underlying dispute is whether roughly forged materials used in the production process are classifiable under the age he has and in heading seventy two twenty four regarding that underlying class kitchen dispute there are two fundamental issues for the court to decide first in the court of international trade err by failing to classify the rough origins in seventy two twenty four by the application of general rule of interpretation one and second did the court of international trade improperly strive to conform its decision to a ruling of the numbing quit your committee of the world customs organization we believe the answer to both these questions is for regarding the first issue in all classification kisses the general rules  finished product he did that ed page three seventy three thirteen seventy three of the reported opinion just after footnote seventeen it seems like the judge said there were indeed thirteen processes that occur after you leave yourself but those thirteen are just finishing they're not further working so in fact it was roughly shake shape by forging when i left brazil if you could address that why isn't all this factual by the way and so we're kind of bound by the factual findings not only of the c i t but of the w mexican processes as well they all seem to have found at the same way well taking the first part of your question your honor the it is entirely unclear to me whether the court below made a factual determination as to whether these articles were roughly shit but my forging at the time it was brazil what the court determined by and large was two things first  the error below was not a factual error as to whether excuse me as to whether the prize had been further worked or or roughly shaped but by and large the argument we're making is that the shaped by forging and also it must just meet the standard english definition of semi finished meaning partially finished which is what we have here partially finished diesel engine crank shipped there's been no dispute as to the fact that the the forging  solid section with respect to whether something is roughly shipped the explanatory notes you describe it is something of a rough appearance large dimensional tolerances crude recognizable shapes and requiring considerable further shaping fa forging that leaves the question of whether the goods are further worked the government has contended that operations that occur in the forging process including trimming pointing and certain milling operations are in  clearly in the in the first approximate third of the opinion he discusses the importance of conforming the harmonizing decisions on classification so that's an underlying basis for his decision then the court should keep in mind that this is the second time t blank or not but the conclusion that was reached was that one machining operation machining of the grease pocket in the flange and of the of the finish crankshaft was significant enough machining to be considered further working in brazil and therefore application of additional united states note to an chapter seven to that no could not have been before the w c we have a different legal basis on which were at least a different legal context in which we're pursuing the claim then please the court i look just briefly address a couple of points raised by the court in my counsel you ask whether there was a factual dispute in this case i wish i could say yes because it makes it easier for me but frankly there really isn't whether those five processes which occurred in brazil after forging consists of further work and that actually is a legal question because you have to interpret what the word further worked besides i think however the rises to the level of further work as in the chapter no i think has a question of why it's probably now that you point it out it makes a question of fact in law because you do need something to occur to it after it's forged but whether that can fulfill the legal notice being further worked has legal implications and that's what you have to resort to winter or frankly there's a series of cases which analyze under the old tariff t s u asked her schedule so the united states whether doing work to meddle further works it be on a forgery because the case came those issues came up under the ts us and they've been litigated and generally the courts found similar to hear if you grind after birth that's considered further working so yes it certainly has factual implications and also has legal implications the other thing  point was commons one is interesting for a number of reasons number one if you read the case carefully the judge acknowledges only a couple of the processes which occurred in mexico the court there only mentions shot blasting mats entering and the grease pocket the court does not look at pointing trimming or milling looking at different facts so made it probably isn't the w c own decision it's he only focuses on three of the processes so while the manufacture of this product in brazil has not factually changed the court's knowledge of what occurred apparently has change and frankly a change because the parties explored the actual processing in brazil much more in the second case and we reached the statement of facts because we had an opportunity to do the discovery and get to the judge here is exactly what happened to it it's a first case the judge didn't have the benefit of the agreed statement of facts he didn't know the full background so while the facts haven't changed what the judge was aware of did change  as an unfinished good under one twenty seven twenty seven two to four that's the question so the only thing that's important here is how does it enter mexico because everybody admits the condition when it leave fourteen treatment steps that it's given in mexico because that would lead you to how it exits mexico those fourteen steps in mexico tell you what the product is when it lea and everybody admits when it leaves it's a finished crankshaft ready to go into a truck so everybody that is undisputed the question is does it go into mexico as an on as finish crankshaft leads mexico the question is did it undergo a tariff shift while it was in there which means you have to see how it went in and then you see how it went out and if it went in them as they came out is be you know what i underwent to change but if it mexico right and frankly the plentiful grease their only point in raising mexico is honestly to say what we're doing in mexico is so significant to this that it sort of renders what we did in  brazil as minor incidental they're using it as sort of a comparison to the huge amount of things they do in mexico means we're just barely doing anything brazil i don't think i think that that's what their argument boils down to but i'm sure counsel clarify if i'm wrong because plaintiffs does it who doesn't agree with the government that the focus of this case is whether the product was or was not for their work in brazil and that's that's really what their whole argument is they're saying what was done there was so insignificant or incidental or so part of forging or the forging process that it doesn't really count crankshaft the other are the only thing i want to point out was regarding the commons one case which you asked about earlier if you read the case not only did the trial court only focus on three things they didn't he didn't have the benefit of everything that actually happened to the product  truly have to weigh whether the other four processes which occurred in brazil made this product for the worked so while the commons one certainly gives you direction on the greece pocket it really doesn't clarify different is the trial court had a much better understanding of what the product is and what the processes in brazil work and i think that's much more accurate as to the reason that coming up here is in some part to differ from comments to does that's not only not bad that's good because we do want to be in harmony with the rest of the world and frankly i think that's what occurred here thank you  if i may respond to judge a new newish question mexico match mexico doesn't matter for several reasons your first question to the government was whether there was a law defining for the working there if there's additional note to chapter seven to which list quite specifically thirteen types of surface treaties the government and the court relied upon a decision in a case called winter wolf which is in fact in a political this case it raises an issue in a different chapter of terror schedule that the importance of what happens in mexico is that it helps us to find further work because the explanatory notes you quote further working with being ready for final machining and you can only tell whether something is ready for final machining by looking at what machining occurs and that that happens predominantly in mexico if if the court looks at the appendix of page one seventeen you'll see the four chart of the processing in mexico and it is not until p church that finished machining begins all of the machining proceedings finished machining in this case actually semi finished machine means that it the article as it entered mexico was not ready for final