Slip Op. 19-116 UNITED STATES COURT OF INTERNATIONAL TRADE

NEXTEEL CO., LTD., Plaintiff, HYUNDAI STEEL COMPANY, HUSTEEL CO., LTD., AJU BESTEEL CO., LTD., MAVERICK TUBE CORPORATION, and SEAH STEEL CORPORATION, Consolidated Plaintiffs,
and HUSTEEL CO., LTD., HYUNDAI STEEL COMPANY, and ILJIN STEEL CORPORATION, Plaintiff-Intervenors,

v. UNITED STATES, Defendant,
and TMK IPSCO, VALLOUREC STAR, L.P., WELDED TUBE USA INC., MAVERICK TUBE CORPORATION, and UNITED STATES STEEL CORPORATION,
Defendant-Intervenors. Before: Jennifer Choe-Groves, Judge &RQVRO Court No. 17-00091

OPINION AND ORDER [Sustaining in part and remanding in part the U.S. Department of Commerce’s remand redetermination following an administrative re view of the antidumping order on oil country tubular goods from the Republic of Korea.]Consol. Court No. 17-00091 Page 2
Dated: September 4, 2019 J. David Park, Michael T. Shor, Henry D. Almond , Daniel R. Wilson, Leslie C. Bailey, and Kang W. Lee, Arnold & Porter Kaye Scholer LLP, of Washington, D.C., for Plaintiff NEXTEEL Co., Ltd. and Consolidated Plaintiff Hyundai Steel Company. Donald B. Cameron, Eugene Degnan, Brady W. M ills, Julie C. Mendoza, Mary S. Hodgins, and Rudi W. Planert, Morris, Manning & Marti n, LLP, of Washington, D.C., for Consolidated Plaintiff Husteel Co., Ltd. Jarrod M. Goldfeder and Robert G. Gosselink, Trade Pacific, PLLC, of Washington, D.C., for Consolidated Plaintiff AJU Besteel Co., Ltd. Gregory J. Spak, Frank J. Schw eitzer, and Kristina Zissis, White & Case, LLP, of Washington, D.C., for Consolidated Plain tiff and Defendant-Intervenor Ma verick Tube Corporation. Jeffrey M. Winton and Amrietha Nellan, Law Office of Jeffrey M. Winton PLLC, of Washington, D.C., for Consolidated Plaintiff Se AH Steel Corporation. Jordan Fleischer also appeared. Roger B. Schagrin, Elizabeth J. Drake, and Ch ristopher T. Cloutier, Schagrin Associates, of Washington, D.C., for Defendant-Intervenors TM K IPSCO, Vallourec Star, L.P., and Welded Tube USA Inc. Paul W. Jameson also appeared. Thomas M. Beline and Sarah E. Shulman, Cassid y Levy Kent (USA) LLP, of Washington, D.C., for Defendant-Intervenor Unite d States Steel Corporation. Hardeep K. Josan, Attorney, U.S. Department of Justice, of New York, N.Y., for Defendant United States. With her on the brief were Joseph H. Hunt, Assistant Attorney General, Jeanne E. Davidson, Director, and Claudia Burke, Assist ant Director. Of counsel on the brief was Mykhaylo A. Gryzlov, Senior Counsel, U.S. De partment of Commerce, Office of the Chief Counsel for Trade Enforcement and Compliance, of Washington, D.C. Joel D. Kaufman and Richard O. Cunningham, Steptoe & Johnson LLP, of Washington, D.C., for Plaintiff-Intervenor ILJIN Steel Corporation.

