Valeo North America, Inc. v. United States

CourtCourt of Appeals for the Federal Circuit
DecidedJuly 23, 2020
Docket20-1136
StatusUnpublished

This text of Valeo North America, Inc. v. United States (Valeo North America, Inc. v. United States) is published on Counsel Stack Legal Research, covering Court of Appeals for the Federal Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Valeo North America, Inc. v. United States, (Fed. Cir. 2020).

Opinion

Case: 20-1136 Document: 65 Page: 1 Filed: 07/23/2020

NOTE: This disposition is nonprecedential.

United States Court of Appeals for the Federal Circuit ______________________

VALEO NORTH AMERICA, INC., MAHLE BEHR TROY INC., MAHLE BEHR USA INC., MAHLE BEHR DAYTON L.L.C., MAHLE BEHR CHARLESTON INC., MAHLE BEHR MANUFACTURING MANAGEMENT, INC., MAHLE MANUFACTURING MANAGEMENT, INC., Plaintiffs

PROAMPAC INTERMEDIATE, INC., AMPAC HOLDINGS, LLC, JEN-COAT, INC., DBA PROLAMINA, Plaintiffs-Appellants

v.

UNITED STATES, ALUMINUM ASSOCIATION TRADE ENFORCEMENT WORKING GROUP AND ITS INDIVIDUAL MEMBERS, JW ALUMINUM COMPANY, NOVELIS CORPORATION, REYNOLDS CONSUMER PRODUCTS LLC, Defendants-Appellees ______________________

2020-1136 ______________________

Appeal from the United States Court of International Trade in Nos. 1:18-cv-00087-MAB, 1:18-cv-00105-MAB, Judge Mark A. Barnett. Case: 20-1136 Document: 65 Page: 2 Filed: 07/23/2020

______________________

Decided: July 23, 2020 ______________________

MARK LUDWIKOWSKI, Clark Hill PLC, Washington, DC, for plaintiffs-appellants. Also represented by WILLIAM C. SJOBERG, COURTNEY GAYLE TAYLOR; ROBERT KEVIN WILLIAMS, Chicago, IL.

ANDREA C. CASSON, Office of the General Counsel, United States International Trade Commission, Washing- ton, DC, for defendant-appellee United States. Also repre- sented by DOMINIC L. BIANCHI, BRIAN RUSSELL SOISET.

JOHN M. HERRMANN, Kelley Drye & Warren, LLP, Washington, DC, for defendants-appellees Aluminum As- sociation Trade Enforcement Working Group and its Indi- vidual Members, JW Aluminum Company, Novelis Corporation, Reynolds Consumer Products LLC. Also rep- resented by KATHLEEN CANNON, GRACE WHANG KIM, JOSHUA MOREY, PAUL C. ROSENTHAL. ______________________

Before O’MALLEY, BRYSON, and HUGHES, Circuit Judges. HUGHES, Circuit Judge. This case involves an antidumping and countervailing duty investigation of aluminum foil. ProAmpac appeals the United States Court of International Trade’s decision affirming the United States International Trade Commis- sion’s determination that ultra-thin aluminum foil was not a separate domestic like product from other gauges of alu- minum foil. Because substantial evidence supports the Commission’s decision, we affirm. Case: 20-1136 Document: 65 Page: 3 Filed: 07/23/2020

