PUBLIC VERSION
degree.” 119 In the later investigations on QSP from India and Turkey, the Commission found that“ cumulated subject imports pervasively undersold the domestic like product throughout the POI” and that“ cumulated subject imports undersold the domestic like product in all 129 quarterly price comparisons involving 18.2 million square feet of cumulated subject imports at underselling margins that ranged from 11.4 percent to 53.9 percent and averaged 28.9 percent.” 120 Moreover, the Commission explained that the significant underselling by subject imports fueled their significant increase in market share over the POI, particularly in 2019 as QSP imports from China exited the market after the imposition of cash deposits and the AD and CVD orders on QSP from China. 121 [ ], the evidence also shows that the domestic industry could not increase prices sufficiently to cover rising costs, and, as a result, experienced price suppression due to lowpriced import competition. The domestic industry’ s ratio of costs of goods sold(“ COGS”) to sales [ ] in 2024. 122 This price suppression, along with reduced sales volumes, caused the domestic industry’ s operating income as a share of net sales to worsen during the POI.
As described earlier, the increase in low-priced import competition forced U. S. producers to substantially reduce their production of QSP, and as a result, the U. S. producers’ capacity utilization and productivity rates plummeted over the POI.
119 Id. at 28-29. 120 Id. at 28. 121 Id. at 28-29. 122 Petitioner’ s Confidential Operational and Financial Performance, attached as Exhibit 12.
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