USITC Filing Chinese Quartz Imports M S International Letter, 1 May 2018

Hogan
Lovells
Hogan Lovells US LLP
Columbia Square
555 Thirteenth Street, NW
Washington, DC 20004
T [phone]
F [phone]
May 1, 2018
Inv. Nos. A-570-084; C-570-085
Pages: 14
Non-Initiated Investigations
Enforcement & Compliance, Office of
AD/CVD Operations
PUBLIC DOCUMENT
VIA ELECTRONIC FILING (ACCESS)
The Honorable Wilbur L. Ross
Secretary of Commerce
Attention: Import Administration
Central Records Unit, Room 18022
U.S. Department of Commerce
14 th Street & Constitution Avenue, N.W.
Washington, DC 20230
Re:
Quartz Surface Products from the People’s Republic of China: Comments on the Lack
of Standing of the Petitioner and Requests for Action
Dear Secretary Ross:
On behalf of our client M S International, Inc. (“MSI”), a U.S. importer, we hereby object to
the lack of standing evidenced in the Petition filed by Cambria Company LLC (“Cambria” or the
“Petitioner”) in the non-initiated investigations referenced above. For the reasons set forth below,
Petitioner has not met its burden of establishing Cambria’s standing and, therefore, the U.S.
Department of Commerce (the “Department”) should not initiate investigations into quartz surface
products from China based on the Petition. 1/ Alternatively and at minimum, due to the substantial
infirmities in the Petition we request that the Department poll the industry pursuant to the governing
1/
Petitions for the Imposition of Antidumping Duties and Countervailing Duties: Certain Quartz
Surface Products from the People’s Republic of China (Apr. 17, 2018) (the “Petition”). Petitioner’s
two supplemental deficiency filings in support of the Petition have not cured these deficiencies.
Certain Quartz Surface Products from the People’s Republic of China: Response to Supplemental
Questions – General Issues, A-570-084 & C-570-085 (Apr. 24, 2018) (“Petitioner’s April 24 General
Issues Submission”); Certain Quartz Surface Products from the People’s Republic of China:
Response to Supplemental Questions –Antidumping, A-570-084 (Apr. 30, 2018).