and these are similar to the ball bearings we all know they work with heavier loads are set up all in the race you'll have a tapered kind of oblong object that is more to i think is a fairly straightforward proposition the scope if you condense it the scope that was as was written by the department of commerce in the original  be as it relates to certainly the case to analysis of the a b s system your primary argument as i understand is that while these have additional functionality that it's up somebody buying essentially electromechanical product instead of just that that there are additional functions as well that you're selling well if you look at the affidavit of dr arthur he said that he's a mechanical engineering so that if you have a wheel for example on an actual you don't want that we're going all over the place the bearing takes a load of those up and down sideways in other directions and cause it to limit the these restrictions by simply building it into something else that has some additional function perhaps your honor but if you take what the congress did to its extreme you would say that anything that has a that's that's where that's why i think the confusion began if you look at the discussion of wheel hub because we have units was the term that they use and part of our problem is that these words these terms in engineering assembly that's what we have here if you look at what the international trade commission said when it defined what a wheel subunit is it said that  the house bearing on the one hand and you take a totally separate cast metal cast part on the other hand that is what we call the inner flange that sits inside the larger opening of the house to bury the bearing is inside that ring you take that larger piece it is the piece that does the torque transmission it is the piece that the brak e rotor is attached to it is a piece that the wheel is attached to it is the actual on this car you take that and then you assemble it together with it with this has very together that makes substantial deference to congress as a termination i mean i have stand your argument that while that my air automobiles polluted because they have tapered roller bearings in them somewhere but it's up to congress to draw the line as to whether or not do except that the car won't stop or go car be completely inoperable so you want us to say that at a commerce was wrong even though we're up to given great deference it's finding that that difference was substantial did under the case the factors they didn't really look at a bearing versus the product what they looked at was a very compared to the  b s system so in other words if you want to be just move ahead you have a couple different arguments have the second argument right which is you're saying that you have as we'll have a unit that or what the scope would believe the scope of order would believe that it will have unit combine in addition with some completely other piece called the inner flange right and now that you're married those two things together into this larger assembly that larger simply is not within the scope of the original order exactly that is your second you have something in the record that shows that  plenary ruling on page four eighty eight of the joint appendix that new trend itself the manufacturer of this product used the troops interchangeably during investigation which is what the which is that when the i trained in the make knowledge that this is already been pointed out this right let me let me take you to the logical extreme argument that that your friend on the other side made because it's one that popped into my head to what i was thinking through and that is that you know if we captured by the plain language of the stuff in the order but the fact of it so is it your position that it had commerce really wanted to take the ultimate position which is that anything that shows up at the cape or grow it varied by definition falls within the scope they would have left it all  assembly or will have unit or tapered roller housing with additional a b s elements the reason like a conversation with a k to hear them in conservative and just to make sure we're talking about a different product but if there are of course not only with the with the talking about something that's within the ballpark and then and that's that's not something for sale from the from the scope of the order and so but the physical characteristics are really there's no concession parking can see that the physical characteristics are captured by the they indicated they made one hundred fifty different types of tapered roller bearings that are sold in twenty six thousand bearing combinations very broad category commerce department looked at this category and developed as per their regulations a general description a generic description that of the subject merchandise that description included tapered roller how things incorporating tapered rollers with or without spindles and i think that part of it goes to judge jones question about assembly and it is not correct to say that the only merchandise in scope is that out flange with the t r p and something is inserted the the inner flange that you attach the wheel to the scope description specifically says with spindles which means that if you're talking about a wheel unit and all of the feet almost all the features identified by new trend in their filing are there there's no a b s sensor there and that certainly is one of the reasons why congress went in dedicate to analysis to determine made a reasonable description when they did it and when they marked on the scope determination they looked at the what new trend said about us devices about it products and found that they fell within the scope language  they said these we will have units are essentially tapered roller housings with lines and then went on and used a k to analysis to determine whether abs answers were one of their feet a feature that would take the product outside the scope they had already decided that the features mentioned the lining in the lugs and so on were engineering or design features of paper paragraph says are more innovative you know pack plus bearing has all of the above plus part of the outside race isn't intercooler all mounting flange so production will have just one piece to bolt on they identify a bearing house bearing in mind something they call a complete wheel package another term that we can put alongside of assembly and wheel hub unit the problem is that unless you identify the terms at the empty set with the definitions are given at that point you end up with this burgeoning definition that can be anything that's used in association with a wheel hub and so saying that the order was somehow invalid for being too broad no i'm saying the interpretation of the language in other words the order says baron's but we end up through a series of steps with your all wheel size wheel hub unit now doesn't it comes in so then if you adopt wheel house we will have unit as your term say that's equivalent to that's within the scope because that's a bare then you say well you will have the somebody is used equivalently with wheel of unit interchangeably th