we are ready to proceed before i start the clock though ms holley i don't know you've heard my comments to prior counsel but you've reserved five phrase minor corrections is a term of art and that commerce is a feeling that they're not minor when they impact a large quantity of sales or have a significant impact on the margin do you agree minor correction were drawn this distinction between verification and unsolicited supplemental questionnaire responses commerce no they haven't specifically drawn this distinction but it would make no sense for commerce to apply is there is such a difference between the two context yes there is so during the verification proceeding congress has completed its fact gathering phase of the review and they're just looking to confirm that the data that responded previously provided is accurate and as respondent says so in that context no two factual information that mr o'reilly that's true they haven't completed their fact gathering  they can continue to gather facts is that not correct well they they can't accept new factual information is what i meant so the question of whether or not something is a minor correction in the context of a verification relates to whether or not that information rises to the the level of new factual information it will hang on then is it fair to of costs that is there are reported didn't change between the initial data set and the revised data set the only thing that changed was the allocation of one dollar specific type of cost to steal scrap c knowledge that it did not initially provide commerce with a complete explanation and that the one sentence statement accompanying is substantial revisions to its cost database the sum quote was a more general former counsel did not concede that the affair did not provide a complete explanation specifically if you look at the transcripts from that hearing and i'm referring to appendix pages fifty five  is counsel at the time clarified that the initial submission in july th in was not entirely unexplained but rather that that initial explanation was more general and that the additional advise cost database was unsupported by contemporaneous business documents and reconciliations you chose instead to rely on the quote one sentence explanation in your  supplemental questionnaire did you ever provide any contemporaneous business documents or reconciliations to supporter explain your revised cost database and where are they on the record so you say that the record quote illustrates only that the asaram made an error in its cost data base voluntarily submitted a corrected database and subsequently provided a full explanation of the nature of the co corrections as well as other supporting evidence supporting information requested by congress how were d s heroes actions voluntary when it didn't offer any meaningful explanation of its revised cost for when party is are supposed to submit corrections if they find them and how the parties are supposed to make those corrections so  i'm sorry you're going to i said of course it is provided guidance there's there are points at which you can no longer provide correct yes that that's that's correct but that has to do with how close the corrections are to the deadline for the preliminary results and in this case revisions were submitted months in advance of the preliminary results stage and they were corrections to it initial submissions so the affair acted proactively and it took the initiative to as soon as it recognized this mistake to correct the mistake and to provide provided for example in this of the specific data fields that had changed so that commerce could verify exactly what the revisions were and congress of course had the initial cost at base counsel on you want to do that and what response of time you have left actual costs and it also said that if the party did not track actual costs for a series of databases and information describing the way that the company actually tracked their costs in response to that questionnaire in february t think if there's noting that in response to another supplemental questionnaire not specifically about this cost database but something unrelated just aero in september th noted that you core had flagged the distinct differences between the two databases that had been received on november th of that year and there for the very st time a full nine months after it had submitted its initial cost of production database to cerro indicated that that initial database notwithstanding the repeated statements that it was based on actual cost converses determination not to accept not to use the information was not because it was deemed to be untimely the database was submitted in july but rather it was because once the actual scope of difference between the two databases was revealed for the very st time by  t a full nine months after it had been received commerce a term and that it could no longer rely on either of those databases and then made the nd additional determination that zero by virtue of evidently having at the very latest identify the scope of the initial error in the initial database and then not revealing the actual difference between the two databases until after the post women we had been issued if there's no questions on that issue i will briefly touch on the proper ations so converse selected in a court in accordance with congress promises practices selected from among the highest rates the highest conversely given the opportunity to on remand to further substantiate the selection of this rate and in the remand redetermination conversely significant information on the record underlying the rationality of its of its decision to use to use this information specifically converse placed on the record mation i do have a question for you certainly commerce use the term minor correction just by explaining the updated database in july by just saying it's minor and providing two sentences explaining the differences had not allowed congress to appreciate the scope of the changes and had for as not afforded commerce an opportunity to addition to all of this information that was placed on the record commerce also took a look at just arrows transaction specific margins for the immediately preceding review and determined that a not insignificant portion so we would submit that the corroborating that is placed on the record by commerce in addition the step of comparing the selected rate to the pharaoh's margin margins on specific transactions in the immediately preceding review more than meets the preliminary results it was obligated to explain why that data became unusable and i do want to mention the statutory provision that creates this obligation for congress shall not decline to consider information that submitted as long as it meets certain the political requirements and one of those requirements is that the information can be used without undue difficulties so  given that congress had no problem relying on the revisions to calculate a margin for the preliminary results it is undisputed that the information may be used without undue difficulty is commerce and no reason not to rely on this information and erred in refusing to do so so the what the government refers to as this usability argument is really related to section six hundred and seventy seven and the requirement operation wilfred you might look it up it was maybe offered because it was so minor and inoffensive that was a cartoon character who had those characteristics thank you the matter will stand