United States Court of Appeals 

for the Federal Circuit ______________________ 

AMERICAN TUBULAR PRODUCTS, LLC, JIANGSU 

CHENGDE STEEL TUBE SHARE CO., LTD.,

Plaintiffs-Appellants

v.

UNITED STATES, UNITED STATES STEEL 

CORPORATION, TMK IPSCO, WHEATLAND TUBE 

COMPANY, V & M STAR L.P.,

Defendants-Appellees

______________________ 

2016-1127

______________________ 

Appeal from the United States Court of International 

Trade in No. 1:13-cv-00029-RWG, Senior Judge Richard 

W. Goldberg.

______________________ 

Decided: February 13, 2017

______________________ 

DONALD CAMERON, JR., Morris, Manning & Martin, 

LLP, Washington, DC, for plaintiffs-appellants. Also 

represented by MARY HODGINS, JULIE MENDOZA, BRADY 

MILLS, R. WILL PLANERT, SARAH SUZANNE SPRINKLE. 

LOREN MISHA PREHEIM, Commercial Litigation

Branch, Civil Division, United States Department of 

Justice, Washington, DC, argued for defendant-appellee 

United States. Also represented by BENJAMIN C. MIZER, 
2 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

JEANNE E. DAVIDSON, CLAUDIA BURKE; WHITNEY MARIE 

ROLIG, Office of the Chief Counsel for Trade Enforcement 

and Compliance, United States Department of Commerce, 

Washington, DC.

PHILIP CHARLES STERNHELL, Quinn Emanuel Urquhart & Sullivan, LLP, Washington, DC, argued for 

defendant-appellee United States Steel Corporation. Also 

represented by DEBBIE LEILANI SHON, JONATHAN GORDON 

COOPER, JON DAVID COREY, KELSEY RULE. 

ROGER BRIAN SCHAGRIN, Schagrin Associates, Washington, DC, for defendants-appellees TMK IPSCO, Wheatland Tube Company, V & M Star L.P. Also represented 

by JOHN W. BOHN, JORDAN CHARLES KAHN. 

______________________ 

Before NEWMAN, MAYER, and LOURIE, Circuit Judges.

LOURIE, Circuit Judge. 

American Tubular Products, LLC (“ATP”) and Jiangsu Chengde Steel Tube Share Co., Ltd. (“Chengde”) (collectively, “the Appellants”) appeal from the decisions of 

the United States Court of International Trade (“the 

Trade Court”) affirming the Department of Commerce’s

(“Commerce”) antidumping duty calculations in the first

administrative review of an antidumping duty order 

directed to certain oil country tubular goods (“OCTG”)

from the People’s Republic of China. See Am. Tubular 

Prods., LLC v. United States, No. 13-00029, 2015 WL 

5236010 (Ct. Int’l Trade Aug. 28, 2015) (“ATP II”) (affirming Commerce’s remand results); Am. Tubular Prods., 

LLC v. United States, No. 13-00029, 2014 WL 4977626

(Ct. Int’l Trade Sept. 26, 2014) (“ATP I”) (affirming in part 

and remanding in part Commerce’s final results). In that 

administrative review, Commerce ultimately calculated a 

weighted average dumping margin of 137.62% for Chengde. See Am. Tubular Prods., LLC v. United States, No. 
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 3

13-00029, ECF No. 102 (Ct. Int’l Trade Jan. 28, 2015) 

(“Remand Results”). Because we agree with the Trade 

Court that Commerce’s antidumping duty calculations 

were supported by substantial evidence and otherwise in 

accordance with law, we affirm. 

BACKGROUND

OCTG are steel tubing products used in oil and gas 

drilling. Chengde is a Chinese producer and exporter of 

OCTG, and ATP is the importer of record during the 

relevant period. In June 2011, Commerce initiated the 

first administrative review of the antidumping duty order 

directed to OCTG from China. Initiation of Antidumping 

and Countervailing Duty Administrative Reviews, 76 Fed. 

Reg. 37,781 (Dep’t of Commerce June 28, 2011); Initiation 

of Antidumping and Countervailing Duty Administrative 

Reviews, 76 Fed. Reg. 53,404 (Dep’t of Commerce Aug. 26, 

2011) (correcting the period of review). Commerce selected Chengde as a mandatory respondent. 

