don't thank you your honor and just point out that the issue was reviewed extensively at the commerce department and commerce also believe greek to permit us to participate in the review below but you're correct this court has not yet here why we're here today primarily is because of this huge one hundred eighty eight percent total adverse facts available rate and we employ this court to to give every consideration as a matter of record evidence to do everything that can be done life will be on what we submit is justified and rome plank held that it's just common sense pick the highest rate you can find and use that as total adverse facts available four years saturday and those two cases this court put we submit severe restrictions are wrong polite almost to the point between the statutory amendments and the later decisions by this court which basically say it's not just common sense you have to fly into a rational relationship between the total adverse facts available rate and the actual rate of the response that had been calculated by the partner here we have an that right in front of me but it was within the last six or seven years it's not the same year no it's a new year there were two respond if that was double digits that was around i think fifteen percent one  investigation the highest calculated rate is fifty percent so we're almost four times that in our own rate of zero so even in back contacts and stiffen up to we submit if there results congress follow it's well established practice which is to go back to the prior segments of the proceedings and then to select the highest rates previously calculated in a crawfish segment corroboration because what you presented is not sufficient so what did they do they abandon their well established practice of going back to prior seconds to find and if they were eight and they decided t the prior review we have your us price from this review they ran out a back of the envelope calculation came up with one hundred percent well there's a problem with x there are substantial record evidence we submit it demonstrates they picked the whole crawfish price from the from the pending review of three dollars a day to six cents a kilogram and then compared it to the actual normal value took from the prior years was for a  into a body review is one immediately follows the other last year it was ten forty this year it's three eighty six now if they want to go back to the statute and the cases are pretty clear they've got a panoply of choices that they could make we're not so much objecting to the ten forty we can't we that was conducted a number that came out of the review that was conducted by commerce would be hard pressed to say that number is an error but we're very very certain that the three that the three eighty six know where they fit for the current review is wrong it's a price for a whole crawfish and that  respondents actual rate that it won eighty eight fields on that alone and then the calculations that the actually conducted fails on the fact that there is substantial record evidence to show that three eighty eighty not not one not the because you have first you say it's a matter of fact all their findings including the finding as to the price of holding the price tail have to be supported by substantial evidence they don't get a free pass just because it's a price you have to go back resubmit and look and say is it supported by substantial evidence or is otherwise contrary to the law and it's contrary to law because he abandoned a well established practice we submit purposely to two hundred twenty three percent said we're happy we challenge the lower court's that not having corroborated so they came back with one eighty eight using that what we submit is a very very faulty methodology using the wrong which was about fifty percent in the prior prior segment of the proceeding because that would not be sufficiently adverse there was substantial number of under reported sales here there's substantial lack of cooperation and i can explain that if i could address the specifics of  challenges of basing substantial evidence but there was significant under reported of the sales of crawfish to tell me and because of that there was a substantial lack of cooperation and relying on the prior used it says these entries are price at a certain price per hour per kilogram which is the same price it was listed in the c p b documents for a significant portion of shaves is under reported sales and this was a significant price and as congress also explained in its adverse facts available memorandum that those that price of tell me it was very consistent with was right within the range of the of the prices of tell me for the other respondents in this sales that were never reported that were that were basically they were selling crawfish tel made at the same praises heikal as the chaise it was not the other respondents she was selling it was understanding crawfished tell me it's at such a degree that it say i would think it's around this i think it would be similar but we wanted to converse wanted to use the normal value of other spine in only the preceding period this wasn't five years before this was in the immediately preceding a review where they did merchandise in the united states and a lot of the confusion in the briefs are that the numbers that washington national uses it's comparing it to its sales of the subject of non subject merchandise total sales of all crawfish and co is based on its own day that had this is not something that congress pulled out of the air i mean i knowledge it's a high rate there's no there's no doubt about th court has not had occasion to address this in this case because there is there is a statute that defines interested party and then congress makes an analysis by regulation whether the party participated aloud and here commerce determine in ministr administrators review of commerce gives a respondent no breaks there may be fewer sales but the procedures the methodology the mechanisms the testing are all identical to a normal administrat a calculated margin of five point four four percent so you've got to calculated margins by commerce in the normal course of business but no nothing being cute pulling one thing from another one is zero one is five percent one hundred eighty eight percent explodes based on gallon ocean and based on the second the it just doesn't hold water the fact that they went back to these numbers is not sacrosanct the fact that they use the three eighty six is not sacrosanct  that's why you have all this all this controversy now about zeroing because you have just as many positive margins as you have negative margins these people compete to throw against losing sales e g you would do not see dump prices that are so uniform they're all over the place and everything tells tells us that's a concept that the f d a was that those entries were whole and we're concerned that that played a material role in the decision of the court below because the f d a came in first with one finding going to another the final