Pay Less Here, LLC v. United States

2025 CIT 50
CourtUnited States Court of International Trade
DecidedApril 22, 2025
Docket24-00152
StatusPublished

This text of 2025 CIT 50 (Pay Less Here, LLC 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
Pay Less Here, LLC v. United States, 2025 CIT 50 (cit 2025).

Opinion

Slip Op. 25-50

UNITED STATES COURT OF INTERNATIONAL TRADE

PAY LESS HERE, LLC,

Plaintiff,

v.

U.S. INTERNATIONAL TRADE COMMISSION,

Defendant,

and

BROOKLYN BEDDING LLC; CARPENTER CO.; CORSICANA Before: Timothy M. Reif, Judge MATTRESS COMPANY; FXI, INC.; KOLCRAFT ENTERPRISES, INC.; Court No. 24-00152 LEGGETT & PLATT, INCORPORATED; SERTA SIMMONS BEDDING, LLC; SOUTHERLAND, INC.; TEMPUR SEALY INTERNATIONAL; FUTURE FOAM, INC.; INTERNATIONAL BROTHERHOOD OF TEAMSTERS; AND UNITED STEEL, PAPER AND FORESTRY, RUBBER, MANUFACTURING, ENERGY, ALLIED INDUSTRIAL AND SERVICE WORKERS INTERNATIONAL UNION, AFL-CIO,

Defendant-Intervenors.

OPINION

[Granting defendant’s motion to dismiss for lack of subject matter jurisdiction.]

Dated: April 22, 2025

Alex Schaefer and Weronika Bukowski, Crowell & Moring LLP, of Washington, D.C., argued for plaintiff Pay Less Here, LLC. Court No. 24-00152 Page 2

Cayla Danielle Ebert DeJaco, Attorney, Office of the General Counsel, and Andrea C. Casson, Assistant General Counsel for Litigation, of Washington, D.C., argued for defendant U.S. International Trade Commission. With them on the brief was Dominic Bianchi, General Counsel.

Mary Jane Alves, Cassidy Levy Kent (USA) LLP, of Washington, D.C., argued for defendant-intervenors Brooklyn Bedding LLC; Carpenter Co.; Corsicana Mattress Company; FXI, Inc.; Kolcraft Enterprises, Inc.; Leggett & Platt, Incorporated; Serta Simmons Bedding, LLC; Southerland, Inc.; Tempur Sealy International; Future Foam, Inc.; International Brotherhood of Teamsters; and United Steel, Paper and Forestry, Rubber, Manufacturing, Energy, Allied Industrial and Service Workers International Union, AFL-CIO.

Reif, Judge: The issue before the court concerns the statutory standing

requirements for a plaintiff contesting a determination of the U.S. International Trade

Commission (the “Commission” or “defendant”). Plaintiff Pay Less Here, LLC (“plaintiff”)

brings the instant action to challenge the Commission’s final affirmative determination of

critical circumstances. Compl. ¶ 2, ECF No. 6. Defendant has filed a motion to dismiss

for lack of subject matter jurisdiction, alleging that plaintiff does not have standing to

bring its action by reason of plaintiff’s failure to file an entry of appearance in the

underlying administrative proceeding as required by the rules of the Commission. Def.’s

Mot. to Dismiss and Mem. in Supp. of its Mot. to Dismiss (“Def. Br.”), ECF No. 9.

Plaintiff counters that it filed a questionnaire response containing factual information that

led to the factual findings and legal conclusions being challenged in this action and that,

as a result, plaintiff has established standing. Pl.’s Resp. in Opp’n to the Commission’s

Mot. to Dismiss (“Pl. Br.”), ECF No. 19.

For the reasons described below, the court grants defendant’s motion to dismiss.