Because China is considered a nonmarket economy 

(“NME”) country, Commerce selected Indonesia, a market 

economy (“ME”) country, as the primary surrogate country from which it would use surrogate values to ascertain 

Chengde’s factors of production. Certain Oil Country 

Tubular Goods from the People’s Republic of China, 77 

Fed. Reg. 34,013 (Dep’t of Commerce June 8, 2012) (“Preliminary Results”). In the Final Results, as later amended, Commerce assigned Chengde a dumping margin of 

162.69%. Certain Oil Country Tubular Goods from the 

People’s Republic of China, 77 Fed. Reg. 74,644 (Dep’t of 

Commerce Dec. 17, 2012) (“Final Results”), as amended by 

Certain Oil Country Tubular Goods from the People’s 

Republic of China, 78 Fed. Reg. 9,033 (Dep’t of Commerce 

Feb. 7, 2013). The Appellants appealed to the Trade 

Court, raising three issues that are relevant in this appeal. We provide further factual and procedural background for each of those issues in turn.
4 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

A. Steel Billets

The first issue pertains to Commerce’s valuation of 

steel billets used in the production of OCTG. Steel billets 

may be composed of carbon steel or the more expensive 

alloy steel. In its initial questionnaire, Commerce requested Chengde to “[d]escribe each type and grade of 

material used in the production process.” J.A. 168. 

Chengde responded that it consumed steel billets, and its 

counsel listed a Harmonized Tariff Schedule (“HTS”) 

subheading that covers products of alloy steel as the 

proper tariff subheading for its steel billets. J.A. 669.

Commerce then issued supplemental questionnaires, 

requesting sample mill test certificates for various control 

numbers (“CONNUMs”). A CONNUM is a code used to 

identify distinct products within the class of subject 

merchandise under review. Chengde submitted the 

sample mill certificates. J.A. 1720–25, 3161–71. Those 

certificates contained information on the chemical composition of the sampled OCTG, which constituted a portion, 

but not all, of OCTG sold in sixteen of nineteen sales

made by Chengde during the period of review. In addition, Commerce requested clarification of the technical 

descriptions of Chengde’s raw material inputs. J.A. 886. 

Chengde again responded with a general description of its 

steel billet input. J.A. 950–51.

In the Preliminary Results, Commerce valued steel 

billets using a surrogate value for alloy steel. Chengde 

then argued that Commerce should have used a surrogate 

value for carbon steel. Chengde explained that its counsel’s prior reference to the HTS number for alloy steel was 

an inadvertent error, and that it in fact used carbon steel 

billets. Chengde called Commerce’s attention to the mill 

certificates on the record, which showed that the tested 

OCTG were all made of carbon steel. 

In the Final Results, as amended, Commerce used a 

carbon-steel surrogate value, but only for the portion of 
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 5

OCTG directly shown to be made of carbon steel by the 

mill certificates. For the remaining OCTG, Commerce 

continued to value the steel billet input using an alloysteel surrogate value. 

On appeal, the Trade Court remanded Commerce’s selection of surrogate values for steel billets. For the sixteen sales partially supported by the mill certificates, the 

court directed Commerce to “explain whether Chengde’s

mill certificates prove the chemical properties of OCTG 

not specifically tested.” ATP I, 2014 WL 4977626, at *7. 

Moreover, the court found that Commerce had failed to 

consider a Customs entry summary relating to an additional (seventeenth) transaction,* which classified the 

OCTG as carbon steel. The court directed Commerce to 

assess whether the entry summary proved that the OCTG 

sold in that transaction were carbon steel. Id.

On remand, Commerce explained that it was unable 

to conclude that the OCTG not specifically tested were 

necessarily carbon steel, noting the uncertainties in

Chengde’s sampling process and its failure to provide the 

requested technical descriptions of its steel billet input. 