VALEO NORTH AMERICA, INC. v. UNITED STATES 3

I In 2017, domestic producers of aluminum foil filed an- tidumping and countervailing duty petitions regarding im- ports of aluminum foil from China. Valeo N. Am., Inc. v. United States, 404 F. Supp. 3d 1303, 1308–09 (Ct. Int’l Trade 2019). The petitions covered aluminum foil having a thickness of 0.2 millimeters or less, in reels ex- ceeding 25 pounds, regardless of width. Id. at 1309. “The petitions listed a range of uses for aluminum foil, including its use in the manufacture [of] thermal insulation for the construction industry, fin stock for air conditioners, electri- cal coils for transformers, capacitors for radios and televi- sions, and insulation for storage tanks.” Id. (alteration in original) (internal quotation marks omitted). While “Commerce determines whether foreign imports into the United States are either being dumped or subsi- dized (or both),” the United States International Trade Commission (Commission) “determine[s] whether these dumped or subsidized imports are causing material injury to a domestic industry in the United States.” Changzhou Trina Solar Energy Co., Ltd. v. U.S. Int’l Trade Comm’n, 100 F. Supp. 3d 1314, 1319 (Ct. Int’l Trade 2015) (internal quotation marks omitted); see 19 U.S.C. §§ 1671, 1673. The Commission “identif[ies] the corresponding universe of items produced in the United States [by the affected indus- try] that are like, or in the absence of like, most similar in characteristics and uses with the items in the scope of the investigation.” Changzhou Trina Solar, 100 F. Supp. 3d at 1319 (citing 19 U.S.C. §§ 1673(i), 1671(a)) (internal quo- tation marks omitted) (additional citation and formatting marks omitted). Here, in the preliminary phase of its injury investiga- tions, the Commission considered the correct definition of the domestic like product, and whether there were clear di- viding lines among the domestically produced products cor- responding to the in-scope imported articles. Certain Case: 20-1136 Document: 65 Page: 4 Filed: 07/23/2020

parties argued that flat-rolled aluminum foil more than 45 microns (0.045 millimeters) thick was a separate domestic like product. Valeo N. Am., Inc., 404 F. Supp. 3d at 1309. Others argued that ultra-thin aluminum foil less than eight microns (0.008 millimeters) thick was a separate do- mestic like product. Id. The Commission conducted its six-factor domestic like product analysis, considering: (1) physical characteristics and uses; (2) interchangeability; (3) channels of distribu- tion; (4) customer and producer perceptions; (5) common manufacturing facilities, production processes, and produc- tion employees; and, where appropriate, (6) price. Id. at 1312. See also, Cleo Inc. v. United States, 501 F.3d 1291, 1295 (Fed. Cir. 2007); Timken Co. v. United States, 913 F. Supp. 580, 584 (Ct. Int’l Trade 1996). “When weigh- ing those factors, the Commission disregards minor differ- ences and focuses on whether there are any clear dividing lines between the products being examined.” Cleo, 501 F.3d at 1295. Here, the Commission found no clear di- viding lines between the varieties and gauges of aluminum foil identified by the parties, including ultra-thin alumi- num foil, and therefore preliminarily found “a single do- mestic like product consisting of all aluminum foil coextensive with the scope of the investigations.” Valeo N. Am., Inc., 404 F. Supp. 3d at 1309 (quoting the Commis- sion’s Preliminary Views). During the final phase of its investigation, ProAmpac disputed the Commission’s preliminary determination. ProAmpac highlighted why it believed ultra-thin alumi- num foil should be classified separately, including that few domestic aluminum foil manufacturers produce ultra-thin aluminum foil. See, e.g., J.A. 752–53. The Commission issued its final determinations in 2018, affirming its preliminary decision that ultra-thin aluminum foil was not a separate domestic like product. Case: 20-1136 Document: 65 Page: 5 Filed: 07/23/2020

VALEO NORTH AMERICA, INC. v. UNITED STATES 5

Valeo N. Am., Inc., 404 F. Supp. 3d at 1311 (citing the Com- mission’s Final Views). ProAmpac appealed the Commission’s decision to the United States Court of International Trade (CIT). The CIT sustained the Commission’s decision and entered judgment in favor of the Commission. 1 Valeo N. Am., Inc., 404 F. Supp. 3d at 1313–15, 1323. 2

ProAmpac timely appealed. We have jurisdiction un- der 28 U.S.C. § 1295(a)(5). II “Like the [CIT], this court reviews the Commission’s determination for substantial evidence.” Cleo, 501 F.3d at 1296; 19 U.S.C. § 1516a(a)(2)(B)(i), (b)(1)(B)(i). Under the substantial evidence standard, we will affirm the Com- mission’s determination if it is supported by the record as a whole, even if some evidence detracts from the Commis- sion’s conclusion. Atl. Sugar, Ltd. v.

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Related

Cleo Inc. v. United States
501 F.3d 1291 (Federal Circuit, 2007)
Timken Co. v. United States
913 F. Supp. 580 (Court of International Trade, 1996)
Changzhou Trina Solar Energy Co. v. United States International Trade Commission
100 F. Supp. 3d 1314 (Court of International Trade, 2015)

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