Choe-Groves, Judge: This action arises from the U.S. Department of Commerce’s (“Commerce”) administrative review of the an tidumping order on oil country tubular goods (“OCTG”) from Korea. See Cert ain Oil Country Tubular Goods from the Republic of Korea, 82 Fed. Reg. 18,105 (Dep’t Commerce Apr. 17, 2017) (final results of antidumping duty administrative review; 2014–2015), as amended, 82 Fed. Reg. 31,750 (Dep’t Commerce July 10,Consol. Court No. 17-00091 Page 3 2017) (amended final results of antidumping duty administrative review; 2014–2015) (“Final Results”). Before the court are the Final Results of Redetermin ation Pursuant to Court Remand, Apr. 2, 2019, ECF No. 169 (“Remand Redetermination”), pursuant to the court’s decision in NEXTEEL Co., Ltd. v. United States, 43 CIT __, __, 355 F. Supp. 3d. 1336, 1343 (2019) (“NEXTEEL I”). For the following reasons, the c ourt sustains in part and remands in part the Remand Redetermination.
PROCEDURAL HISTORY The court presumes familiarity with the fact s of this case. See NEXTEEL I, 355 F. Supp. 3d at 1344–52, 1357–58, 1360–61. In NEXTEEL I, the court considered seven Rule 56.2 motions for judgment on the agency record and four teen issues presented by the Parties. See id. at __, 355 F. Supp. 3d at 1343–44. The court sust ained in part and remanded in part Commerce’s Final Results. Id. at 1344, 1364. Cons olidated Plaintiff SeAH Steel Corporation (“SeAH”) and Defendant-Intervenors Maverick Tube Corporation, TMK IPSCO, Vallourec Star, L.P., Welded Tube USA, and United States Steel Corporation filed moti ons for reconsideration of the court’s decision in NEXTEEL I as to SeAH’s ocean freight expenses, Commerce’s application of differentia l pricing analysis, and the particular market situation adjustment. See, 43 CIT __, __, __ F. Supp. 3d __, __, Consol. Court No. 17-00091, 2019 WL 2218739, at *1 (CIT May 21, 2019) (“NEXTEEL II”). The court deni ed both motions for reconsideration. Id. at *4. Commerce filed its Rema nd Redetermination on Ap ril 2, 2019. See Remand Redetermination. Plaintiff NEXTEEL Co., Ltd. (“ NEXTEEL”) and Plaintiff Intervenor Hyundai Steel Company (“Hyundai Steel”) filed comment s. Comments of NEXTEEL and Hyundai Steel in Support of the U.S. Dep’t of Commerce’s Final Resu lts of Redete rmination Pursuant to Ct.Consol. Court No. 17-00091 Page 4 Remand, May 2, 2019, ECF No. 174 (“NEXTEEL and Hyundai Steel Br.”). Consolidated Plaintiff AJU Besteel Co., Ltd. (“ AJU Besteel”) filed comments. Comments of Consolidated Pl., AJU Besteel Co., Ltd., on Commerce’s Rema nd Redetermination May 2, 2019, ECF No. 175 (“AJU Besteel’s Br.”). Plaintiff-Intervenor Husteel Co., Ltd. (“Husteel”) filed comments. Husteel’s Comments on Redeter mination Pursuant to Ct. Re mand Order, May 2, 2019, ECF No. 171 (“Husteel Br.”). SeAH filed comments. Comments of SeAH Steel Corp. on Commerce’s April 2, 2019, Redetermination, Ma y 2, 2019, ECF No. 173 (“SeAH Br.”). 1 DefendantIntervenors TMK Ipsco, Vallourec Star, L.P., We lded Tube USA Inc., Maverick, and United States Steel Corporation filed comments. Def.-Intervenors’ Comme nts on Commerce’s Remand Results, May 2, 2019, ECF No. 172 (“Def.-Intervenors’ Br.”). Defendant United States replied. Def.’s Resp. to Comments Regarding the Remand Redetermination, Jun. 3, 2019, ECF N o. 178 (Def.’s Reply Br.”). Maverick replied. Reply of Def.-Intervenor Maverick Tube Corp. to Comme nts of SeAH Steel on Co mmerce’s Final Results of Redeterminati on Pursuant to Ct. Remand, Jun. 3, 2019, ECF No. 179 (“Maverick’s Reply Br.”). NEXTEEL and Hyundai Steel replied. Reply of NEXTEEL and Hyundai Steel to Def.- Intervenors’ Comments on the U.S. Dep’t of Co mmerce’s Final Results of Redetermination Pursuant to Ct. Remand, Jun. 3, 2019, ECF No. 180 (“NEXTEEL’s and Hyundai’s Reply Br.”).