Commerce found, however, that the Customs entry summary established that the entered OCTG were composed 

of carbon steel. Commerce thus continued to use a carbon-steel surrogate value to value the portion of steel 

billets for which there was direct evidence, viz., the mill 

certificates or entry summary, to show that carbon steel 

billets were consumed. As for the remaining portion of 

 

* As to the remaining two of the nineteen sales covered by the review, the Trade Court affirmed Commerce’s 

use of an alloy-steel surrogate value based on evidence of 

a screenshot of Chengde’s website, which showed that the 

OCTG sold in those two transactions were composed of 

alloy steel. The Appellants do not challenge that aspect of 

the Trade Court’s decision.
6 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

steel billets at issue, Commerce used a simple average of 

the surrogate values for carbon steel billets and alloy steel

billets. Accordingly, Commerce recalculated Chengde’s 

weighted average dumping margin as 137.62%.

The Appellants again appealed to the Trade Court. 

The court sustained Commerce’s Remand Results, finding 

that Commerce reasonably chose to use a simple average 

of the surrogate values of carbon and alloy steel billets for 

the untested OCTG. ATP II, 2015 WL 5236010, at *6–9. 

The court agreed with Commerce that OCTG under the 

same contract or CONNUM could have different chemical 

compositions, id. at *7, and that Chengde’s mill certificates lacked sufficient detail to establish that the untested OCTG were made of carbon steel, id. at *8. The court

further noted that Chengde could have shown that its 

billets were carbon steel by answering Commerce’s questionnaires “with exactness,” but it failed to do so. Id.

B. Byproduct Offset

The second issue pertains to byproduct offset. The 

production of OCTG may generate steel scrap, which may 

be sold for revenue to offset the raw material cost for 

producing the OCTG that generated the scrap. In its 

initial questionnaire, Commerce requested information on 

the quantity of byproduct “produced, sold, reintroduced 

into production, or otherwise disposed of,” as well as 

records demonstrating the production of byproduct during 

one month of the period of review. J.A. 169. In response, 

Chengde explained that it did not measure or record steel 

scrap production at the time it was produced, but rather 

measured the scrap quantity when it was sold. J.A. 651–

52. Chengde provided the quantities of monthly scrap 

sales for the period of review. J.A. 685–86. Commerce 

did not request further information regarding scrap offset.

In the Preliminary Results and the Final Results, 

Commerce declined to allow any scrap offset because 

Chengde had failed to quantify the amount of scrap 
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 7

produced. On appeal, the Trade Court sustained Commerce’s denial of scrap offset as supported by substantial 

evidence and in accordance with law, finding that Chengde had failed to meet Commerce’s requirements to secure

a scrap offset. ATP I, 2014 WL 4977626, at *9–12.

C. International Freight

The third issue pertains to Commerce’s valuation of 

Chengde’s international freight expense. Chengde reported that most of its OCTG exports to the United States 

were shipped by carriers based in South Korea, an ME 

country, and that it paid for ocean freight in U.S. dollars. 

Chengde showed that it remitted the freight expense via a 

Chinese freight forwarder, which in turn paid the Chinese 

agents of the Korean carriers, and those agents then paid

the carriers in U.S. dollars. However, Chengde did not 

provide any evidence on the amount paid by the Chinese 

agents to the Korean carriers. It instead submitted

certifications from two Chinese agents stating that payments were made in U.S. dollars, and that actual payment documentation was proprietary.

In the Preliminary Results, Commerce calculated international freight using a surrogate value, as if it was

purchased from an NME supplier. Commerce continued 

to do so in the Final Results, finding that Chengde had 

failed to establish that the Korean carriers set the freight 

price. On appeal, the Trade Court sustained Commerce’s 

use of a surrogate value to calculate international freight. 

The court observed that “there is no proof that the Korean 

shippers hired the Chinese agents to collect Chengde’s 

fees,” and thus “there is little reason to believe that the 

price paid to the agents equaled the price remitted to the 

shippers.” ATP I, 2014 WL 4977626, at *13.

After the Trade Court affirmed Commerce’s Remand 

Results, the Appellants appealed to this court. We have 

jurisdiction under 28 U.S.C. § 1295(a)(5). 
8 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

DISCUSSION

In trade cases, we apply the same standard of review 

as the Trade Court, upholding Commerce’s determinations unless they are “unsupported by substantial evidence on the record, or otherwise not in accordance with 

law.” 19 U.S.C. § 1516a(b)(1)(B)(i). Although we review 

the decisions of the Trade Court de novo, “we give great 

weight to the informed opinion of the [Trade Court] . . . , 

and it is nearly always the starting point of our analysis.” 

