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WORKING 

PAPERS

 One Lump or Two: 

Unitary Versus Bifurcated Measures of Injury 

at the USITC

Kenneth H. Kelly

and

Morris E. Morkre

WORKING PAPER NO. 282

March 2006

FTC Bureau of Economics working papers are preliminary materials circulated to stimulate discussion 

and critical comment. The analyses and conclusions set forth are those of the authors and do not 

necessarily reflect the views of other members of the Bureau of Economics, other Commission staff, or 

the Commission itself. Upon request, single copies of the paper will be provided. References in 

publications to FTC Bureau of Economics working papers by FTC economists (other than 

acknowledgment by a writer that he has access to such unpublished materials) should be cleared with the 

author to protect the tentative character of these papers. 

BUREAU OF ECONOMICS

FEDERAL TRADE COMMISSION

WASHINGTON, DC 20580
One Lump or Two:

Unitary Versus Bifurcated Measures of Injury

at the USITC

by

Kenneth H. Kelly

and

Morris E. Morkre*
ABSTRACT 

The most popular methodology used by the U.S. International Trade Commission 

(USITC) from 1989 through 1994 to determine whether unfairly traded imports injure competing 

domestic industries was known as the bifurcated approach. Injury determinations based on this 

approach have been rejected by reviewing bodies because the methodology does not distinguish 

injury caused by unfairly traded imports from other demand or supply changes. We estimate 

injury to the domestic industry due to changes in unfairly traded import price and to other 

causes for 44 USITC dumping and/or subsidy investigations. Change in unfairly traded import 

price was typically not the most important cause of injury to the domestic industry. 
I. INTRODUCTION 

Firms that face competition frequently have a number of legal avenues to limit such 

competition. When such competition comes from overseas competitors, they might avail 

themselves of laws to limit imports. In the major industrialized countries, laws to limit 

competition from imports fall into two broad categories: safeguards, and laws against unfairly 

traded imports. 

Safeguards, also known as escape clause procedures, allow a World Trade Organization 

(WTO) member state to temporarily restrict imports when a product is imported to its territory in 

such increased quantities as to cause or threaten serious injury to competing domestic producers. 

These temporary restrictions (quotas or tariffs) can either allow the domestic industry to become 

more competitive, or allow an orderly transfer of resources from the industry. 

Unfairly traded imports are imports that are subsidized and/or dumped, that is, sold at 

less than fair value. “Fair value” can be the price that the imports are sold for in their home 

market, the price that the imports are sold for in a third country, or the estimated cost of 

production including a profit. In accordance with international agreements, U.S. law requires 

that remedial duties (antidumping duties or countervailing duties) can only be imposed on 

unfairly traded imports if these imports have caused (or threaten to cause) material injury to 

competing domestic producers. 

The U.S. International Trade Commission (USITC) is responsible for investigating and 

determining whether or not unfairly traded imports have caused material injury to a domestic 

industry. The USITC is also responsible for investigating and determining whether or not a 

domestic industry that petitions for relief in a safeguard proceeding has suffered serious injury 

1
because of increased imports. 

USITC Commissioners have adopted a variety of approaches to determining whether or 

not dumped or subsidized imports have caused material injury to competing domestic producers. 

An important one that has been used by several Commissioners is the unitary approach. This 

approach uses production and prices for the unfairly traded imports, the domestic industry, and 

fairly traded imports (if any), estimates of demand and supply elasticities, and dumping or 

subsidy margins to calculate what the performance of the domestic industry would have been 

had it not had to compete with unfairly traded imports.1 

An alternative approach that has been adopted by more Commissioners is the bifurcated 

approach. The bifurcated approach first asks if the domestic industry has suffered material 

injury, and then asks whether or not unfairly traded imports contributed to this injury. By 

separating the injury determination into two separate questions, the presence of injury and the 

causation of injury, the bifurcated approach is similar to the sort of inquiry that the USITC 

conducts in its safeguards investigations.2 

Commissioners who used the unitary approach relied upon an explicit economic model to 

compare actual domestic industry performance with what the performance would have been 

absent competition from unfairly traded imports. In contrast, Commissioners who used the 

bifurcated approach rejected formal economic analysis; in fact, many of them were openly 

hostile to the use of economic analysis. Because of these different attitudes towards quantitative 

economics, the unitary approach has also been called the economic approach.3 

We adapt an economic model developed to measure the causes of injury in USITC 

safeguard investigations to measure the effect of unfairly traded imports to domestic industry 

2
performance, that is, the second question under the bifurcated approach. We apply this 

methodology to all USITC unfairly traded import investigations for a time period between two 

major changes in the law; during this period there were Commissioners who used the unitary 

approach and Commissioners who used the bifurcated approach. 

For those industries that petitioned for import protection against unfairly traded imports, 

why did they perform poorly? Were unfairly traded imports the source of their difficulties, or 

were there other causes? 

One of the criticisms of the USITC Commissioners who used the bifurcated approach is 

that they incorrectly attributed to unfairly traded imports damages that may have been caused by 

other factors. Both a U.S. court and the World Trade Organization have overturned USITC 

antidumping decisions that were based on the bifurcated approach because they failed to 

distinguish injury from unfairly traded imports from other sources of injury. Our estimates allow 

us to analyze this criticism. 

We compute injury estimates for these same investigations under the unitary approach, 

and compare them to the injury estimates under the bifurcated approach. Do the two methods 

really give different results? 

II. THE TRADE LAWS OF THE UNITED STATES 

In the United States, safeguard petitions are administered under Section 201 of the Trade 

Reform Act of 1974. Upon receipt of a petition for relief under Section 201, the USITC 

undertakes an investigation to answer three questions: (a) have imports increased, (b) has the 

domestic industry been seriously injured, and if so, (c) are increased imports the substantial 

3
cause4

 of that injury? If a majority of the USITC Commissioners answers all questions in the 

affirmative, then they must recommend to the President of the United States relief sufficient to 

remedy the problem. The President can then impose quantitative restrictions or tariffs, or grant 

adjustment assistance to the industry and its workers. Alternatively, he can grant no relief if in 

his opinion such relief would not be in the national interest. 