JURISDICTION AND STANDARD OF REVIEW The court has jurisdiction pursuant to 19 U.S. C. § 1516a(a)(2)(B)(i) (2012) and 28 U.S.C. § 1581(c), which grant the court the authority to re view actions contesting the final results of an

1 SeAH submitted comments requesting that the court remand the dumping margin recalculation issue as to SeAH’s ocean freight costs. The court considers the issue moot following the court’s ruling in NEXTEEL II. See 43 CIT __, __, __ F. Supp. 3d __, __, Consol. Court No. 17-00091, 2019 WL 2218739, *1.Consol. Court No. 17-00091 Page 5 administrative review of an antidumping duty order. The court will uphold Commerce’s determinations, findings, or c onclusions unless they are unsupporte d by substantial evidence on the record or otherwise not in accordance w ith the law. 19 U.S.C. § 1516a(b)(1)(B)(i).
ANALYSIS
I. Particular Market Situation During the initial administrative proceedings, Commerce did not find the existence of a particular market situation in its preliminary results, but later relied on the same administrative record to reverse its position and conclude that a particular market situation existed in the final results. See NEXTEEL I, 43 CIT at __, 355 F. Supp. 3d at 1345–46. The court concluded that Commerce’s determinati on was unsupported by substantial ev idence and instructed Commerce on remand to remove its finding of a particular market situation from its antidumping duty calculations. See id. at __, 355 F. Supp. 3d at 1349–51. On remand, Commerce recalculated the dumping margin for SeAH, NEXTEEL, and the non-examined companies under protest. Rema nd Redetermination 5–6, 23. Commerce did not apply the particular market situation adjustment in the recalculated margins. Id. 2 Defendant-Intervenors argue that the Remand Redeter mination is unsupported by substantial evidence and that a second remand is warranted. Def.-Intervenors’ Br. 1–2. Defendant counters that Commer ce complied with the court’s in structions, Commerce could not have reached a different result on the basis of a party’s comments, a nd Defendant-Intervenors

2 In NEXTEEL I, the court did not reach the issue of Commerce’s adjustment of NEXTEEL’s input costs based on a separate administrative proceeding that resulted from Commerce’s finding of a particular market situation. See NEXTEEL I, 43 CIT __, __, 355 F. Supp. 3d. at 1351. Because Commerce removed the particular market situation adjustment on remand, Commerce recalculated NEXTEEL’s margins, and NEXTEEL requests that the court sustain the Remand Redetermination as to pa rticular market situation, the cour t considers this issue moot. See Remand Redetermination 6; NEX TEEL and Hyundai Steel Br. 7.Consol. Court No. 17-00091 Page 6 already sought reconsideration of the particular ma rket situation issue. Def.’s Reply Br. 5–7; see also NEXTEEL II, 43 CIT at __, __ F. Supp. 3d at ___, 2019 WL 2218739, at *1. Husteel and AJU Besteel agree that Commerce’s Remand Redetermination complies with the court’s remand instructions and request that the court affirm the Remand Redetermination as to the particular market situation issue. Husteel Br. 2; AJU Besteel Br. 1–2. Defendant-Intervenors’ arguments are unpersuas ive. First, Defendant-Intervenors argue that Commerce’s removal of a particular market situation adjustment is unsupported by substantial evidence. Def.-Intervenors’ Br . 6–7. To the contrary, in the underlying administrative proceeding, Commerce found that th e record did not support any of Maverick’s four allegations of a particular market situation in Korea. See NEXTEEL I, 43 CIT at __, 355 F. Supp. 3d at 1349–51 (citing Department’s Memorandum Pertaining to Maverick’s Particular Market Situation Allegati ons, PD 531, bar code 3545522-01 (Feb. 22, 2017)). DefendantIntervenors fail to point to any evidence to support Defendant-Interve nors’ contention that Commerce’s decision on remand to remove the particular market situation adjustment is unsupported by substantial evidence. See Def.-Intervenors’ Br. 1–2. Second, Defendant-Intervenors’ arguments re garding the court’s instructions to Commerce as to particular market situation we re briefed when Defendant-Intervenors sought reconsideration of the court’s opinion. See NEXTEEL II, 43 CIT at __, __ F. Supp. 3d at __, 2019 WL 2218739, at *3–4, *8–10. Defendant-Intervenors do not identify any arguments that would be raised in comments to Commerce that Defendant-Intervenors did not raise in their motion for reconsideration or other briefing before Commerce or this court. See Def.-