Ningbo Dafa Chem. Fiber Co. v. United States, 580 F.3d 

1247, 1253 (Fed. Cir. 2009) (internal quotation marks, 

brackets, and citations omitted).

The Appellants challenge three aspects of Commerce’s 

antidumping duty calculations: (1) Commerce’s decision to 

use a simple average of surrogate values for carbon steel 

billets and alloy steel billets for the untested OCTG; 

(2) its denial of scrap byproduct offset; and (3) its treatment of international freight as NME transactions. We 

address each of those issues in turn.

A. Steel Billets

We first consider whether Commerce erred in using a 

simple average of surrogate values for carbon steel billets 

and alloy steel billets for the untested OCTG.

The Appellants argue that the sample mill certificates 

demonstrate that the untested OCTG were composed of 

carbon steel, not alloy steel. They emphasize that the 

untested OCTG were sold in the same transactions under 

the same CONNUMs as the tested OCTG. They criticize 

Commerce for not finding the mill certificates representative of the untested OCTG because Commerce requested 

only sample mill certificates. According to the Appellants, 

for the seventeen transactions at issue, there is no evidence that Chengde consumed alloy steel billets. They 

assert that Commerce improperly relied on the erroneous 

HTS number provided by Chengde’s former counsel. 
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 9

The United States, United States Steel Corporation, 

TMK IPSCO, Wheatland Tube Co., and V & M Star L.P.

(collectively, “the Appellees”), filing three separate briefs,

respond that Commerce’s selection of surrogate value for 

steel billet input was supported by substantial evidence. 

The Appellees contend that the record is inconclusive as 

to the chemical content of the untested OCTG, and that

Chengde failed to prove that all of its steel billets were 

made of carbon steel. The Appellees note that Chengde 

used both carbon steel billets, as shown by the mill certificates and entry summary, and alloy steel billets, as shown 

by Chengde’s website, to produce OCTG. They argue that 

Commerce therefore reasonably valued the steel billets by 

averaging the surrogate values. 

We agree with the Trade Court and the Appellees that 

substantial evidence supports Commerce’s decision to use 

an average surrogate value of carbon steel and alloy steel. 

Commerce reasonably concluded that the record did not 

demonstrate whether the untested OCTG were produced 

exclusively from carbon steel or alloy steel billets. Rather, 

it is undisputed that Chengde’s website showed that it

sold OCTG made of alloy steel under two contracts during 

the period of review, whereas the sample mill certificates 

and entry summary showed that Chengde used carbon 

steel billets for some of its OCTG. Faced with this record, 

Commerce reasonably used a simple average of the surrogate values for alloy and carbon steel for the portion of the 

billets for which the type of steel was not apparent. 

Substantial evidence thus supports Commerce’s decision. 

As Commerce correctly found, the sample mill certificates submitted by Chengde were limited. They did not 

indicate whether they represented the entire quantity of a 

sales contract, and did not provide context for their relevance to the untested products by describing the testing 

procedures. The certificates represented limited quantities of the sales contracts or CONNUMs involved. Moreover, as Commerce found, the OCTG under each contract 
10 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

could be produced in multiple heats, i.e., production runs 

or batches, and that the mill certificates did not list all of 

the required test results for each heat. Thus, we agree 

with Commerce and the Trade Court that the mill certificates were not representative of the untested OCTG.

As the Trade Court noted, Commerce repeatedly requested technical descriptions of Chengde’s raw material 

input, but Chengde failed to provide a straightforward 

and sufficient description of the chemical composition of 

its steel billets. Chengde’s other submissions, including 

the sample mill certificates, were insufficient to establish 

the nature of its steel billet input as to the untested 

OCTG. Given this record, Commerce reasonably valued 

the untested steel billets by averaging the surrogate 

values of both carbon and alloy steel. See Nan Ya Plastics 

Corp. v. United States, 810 F.3d 1333, 1337–38 (Fed. Cir. 