The U.S. law against unfairly traded imports, Title VII of the Trade Act of 1979, is 

administered by both the International Trade Administration of the Department of Commerce 

(“Commerce”) and by the USITC. For alleged subsidization, Commerce determines the amount 

of such subsidy as a percentage of the selling price (the countervailing duty margin). For alleged 

dumping, Commerce determines the “fair value,” which can be the price the foreign firm charges 

in its home market or in a third country, or it can be the estimated cost (including profit) of 

production, transportation, and distribution. The percentage amount that the price of the less 

than fair value (LTFV) imports must be increased to equal the fair price is called the dumping 

margin. The USITC determines whether or not the competing domestic industry was materially 

injured (or is threatened with material injury) by reason of dumped or subsidized imports. If a 

majority of USITC Commissioners (or if there is a tie) finds affirmatively, then a tariff equal to 

the countervailing duty margin or the dumping margin is automatically imposed on the imports 

in question. 

Different USITC Commissioners have adopted, and reviewing courts have ratified,5 

different methodologies for determining whether unfairly traded imports have caused material 

injury to competing domestic industries. The two most important have been (a) the unitary 

approach, also known as the “but-for” approach, the elasticities approach, or the economic 

4
approach, and (b) the bifurcated approach, also known as the trends approach, or the traditional 

approach.6 

The rationale of the unitary approach is to compare the actual performance of the 

domestic industry with what its performance would have been absent the unfair practice. For 

subsidies and for dumped imports that are sold below cost, the unitary approach asks what would 

the performance of the competing domestic industry have been if the price of the subsidized 

and/or dumped imports were higher by the amount of the countervailing duty margin or 

antidumping margin computed by Commerce. For price discrimination dumping where data on 

home market sales are available, the unitary approach asks what would the performance of the 

competing domestic industry have been if the foreign firm(s) had been required to charge the 

same price in the U.S. and in its (their) home market. 

The bifurcated approach instead asks two questions: (a) did the domestic industry suffer 

material injury over the period of investigation (which is typically the previous three years); and 

(b) if so, did unfairly traded imports contribute to this material injury? The bifurcated approach 

is therefore similar to the approach that the USITC takes in analyzing safeguard petitions: it first 

asks if there is injury, and then asks whether or not imports are a cause of said injury.7 In fact, 

commentators call Title VII “the poor (or small) man’s escape clause.”8 

The unitary approach uses the standard tools of economic analysis to determine the effect 

of unfairly traded imports on the domestic industry. The USITC staff have used economic 

models9

 to simulate the performance of the domestic industry but for it having to compete with 

unfairly traded imports. The difference between the simulated and the actual performance 

depends upon the quantity sold and prices in the U.S. of the domestic industry output, unfairly 

5
traded imports, and fairly traded imports, if any, the antidumping margin and/or countervailing 

duty margin as computed by Commerce, and demand and supply elasticities. Price and quantity 

data have traditionally been collected in USITC investigations. Information on elasticities have 

been collected since the advent of the unitary approach. Both petitioners and respondents are 

free to submit information and commentary regarding elasticity estimates. In contrast, the 

USITC Commissioners who use the bifurcated approach have not tended to use economic tools 

in their analysis.10 This aversion to quantitative economic analysis has caused USITC decisions 

to be overturned, both by the Court of Appeals for the Federal Circuit, the reviewing court for 

the Court of International Trade that reviews USITC decisions, and by the World Trade 

Organization.11 

In August, 1992 the USITC found that domestic producers of magnesium were 

experiencing material injury by reason of unfairly traded imports from Canada. After 

countervailing and dumping duties were imposed against Canadian magnesium, imports from 

other sources, including China, Russia, and the Ukraine, increased. In March, 1994 domestic 

producers of magnesium filed a petition, alleging dumping. In May, 1995, three of the six 

USITC Commissioners found that domestic magnesium producers suffered declining market 

share, decreased employment, poor financial performance, declining capital expenditures, and 

falling research and development expenses over the previous three years. These same three 

Commissioners observed that the market share of unfairly traded imports from China, Russia, 

and Ukraine had increased, and said that “the effect of the large and increasing volume of subject 

imports during the period of investigation has been to depress prices or prevent price increases to 

a significant degree.” They concluded: “[G]iven the substitutability between subject imports and 

6
[U.S. produced magnesium], the rapid and significant increase in the LTFV [less than fair value] 

imports, the consistent underselling by these imports, the resulting decline in domestic market 

share and the poor financial condition of the U.S. industry, we determine that the domestic 

industry producing pure magnesium is materially injured by reason of the subject LTFV imports 

of pure magnesium.”12 

This USITC decision was overturned by the U.S. Court of Appeals for the Federal 

Circuit. The court said that “ . . . a showing that economic harm to domestic industry occurred 

when LTFV imports are also on the market is not enough to show that the imports caused a 

material injury. . . . Hence, the anti-dumping statute mandates a showing of causal – not 

merely temporal – connection between the LTFV goods and the material injury.”13 The court 

went on to note that imports from Russia came from only two producers, but were sold by 

several trading firms. The U.S. price for Russian magnesium was set by the importer, not the 

producer. Commerce had found that only some of these importers had priced below fair value, 

and so a sizeable portion of the imports coming from Russia were not dumped but fairly traded. 

Because the unfairly traded imports and the fairly trade imports differed only in the importer 

who sold them, these fairly traded imports were very close, if not perfect, substitutes for the 

unfairly traded imports.14 Because domestic users of magnesium could have bought fairly traded 

Russian magnesium rather than dumped magnesium, the court found that imports of dumped 

magnesium did not injure the domestic industry, and therefore whatever difficulties the domestic 

industry faced were the result of market forces rather than unfair trade practices. 

A 1999 USITC decision on dumped steel products that relied on bifurcated analysis was 

challenged by Japan before the World Trade Organization (WTO). Article 3.5 of the WTO Anti7
Dumping Agreement states: 

It must be demonstrated that the dumped imports are, through the effects of 

dumping, as set forth in paragraphs 2 and 4, causing injury within the meaning of 

this Agreement. The demonstration of a causal relationship between the dumped 

imports and the injury to the domestic industry shall be based on an examination 

of all relevant evidence before the authorities. The authorities shall also examine 

any known factors other than the dumped imports which at the same time are 

injuring the domestic industry, and the injuries caused by these other factors must 

not be attributed to the dumped imports.

