Magnum Magnetics Corp. v. United States

• Court: Court of Appeals for the Federal Circuit
• Decided: February 17, 2026
• Docket: 24-1164
• Status: Published

Opinion

Case: 24-1164 Document: 71 Page: 1 Filed: 02/17/2026

United States Court of Appeals for the Federal Circuit ______________________

MAGNUM MAGNETICS CORP., Plaintiff-Appellant

v.

UNITED STATES, FASTENERS FOR RETAIL, INC., DBA SIFFRON, Defendants-Appellees ______________________

2024-1164 ______________________

Appeal from the United States Court of International Trade in No. 1:22-cv-00254-JCG, Judge Jennifer Choe- Groves. ______________________

Decided: February 17, 2026 ______________________

JEREMY WILLIAM DUTRA, Squire Patton Boggs (US) LLP, Washington, DC, argued for plaintiff-appellant.

CHRISTOPHER BERRIDGE, Commercial Litigation Branch, Civil Division, United States Department of Jus- tice, Washington, DC, argued for defendant-appellee United States. Also represented by BRIAN M. BOYNTON, CLAUDIA BURKE, PATRICIA M. MCCARTHY; KENNETH GARRETT KAYS, Office of the Chief Counsel for Trade En- forcement and Compliance, United States Department of Commerce. Case: 24-1164 Document: 71 Page: 2 Filed: 02/17/2026

WILLIAM FRANCIS MARSHALL, Sandler, Travis & Rosen- berg, P.A., New York, NY, argued for defendant-appellee Fasteners for Retail, Inc. ______________________

Before PROST, LINN, and REYNA, Circuit Judges. REYNA, Circuit Judge. Magnum Magnetics Corporation appeals a judgment of the United States Court of International Trade. The Trade Court affirmed a final scope ruling determination by the United States Department of Commerce that certain plas- tic shelf dividers containing magnets are not covered by an- tidumping and countervailing duty orders on U.S. imports of raw flexible magnets from the People’s Republic of China. For the reasons stated below, we affirm. BACKGROUND This appeal involves U.S. imports of certain plastic shelf dividers that contain magnets. The question ad- dressed is whether the shelf dividers are covered by the scope of antidumping and countervailing duty orders on raw flexible magnets from the People’s Republic of China. See Antidumping Duty Order: Raw Flexible Magnets from the People’s Republic of China, 73 Fed. Reg. 53847–48 (Sep. 17, 2008) (“ADD Order”), at J.A. 33–34; Raw Flexible Mag- nets from the People’s Republic of China: Countervailing Duty Order, 73 Fed. Reg. 53849–50 (Sep. 17, 2008) (“CVD Order”), at J.A. 35–36 (collectively, the “Duty Orders”).1

1 The ADD Order and the CVD Order contain iden- tical scope language, and the U.S. Department of Com- merce issued a single scope ruling for both. Compare ADD Order, J.A. 33–34, with CVD Order, J.A. 35–36. As a re- sult, we reference to both orders as “Duty Orders.” Case: 24-1164 Document: 71 Page: 3 Filed: 02/17/2026

MAGNUM MAGNETICS CORP. v. US 3

Generally, when an interested party believes merchan- dise that is like the merchandise it produces is sold in the United States at less than fair value (i.e., dumped or dump- ing) or benefits from countervailable subsidies, it may pe- tition the U.S. Department of Commerce (“Commerce”) to initiate an antidumping or countervailing duty investiga- tion, or both. 19 U.S.C. §§ 1671, 1673; see also id. §§ 1671a(b), 1673a(b). If Commerce initiates an investiga- tion, it determines whether the imported merchandise is sold in the U.S. market at less than fair value or is improp- erly subsidized. Id. §§ 1671b(b), 1671d(a), 1673b(b), 1673d(a). The U.S. International Trade Commission (“Commis- sion”) conducts a parallel investigation to determine whether a U.S. domestic industry that produces a product like the imported product subject to the investigations is materially injured or threatened with material injury by the subject imports. Id. §§ 1671b(a), 1671d(b), 1673b(a), 1673d(b). If both Commerce and the Commission reach af- firmative determinations, Commerce issues duty orders imposing antidumping or countervailing duties on the im- ported merchandise. Id. §§ 1671e, 1673e. Such duty orders include a description of the merchandise that is subject to the order. Id. §§ 1671e(a)(2), 1673e(a)(2). The description is written in general terms because it pertains to an overall class or kind of goods. 19 C.F.R. § 351.225(a). Questions often arise in the marketplace as to whether a particular product is covered by the scope of an existing order. In such instances, an interested party may request that Commerce issue a ruling on whether the product is covered by the scope of a duty order. Id. This appeal in- volves such a scope ruling. I. The Duty Investigations On September 21, 2007, Plaintiff-Appellant Magnum Magnetics Corporation (“Magnum”), a U.S. producer of flexible magnets, filed a petition with Commerce Case: 24-1164 Document: 71 Page: 4 Filed: 02/17/2026