Intervenors’ Br. 5–6.Consol. Court No. 17-00091 Page 7 Because Commerce recalculated the dumping margin for SeAH, NEXTEEL, and the non-examined companies without applying the par ticular market situation adjustment in the recalculated margins, the court concludes that Commerce’s Remand Redetermination is consistent with the court’s rema nd order and opinion in NEXTEEL I as to the issue of particular market situation. See NEXTEEL I, 43 CIT at __, 355 F. Supp. 3d at 1364.
II. Classification of Prop rietary SeAH Products In NEXTEEL I, the court addressed Commerce’s decision to combine SeAH’s proprietary OCTG under reporting code 075 with reporting code 080. See 43 CIT at __, 355 F. Supp. 3d at 1357–58. During the investigation, Co mmerce’s initial questi onnaire asked SeAH to report a separate reporting code for proprietary grades of OCTGs that were not listed in the American Petroleum Institute (“API”) Specification for Casing and Tubing (“API Specification 5CT”). See Remand Redetermin ation 6; see also Initial Qu estionnaire, PR 100, bar code 3441771-01 (Feb. 12, 2016) (“Initial Questionnaire”) . SeAH informed Commerce that SeAH sold three proprietary grades of OCTG in the Unit ed States during the period of review that had “the same tensile strength required by the N-80 specification but is not heat treated (by normalization or by quenching-a nd-tempering) in the manner re quired by the N-80 norms.” SeAH’s Initial Section B–E Response at 8 n.4, PD 140, bar code 3454399-02 (Mar. 31, 2016) (“SeAH’s Initial Section B–E Response”). In the Final Results, Commerce combined SeAH’s reported code 075 with code 080. See Issues a nd Decision Memorandum for the Final Results of the 2014-2015 Administrative Review of the Anti dumping Duty Order on Certain Oil Country Tubular Goods from the Republic of Kore a, 95–97, A-580-870, ECF No. 58–2 (Apr. 17, 2017) (“Final IDM”). Commerce found that because SeAH’s proprietary OCTG products shared the same mechanical properties as OCTG under reporting code 080 (i.e., tensile and hardnessConsol. Court No. 17-00091 Page 8 requirements), the goods should be grouped togeth er and that “[a]ny differences between these grades were already captured in other product characteristics.” Id. at 96. The court determined in NEXTEEL I that Commerce did not distinguish meaningfully between a product’s physical characteristics and pr oduction process in the Fi nal Results and that Commerce did not address evidence on the record adequately in making its determination. NEXTEEL I, 43 CIT at __, 355 F. Supp. 3d at 1358. The court concluded that Commerce’s classification of SeAH’s proprie tary OCTG products was unsupporte d by substantial evidence. Id. On remand, Commerce explained that the m odel match methodology used to determine dumping margins in this action contained a hierar chy of criteria designed to reflect differences between products, and that Comme rce ranked those differences in order of importance. See Def.’s Reply Br. 7–8. The more important matching characteristic s were listed higher than the less important criteria in the hierarchy. Remand Redetermination 7. Commerce ranked physical characteristics (such as grade) above production processes (such as heat treatment). Id. at 7–8. In the hierarchy, grade was the third-highest product characteristic, and heat treatment was the ninth-highest. Id.; see also Initial Questionnair e B-6–B-12. Commerce noted that the absence of the heat treatment process was the distinguishing characteristic between API Specification 5CT grade code N-80 products and SeAH’s proprietar y products. Remand Rede termination 7. Under the model match hierarchy, the distinguishing characteristic of heat treatment was captured by the ninth-highest criteria. Id. Commerce asse ssed that the distinction between the physical