 In rejecting the USITC decision on dumped hot-rolled steel products from Japan, the WTO 

Appellate Body said that in applying Article 3.5 investigating authorities must15 

ensure that the injurious effects of the other known factors are not “attributed” to 

dumped imports, they must appropriately assess the injurious effects of those 

other factors. Logically, such an assessment must involve separating and 

distinguishing the injurious effects of the other factors from the injurious effects 

of the dumped imports. If the injurious effects of the dumped imports are not 

appropriately separated and distinguished from the injurious effects of the other 

factors, the authorities will be unable to conclude that the injury they ascribe to 

dumped imports is actually caused by those imports, rather than by the other 

factors. Thus, in the absence of such separation and distinction of the different 

injurious effects, the investigating authorities would have no rational basis to 

conclude that the dumped imports are indeed causing the injury which, under the 

Anti-Dumping Agreement, justifies the imposition of anti-dumping duties. 

III. THE MODEL 

As noted above, the bifurcated approach to injury determination in an unfairly traded 

imports investigation has much in common with the approach to injury in a Section 201 

safeguard investigation. A methodology for measuring the causes of injury to a domestic 

industry under Section 201 was developed by Kelly (1988).16 That paper set out three different 

models, and for each one showed how observed changes in domestic production, imports, and 

prices could be combined with elasticity estimates to decompose the change in industry output 

8
over a time period into changes due to shifts in demand, supply, or in the case of monopoly, cost. 

That paper assumed that the underlying demand and supply relationships were linear. 

Here we relax the assumption of linearity, and use instead a model developed for our earlier 

study of unfairly traded imports (Kelly and Morkre, 1998) that used the well known Armington 

constant-elasticity-of-substitution (CES) demand system. We assume that, for any industry 

definition, all goods sold in the United States can be aggregated into one of three categories: 

domestically produced, unfairly traded imports, and fairly traded imports. Let Qd be the quantity 

of the domestic product, Qu the quantity of unfairly traded imports, and Qf the quantity of fairly 

traded imports. Qd, Qu, and Qf are close, but not perfect, substitutes. Let Pd, Pu, and Pf be, 

respectively, the prices of domestic products, unfairly traded imports, and fairly traded imports. 

These three products are in turn related through an aggregation function of the CES type, so that 

QA, the quantity of the aggregate product, is defined as: 

where bd, bu, bf, and D are constants with bd + bu + bf = 1 and D > -1. As the name of the model 

implies, the elasticity of substitution between any two products, F, will be constant, and can be 

shown to be equal to 1/(1+D). 

It is assumed that for any value of the aggregate product QA, purchasers choose Qd, Qu, 

and Qf

 so as to minimize their total expenditure given the prices Pd, Pu, and Pf. The price of the 

aggregate product, PA, is defined to be: 

Demand for the aggregate product, DA, is assumed to take the constant elasticity form, so that: 

9
where ,A is the own price elasticity of demand for the aggregate good. 

From the first order conditions for expenditure minimization,17 demand for an individual 

product can be expressed as a function of its own (industry) price, the aggregate product price, 

and the quantity of the aggregate product: 

(1) 

(2) 

(3) 

It is assumed that both domestic production and fair imports are supplied competitively 

to the U.S. market. It is further assumed that these supply relationships are of the constant 

elasticity form, so that we have: 

(4) 

(5) 

where Sd and Sf are domestic supply and fair import supply, respectively, and 

"d, "f, 0d, and 0f are all positive constants. 

The values of D, ,A, 0d, and 0f

 are assumed to be fixed over time for each industry. The 

values bd, bu, bf

, "d, "f, and "A vary over time, and are shift parameters for the demand and 

10
supply functions. 

A domestic industry can suffer injury from changes in demand for its product in two 

ways. The first is through changes in the overall demand for the product, that is, the aggregate 

demand shift parameter "A decreases. The second is for purchasers’ perceptions of the relative 

quality differences between domestically produced and imported goods to change, that is, the 

shift parameters bd, bu, and bf

 change. These parameters can change because the physical 

properties of the products can change, because purchasers’ perceptions of the products can 

change, or because of other changes that change the relative values that purchasers place on the 

products. 

The cost of production of the domestic industry, or the cost of production for the 

producers of fairly traded imports, could change. This will happen if the supply shift parameters 

"d or "f change. 

The underlying assumption behind laws against dumped imports is that dumping is done 

by foreign firms with market power that have the ability to price discriminate between American 

consumers and foreign ones, or the ability to charge prices in the U.S. below their cost of 

production. If this assumption were valid, then it would not be appropriate to model these 

foreign firms as perfect competitors, and therefore they would not have supply functions. We 

will therefore take the price of the unfairly traded imports to be another shift parameter of the 

model. 

This model allows us to compute injury estimates for both the unitary and the bifurcated 

approaches. To compute the unitary estimates, we raise the raise the price of unfairly traded 

imports so that they are no longer unfairly traded. For subsidized imports, or imports that 

11
Commerce has found to be sold in the U.S. below the cost of production, we increase the price of 

unfairly traded imports by the amount of the countervailing duty margin or dumping margin, 

then compute new equilibrium prices and quantities. In those investigations where foreign 

producers engage in price discrimination, we compute a new equilibrium given the constraint 

that these producers must charge the same price in their home market as in the U.S.18 

To compute the bifurcated injury estimates, we compute the price of unfairly traded 

imports at the beginning of the period of investigation and at the end of the period of 

investigation. We then use the model to compute new equilibrium prices and quantities using 

the final year price of unfairly traded imports with the other shift parameters held equal to their 

initial year values. Similarly, we can vary in turn each of the shift parameters to measure how 

different demand and supply changes affected domestic industry revenue and output over the 

period of investigation. 

IV. ESTIMATION 

Our data set consists of the 41 domestic industries that petitioned for relief from unfairly 

traded imports between 1989 and 1994 for which there is sufficient price and quantity data in the 

public version of the USITC investigation reports.19 This period is between two major changes 

in Title VII: the Omnibus Trade and Competitiveness Act of 1988, and the Uruguay Round 

Trade Agreements Implementing Act. During this time period the USITC had Commissioners 

who used the unitary approach as well as those who used the bifurcated approach. As a result, 

domestic firms that could present a case for injury under either approach would have an 

incentive to petition for relief. 

12
For most of the investigations in which the imports that were alleged to be dumped by 

firms from different countries, the USITC majority cumulated the imports across countries. 

There were three investigations where this was not done, giving us a total of 44 different 

investigations. 

The industries in our data set produced a broad range of products, including garlic, 

lumber, DRAMS, and steel, from a broad range of countries. Thirty two of the investigations 

involved allegations of dumping, two involved allegations of subsidization, and ten involved 

allegations of both dumping and subsidization. Details of how we constructed our data set are 

given in the Appendix. 