requesting the initiation of an antidumping duty investiga- tion on imports of raw flexible magnets from the People’s Republic of China. See Notice of Initiation of Antidumping Duty Investigations: Raw Flexible Magnets from the Peo- ple’s Republic of China and Taiwan, 72 Fed. Reg. 59071 (Oct. 18, 2007).2 Commerce initiated an investigation on October 11, 2007, and notified the Commission. Id. at 59076. The investigation generally covered “certain flexi- ble magnet sheeting, strips, and profile shapes.” Id. at 59072. The Commission initiated investigations on September 28, 2007. Raw Flexible Magnets from China and Taiwan, Investigation Nos. 701-TA-452, 731-TA-1129, 731-TA- 1130, 72 Fed. Reg. 55248 (Sept. 28, 2007). On November 5, 2007, the Commission issued an affirmative preliminary determination of material injury or threat of material in- jury. Raw Flexible Magnets from China and Taiwan, In- vestigation Nos. 701-TA-452, 731-TA-1129, 731-TA-1130, 72 Fed. Reg. 63629 (Nov. 9, 2007) (Preliminary). On April 25, 2008, Commerce issued an affirmative prelimi- nary determination of sales at less than fair value. Prelim- inary Determination of Sales at Less Than Fair Value: Raw Flexible Magnets from the People’s Republic of China, 73 Fed. Reg. 22327, 22328 (Apr. 25, 2008). On July 2, 2008, Commerce issued an affirmative final determination of sales at less than fair value. Final Deter- mination of Sales at Less Than Fair Value: Raw Flexible Magnets from the People’s Republic of China, 73 Fed. Reg. 39669 (July 10, 2008). In August 2008, the Commission issued an affirmative final injury determination finding that an industry in the United States was materially in- jured or threatened with material injury by reason of the subject imports. Raw Flexible Magnets from China and

2 This opinion addresses only the investigations in- volving China. Case: 24-1164 Document: 71 Page: 5 Filed: 02/17/2026

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Taiwan, Inv. Nos. 701-TA-452, 731-TA-1129-1130, USITC Pub. 4030 (August 2008) (Final) (“Commission Injury Re- port”). II. Duty Orders On September 17, 2008, Commerce issued Duty Orders on raw flexible magnets from China. ADD Order, J.A. 33– 34; CVD Order, J.A. 35–36. According to the scope lan- guage of the Duty Orders: The products covered by [the Duty Orders] are cer- tain flexible magnets regardless of shape, color, or packaging. Subject flexible magnets are bonded magnets composed (not necessarily exclusively) of (i) any one or combination of various flexible bind- ers (such as polymers or co-polymers, or rubber) and (ii) a magnetic element, which may consist of a ferrite permanent magnet material (commonly, strontium or barium ferrite, or a combination of the two), a metal alloy (such as NdFeB or Alnico), any combination of the foregoing with each other or any other material, or any other material capable of be- ing permanently magnetized. Subject flexible magnets may be in either magnet- ized or unmagnetized (including demagnetized) condition, and may or may not be fully or partially laminated or fully or partially bonded with paper, plastic, or other material, of any composition and/or color. ADD Order, J.A. 33; CVD Order, J.A. 36 (same). III. Scope Ruling Defendant-Appellee Fasteners for Retail, Inc., d/b/a Siffron (“Siffron”), is a U.S. retailer that imports shelf di- viders composed of flexible magnets bonded to a plastic base. On March 11, 2022, Siffron submitted to Commerce a scope ruling request seeking a determination that its Case: 24-1164 Document: 71 Page: 6 Filed: 02/17/2026

