PUBLIC VERSION
1. Imports Have Captured Sales and Market Share at the Direct Expense of the Domestic Industry
The fact that low-priced imports are a substantial cause of serious injury to the domestic industry is evidenced by the decline in U. S. producers’ market share as imports of QSP surged over the POI and captured market share from the domestic industry. As the volume of imports surged from 135 million SQF in 2020 to 234 million SQF in 2024, the market share held by imports rose from [ ] to [ ]. 152 The market share held by the domestic industry, in turn, dropped from [ ] to [ ]. 153 As imports captured sales and revenues from U. S. producers— precipitating facility closures, production curtailments, and layoffs— the volume of imports also increased substantially as a share of domestic production. Indeed, as discussed above, the ratio of imports to U. S. production grew from [ ] in 2020 to [ ] in 2024. In other words, by the end of the POI, the volume of imports in a single year represented exactly [ ] times the entire production of the domestic industry.
2. Imports Have Undersold Domestically Produced QSP by Substantial Margins
The fact that subject imports are a substantial cause of the serious injury experienced by the domestic industry is also evidenced by the pervasive underselling that took place during the POI. As discussed above, annual price comparisons based on AUVs demonstrate that imports were priced lower than U. S. producers’ U. S. shipments in each year between 2020 and 2024. Indeed, imports overwhelmingly undersold the domestic product during the POI, with margins of
152 Calculation of Market Share, attached as Exhibit 9.
153 Id.
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