Table 1 summarizes the percentage change in various variables over the USITC’s three 

year period of investigation for the industries in our sample. Of these 41 industries, 36 saw their 

real revenue decline over the period of investigation, and for 24 of these, the decline was greater 

than 10%. Twenty nine of these industries saw their output decline over the period of 

investigation, and for ten the decline was greater than 10%. Thirty five saw their real price 

decline over the period of investigation, and for 17 the decline was greater than 10%. Forty of 

the 41 saw either their output or their real price decline over the period of investigation; 24 of the 

41 saw both their output and their real price decline over the period of investigation. 

Reports published by the USITC provided the data on prices (Pd, Pu, and Pf

) and 

quantities (Qd, Qu, and Qf ), as well as USITC staff estimates of the elasticities ,A, F, 0d, and 0f

. 

With this data, it is possible to compute the shift parameters of the model for both the initial year 

and the final year of the USITC’s three year period of investigation.20 

By substituting a given shift parameter for the final year of the investigation into the 

13
model using the other shift parameters for the initial year of the investigation, we compute a new 

equilibrium, and compare this to the observed revenues, prices, and quantities of the domestic 

industry for the initial year. This gives us an estimate of the independent effect of the change in 

that relationship over the period of investigation. 

To illustrate, the first investigation in our data set is dumped digital readouts consoles 

from Japan. The real revenue of the U.S. producers of consoles for digital readouts fell by 

14.5% over the period of investigation. The change in aggregate demand for the product would, 

in the absence of any other changes, have caused domestic industry revenue to decline by 12.3%. 

Such a decline represents 84.5% of the observed decline of 14.5%. 

Changes in relative quality over the period benefitted the industry: in the absence of any 

other changes, domestic industry revenue would have been higher by 0.5%. Changes in 

domestic supply also benefitted the domestic industry: in the absence of any other changes, 

domestic industry revenue would have been higher by 1.5%. These numbers are -3.5% and -

10.5% of the change in domestic industry revenue. We do not have data on fairly traded 

imports, but know them to be small, so we assumed that all imports were unfairly traded. 

The price of unfairly traded imports decreased in real terms over the period of 

investigation. This decrease lowered domestic industry revenue by 4.8%, holding all other 

demand and supply parameters constant. This figure is 33% of the 14.5% decline in real 

domestic industry revenue over the period of investigation. 

We also estimated the upper bound effects of the unfair practice(s) on the domestic 

industry revenue and output. The methodology used here is that used in Kelly and Morkre 

(1998). The technique for most investigations is to raise the price of the unfairly traded imports 

14
by the amount of the countervailing duty margin and/or antidumping margin, and compute new 

equilibrium prices and outputs. 

For those cases of price discrimination dumping where the data is available we computed 

a new equilibrium by maximizing the profit of the producers of the unfairly traded imports 

subject to the constraint that the foreign producers had to charge the same price in their home 

market as they did in the U.S.21 

These are upper bound estimates, which overstate the actual effect of the unfair practice 

for a number of reasons. First, they rely upon the countervailing duty and dumping margins 

computed by Commerce. The consensus of opinion is that the methods and practices of 

Commerce significantly bias these margins upward.22 As the margins are biased upward, so will 

be the injury estimates computed from them. 

Second, dumping and subsidy margins are computed by Commerce on the value of the 

product at the (foreign) factory gate. The price of the product sold in the United States will be 

the price at the factory gate plus the costs of transportation (which includes freight and 

insurance) and ordinary tariffs (as opposed to AD or CVD duties). Although some of these costs 

will be proportional to the value of the product, others will not. Because of this, when the price 

of an unfairly traded product is raised by the amount of the margin at the factory gate, the price 

of the good in the United States will increase by proportionally less than the margin. However, 

our methodology assumes that price in the United States rises by the amount of the margin and 

therefore overstates somewhat the effect of unfair trade practices on domestic industry.23 

Third, we model the domestic industry as being perfectly competitive and the victim of 

unfair practices by foreign firms that, in the case of price discrimination dumping, behave as 

15
monopolists. This combination of assumptions maximizes the impact of unfair imports on the 

domestic industry.24 This market structure is, however, often at considerable variance with 

reality. There are cases where foreign industries are highly fragmented, such as shop towels 

from Bangladesh, and/or involve firms from several different countries.25 Such circumstances 

would tend to make it more difficult for foreign firms to coordinate their activities sufficiently to 

behave as the tight cartels that our assumptions imply, and are inconsistent with international 

price discrimination with large dumping margins. 

Fourth, price discrimination can be eliminated not just by raising the price that a foreign 

firm sells its product for in the U.S., it can also be eliminated by lowering the price that the firm 

charges in its home market. Where we had data on the quantity that was sold in the home 

market, we were able to compute partial pass through injury estimates. Where we did not have 

this data, we were forced to make full pass through injury estimates, that is, we assumed that in 

the absence of dumping the unfairly traded imports would be higher by the full amount of the 

dumping margin. Because full pass through injury estimates are higher than partial pass through 

injury estimates,26 this will overstate the true injury to the domestic industry. 

There were ten cases in which the imports in question were alleged to be both dumped 

and subsidized. For two of these, the subsidy margin turned out to be zero. For six cases the 

USITC majority “cross-cumulated,” that is, it combined the injury from the practice of 

subsidization with the injury from dumping in determining whether or not the domestic industry 

was materially injured. For these cases we computed the effect of the unfair practices by 

combing the dumping margin with the countervailing duty margin. For two industries the 

USITC majority did not cross cumulate its injury determinations, and so for these two cases we 

16
computed separate estimates of the effects of dumping and the effects of subsidization. 

Therefore, there are 46 different sets of estimates of injury to the domestic industry from 

dumping and/or subsidization. 

Table 2 summarizes our estimates of the effects of changes in aggregate demand, relative 

quality, domestic supply, fair import supply, and unfairly traded import price over the three year 

period of investigation on revenue for the 44 investigations. The final row presents a summary 

of our upper bound estimates of the effects of the unfair practice on domestic industry revenue in 

the final year of the investigation, that is, the unitary approach’s measure of injury. 

The median total revenue decrease was 13.6 %. Changes in aggregate demand had the 

largest effect, decreasing domestic industry revenue by 5.3 %, or 41.7 % of the total median 

decrease. Changes in relative quality decreased domestic industry revenue by 1.0 % (7.9%). 

