USITC Filing Chinese Quartz Imports M S International Letter, 1 May 2018 | Page 4

The Honorable Wilbur L. Ross
May 1, 2018
Page 4
fabricated, cured or uncured, edged or not edged, finished or
unfinished, thermoformed or not thermoformed, further processed or
not further processed, packaged or unpackaged, and regardless of
the type of surface finish. 7/
Accordingly, Petitioner included both fabricated and non-fabricated in the scope of the Petition and,
therefore, in the scope of the domestic industry. Petitioner has not accounted for the fabricators in
any way shape or form, however, in its purported calculation of industry support. On the contrary,
Petitioner has entirely ignored the part of the industry that purchases slabs from Cambria and other
distributors (or other sources, including China) to manufacture a fabricated product.
Petitioner certainly possesses information on fabricators, but such data appear to have been
ignored to manufacture standing in these proceedings. In fact, Cambria’s own webpage includes a
specified portal for fabricators to log-in for business purposes – and even to enjoy the film “Legend
-
of Cambria” should they so choose. 8/ Furthermore, Cambria runs “Cambria University” to help
-
fabricators hone their skills at using Cambria’s quartz products. 9/ Accordingly, Petitioner should
have included data on fabricators in its purported standing analysis and should have made an
upward adjustment to the size of the industry to account for them. 10/
For these reasons, Petitioner has failed to establish standing. Accordingly, the Department
should not initiate these investigations. Alternatively, the Department poll the industry (including
fabricators) pursuant to 19 C.F.R. § 351.203(b)(2) to determine whether there is adequate industry
support.
- 7/
- 8/
- 9/
Petition at 4 (emphasis added).
See Exhibit 1, Cambria Fabricators & Installers.
See Exhibit 2, Cambria University.
10/
Notice of Initiation of Countervailing Duty Investigation: Certain Softwood Lumber Products
from Canada, 66 Fed. Reg. 21332, 21333 (April 30, 2001)