PUBLIC VERSION
* * * As demonstrated throughout this petition, the surge of imports of QSP that has overwhelmed the U. S. market over the last five years is a substantial cause of the serious injury to the domestic QSP industry. Especially given that this remarkable import surge is significantly attributable to transshipped and misclassified QSP or merchandise that is in violation of intellectual property laws, these circumstances demand the immediate imposition of targeted import measures to stop the serious injury against the domestic QSP industry. Without decisive relief, as demonstrated by the mothballing of two U. S. production facilities over the POI, the domestic industry cannot fairly compete, recoup substantial past investments, or realize the recovery ordinarily seen after the trade orders. Especially where the U. S. market is so attractive to unfair imports, safeguard measures are appropriate to permit domestic producers to earn a fair return on investment and continue to reinvest in production, research and development, and innovation.
II. PRODUCT DESCRIPTION AND DOMESTIC LIKE ARTICLE( 19 C. F. R. § 206.14( A))
A.
Name and Definition of the Imported Article
The imported article covered by this petition is quartz surface products. The product is the same product that was the subject to the AD / CVD investigations of QSP from China, India, and Turkey that led to the imposition of AD and CVD orders against those countries. 45 The only exception is that Petitioner has removed the exclusion for“ crushed glass surface products” that
45 See AD / CVD Orders on QSP from China; AD / CVD Orders on QSP from India and Turkey.
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