2016) (explaining that “the burden of creating an adequate record lies with interested parties and not with 

Commerce” (internal quotation marks and citation omitted)).

We therefore conclude that Commerce’s use of a simple average of surrogate values of carbon and alloy steel 

billets for the untested OCTG is supported by substantial 

evidence and otherwise in accordance with law.

B. Byproduct Offset

We next consider whether Commerce erred in declining to make any scrap byproduct offset because Chengde

failed to provide any records to establish the quantity of 

scrap produced, rather than the quantity of scrap sold. 

The Appellants raise numerous arguments challenging Commerce’s denial of scrap offset. First, they argue

that Commerce acted arbitrarily in this case because, in 

previous cases, it has allowed byproduct offsets based on 

information similar to that provided by Chengde. Second, 

they argue that 19 U.S.C. § 1677b(f)(1)(A) requires that 
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 11

Commerce base its cost calculations on the books and 

records of the producer unless it determines that the 

information does not “reasonably reflect” actual costs, and 

that Commerce failed to make such a finding here. Third, 

they argue that under 19 U.S.C. § 1677m(d), when Commerce finds that information submitted by a respondent is 

deficient, it must notify the party of the deficiency and 

provide an opportunity for correction, and that Commerce 

failed to do so here. Fourth, they argue that the scrap 

sales data submitted by Chengde satisfy all of the statutory requirements of 19 U.S.C. § 1677m(e), and thus that 

Commerce may not decline to consider the information 

even if it did not comply with all of Commerce’s requirements. Finally, they argue that Commerce’s refusal to 

make any byproduct offset constituted a de facto application of adverse facts available, without any finding that 

Chengde had failed to cooperate to the best of its ability.

The Appellees respond that Commerce reasonably denied Chengde’s request for scrap offset because Chengde 

failed to show that the scrap sold was generated from the 

production of OCTG, not some other products, and that 

the scrap was in fact produced during the period of review. The Appellees maintain that Commerce’s denial of 

scrap offset in this case is consistent with its standard 

practice. The Appellees contend that the statute is silent 

on scrap offset, and Commerce has filled that gap with 

regulations. The Appellees also respond that Chengde 

informed Commerce that it did not account for the quantities of scrap as produced, and thus Commerce was not 

required to continue asking for that information or to 

accept Chengde’s deficient evidence. Finally, the Appellees respond that Commerce did not apply any adverse 

inference; rather, according to the Appellees, Commerce

simply concluded that Chengde did not meet its burden of 

establishing the requested scrap offset.

We agree with the Trade Court and the Appellees that 

Commerce did not err in declining to allow any scrap 
12 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

offset in this case. Chengde did not establish the quantity 

of scrap generated from the production of OCTG during 

the period of review. It simply failed to satisfy its evidentiary burden, and Commerce properly decided not to grant 

the requested offset.

The statute governing the calculation of normal value, 

19 U.S.C. § 1677b(c), does not discuss the treatment of 

byproducts. Commerce promulgated regulations stating 

that it may make adjustments to normal value, but that 

“[t]he interested party that is in possession of the relevant 

information has the burden of establishing to the satisfaction of the Secretary the amount and nature of a particular adjustment.” 19 C.F.R. § 351.401(b). Accordingly, 

Chengde bears the burden of establishing its entitlement 

to a scrap offset. 

Here, Chengde submitted documentation of its scrap 

sales to Commerce, but it could not document the quantity of scrap produced during the period of review. Chengde’s proposed offset calculation instead equated total 

scrap sold during the period of review with total scrap 

produced during the period of review. However, as Commerce explained, Chengde failed to present any evidence 

to show either that the production of OCTG, the subject 

merchandise, actually generated the scrap sold, or that 

the scrap sold was indeed produced during the period of 

review. Absent evidence linking the scrap sold with any

scrap generated resulting from the production of OCTG 

during the period of review, Commerce properly found 

that Chengde’s submissions were insufficient and properly denied the requested offset.