Changes in domestic supply and fair import supply caused decreases of revenue of 0.6 % (4.7%) 

and 0.7% (5.5%). Changes in unfairly traded import price decreased domestic industry revenue 

by 3.7 % (29.1%).

 From the first row of Table 2, we see that five industries saw their revenue increase over 

the period of investigation, two saw their revenue decrease by less than 5%, ten saw their 

revenue decrease by between 5% and 10%, and 24 saw their revenue decrease by more than 

10%. The second row shows that eight industries benefitted from changes in aggregate demand 

over the period of investigation, 13 had revenue losses of less than 5%, eight had revenue losses 

of more than 5% but less than 10%, and 15 had revenue losses of more than 10% due to changes 

in aggregate demand. The numbers in parentheses show the number above it as a percentage of 

all investigations in our sample. Nine industries did not compete with fairly traded imports, and 

17
so the numbers in that row sum to 35. 

In 36 of the 44 cases, changes in aggregate demand for the product in question caused 

revenue to decrease during the period of investigation. For a majority of the cases, the loss in 

revenue exceeded 10%. The growth of the U.S. economy was in recession in the fourth quarter 

of 1990 and the first quarter of 1991. However, the cases in which the estimates indicate that 

demand fell do not seem to be concentrated in this period, but rather appear to be evenly 

distributed throughout the sample period. In 29 cases changes in relative quality adversely 

affected domestic revenue. In 28 of the 44 cases, changes in domestic supply adversely affected 

domestic industry revenue. There were fairly traded imports in 35 of the 44 cases; in 22 of these 

35, changes in fairly traded imports supply adversely affected domestic industry revenue. The 

price of unfairly traded imports decreased in real terms over the period of investigation in 37 

cases, adversely affecting domestic industry revenue. 

Changes in aggregate demand had the largest negative impact on domestic revenue in 20 

cases, changes in relative quality in eight, changes in domestic supply in three, changes in fairly 

traded import supply in five, and changes in unfair import price in eight. 

The final row of Table 2 summarizes our estimates of the injury to the domestic industry 

from the dumping and/or subsidization under the unitary approach. Since these estimates are 

always negative when the antidumping or countervailing duty margins are positive, there is no 

entry in the first column. The next to last column in the final row shows that for 13 of the 46 

USITC injury determinations, the estimated effect of the unfair practice in the final year of the 

investigation was larger than any of the estimates of the effect of changes in other factors over 

the previous three years. 

18
Table 3 presents comparable figures for changes in domestic industry output due to 

changes in supply and demand functions, and the upper bound estimates of the effects of 

dumping and/or subsidization. 

Once again, in the majority of the cases, aggregate demand, relative quality, fair import 

supply, and unfair import price changed to the detriment of the domestic industry. In 34 of 44 

cases, or 77.3%, domestic supply actually increased, which ceteris paribus would have caused 

domestic industry output to rise. In 19 of these cases the domestic industry revenue fell as a 

result of the supply increase (and in one case revenue increased as a result of a domestic supply 

decrease). 

Changes in aggregate demand had the largest effect on domestic industry output in 18 

cases. Changes in relative quality had the largest effect on domestic industry output in seven 

cases. Changes in domestic industry supply and fair import supply were the most important 

cause of injury in seven and four cases, respectively. The change in unfair import price had the 

largest negative effect on domestic industry revenue in eight cases. 

For more than 60% of the cases the effect of the unfair practice on domestic industry 

output (that is, the unitary measure of injury from unfairly traded imports) was less than 5%. The 

effect of the unfair practice in the final year of the investigation caused a larger decrease in 

domestic industry output than any individual cause of injury to the domestic industry in 11 

cases.27 

In summary, industries that petitioned for relief from imports that they alleged were 

dumped and/or subsidized performed poorly on average, with their revenue, output, and price 

declining over the three years prior to their petition. However, these same industries generally 

19
suffered from adverse changes apart from a decrease in price of the unfairly traded imports in 

question. Furthermore, more often than not adverse economic changes had a bigger economic 

impact upon the domestic industry than did the impact of unfair trade practices. Of the 39 

USITC injury determinations where domestic industry revenue declined, for only seven (17.9%) 

was the estimated effect of the unfair practice greater than the revenue decline. Of the 34 USITC 

injury determinations where domestic industry output declined, for only 16 (47.1%) was the 

estimated effect of the unfair practice greater than the output decline. The majority of industries 

in our sample suffered hardship for reasons other than the unfair trade practice. 

Sensitivity Analysis 

The USITC staff typically reports its elasticity estimates as ranges. The elasticity 

parameters used in the calculations for Tables 2 and 3 were the mid-points of the USITC staff 

estimates. We have also done the same calculations using both the lower bound elasticity 

estimates and the upper bound elasticity estimates. Using the end-points of the ranges does not 

materially change the finding that the change in the price of unfairly traded imports was typically 

not the most important cause of injury to the domestic industry. The change in unfairly traded 

import price was the most important cause of declining revenue for six industries using the lower 

bound elasticity estimates, eight industries using the mid-point elasticity estimates, and seven 

industries using the upper bound elasticity estimates. The change in unfairly traded import price 

was the most important cause of declining output for six industries using the lower bound 

elasticity estimates, eight industries using the mid-point elasticity estimates, and six industries 

using the upper bound elasticity estimates. 

As discussed above, when the underlying model is not linear, the sum of individual 

20
changes due to changes in individual supply and demand functions will no longer add up to the 

observed change in revenue or output. 

The numbers in Tables 2 and 3 were calculated by substituting the final year value of the 

shift parameter of interest while holding the values of the other shift parameters constant at their 

initial year values. Another way to perform these calculations would be to substitute the initial 

year value of the shift parameter of interest while using the final year values of all of the other 

shift parameters. This is therefore equivalent to asking, what would the performance of the 

industry have been if everything else had changed, except the particular supply or demand 

relationship in question. Because the underlying model is non-linear, this gives a different 

answer than the methodology used to compute Tables 2 and 3. 

While the injury calculations are different, our conclusion that unfair import price is 

typically not the most important source of injury to the domestic industry remains valid. In only 

nine of 44 investigations was the change in the price of unfairly traded imports the most 

important cause of declining revenue, and for only seven of 44 investigations was it the most 

important cause of declining output. 

V. COMPARING UNITARY AND BIFURCATED INJURY ESTIMATES 

The debate among USITC Commissioners as to the correct way to measure injury from 

unfairly traded imports was, to put it mildly, a spirited one. Was this debate warranted? Do the 

approaches give significantly different answers? 