BACKGROUND

The underlying administrative proceedings followed a petition by U.S. domestic

producers of mattresses and unions representing workers in domestic mattress Court No. 24-00152 Page 3

factories for antidumping (“AD”) and countervailing duty (“CVD”) investigations. Def. Br.

at 1-2; Mattresses from Bosnia & Herzegovina, Bulgaria, Burma, Italy, Philippines,

Poland, Slovenia, and Taiwan, USITC Pub. 5520, Inv. Nos. 731-TA-1629-31, 1633,

1636-38, 1640, at 2 (June 2024). Petitioners alleged to both the U.S. Department of

Commerce (“Commerce”) and the Commission that “critical circumstances” existed

regarding the importation of mattresses from Burma. Pl. Br. at 2. Critical circumstances

exist where Commerce finds that “there have been massive imports of the subject

merchandise over a relatively short period,” 19 U.S.C. § 1673d(a)(3), and the

Commission finds that those imports “are likely to undermine seriously the remedial

effect of the antidumping duty order,” id. § 1673d(b)(4)(A)(i). An affirmative finding of

critical circumstances results in antidumping duties going into effect 90 days earlier than

would be the case in the absence of critical circumstances — referred to as “retroactive

application.” Id. §§ 1673b(e)(1), 1673d(c)(4). In response to petitioners’ allegations,

several parties — not including plaintiff — argued that the record did not support an

affirmative finding of critical circumstances in that the post-petition imports from Burma

were not likely to undermine seriously the efficacy of the AD order. Pl. Br., Exs. 1-3.

On July 28, 2023, the Commission instituted AD investigation No. 731-TA-1629-

1640 and CVD investigation No. 701-TA-693, and on August 3, 2023, the Commission

published notice of the investigations on the Federal Register. Mattresses From Bosnia

and Herzegovina, Bulgaria, Burma, India, Indonesia, Italy, Kosovo, Mexico, Philippines,

Poland, Slovenia, Spain, and Taiwan; Institution of Anti-Dumping and Countervailing

Duty Investigations and Scheduling of Preliminary Phase Investigations, 88 Fed. Reg.

51,351 (ITC Aug. 3, 2023). On September 1, 2023, the Commission determined Court No. 24-00152 Page 4

preliminarily that “there is a reasonable indication that an industry in the United States is

materially injured by reason of imports of mattresses” from the countries under

investigation, including Burma, “that are alleged to be sold in the United States at less

than fair value.” Mattresses from Bosnia & Herzegovina, Bulgaria, Burma, India,

Indonesia, Italy, Kosovo, Mexico, Philippines, Poland, Slovenia, Spain, and Taiwan,

USITC Pub. 5460, Inv. Nos. 701-TA-693, 731-TA-1629-1640 (Sept. 2023). As a result,

the Commission announced the commencement of the final phase of the investigation.

Id. at 2; see 19 C.F.R. § 207.18.

On March 1, 2024, Commerce issued its affirmative preliminary determination of

sales at less than fair value in the AD investigation. Mattresses from Burma:

Preliminary Affirmative Determination of Sales at Less than Fair Value and Preliminary

Affirmative Determination of Critical Circumstances, 89 Fed. Reg. 15,149 (Dep’t of

Commerce Mar. 1, 2024). Also in that preliminary determination, Commerce found that

critical circumstances existed for mattresses from Burma.1 Id. at 15,150.

On March 6, 2024, the Commission published on the Federal Register its notice

of the “final phase of antidumping and countervailing duty investigation[s] . . . to

1 Under 19 U.S.C. § 1673d(a)(3), in any AD investigation in which “the presence of critical circumstances has been alleged,” if Commerce makes an affirmative determination of sales at less than fair value, the final determination “shall also contain a finding” of whether:

(A)(i) there is a history of dumping and material injury by reason of dumped imports in the United States or elsewhere of the subject merchandise, or (ii) the person by whom, or for whose account, the merchandise was imported knew or should have known that the exporter was selling the subject merchandise at less than its fair value and that there would be material injury by reason of such sales, and (B) there have been massive imports of the subject merchandise over a relatively short period. Court No. 24-00152 Page 5

determine whether an industry in the United States is materially injured . . . by reason of

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Laclede Steel Co. v. United States
92 F.3d 1206 (Federal Circuit, 1996)
Specialty Merchandise Corp. v. United States
477 F. Supp. 2d 1359 (Court of International Trade, 2007)
American Grape Growers v. United States
604 F. Supp. 1245 (Court of International Trade, 1985)
Matsushita Electric Industrial Co. v. United States
529 F. Supp. 664 (Court of International Trade, 1981)
Hor Liang Industrial Corp. v. United States
337 F. Supp. 3d 1310 (Court of International Trade, 2018)
Gov't of Canada v. United States
686 F. Supp. 3d 1320 (Court of International Trade, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2025 CIT 50, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pay-less-here-llc-v-united-states-cit-2025.