US Magnesium LLC v. United States

2012 CIT 64
CourtUnited States Court of International Trade
DecidedMay 16, 2012
Docket11-00076
StatusPublished

This text of 2012 CIT 64 (US Magnesium 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.

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US Magnesium LLC v. United States, 2012 CIT 64 (cit 2012).

Opinion

Slip Op. 12-64

UNITED STATES COURT OF INTERNATIONAL TRADE

US MAGNESIUM LLC,

Plaintiff,

v. Before Richard W. Goldberg, Senior Judge Court No. 11-00076 UNITED STATES, PUBLIC VERSION Defendant,

and

PSC VSMPO-AVISMA CORP. and VSMPO- TIRUS, US INC.,

Defendant-Intervenors.

OPINION & ORDER

[Plaintiff’s Motion for Judgment on the Agency Record is denied.]

Dated: May 16, 2012

Stephen A. Jones, King & Spalding LLP, of Washington, D.C., for plaintiff.

Peter L. Sultan, Attorney, Office of the General Counsel, U.S. International Trade Commission, of Washington, D.C.; James M. Lyons, General Counsel; and Andrea C. Casson, Assistant General Counsel, for defendant.

John M. Gurley and Diana Dimitriuc-Quaia, Arent Fox LLP, of Washington, D.C., for defendant-intervenors. Court No. 11-00076 Page 2

Goldberg, Senior Judge: Plaintiff US Magnesium LLC (“US Magnesium”) contests the

U.S. International Trade Commission’s (“the Commission”) negative determination in the sunset

review of the antidumping duty order on Magnesium Metal from the Russian Federation.

Magnesium from China and Russia, USITC Pub. 4214, Inv. Nos. 731-TA-1071-1072 (Feb.

2011) (Sunset Review Determination), published in the Federal Register at 76 Fed. Reg. 11,813

(ITC Mar. 3, 2011).

Background

In 2005, the Commission determined that imports of magnesium metal from Russia and

China were causing material injury to the domestic industry. Magnesium from China and

Russia, USITC Pub. 3763, Inv. Nos. 731-TA-1071-1072 (Apr. 2005) (Final); Magnesium from

China and Russia, 70 Fed. Reg. 19,969 (ITC Apr. 15, 2005). Based on the affirmative final

determinations by the Commission and the United States Department of Commerce

(“Commerce”), Commerce issued antidumping duty orders on magnesium metal from Russia

and China. Notice of Antidumping Duty Order: Magnesium Metal from the People's Republic of

China, 70 Fed. Reg. 19,928 (Dep’t Commerce Apr. 15, 2005); Notice of Antidumping Duty

Order: Magnesium Metal from the Russian Federation, 70 Fed. Reg. 19,930 (Dep’t Commerce

Apr. 15, 2005).

In 2010, the antidumping duty orders were reviewed pursuant to the five-year sunset

review requirement of section 751(c) of the Tariff Act of 1930, 19 U.S.C. § 1675(c) (2006). The

Commission declined to cumulate the subject imports from China and Russia because it Court No. 11-00076 Page 3

concluded that they were subject to different conditions of competition. The Commission based

this conclusion on the fact that: (1) imports from Russia are primarily pure magnesium, whereas

the scope of the order with respect to China is limited to alloy magnesium; (2) trends in the

capacity, production, and shipments of the two countries’ industries differ; (3) there is a raw

material shortage affecting the Russian industry; and (4) the Chinese and Russian industries

show different export trends.

The Commission also concluded that the circumstances warranted revocation of the

antidumping duty order with respect to magnesium metal from Russia. The Commission based

this conclusion on the fact that: (1) there has been a decline in the capacity, production, and

shipments of the Russian magnesium industry since the original investigations; (2) raw material

shortages affect the Russian producers; and (3) the Russian industry’s production has been

redirected toward its home market. The Commission determined that these factors limit the

availability and amount of magnesium that the Russian industry is able to ship to the United

States.

Based on the foregoing, the Commission concluded that revocation would not be likely to

lead to the continuation or recurrence of material injury to the domestic industry in the

reasonably foreseeable future. Specifically, the Commission found that revocation was: (1)

unlikely to lead to subject imports from Russia entering the United States in significant volumes

within a reasonably foreseeable time; (2) unlikely to lead to significant underselling by the

subject imports of the domestic like product, or to significant price depression or suppression, Court No. 11-00076 Page 4

within a reasonably foreseeable time; and (3) unlikely to have a significant impact on the

domestic industry. Accordingly, the Commission revoked the antidumping duty order with

respect to Russia.

US Magnesium brought this appeal, challenging the Commission’s determinations in the

sunset review.

Jurisdiction and Standard of Review

This Court has jurisdiction pursuant to section 201 of the Customs Court Act of 1980, 28

U.S.C. § 1581(c) (2006).

This Court upholds the Commission’s determinations unless they are “unsupported by

substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. §

1516a(b)(1)(B)(i). The Commission has “discretion to make reasonable interpretations of the

evidence and to determine the overall significance of any particular factor in its analysis.” Goss

Graphics Sys., Inc. v. United States, 22 CIT 983, 1005, 33 F. Supp. 2d 1082, 1100 (1998), aff’d,

216 F.3d 1357 (Fed. Cir. 2000). “[E]ven if it is possible to draw two inconsistent conclusions

from evidence in the record, such a possibility does not prevent [the Commission’s]

determination from being supported by substantial evidence.” Nippon Steel Corp. v. United

States, 458 F.3d 1345, 1352 (Fed. Cir. 2006) (citing Am. Silicon Techs. v. United States, 261

F.3d 1371, 1376 (Fed. Cir. 2001)). Court No. 11-00076 Page 5

Thus, this Court determines whether the agency’s determinations are “reasonable and

supported by the record as a whole, even if some evidence detracts from the Commission’s

conclusion.” Id. at 1352.

Discussion

US Magnesium challenges: (I) the Commission’s decision not to cumulate the subject

imports from Russia and China; and (II) the revocation of the order with respect to Russia as

unsupported by substantial evidence. For the following reasons, US Magnesium’s arguments

fail.

I. The Commission’s decision not to cumulate subject imports from China and Russia is supported by substantial evidence

In sunset reviews, the Commission has discretion to cumulate subject imports from

different countries if certain conditions are met:

the Commission may cumulatively assess the volume and effect of imports of the subject merchandise from all countries with respect to which reviews under [19 U.S.C. section 1675(b) or (c)] were initiated on the same day, if such imports would be likely to compete with each other and with domestic like products in the United States market. The Commission shall not cumulatively assess the volume and effects of imports of the subject merchandise in a case in which it determines that such imports are likely to have no discernible adverse impact on the domestic industry.

19 U.S.C. § 1675a(a)(7). The Commission has discretion not to cumulate even if the

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