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

2015 CIT 41
CourtUnited States Court of International Trade
DecidedMay 4, 2015
Docket13-00204
StatusPublished

This text of 2015 CIT 41 (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.

Bluebook
Navneet Publ'ns (India) Ltd. v. United States, 2015 CIT 41 (cit 2015).

Opinion

Slip Op. 15- 

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

[Sustaining the Department of Commerce’s 0.5% all-others antidumping rate on remand.]

Dated: 0D\

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 Joyce R. Branda, Acting 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.

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

Goldberg, Senior Judge: This case comes before the court following remand. In its

previous opinion, the court invalidated the 11.01% weighted average dumping margin that the

U.S. Department of Commerce (“Commerce” or “the agency”) had established for companies

that neither failed to cooperate with the agency nor were selected for individual investigation (the

“all-others rate” or “rate”). The court gave two reasons: (1) Commerce justified the all-others

rate partly on the basis of the low number of individually investigated companies, which was a

product of Commerce’s own decision-making, and (2) Commerce failed to corroborate the rate

with economic reality. Navneet Publ’ns (India) Ltd. v. United States, 38 CIT __, __, 999 F.

Supp. 2d 1354, 1362–66 (2014). On remand, Commerce provided a new all-others rate together

with a reasonable explanation of that rate. The court accordingly sustains Commerce’s

redetermination.

BACKGROUND

The court presumes familiarity with its prior opinion, including the explanation of the

role of all-others rates, and the statutory guidelines for establishing those rates set forth in 19

U.S.C. § 1673d(c)(5) (2012).1 The abridged facts that follow will suffice for the sake of this

decision.

In 2011, Commerce initiated its fifth administrative review of an antidumping duty order

on certain lined paper products from India. Initiation of Antidumping and Countervailing Duty

Administrative Reviews, 76 Fed. Reg. 67,133, 67,134 (Dep’t Commerce Oct. 31, 2011). The

review covered fifty-seven Indian producers and exporters of the subject merchandise. Resp’t

Selection Mem. at 2–3, PD 61 (Jan. 20, 2012). Commerce determined that it could not

individually investigate all fifty-seven companies subject to the review and instead limited its

1 The statutory provisions are called as guidelines because they expressly apply only to investigations, but Commerce nonetheless uses the provisions to inform its analysis in administrative reviews. Navneet, 38 CIT at __, 999 F. Supp. 2d at 1358. Court No. 13-00204 Page 3

review to the two respondents accounting for the largest known volume of subject merchandise.

Id. at 7–8; see 19 U.S.C. § 1677f-1(c)(2). The two individually investigated respondents were

Riddhi Enterprises (“Riddhi”) and SAB International (“SAB”). Resp’t Selection Mem. at 9. In

its Final Results, Commerce assigned zero percent individual rates to both Riddhi and SAB.

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

15, 2013) (final admin. review).

For the other fifty-five companies, Commerce assigned one of two rates. Four companies

had not cooperated by providing data during the administrative review; as a result, Commerce

applied an adverse facts available (“AFA”) rate of 22.02%. Id. at 22,233–34. The AFA rate

matched the highest non-aberrational transaction-specific dumping margin calculated for Riddhi

during the review. Id.

With respect to companies that were neither uncooperative nor selected for individual

investigation, Commerce applied a rate of 11.01%. Id. Commerce established the 11.01% rate

by simple averaging both individually investigated respondents’ zero-percent rates with 22.02%

rates from two of the uncooperative companies. Id. Commerce chose this method pursuant to 19

U.S.C. § 1673d(c)(5)(B). Under that provision, Commerce chooses “any reasonable method” for

establishing all-others rates when, inter alia, all individually investigated respondents have been

assigned zero-percent rates. Id.; see also Issues & Decision Mem. (“I&D Mem.”) at 13–14, PD

188 (Apr. 9, 2013).2 According to Commerce, including uncooperative companies’ AFA rates in

the all-others average was reasonable because, without data from the uncooperative companies,

2 In choosing the method, Commerce forewent both the “reasonable method” expressly contemplated in § 1673d(c)(5)(B) and another “reasonable method” the agency had used in past reviews. The “reasonable method” contemplated by statute is to average individually investigated respondents’ rates; the method used in past reviews is to average recently calculated non-zero rates (from either individually investigated respondents or all-others companies, depending on the circumstances). See I&D Mem. at 13–14. Commerce explained that it did not use the “reasonable method” from past reviews because all recent non-zero rates had been calculated using the zeroing methodology, which the agency no longer employs. Id. Court No. 13-00204 Page 4

Commerce could not know whether the individually investigated respondents’ zero-percent rates

“serve[d] as a proper basis” for establishing the all-others rate. I&D Mem. at 14. Commerce

limited the number of AFA rates to two because that was the number of respondents Commerce

had determined it could individually investigate. Id. As such, had the uncooperative companies

cooperated, Commerce might have individually investigated “up to two.” Id.

Plaintiffs (all of them companies assigned the all-others rate) filed suit at the Court of

International Trade on May 15, 2013. Summons, ECF No. 1. Plaintiffs claimed that

Commerce’s decision to include AFA rates in the all-others average was both contrary to statute

and unsupported by substantial evidence.

The court accepted plaintiffs’ substantial-evidence claim, and accordingly invalidated the

11.01% all-others rate. Navneet, 38 CIT at __, 999 F. Supp. 2d at 1362–66. The court offered

two reasons for its holding. First, Commerce’s inability to confirm the representativeness of

Riddhi’s and SAB’s zero-percent rates was in part a product of Commerce’s own decision to

individually investigate only those two companies. Id. at 1363. Second, Commerce had failed to

“verify that the [11.01% rate] reflects economic reality.” Id. Commerce never cited any record

evidence corroborating the accuracy of the 11.01% rate, and, in fact, record evidence

affirmatively undermined that rate. Id. at 1363–64.

As to Commerce’s failure to square the 11.01% rate with record evidence, the court

rejected a belated argument made by the Government during litigation.

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