characteristics and production pr ocess stemmed from the effect of those criteria on the products’ performance capabilities. Id. at 7–10; see also id. at 8 (identifying that “[b]ecause OCTG are used in the well and, thus, must withstand signifi cant internal and external pressures at variousConsol. Court No. 17-00091 Page 9 depths, the key physical properties, such as te nsile strength and har dness, are essential to determining the capabilities of a particular OCTG product”) (interna l quotation omitted). Commerce concluded that it was not logical to create a grade distinction at the third-level of the model match hierarchy for heat treatment because heat treatmentwas captured by the ninthhighest level. Id. Addressing the record on remand, Commerce identified that SeAH’s proprietary products “offered higher strength levels than [API Spec ification 5CT grade code] J-55 or K-55, equivalent with N-80 grade products” and had “the same mech anical properties (i.e., tensile strength and hardness) required by the N-80 specification, which [had] the assigned code 080.” Id. at 7–10 (citing Administrative Review of the Antidum ping Order on Oil Country Tubular Goods from Korea – Case Brief of SeAH Steel Cor poration, 10–11, bar code 3541806-01 (Feb. 9, 2017)) (internal quotations omitted); see also Administr ative Review of the Antidumping Order on Oil Country Tubular Goods from Korea – Case Br ief of SeAH Steel Corporation, 11, bar code 3541806-01 (Feb. 9, 2017); SeAH’s Initial Section B–E Response 8, 55–56. Commerce noted that “SeAH stated that it devel oped its proprietary grades specifically to compete with N-80 grade products and upgradeable L-80 products in the North American market, but without going through the heat treatment process.” Rema nd Redetermination 8; see also SeAH Steel’s Response to July 1 Supplemental Questi onnaire, P.D. 253 (Jul. 29, 2016) at 11 n.6. SeAH argues that Commerce’s Remand Redete rmination does not correctly classify SeAH’s proprietary products as API Speci fication 5CT grade code N-80 based on the mechanical properties of the pipe. SeAH Br. 2–5. SeAH contends that under the API grading criteria, it would be possible for a particular pi pe to be categorized under multiple grade codes based on mechanical properties such as yield streng th and tensile strength, if heat treatment is notConsol. Court No. 17-00091 Page 10

considered. Id. at 4–5. SeAH also asserts that the stencil on the OCTG pr oduct, which identifies the grade of the pipe, constitutes a physical characteristic of the pipe. SeAH Br. 5–6. Defendant counters that the model match hierar chy employed in this case was adopted to compare products with similar characteristics for the purpose of determining the dumping margin. See Def.’s Reply Br. 7–8, 10; Remand Redetermination 6–9. Defe ndant contends that the model match hierarchy does not equate tensile strength w ith grade, and that the API standards are designed to establish specifications for certain products, not compare products with similar physical characteristics. See Def.’s Reply Br. 11–12. Defendant also counters that stenciling is not a physical characteristic because if the stencil is required, then SeAH would not create non-API grade proprietary products to co mpete with API grade code N-80 products. The court is not persuaded by SeAH’s argu ments. First, while API Specification 5CT may be informative, it is not controlling as to the methodology employed by Commerce. See Fujitsu Gen. Ltd. v. United States, 88 F.3d 1034, 1044 (1996). 3 Second, Defendant’s model match hierarchy did not classify SeAH’s produc ts within the precise meaning of the API Specification 5CT. Commerce’s questionnaire as ked SeAH to report OCTG product grades and provided a reference chart to allow conversion between API Specification 5CT grade code N-80 and Commerce’s reporting code 080. Initial Questionnaire 9. For proprietary products not fitting within the API Specification 5CT, the In itial Questionnaire directed the creation of a separate reporting code along w ith technical documentation descri bing how the additional grades compared to Commerce’s reporting codes and API Specification 5CT. Id.