The first investigation in our study showed very different injury estimates between the 

two approaches. As discussed above, the revenue of domestic producers of digital readout 

21
consoles declined by 14.5% in real terms over the period of investigation. The bifurcated injury 

estimate was 4.8%. The unitary injury estimate was 15.4% using the partial pass through model, 

and 21.0% using the full pass through model. Although the Commissioners who used the 

bifurcated approach tended to be more likely to find that the domestic industry was materially 

injured or threatened with material injury from unfairly traded imports than were those 

Commissioners who used the unitary approach, in this case the four Commissioners who relied 

on the bifurcated approach28 voted negative, while the two Commissioners who relied on the 

unitary approach29 found material injury to the domestic industry from unfairly traded imports. 

We can point to examples such as dumped DRAMs from Korea, where the bifurcated 

injury estimate was large (84.8%) while the unitary injury estimate was not (4.1%). We also 

find examples where both the unitary and the bifurcated estimates were large, such as dumped 

stainless steel flanges from India and Taiwan, where the unitary injury estimate was 33.6%, and 

the bifurcated injury estimate was 13.3%. Then there are examples where neither the unitary nor 

the bifurcated injury estimate was large, such as dumped shop towels from Bangladesh, where 

the unitary injury estimate was 1.2%, and the bifurcated injury estimate was .01%.30 

We computed a correlation coefficient for our unitary injury estimates with our 

bifurcated injury estimates. The correlation coefficient is .23, which is not statistically 

significant at a 5% level.31 

One lump or two? It is an important question. In general, the unitary approach and the 

bifurcated approach will give different injury estimates. 

22
VI. CONCLUSION 

For more than twenty years the predominant approach used by the USITC to determine 

whether or not unfairly traded imports have caused material injury to a competing domestic 

industry has been the bifurcated approach. One criticism of this approach is that it fails to 

distinguish between injury from unfairly traded imports from other sources of injury. This 

shortcoming has caused USITC determinations to be rejected by reviewing bodies (U.S. courts 

and the WTO).32 

Our results indicate that this concern is a serious one. A variety of industries that have 

performed poorly have petitioned for protection from unfairly traded imports. However, 

competition from unfairly traded imports is only one of the problems that they face, and more 

often than not, it is not the most important source of their difficulties. 

The unitary approach, which compares the actual performance of a domestic industry 

with a simulation of what that performance would have been if the industry had not had to 

compete with unfairly traded imports, in every case we examine gives a very different measure 

of injury than the bifurcated approach. This suggests that there are domestic industries that have 

suffered lower revenue and output because they have had to compete with dumped or subsidized 

imports that will not be able to obtain import relief from a USITC relying on the bifurcated 

approach. 

23
 

 

 

 

REFERENCES 

Armington, P. S., “A Theory of Demand for Products Distinguished by Place of Production,” 

IMF Staff Papers, 16(1), 1969, 159-178. 

Boltuck, R. D., “Assessing the Effects on the Domestic Industry of Price Dumping,” in Policy 

Implications of Antidumping Measures, edited by P.K.M. Tharakan. Amsterdam: NorthHolland, 1991, 99-141. 

____ and R. Litan, eds. Down in the Dumps, Washington: Brookings Institution, 1991. 

Cass, R. A., “Economics and International Law,” 29(4) New York University Journal of 

International Law and Politics, 1997, 473-522. 

______ and R. D. Boltuck, “Antidumping and Countervailing Duty Law: The Mirage of 

 Equitable International Competition,” in Fair Trade and Harmonization: Prerequisites for 

Free Trade? Volume 2 Legal Analysis, edited by J. N. Bhagwati and R. E. Hudec. 

Cambridge: MIT Press, 1996, 351-414. 

Cass, R. A. and M. S. Knoll, “The Economics of ‘Injury’ in Antidumping and Countervailing 

Duty Cases: A Reply to Professor Sykes,” in Economic Dimensions in International Law: 

Comparative and Empirical Perspectives, edited by J. S. Bhandari and A. O. Sykes. 

Cambridge: Cambridge University Press, 1997, 126-165. 

Durling, James P. and Matthew McCullough, “Teaching Old Laws New Tricks: The Legal 

 Obligation of Non-Attribution and the Need for Economic Rigor in Injury Analysis Under 

US Trade Law,” in Handbook of International Trade Volume II: Economic and Legal 

Analyses of Trade Policy and Institutions, edited by E. K. Choi and J. C. Hartigan. 

Oxford: Blackwell Publishers, 2005, 73-106. 

Finger, J.M, H. K. Hall, and D. R. Nelson, “The Political Economy of Administered Protection,”

 American Economic Review, 72(3), 1982, 452-56. 

Grossman, G. M., “Imports as a Cause of Injury: The Case of the U.S. Steel Industry,” Journal 

of International Economics 20(3/4), 1986, 201-23. 

Hansen, W. L. and T. J. Prusa, “The Road Most Taken: The Rise of Title VII Protection,” World 

Economy, 18(2) March, 1995, 295-313. 

Horlick, G. N., “The United States Antidumping System,”Antidumping Law and Practice: A 

Comparative Study, edited by J. Jackson and E. A. Vermulst. Ann Arbor: University of 

Michigan Press, 1989, 99-166. 

Hummels, D., “Toward a Geography of Trade Costs,” Graduate School of Business, University 

 of Chicago Working Paper, 1999. 

Irwin, D. A., “Causing Problems? The WTO Review of Causation and Injury Attribution in U.S. 

Section 201 Cases,” The World Trade Review, 2(3), 2003, 297-325. 

Kaplan, S., “Injury and Causation in USITC Antidumping Determinations: Five Recent 

Approaches,” in Policy Implications of Antidumping Measures, edited by P.K.M. Tharakan. 

 Amsterdam: North-Holland, 1991, 143-73. 

Kelly, K., "The Analysis of Causality in Escape Clause Cases," Journal of Industrial Economics, 

37(2), 1988, 187-207. 

___ and M. E. Morkre, "Do Unfairly Traded Imports Injure Domestic Industries?," Review of 

24
 

 International Economics, 6(2), 1998, 321-32. 

____________. Quantifying Causes of Injury to U.S. Industries Competing With Unfairly Traded 

Imports: 1989 to 1994. Washington: Federal Trade Commission, 2002. 

Knoll, M. S., “An Economic Approach to the Determination of Injury Under United States 

 Antidumping and Countervailing Duty Law,” 22(1) New York University Journal of 

International Law and Politics, 22(1), 1989, 37-116. 