imports of shelf dividers were not covered by the Duty Or- ders and thereby not subject to antidumping or counter- vailing duties. Siffron argued that its shelf divider magnets were substantially different from the subject flex- ible magnets because they were bonded to a rigid plastic component, which made the magnet inflexible and unable to bend or twist without damage. On August 9, 2022, Commerce issued a final scope rul- ing concluding that Siffron’s shelf dividers were not cov- ered by the scope of the Duty Orders. See Antidumping Duty and Countervailing Duty Orders on Raw Flexible Magnets from the People’s Republic of China: Final Scope Ruling on Siffron Plastic Shelf Dividers (Aug. 9, 2022) (“Fi- nal Scope Ruling”), at J.A. 569–81. Commerce based its determination on both the plain language of the Duty Or- ders and on other interpretative sources provided for in 19 C.F.R. § 351.225(k)(1)(i), which the parties refer to as the “(k)(1) sources.” These (k)(1) sources included the Commis- sion’s Injury Report issued in the underlying investigation, and prior scope rulings issued by Commerce in other inves- tigations. See Final Scope Ruling, J.A. 578–80. In its scope analysis, Commerce asserted that “based on the plain language of the scope, Siffron’s product ap- pears to fall within the scope” of the Duty Orders. Final Scope Ruling, J.A. 578. But Commerce further reasoned that “previous scope rulings and language from the under- lying [Commission] investigation provide further guid- ance.” Id. Accordingly, in addition to the plain language of the Duty Order, Commerce considered the (k)(1) sources. Final Scope Ruling, J.A. 579–80. Commerce then deter- mined that Siffron’s shelf dividers were not covered by the scope of the Duty Orders. Id. Magnum appealed Commerce’s scope ruling before the U.S. Court of International Trade (“Trade Court”), which upheld Commerce’s final scope ruling. Magnum Magnetics Case: 24-1164 Document: 71 Page: 7 Filed: 02/17/2026

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Corp. v. United States, 657 F. Supp. 3d 1387, 1401 (Ct. Int’l Trade 2023). Magnum timely appeals to this court. We have juris- diction under 28 U.S.C. § 1295(a)(5). STANDARD OF REVIEW We review decisions of the Trade Court de novo and ap- ply the same standard of review that the Trade Court ap- plies in its review of Commerce’s final antidumping and countervailing duty determinations. Sunpreme Inc. v. United States, 946 F.3d 1300, 1308 (Fed. Cir. 2020). We will uphold Commerce’s scope determinations unless they are unsupported by substantial evidence or otherwise not in accordance with law. 19 U.S.C. § 1516a(b)(1)(B)(i). Sub- stantial evidence means “such relevant evidence as a rea- sonable mind might accept as adequate to support a conclusion.” Consol. Edison Co. v. NLRB, 305 U.S. 197, 217 (1938). Finally, we recognize that “scope determinations are highly fact-intensive and case-specific.” Meridian Prods. v. United States, 890 F.3d 1272, 1277 (Fed. Cir. 2018) (citation modified). DISCUSSION On appeal, Magnum raises two issues. First, Magnum argues that Commerce’s reliance on the (k)(1) factors in its analysis of the language of the Duty Orders was contrary to law. Second, Magnum argues that, even assuming Com- merce properly consulted the (k)(1) factors, Commerce’s scope determination was erroneous. We address each issue in turn. I. The first issue on appeal turns on the interpretation of 19 C.F.R. §§ 351.225(k)(1) and 351.225(k)(1)(i), which gov- ern Commerce’s scope inquiries. Specifically, the parties dispute under what circumstances these provisions allow Commerce to consider (k)(1) sources when analyzing scope Case: 24-1164 Document: 71 Page: 8 Filed: 02/17/2026