3 See also SeAH’s Section A Questionnaire Res p., API Specification 5CT, App’x A–10, PR 130 (Mar. 18, 2016) (“API publications necessarily addr ess problems of a general nature. . . . API publications are published to fac ilitate the broad ava ilability of proven, sound engineering and operating practices. . . . Users of this specifica tion should not rely exclusively on the information contained in this document.”).Consol. Court No. 17-00091 Page 11
Because Commerce’s additional explanation of the record supports Commerce’s decision to combine SeAH’s proprietary OCTG under re porting code 075 with 080, the court concludes that Commerce’s model match hierarchy dis tinguishes between a product’s physical characteristics and producti on process and that Commerce’ s Remand Redetermination is supported by substantial evidence. See NEXTEEL I, 43 CIT at __, 355 F. Supp. 3d at 1357–58; Fujitsu Gen., 88 F.3d at 1044. The court affirms Commerce’s Remand Rede termination as to Commerce’s classification of SeAH’s proprietary products.
III. Deduction of General and Administrative Expenses as U.S. Selling Expenses In the Final Results, Commerce deducted general and administrative (“G&A”) expenses from constructed export price (“CE P”) related to resold United St ates products for SeAH’s U.S. affiliate Pusan Pipe Am erica Inc. (“PPA”). See Remand Re determination at 11–12; Final IDM at 6, 87–88. Commerce explained that “[b]ecause PPA ’s G&A activities support the general activities of the company as a whole, including its sales and further manufacturing functions of all products,” Commerce a pplied the “G&A ratio to the total cost of further manufactured products . . . as well as to the cost of all resold products.” Final IDM at 87–88. The court noted that Commerce’s explanation did not clarify wh y it deducted PPA’s G&A expenses for resold products and did not clarify how Commerce deter mined that it would apply all of PPA’s G&A expenses to resold products. NEXTEEL I, 355 F. Supp. 3d. at 1360–61. The court concluded in NEXTEEL I that Commerce’s decision to deduct G&A expenses in the Final Results was unsupported by substantial evidence on the record and remanded this issue for clarification or reconsideration of Commerce’ s methodology. Id. at 1361. On remand, Commerce explained that “Co mmerce did not apply ‘all’ of PPA G&A expenses to directly resold products” a nd “Commerce allocated PPA G&A expensesConsol. Court No. 17-00091 Page 12 proportionally to all of the produc ts PPA sold (i.e., products wh ich PPA directly resold and products PPA further processed and then resold).” Remand Redetermination at 11–12. For further manufactured products, Commerce “applied PPA’s G&A expense ratio to the total cost of further manufacturing, plus the cost of producti on . . . of imported OCTG pipe that was further manufactured, and [Commerce] included the amo unt as further manufacturing under 19 U.S.C. § 1677a(d)(2).” Id. at 14. Commerce also “applied PPA’s G&A expense ratio to the [cost of production] of the imported OCTG for products not further manufactured and included the amount as indirect selling expenses under 19 U.S.C. § 1677a(d)(1)(D).” Id. An antidumping duty represents the am ount by which the normal value of the merchandise exceeds its export price or CEP. 19 U.S.C. § 1673. CEP is the price at which the subject merchandise is first sold in the United St ates by a seller affiliate d with the producer or exporter to a non-affiliated purchaser. 19 U.S.C. § 1677a(b). When calculating CEP, Commerce must make adjustments for certain expenses. Id.; 19 U.S.C. § 1677a(d). Under 19 U.S.C. § 1677a(d)(2), Commerce is directed to reduce CEP by “the cost of any further manufacture or assembly (including additional material and labor). . . .” 