Morkre, M. E. and K. H. Kelly. Effects of Unfair Imports on Domestic Industries: U.S. 

Antidumping and Countervailing Duty Cases, 1980 to 1988. Washington: Federal Trade 

 Commission, 1994. 

Morkre, M. E. and H. E. Kruth, “Determining Whether Dumped or Subsidized Imports Cause 

 Injury to Domestic Industries: The International Trade Commission Approach,” 

Contemporary Policy Issues, 7(3), 1989, 78-95. 

Palmeter, N. D., “Injury Determinations in Antidumping and Countervailing Duty Cases – A 

 Commentary on U.S. Practice,” Journal of World Trade Law, 21(1), 1987, 7-45. 

_______________,“The Rhetoric and Reality of US Anti-dumping Law,” The World Economy, 

14(1), 1991, 19-36. 

Pindyk, R. S. and J.J. Rotemberg, “Are Imports to Blame: Attribution of Injury Under the 

1974 Trade Act,” Journal of Law & Economics, 30(1), 1987, 101-22. 

Rousslang, D., “Import Injury in U.S. Trade Law: An Economic View,” International Review of 

Law & Economics, 8(1), 1988, 117-22. 

Suomela, J. W. Free Trade versus Fair Trade. Turku: Institute for European Studies, Turku 

 School of Economics, 1993. 

25
APPENDIX 

Our principal data sources are the USITC reports for final antidumping and 

countervailing duty investigations conducted between 1989 and 1994. During this period there 

were 97 final reports, covering 207 antidumping investigations and 49 countervailing duty 

investigations. An investigation refers to a particular product from a particular country that is 

either dumped or subsidized. 

U.S. law requires the USITC to cumulate imports from different countries in analyzing 

injury under a broad variety of circumstances. We followed the USITC in this regard: when the 

USITC majority cumulated imports in their analysis, so did we. For example, Investigation 

Numbers 731-TA-532 through 537 covered certain dumped circular, welded, non-alloy steel 

pipes and tubes from Brazil, South Korea, Mexico, Romania, Taiwan, and Venezuela. The 

USITC cumulated imports from Brazil, South Korea, Romania, Taiwan and Venezuela, but not 

Romania. As a result, we treated these six investigations as two cases. The competing domestic 

industry was the same in both cases. 

The exact boundaries of industry definition are not clear, and as Palmeter (1987) 

documents, there do not appear to be any clear principles to industry definition. Petitioners (the 

domestic industry) and respondents (importers) frequently argue for different definitions, and 

different Commissioners use different definitions in their analysis. We used the domestic 

industry definition that was used by the USITC majority. 

Data on prices and quantities came from the USITC reports. Data is frequently withheld 

from publication to preserve confidentiality, and so we were limited to 44 cases. 

Data on countervailing duty and dumping margins came from the Federal Register 

26
notices of the Department of Commerce, as reprinted in the USITC reports. We used the “all 

other” rate, which is a weighted average for all firms investigated by Commerce. 

The elasticities came from memoranda prepared in each case by the Office of Economics 

of the USITC. These memoranda were prepared by the USITC economists based on their review 

of the evidence in the investigations and were informed by the views of lawyers and economists 

for petitioners and respondents. 

Calculations were done using GAMS, a software package designed for modeling. 

27
 

 

Table 1 

Performance of Industries That Petitioned for Relief 

Magnitude >0 <0, >-5.0 <-5.0, >-10.0 <-10.0 Median 

Revenue 5 2 10 24 -13.6 

Output 12 12 7 10 -2.9 

Price 6 7 11 17 -9.1 

28
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 2 

Sources of Change to 

and Effect of Unfair Practice on 

Domestic Industry Revenue

 >0 <0, >-5.0 <-5.0, >-10.0 <-10.0 Largest Change Median 

Revenue 5 2 10 24 -13.6

 (12.2%) (4.9%) (24.4%) (58.5%) 

Aggregate 8 13 8 15 20 -5.3 

Demand (18.2%) (29.5%) (18.2%) (34.1%) 

Relative 15 12 10 7 8 -1.0 

Quality (34.1%) (27.3%) (22.7%) (15.9%) 

Domestic 16 20 2 6 3 -0.6 

Supply (36.4%) (45.5%) (4.5%) (13.6%) 

Fair Import 13 13 5 4 5 -0.7 

Supply (29.5%) (29.5%) (11.4%) (9.1%) 

Unfair Import 7 22 6 9 8 -3.7 

Price (15.9%) (50.0%) (13.6%) (20.5%) 

Effect of 26 5 15 13 

Practice (56.5%) (11.4%) (32.6%) 

29
 

 

 

 

 

 

 

 

 

 

 

 

 

 

Table 3

Sources of Change to

and Effect of Unfair Practice on

Domestic Industry Output

>0 <0, >-5.0 <-5.0, >-10.0 <-10.0 Largest Median

 Change 

Output 12 12 7 10 -2.9

 (29.3%) (29.3%) (17.1%) (24.4%) 

Aggregate 8 17 9 10 18 -4.4 

Demand (18.2%) (38.6%) (20.5%) (22.7%) 

Relative 15 16 7 6 7 -0.8 

Quality (34.1%) (36.4%) (15.9%) (13.6%) 

Domestic 34 2 2 6 7 8 

Supply (77.3%) (4.5%) (4.5%) (13.6%) 

Fair Import 13 14 4 4 4 -0.6 

Supply (29.5%) (31.8%) (9.1%) (9.1%) 

Unfair 7 26 5 6 8 -2.7 

Import Price (15.9%) (59.1%) (11.4%) (13.6%) 

Effect of 29 6 11 11 

Practice (63%) (13%) (23.9%) 

30
FOOTNOTES

* The views expressed in this paper do not necessarily reflect the views of the Federal Trade 

Commission or any individual Commissioner. We wish to thank Sandy Lin and Van Vu 

Brantner for research assistance, and Thomas F. Jennings, Denis Breen, and two anonymous 

referees for helpful comments on an earlier draft. 

Authors: Economists, Bureau of Economics, Federal Trade Commission, Phone 202-326-3358 

(Kelly) and 202-326-3365 (Morkre), Fax 202-326-3443, E-mail kkelly@ftc.gov and 

mmorkre@ftc.gov 

1. See Durling and McCullough (2005). 

2. Ibid. 

3. Ibid. 

4. Substantial cause is defined as a cause “which is important and not less than any other cause.” 

19 U.S.C. § 201 (b)(4). Prior to 1974, increased imports had to be a more important cause of 

injury than all other causes in aggregate. This was relaxed by the Trade Law of 1974, so that all 

that was necessary was that injury from increased imports be more important than any other 

individual cause of injury. 