We find the Appellants’ remaining arguments to be 

unavailing. First, this case is factually distinct from the 

cases cited by the Appellants. In those cases, Commerce 

had additional information linking the requested byproduct offset to the production of subject merchandise during 

the period of review. Chengde failed to make that show-
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 13

ing in this case. Second, the statutory provisions cited by 

the Appellants are inapposite. In this review, Commerce 

requested Chengde to provide records demonstrating the 

production of OCTG during the period of review. Chengde 

unambiguously responded that it did not measure or 

record steel scrap production at the time it was produced. 

On this record, Commerce was not obligated to accommodate Chengde’s failure to document scrap production; nor 

was Commerce obligated to continue asking for information that Chengde clearly stated it did not record. 

Lastly, we agree with the Appellees that Commerce did 

not apply any adverse inference in its denial of scrap 

offset. Rather, Chengde simply failed to satisfy its evidentiary burden of establishing the requested offset, as 

the regulation requires. See 19 C.F.R. § 351.401(b). 

Accordingly, we conclude that Commerce’s denial of 

steel scrap offset is supported by substantial evidence and 

otherwise in accordance with law.

C. International Freight

We last consider whether Commerce erred in finding 

that Chengde’s international freight transactions constituted NME transactions. The Appellants argue that the

record evidence shows that Chengde’s ocean freight was 

in fact furnished by ME carriers and that Chengde paid 

for the freight in U.S. dollars. They argue that Commerce 

acted unreasonably in finding that Chengde purchased 

ocean freight from an NME supplier.

The Appellees respond that Chengde failed to satisfy 

Commerce’s requirements to prove that its ocean freight 

constituted ME purchases. Specifically, the Appellees 

argue that Chengde failed to provide any documentation 

to establish the amount paid by the Chinese agents to the 

Korean shippers, or to otherwise show that the price it 

paid for ocean freight was set by ME shippers. The Appellees also argue that Commerce has consistently required respondents such as Chengde to link the amount 
14 AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES

paid to an NME intermediary or agent with that paid to 

an ME carrier.

We agree with the Trade Court and the Appellees that

Commerce properly calculated Chengde’s ocean freight 

expenses using a surrogate value. The statute presumes 

that government action distorts the prices that NME 

exporters pay for their inputs. See 19 U.S.C. §§ 1677(18), 

1677b(c)(1). In limited circumstances, however, pursuant 

to the regulation in effect at the relevant time, Commerce 

would “normally” value an input purchased from an ME 

supplier and paid for in an ME currency using “the price

paid to the [ME] supplier.” 19 C.F.R. § 351.408(c)(1) 

(2012). Accordingly, “under the regulation, merely establishing that the factor was purchased from [an ME]

supplier is not enough; rather, the amount paid to the 

supplier must be documented.” Yantai Oriental Juice Co. 

v. United States, 26 Ct. Int’l Trade 605, 615 (2002).

Here, Chengde failed to properly establish the price 

paid to the ME shippers or to otherwise show that the 

price it paid for ocean freight was set by the ME shippers. 

The record shows that Chengde paid its ocean freight 

expenses to a freight forwarder in China, who then paid 

the Chinese agents of Korean carriers, who in turn paid 

the Korean carriers. Because the first two transactions 

were between Chinese entities, Chengde is required to 

link the price it paid to the freight forwarder to the price 

paid to the Korean shippers. However, Chengde failed to

make that showing. It only provided declarations that the 

Chinese agents paid the Korean shippers in U.S. dollars.

Accordingly, the only prices on the record relating to 

ocean freight are those between Chinese entities, not the 

prices paid to the Korean carriers. On this record, Commerce properly declined to value Chengde’s international 

freight as an ME input and properly used a surrogate 

value to calculate international freight costs. See Nan Ya, 

810 F.3d at 1337–38. We therefore conclude that Com-
AMERICAN TUBULAR PRODUCTS, LLC v. UNITED STATES 15

merce’s decision is supported by substantial evidence and 

otherwise in accordance with law.

CONCLUSION

We have considered the Appellants’ remaining arguments, but find them to be unpersuasive. For the foregoing reasons, we conclude that Commerce’s antidumping 

duty calculations were supported by substantial evidence 

and otherwise in according with law. We therefore affirm 

the Trade Court’s decisions sustaining Commerce’s antidumping duty calculations.

AFFIRMED