language. According to Magnum, these provisions prohibit Commerce from consulting the (k)(1) sources when the scope language is plainly unambiguous. Appellant Br. 12. In contrast, appellees the United States and Siffron argue that under these provisions, Commerce has the discretion to consider (k)(1) sources “regardless of whether the plain language may appear ambiguous.” Appellee United States Br. 13–14 (citing 19 C.F.R. § 351.225(k)(1)(i)); see also Ap- pellee Siffron Br. 14 (“Commerce’s discretion to consider (k)(1) materials in analyzing a scope order exists whether the plain language may appear ambiguous or not.”). For the following reasons, we agree with appellees that the reg- ulatory provisions give Commerce the discretion to con- sider (k)(1) sources when analyzing the scope of an order, regardless of whether the plain language appears to be am- biguous or not. As an initial matter, we address Magnum’s argument that Commerce “concede[d] at the outset of the scope ruling analysis that the unambiguous text of the Orders’ scope provision squarely applies to Siffron’s Chinese-origin shelf dividers.” Appellant Br. 12 (citing Final Scope Ruling, J.A. 578). Whether Commerce made such an alleged con- cession stems from Commerce’s statement in its Final Scope Ruling that “based on the plain language of the scope, Siffron’s product appears to fall within the scope of the Orders.” Final Scope Ruling, J.A. 578 (first emphasis added). But we need not decide whether Commerce made such a concession because, as explained below, the regula- tory provisions give Commerce broad discretion to consider the (k)(1) factors regardless of whether the scope language is clear on its face. Case: 24-1164 Document: 71 Page: 9 Filed: 02/17/2026

MAGNUM MAGNETICS CORP. v. US 9

We now turn to the regulatory provisions at issue, as amended in 2021.3 Section 351.225(k)(1) provides that: [i]n determining whether a product is covered by the scope of the order at issue, the Secretary will consider the language of the scope and may make its determination on this basis alone if the lan- guage of the scope . . . is dispositive. 19 C.F.R. § 351.225(k)(1) (2021) (emphasis added). To de- termine whether the language is dispositive, Commerce may rely on certain interpretive tools. Specifically: [t]he following primary interpretive sources [i.e., (k)(1) sources] may be taken into account under paragraph (k)(1) introductory text of this section, at the discretion of the Secretary: (A) The descriptions of the merchandise contained in the petition pertaining to the order at issue; (B) The descriptions of the merchandise contained in the initial investigation pertaining to the order at issue; (C) Previous or concurrent determinations of the Secretary, including prior scope rulings, memo- randa, or clarifications pertaining to both the order

3 The 2021 version of 19 C.F.R. § 351.225 governs this appeal. Regulations to Improve Administration and Enforcement of Antidumping and Countervailing Duty Laws, 86 Fed. Reg. 52,300, 52,322 (Sep. 20, 2021) (“Final Rule”) (“Amendments to § 351.225 . . . apply to scope in- quiries for which a scope ruling application is filed . . . on or after November 4, 2021.”). Siffron filed its application for a scope ruling on March 3, 2022, and Commerce issued its ruling on August 9, 2022. Case: 24-1164 Document: 71 Page: 10 Filed: 02/17/2026

at issue, as well as other orders with same or simi- lar language as that of the order at issue; and (D) Determinations of the Commission pertaining to the order at issue, including reports issued pur- suant to the Commission’s initial investigation. 19 C.F.R. § 351.225(k)(l)(i). Relevant here, there is no re- quirement in this provision for Commerce to first deter- mine whether the scope language is clear on its face before turning to the (k)(1) factors. Rather, the regulation broadly provides that Commerce “may” take the (k)(1) factors “into account . . . at the discretion of the Secretary.” Id. (emphasis added). As such, even if Commerce indicates that the scope language appears clear on its face, Commerce may still turn to the (k)(1) factors as additional guidance for inter- preting the disputed language at issue. The history and purpose of these two provisions con- firm that Commerce is imbued with such discretion. In 2021, Commerce amended 19 C.F.R. § 351.225(k), result- ing in the current language of § 351.225(k)(1) and in the creation of § 351.225(k)(1)(i). These amendments were pre- cipitated by confusion as to whether Commerce could use the (k)(1) factors to interpret the plain meaning of the scope language or “whether the plain meaning analysis comes first, and only once a determination on the plain meaning is [made], then the [(k)(1)] sources [could be] considered.” Final Rule at 53,323. By amending 19 C.F.R. § 351.225(k), Commerce clarified its belief that the (k)(1) sources: were never intended by Commerce to be separate from the initial analysis of the scope language, but were instead to be interpretive tools that could be considered by Commerce, at its discretion and un- der consideration of the arguments on the admin- istrative record, to determine the meaning of the scope of the order. Case: 24-1164 Document: 71 Page: 11 Filed: 02/17/2026

