PUBLIC VERSION
QSP without any pigments is generally white with fine particulates. 54 Producers of QSP invest in the development of new collections and designs to attract customers. 55 Manufacturing advances have improved the appearance of QSP and enabled producers to make QSP with designs inspired by various types of quarried stone, such as the veined movement of marble, or that otherwise has unique aesthetic patterns. 56 These patterns require specialized machinery and design by teams of engineers whose end products are protected and registered as intellectual property. 57 The domestic industry has been a pioneer in advancing new production techniques and innovative new designs for QSP that have led to growing demand for the product among consumers. And imports regularly infringe on the intellectual property rights of members of the alliance. For example, Cambria has filed several intellectual property lawsuits against imported products. 58
C.
Current Tariff Treatment of the Imported Article
The imported article covered by this petition is classifiable under the Harmonized Tariff Schedule of the United States(“ HTSUS”) reporting numbers 6810.99.0020, 6810.99.0040, and 7020.00.6000. All imports under the first two HTSUS numbers( i. e., 6810.99.0020 and 6810.99.0040) are covered articles as these two numbers are specific to QSP made from
54 Id.
55 Id.
56 Id.
57 Id.
58 See, e. g., Cambria Company LLC v. Quartz Master, LLC and Raphael Stone Collection, Inc., C. A. No
2:2020-cv-01637( D. N. J.); Cambria Company LLC v. Hirsch Glass Corp. d / b / a Spectrum Quartz, Case No. 1:21-cv-00143( E. D. Va.); Cambria Company v. Cosmos Granite & Marble, NC, LLC, Case No. 5:18-cv-601( E. D. N. C.).
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