shows that hyundai was reasonably was reasonable and relying on the department of s are the department of use previously it previously used a particular definition and three proceedings for the term the term is not defined in the statute was it defined in the questionnaire that hyundai which obama is on is congress required to rely on the eventually get tory steps it took in prior annual review particular definition of service related revenue and i just couldn't find that in the record point where commerce prior to a are three had said here's was no service for your revenue mr bond sale in the course of that verification it seems to me that's for a b and b acquired documents that showed that that han die could in fact separate the by blowing a whistle i mean that a challenge to challenge hundreds of searches that it did not have the ability or it was unable to separate the stream of revenue related to services   if i'm wrong but it seems that doing duty of the rd review that a a b b acquired the verification documents that show that ondine in fact was able and had been separating  the service related revenue stream from that she was priced in the quote she was given to us customers that's that sort of blowing the whistle part and if i could clarify two points on the record including the sales traces review that verification showed no indication that hyundai impropriety reported sales data none of these expenses were inconsistent with the terms of sale so the idea that the commerce department discovered this issue based means the definitions on the record come from as i say the memos from i know we were talking about this before how you you know you're saying you relied on their definitions and i checked and looking for a page to pinpoint a line that where i can read where i can see where congress said here's our definition of s are for purposes of this case your argument you argued that they had an express definition that you relied on detriment to your detriment and so i just want to see what that definition actually read that the any original best against in this case and since then there were two operative potential definitions of service related revenue as i say it's not defined in the statute the regulations are the questionnaire eleven dollars option which is the option that they had to follow it was that service related revenue existed if someone was performing a service but it wasn't required to perform under the terms of sale that was the approach that commerce had adopted him accepted the nd approach which was a b b s proposal was that service related revenue existed wherever there was a separate amount of money that appeared on the sales document so the tension here is that on certain sales documents there are revenues for separate services but those services w for service and there's a line your honor it seems pretty clear that the commerce department changed the definition because n p r to looking at precisely the same sales documents that it reviewed in p r three and it reached different different conclusions and the reason that it did that is because  conclusions based on the sales the same sales documents you know the facts didn't change what changed was their interpretation of those facts through its definition of what service weighted revenue was like a this is this is  my understanding is there's two factors one is the initial questionnaire in the rd review was much more explicit then the one in the nd review as to how the service related revenue than expenses should be reported the initial question on the rd of you made it explicit that those revenue from expenses should be reported in separate fields in the separate database and that all such expensive and revenues should be report previous commerce in ministre to determinations that had explained the basis for the capping methodology and the limiting of service related revenues to the amount of corresponding revenues after after that that information was late and then complete commerce was under no obligation to consider it given that it was late and cannot be verified there should be no question that congress gave the appropriate notice required commissions only at the verification stage here congress made explicit on the record tried to get accurate information on this so that there was no confusion as to whether there were these revenues and what the amount was and what the amount  reasonable given hyundai's first refusal to do so and then when it did provide the information provided in the form or manner the commerce requested to answer the court's question with respect to s so it was a factual line item revenues for service and we were pretty flabbergasted when the commerce department issued a determination that said those didn't exist so we did appeal when we got to the rd review we preparing its responses three times and i've been told by the commerce department approach that it was correct and therefore it was reasonable for honda to continue following that approach but was until after the preliminary determination that the commerce department expressly said that it was