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Id. As such, the 2021 amendments clarify that Commerce is not subject to a rigid and mechanical process for deter- mining the meaning of the scope order. Rather, Commerce has the discretion to use the (k)(1) factors as part of its analysis of the scope language. Id. Magnum, however, argues that Commerce’s discretion to consider the (k)(1) factors is limited to only those scenar- ios in which Commerce first determined the scope language is not dispositive. Appellant Br. 11. Specifically, Magnum relies on Commerce’s comments to the 2021 amendments that: if Commerce determines that the language of the scope is not itself dispositive (i.e., it is not disposi- tive using no interpretive tools whatsoever), Com- merce may take into account the identified primary interpretive sources, which are the traditional (k)(1) sources, in determining if the language is dis- positive and the scope covers the product at issue. Final Rule at 52,323. But the above quoted material stands for the limited proposition that if the scope language is un- clear on its face, Commerce “may take into account” the (k)(1) sources. The above quoted material does not stand for the separate proposition that if the scope language ap- pears to be clear on its face, Commerce is prohibited from considering the (k)(1) sources as additional guidance. In- deed, Commerce recognized that a term’s plain meaning may shift with time. As such, although once plain, scope language may need to be analyzed through the lens of the (k)(1) sources. Specifically, Commerce noted that: Commerce’s understanding [is] that the [(k)(1] sources . . . were always intended to be interpretive tools to understand the plain meaning of the scope, recognizing that terms that may have been plain at the time they were drafted and adopted upon the issuance of the Case: 24-1164 Document: 71 Page: 12 Filed: 02/17/2026

order could be interpreted differently at some later point. Id. (emphasis added). Magnum further argues that this court has, in prior cases, explained that Commerce must first find the plain language ambiguous before it can consult (k)(1) sources. Appellant Br. 10–12. But these cases interpreted and ap- plied an earlier version of § 351.225(k) that pre-dated the 2021 amendment.4 Consequently, these cases do not con- trol Commerce’s consideration of the (k)(1) factors in this case. To be clear, Commerce cannot exercise its discretion to consider the (k)(1) sources under 19 C.F.R. §§ 351.225(k)(1) and 351.225(k)(1)(i) to change the scope of a duty order; it may consider the (k)(1) sources only to interpret the scope of the duty order. See Saha Thai Steel Pipe, 101 F.4th at 1325 (“The (k)(1) material cannot control or alter the scope language of the order.”); Duferco Steel, Inc. v. United States, 296 F.3d 1087, 1095 (Fed. Cir. 2002) (“Commerce

4 See, e.g., ArcelorMittal Stainless Belg. N.V. v. United States, 694 F.3d 82, 87 (Fed. Cir. 2012) (reviewing scope ruling from 2010); Mid Continent Nail Corp. v. United States, 725 F.3d 1295, 1299 (Fed. Cir. 2013) (re- viewing scope ruling from 2010); Meridian Prods., LLC v. United States, 851 F.3d 1375, 1381 (Fed. Cir. 2017) (re- viewing scope ruling from 2012); Whirlpool Corp. v. United States, 890 F.3d 1302, 1306 (Fed. Cir. 2018) (reviewing scope ruling from 2013); Vandewater Int’l Inc. v. United States, 130 F.4th 981, 984 n.1, 988 (Fed. Cir. 2025) (review- ing scope ruling from 2018); Saha Thai Steel Pipe Pub. Co. Ltd. v. United States, 101 F.4th 1310, 1319 (Fed. Cir. 2024) (reviewing scope ruling from 2020), cert. denied sub nom. Saha Thai Steel Pipe Pub. Co. Ltd. v. Wheatland Tube Co., 145 S. Ct. 1309 (2025)). Case: 24-1164 Document: 71 Page: 13 Filed: 02/17/2026

