Int’l Trade Comm’n June 21, 2019), Commerce issued an amended final

affirmative less than fair value determination (“Amended Final LTFV Determination”)

and issued antidumping duty orders, including an order on glycine from India (the

“Order”). Glycine From India and Japan: Amended Final Affirmative Antidumping Duty

Determination and Antidumping Duty Orders, 84 Fed. Reg. 29,170 (Int’l Trade Admin.

June 21, 2019).2 In the Amended Final LTFV Determination, Commerce assigned

Kumar a weighted average dumping margin of 13.61%. Id., 84 Fed. Reg. at 29,171.

1 Documents in the Joint Appendix (Dec. 5, 2022), ECF Nos. 35, 36, 37, 41 (Conf.), 38, 39, 42 (Public) are cited as “P.R. Doc __.” All citations are to the public versions of these documents.

2 The scope of the antidumping duty order includes “glycine,” an amino acid, “at (continued . . .) Court No. 21-00622 Page 4

In 2020, Commerce initiated the first administrative review of the Order,

designating the period of review (“POR”) as October 31, 2018 to May 31, 2020. Initiation

of Antidumping and Countervailing Duty Administrative Reviews, 85 Fed. Reg. 47,731,

47,734 (Int’l Trade Admin. Aug. 6, 2020). Commerce issued “Preliminary Results” and

an accompanying “Preliminary Decision Memorandum” for the first administrative

review in 2021, in which Commerce preliminarily assigned Kumar an antidumping

duty rate of 13.61%. Glycine From India: Preliminary Results of Antidumping Duty

Administrative Review; 2018–2020, 86 Fed. Reg. 35,733, 35,734 (Int’l Trade Admin. July 7,

2021) (“Prelim. Results”); Glycine from India: Decision Memorandum for Preliminary Results

of Antidumping Duty Administrative Review; 2018–2020 at 5–8 (Int’l Trade Admin.

June 30, 2021), P.R. Doc. 164 (“Prelim. Decision Mem.”). Commerce assigned the same

13.61% rate in the Final Results. Final Results, 86 Fed. Reg. at 62,509; Final I&D Mem.

at 35–36.

D. Proceedings before the Court

Plaintiff commenced this action on January 10, 2022. Summons; Compl. Before

the court is Kumar’s motion for judgment on the agency record under USCIT Rule 56.2

and accompanying brief. Pl.’s 56.2 Mot. for J. on the Agency R. (July 27, 2022), ECF

any purity level or grade” and “all forms of crude or technical glycine including, but not limited to, sodium glycinate, glycine slurry and any other forms of amino acetic acid or glycine.” Glycine From India and Japan: Amended Final Affirmative Antidumping Duty Determination and Antidumping Duty Orders, 84 Fed. Reg. 29,170, 29,172 (Int’l Trade Admin. June 21, 2019). Court No. 21-00622 Page 5

Nos. 23 (Conf.), 24 (Public); Mem. of Points and Authorities in Supp. of Pl.’s 56.2 Mot.

for J. on the Agency R. (July 27, 2022), ECF Nos. 23 (Conf.), 24 (Public) (“Kumar’s Br.”).

Defendant United States opposes Kumar’s motion. Def.’s Resp. in Opp’n to Pl.’s

Mot. for J. Upon the Agency R. (Sept. 26, 2022), ECF Nos. 25 (Conf.), 26 (Public).

Plaintiff replied to defendant’s opposition. Pl.’s Reply Br. (Nov. 18, 2022), ECF No. 32.

II. DISCUSSION

A. Jurisdiction and Standard of Review

The court exercises jurisdiction according to section 201 of the Customs Courts

Act of 1980, 28 U.S.C. § 1581(c),3 pursuant to which the court reviews actions

commenced under section 516A of the Tariff Act of 1930 (“Tariff Act”), as amended,

19 U.S.C. § 1516a, including actions contesting final affirmative determinations that

Commerce issues to conclude administrative reviews of antidumping duty orders.

See id. §§ 1516a(a)(2)(B)(iii), 1675.

In reviewing an agency determination, the court “shall hold unlawful any

determination, finding, or conclusion found . . . to be unsupported by substantial

evidence on the record, or otherwise not in accordance with law.” Id. § 1516a(b)(1).

Substantial evidence refers to “such relevant evidence as a reasonable mind might

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

the Code of Federal Regulations are to the 2021 edition.

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