Navneet Publ'ns (India) Ltd. v. United States

2014 CIT 119
CourtUnited States Court of International Trade
DecidedOctober 6, 2014
Docket13-00204
StatusPublished

This text of 2014 CIT 119 (Navneet Publ'ns (India) Ltd. 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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Navneet Publ'ns (India) Ltd. v. United States, 2014 CIT 119 (cit 2014).

Opinion

Slip Op. 14-119

UNITED STATES COURT OF INTERNATIONAL TRADE

NAVNEET PUBLICATIONS (INDIA) LTD., MARISA INTERNATIONAL, SUPER IMPEX, PIONEER STATIONARY Before: Richard W. Goldberg, Senior Judge PVT. LTD., SGM PAPER PRODUCTS, Court No. 13-00204 LODHA OFFSET LIMITED, and MAGIC INTERNATIONAL PVT. LTD.,

Plaintiffs,

v.

UNITED STATES, Defendant,

and

ASSOCIATION OF AMERICAN SCHOOL PAPER SUPPLIERS,

Defendant-Intervenor.

OPINION

[Granting plaintiff’s motion for a preliminary injunction.]

Dated: October 6, 2014

Neil R. Ellis, Richard L.A. Weiner, and Rajib Pal, Sidley Austin LLP, of Washington, DC, for plaintiffs.

Antonia R. Soares, Trial Attorney, Commercial Litigation Branch, Civil Division, U.S. Department of Justice, of Washington, DC, for defendant. With her on the brief were Stuart F. Delery, Assistant Attorney General, Jeanne E. Davidson, Director, and Patricia M. McCarthy, Assistant Director. Of counsel on the brief was Elika Eftekhari, Office of the Chief Counsel for Trade Enforcement and Compliance, U.S. Department of Commerce, of Washington, DC.

Timothy C. Brightbill, Maureen E. Thorson, and Tessa V. Capeloto, Wiley Rein LLP, of Washington, DC, for defendant-intervenor. Court No. 13-00204 Page 2

Goldberg, Senior Judge: The court considers a motion by plaintiff Navneet Publications

(India) Ltd. (“Navneet”), for a preliminary injunction under USCIT Rule 65. During the fifth

administrative review of an antidumping order on lined paper products from India, the

Department of Commerce assigned Navneet an ad valorem antidumping rate of 11.01 percent.

See Certain Lined Paper Products from India, 78 Fed. Reg. 22,232, 22,234 (Dep’t Commerce

Apr. 15, 2013) (final admin. review) (“Final Results”). Navneet now seeks to prevent entries

from a later review period from being liquidated at this 11.01 percent rate. Defendant the United

States (“the Government”) rejoins that the court lacks jurisdiction to issue an injunction.

The court grants the motion over the Government’s objections. The court first holds that

it has jurisdiction to enjoin the liquidation of entries at the 11.01 percent rate, even though those

entries were made during a subsequent review period. The court also finds that Navneet meets

the traditional requirements to secure a preliminary injunction, as discussed below.

BACKGROUND

In 2006, the Department of Commerce (“Commerce”) issued an antidumping order on

certain lined paper products (“CLPP”) from India. Certain Lined Paper Products from India, 71

Fed. Reg. 56,949 (Dep’t Commerce Sept. 28, 2006) (notice of antidumping duty order). The

agency launched the fifth administrative review of this order in October 2011. See Initiation of

Antidumping and Countervailing Duty Administrative Reviews, 76 Fed. Reg. 67,133, 67,134

(Dep’t Commerce Oct. 31, 2011). During the proceeding, Commerce assigned Navneet, a

cooperative respondent not selected for individual review, an 11.01 percent antidumping rate, or

“all-others” rate. Final Results at 22,233 34. This all-others rate would serve as the rate of

liquidation—or the final antidumping duty imposed—for each entry of Navneet’s CLPP

imported during the fifth review period (September 1, 2010 to August 31, 2011). Id. at 22,232. Court No. 13-00204 Page 3

The rate also became the amount importers paid in deposits for Navneet’s CLPP that entered, or

was withdrawn from warehouse, after the Final Results were published. Id. at 22,234; see also

19 U.S.C. § 1675(a)(2)(C). The Final Results were published on April 15, 2013.

Navneet appealed the Final Results a month later. See Summons, ECF No. 1 (May 15,

2013). The Court of International Trade took jurisdiction under 28 U.S.C. § 1581(c), which

gives the court exclusive authority to review final determinations from antidumping

investigations and reviews. See Navneet Publ’ns (India) Ltd. v. United States, 38 CIT __, __,

999 F. Supp. 2d 1354, 1357 (2014). Thus empowered, the court held that the all-others rate from

the fifth review was not based in substantial evidence. Id. at __, 999 F. Supp. 2d at 1366. The

Final Results were remanded so Commerce could revise the rate to comply with the court’s

opinion and order. Id.

As the parties litigated the Final Results of the fifth review, Commerce initiated its sixth

review of the CLPP order. See Initiation of Antidumping and Countervailing Duty

Administrative Reviews, 77 Fed. Reg. 65,858, 65,859 (Dep’t Commerce Oct. 31, 2012).

Commerce completed the sixth review on May 7, 2014, and assigned Navneet a 0.25 percent rate

for entries of CLPP from the sixth review period (September 1, 2011, and August 31, 2012).

Certain Lined Paper Products from India, 79 Fed. Reg. 26,205, 26,206 (Dep’t Commerce May

7, 2014) (final admin. review).

Later, but still during the fifth-review litigation, Navneet and the Association of

American School Paper Suppliers (“AASPS”) requested a seventh review of Navneet’s CLPP

imports. See Appl. for Prelim. Inj. at Ex. 1, ECF No. 57 (“Pl.’s App.”). Commerce duly

initiated the review, which would have calculated duties for CLPP entered between September 1, Court No. 13-00204 Page 4

2012, and August 31, 2013. See Initiation of Antidumping and Countervailing Duty

Administrative Reviews, 78 Fed. Reg. 67,104, 67,105 (Dep’t Commerce Nov. 8, 2013).

In December 2013, however, both Navneet and AASPS withdrew their requests for

review. Pl.’s App. at Ex. 2. This set off a legal chain reaction that culminated in Navneet’s

motion for a preliminary injunction. First, because both Navneet and AASPS withdrew their

review requests within 90 days of initiation, Commerce had to rescind the review with respect to

Navneet. See § 19 C.F.R. § 351.213(d)(1). The agency issued its notice of rescission on

September 30, 2014. See Notice of Recent Development at Ex. A, ECF No. 60 (“Rescission

Notice”); 19 C.F.R. § 351.213(d)(4). Second, now that the review is rescinded, Commerce must

instruct Customs and Border Protection (“CBP”) to liquidate Navneet’s seventh-review-period

entries at the cash deposit rate in effect at the time those entries were made. See 19 C.F.R.

§ 351.212(c); see also 19 U.S.C. § 1516a(c)(1) (requiring liquidation, absent an injunction, in

accordance with agency determination). The cash deposit rate in effect during the latter part of

the seventh review period—or April 15 to August 31, 2013—was the invalidated all-others rate

issued in the fifth-review Final Results.

To avoid having its seventh-review-period entries liquidated at the invalid fifth-review

rate, Navneet applied for a preliminary injunction. See 19 U.S.C. § 1516a(c)(2) (allowing court

to enjoin liquidation of entries covered by agency decision). Plaintiff would limit relief to entries

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