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cannot interpret an antidumping order so as to change the scope of that order, nor can Commerce interpret an order in a manner contrary to its terms.” (citation modified)).5 We need not here decide whether there are limits to Com- merce’s discretion to use the (k)(1) factors as tools to inter- pret the language of a duty order. It is enough to note that these are “interpretive” sources, § 351.225(k)(1), and may not be used to rewrite a duty order. Here, rather than changing the scope of the Duty Orders to exclude the very products it seeks to cover, i.e., “flexible magnets,” Com- merce permissively used the (k)(1) factors to ascertain the meaning of the term “flexible magnets” in the Duty Orders, specifically, the term “flexible,” and whether Siffron’s prod- ucts meet such a description. See Final Scope Ruling, J.A. 587–88. In sum, based on the plain language and purpose of 19 C.F.R. §§ 351.225(k)(1) and 351.225(k)(1)(i), we hold that Commerce has the discretion to consider (k)(1) factors in assessing the meaning of the scope language, regardless of whether the language appears to be ambiguous or not. We next examine whether in light of the (k)(1) sources, Com- merce erred in its determination that Siffron’s shelf divid- ers are not covered by the scope of the Duty Orders. II. Magnum argues that even assuming Commerce properly relied on (k)(1) sources, Commerce’s scope

5 The (k)(1) factors include the petitions and other sources that relate to Commerce’s and the Commission’s definitions of the products that were subject to the under- lying investigations. The scope of a duty order directly re- lates to and is framed by those definitions. As such, when the scope of a duty order is disputed, it makes practical sense for Commerce to seek to understand the scope of that duty order in the context of the underlying investigations. Case: 24-1164 Document: 71 Page: 14 Filed: 02/17/2026

determination is erroneous. We disagree with Magnum. As explained below, Commerce’s scope determination is supported by substantial evidence and in accordance with the law. Here, Commerce determined that its prior scope ruling in InterDesign “support[s] a determination that Siffron’s plastic shelf dividers are excluded from the scope of the Or- ders.” Final Scope Ruling, J.A. 579 (discussing Final Scope Ruling on Certain Retail Hook and Paper Towel Magnets (Jan. 10, 2011) (“InterDesign Scope Ruling”)). Commerce explained that in InterDesign, it had previously deter- mined that the scope language, “flexible magnets,” ex- cludes “magnets that have been rendered inflexible by attached materials.” Id. (quoting InterDesign Scope Rul- ing). In light of this understanding, Commerce concluded that Siffron’s shelf dividers are not “flexible magnets” un- der the Duty Orders. Id. Specifically, Commerce found that “Siffron has demonstrated that bonding raw flexible magnets with an adhesive to a plastic blade renders the plastic shelf dividers inflexible to the extent that the plas- tic shelf divider cannot be manipulated without damaging the product.” Id. We see no legal error with Commerce’s reliance on In- terDesign’s interpretation of “flexible magnets.” Contrary to Magnum’s position, see Appellant Br. 15–17, InterDesign did not improperly change the scope of the Duty Orders to exclude functionally inflexible magnets but rather pro- vided a reasonable interpretation of the term “flexible mag- nets.” It stands to reason that a magnet cannot be a “flexible magnet” if rendered functionally inflexible when attached to some other material. We also determine that Commerce’s finding—that Sif- fron’s shelf dividers are functionally inflexible because they cannot be manipulated without damaging the product—is supported by substantial evidence. Here, Siffron provided video evidence supporting its claim that once bent, the Case: 24-1164 Document: 71 Page: 15 Filed: 02/17/2026

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shelf dividers lose their shape and cannot function as shelf dividers. J.A. 361, 565–68, 579. This is substantial evi- dence supporting Commerce’s functional inflexibility find- ing. Magnum’s argument that Siffron’s shelf dividers are flexible, see Appellant Br. 17, is an invitation to reweigh the evidence, which we do not do. Full Member Subgroup of Am. Inst. of Steel Constr., LLC v. United States, 81 F.4th 1242, 1257–58 (Fed. Cir. 2023). In sum, we affirm Commerce’s determination that Sif- fron’s products are not “flexible magnets” under the Duty Orders. Commerce did not err in relying on InterDesign, a (k)(1) source. Additionally, Commerce’s finding that Sif- fron’s shelf dividers are functionally inflexible is supported by substantial evidence.6 CONCLUSION We have considered Magnum’s remaining arguments and find them unpersuasive. For the reasons provided, we affirm the Trade Court’s judgment sustaining Commerce’s scope ruling that Siffron’s shelf dividers are not covered by the Duty Orders. AFFIRMED COSTS Costs against Magnum.

6 We need not reach Magnum’s challenges to Com- merce’s reliance on additional (k)(1) sources given that Commerce’s scope determination is sufficiently supported by InterDesign and Commerce’s finding that Siffron’s prod- ucts are functionally inflexible.