5. United States Steel Group v. U.S. 96 F.3d 1332 (Fed. Cir. 1996) at 1361-2, affirming United 

States Steel Group v. U.S. 873 F. Supp. 673 (CIT 1994). 

6. Advantages of the unitary approach are given by Knoll (1989) and Cass and Knoll (1997). 

The bifurcated approach is discussed by Morkre and Kruth (1989) and Kaplan (1990). 

7. The bifurcated approach to unfairly traded imports differs from that used for safeguards in 

several ways. First, the material injury standard of Title VII is lower than the serious injury 

standard of Section 201. Second, in a safeguards investigation the USITC will find affirmatively 

only if it finds that increased imports are at least as important a cause of injury to the domestic 

industry as any other cause. In contrast, Commissioners who use the bifurcated approach in a 

Title VII investigation will find affirmatively provided that unfairly traded imports have been a 

non-de minimus cause of injury to the domestic industry. Third, in a Section 201 investigation 

the USITC considers the aggregate effect of increased imports from all sources on the domestic 

industry, while in a Title VII investigation the USITC only considers the effect of imports that 

the Commerce Department has determined to be unfairly traded. 

8. Finger, Hall and Nelson (1982) at 465; see also Hansen and Prussa (1995) at 311. Suomela 

(1993) at 44 argues that “[A]lthough the intent of the entire Congress appears to have been to 

bring U.S. law into conformity with the [General Agreement on Tariffs and Trade, the forerunner 

of the WTO], the intent of the subcommittees was to provide an escape-clause form of relief.” 

31
9. The USITC staff’s original model was the Comparative Analysis of Domestic Industry 

Condition, or CADIC, developed by Boltuck (1991). This was then followed by the Commercial 

Policy Analysis System, or COMPAS. 

10. See Cass (1997) and Durling and McCullough (2005). 

11. See Durling and McCullough (2005). 

12. Magnesium from China, Russia, and Ukraine, U.S. International Trade Commission, May, 

1995. [“Magnesium”] 

13. Gerald Metals, Inc. v. U.S., 132 F. 3d 716 (Fed. Cir. 1997) at 719-20. 

14. Fairly traded and unfairly traded magnesium appear to have been sold at the same price. 

This is suggested by the opinion of Commissioner Crawford (Magnesium, p. 48) The actual 

pricing data are confidential. Note that for the dumping margin Commerce did not rely on 

observed prices in Russia but rather resorted to “Best Information Available,” which was the 

margin alleged by the petitioner. 60 F.R. 1660, March 30, 1995. 

15. World Trade Organization, “United States – Antidumping Measures on Certain Hot-Rolled 

Steel Products from Japan,” Report of the Appellate Body, WT/DS184/AB/R, July 24, 2001, at 

page 74, paragraph 223. 

16. Other economists who have discussed causation in safeguard actions under U.S. law include 

Grossman (1986), Pindyk and Rotemberg (1987), and Rousslang (1988). Irwin (2003) uses the 

Kelly methodology to study U.S. safeguards actions that have been overturned by the WTO 

because they fail to distinguish injury to the domestic industry caused by increased imports from 

other sources of injury. He finds that for most of these actions increased import supply was the 

substantial cause of injury to the domestic industry. 

17. See Armington (1969) at 167. 

18. Details of how the shift parameters are calculated are in Morkre and Kelly (1994). 

19. Details on these industries, as well as individual case estimates, are given in Kelly and 

Morkre (2002), available as of this writing at http://www.ftc.gov/be/morkre.pdf. 

20. Op. cit. Endnote 14. 

21. These were dumped consoles for digital readouts from Japan, dumped motorcycle batteries 

from Taiwan, dumped martial arts uniforms from Taiwan, dumped residential door locks from 

Taiwan, dumped cement and clinker from Japan, and dumped groundwood paper from Finland, 

Belgium, France, Germany, and the United Kingdom. 

22. See Cass and Boltuck (1996) at 365-8, Boltuck and Litan (1991), Horlick (1989) at 146, and 

Palmeter (1991) at 20. 

32
23. The extent of the overstatement depends on the importance of international freight charges 

(transportation plus insurance). A study by Hummels (1999) using 1994 data from the U.S. 

Census shows that freight charges vary considerably across categories of imports. They exceed 

20 % (of total import value) for the several products including: meat and meat products (21.1 %), 

crude fertilizer (21.1 %), natural gas (23.6 %), coal and coke (28.6 %). In general the 

overstatement equals the ratio of freight charges to total value of imports. 

24. This conclusion also receives support from efforts of one of the authors to model the adverse 

effect of a foreign subsidy on domestic industry under different market structures. The specific 

model used has two substitute products produced by two firms (one domestic the other foreign), 

linear demands, and constant marginal costs. The foreign firm benefits from a unit export 

subsidy. It can be shown that the adverse effect of a foreign subsidy is more severe for domestic 

industry under perfect competition than under Bertrand competition. Moreover, the subsidy 

effect is more severe under Bertrand competition than under Cournot competition. Bertrand 

competition is more competitive-like than Cournot competition. Unpublished materials 

available upon request. 

25. For example, industrial belts is a price dumping case involving the following eight countries: 

Israel, Italy, Japan, Singapore, South Korea, Taiwan, the United Kingdom, and West Germany. 

26. There were six cases where we were able to compute partial pass through estimates. On 

average, the partial pass through injury estimate is 59.33% of the full pass through injury 

estimate. 

27. There was also a de facto tie in the case of dumped pipe from Brazil, Mexico, South Korea, 

Taiwan, and Venezuela: the effect of the unfair practice was to decrease output by 11.43%, while 

the change in aggregate demand decreased output by 11.45%. 

28. Commissioners Eckes, Lodwick, Newquist, and Rohr. 

29. Commissioners Brunsdale and Cass. 

30. Commissioners Newquist, Rohr, and Nuzum found material injury here. 

31. If we limit the correlation analysis to only the 36 USITC determinations in which at least one 

Commissioner determined that the domestic industry had suffered material injury (regardless of 

the reason(s)), the correlation coefficient is only .20, which is again not statistically significant at 

the 5% level. 

32. See Durling and McCullough (2005). 

33