19 U.S.C. § 1677a(d)(2). Commerce also must reduce the constructed export price by: (1) the amount of any of the following expens es generally incurred by or for the account of the producer or exporter, or th e affiliated seller in the United States, in selling the subject merchandise (or subject merchandise to which value has been added)— (A) commissions for selling the subject merchandise in the United States; (B) expenses that result from, and bear a direct relationship to, the sale, such as credit expenses, guarantees and warranties; (C) any selling expenses that the seller pays on behalf of the purchaser; and (D) any selling expenses not deducted unde r subparagraph (A), (B), or (C).Consol. Court No. 17-00091 Page 13
19 U.S.C. § 1677a(d)(1)(A)–(D). SeAH argues that Commerce’s methodology is inconsistent with 19 U.S.C. § 1677a(d), that Commerce may not reclassify G&A expenses as selling expenses, that Commerce does not explain why G&A expenses may be reclassified as indirect selling expenses, and that Commerce’s treatment of G&A expenses as indirect selling expenses is not consistent with Commerce’s treatment of home-market G&A expenses. SeAH Br. at 9–12. Commerce counters that G&A expenses can be treated as indirect selling expenses when reselling activity occurs, and all G&A expenses can be treated as further manufacturing expenses when further manufacturing activity occurs. Re mand Redetermination at 22; Def.’s Reply Br. 14. Commerce supports its application of G&A expenses as selling expenses in this case because “PPA, SeAH’s affiliated re seller in the United States, employs individuals responsible for overseeing, coordinating, and supporting sales of both further manufactured and non-further manufactured products.” Def.’s Reply Br. 14. Commerce does not provide support for this proposition. Id.; see also SeAH Br. at 9–12. Based on that proposition, Commerce concludes that “PPA’s G&A activities support the general activities of the company, encompassing the sale and further manufacture of products, and the sale of non-further manufactured products.” Remand Redetermina tion at 14. Commerce’s explanation on remand does not identify what record evidence supports treatment of G&A ex penses as selling expenses. Commerce also responds that treatment of G&A expenses as indi rect selling expenses was consistent with its treatment of home-market G&A expenses because Commerce did not calculate a CEP offset in this case. Def.’s Reply Br. at 16. Commerce’s explanation on remand does not explain adequately what evidence specifically supports the treatment of G&A expe nses as selling expenses or why Commerce mayConsol. Court No. 17-00091 Page 14 treat G&A expenses as selling expenses. See also Final IDM 87–88; Issues and Decision Memorandum for Certain Oil Country Tubular Goods from the Republic of Korea, 12, A-580- 870 (Oct. 5, 2016) (preliminary results), ava ilable at https://enforcement.trade.gov/ frn/summary/korea-south/2016-24800-1.pdf (last visited September 4, 2019). The court concludes that Commerce’s Remand Redetermination as to the deduction of G&A as selling expenses is not supported by substantial evidence on the record. The court remands this issue for Commerce to provide additional clarification of Commerce’s calculation of CEP as to PPA, further explanation of why Commerce may treat G&A expenses as selling expenses as to PPA, and record evidence support for the treatment of PPA’s G&A expenses as selling expenses.
CONCLUSION For the foregoing reasons, the court concludes that:
1. Commerce’s finding of a particular market situation and dumping margin calculation for non-examined companies is suppor ted by substantial evidence;
2. Commerce’s classification of proprietary SeAH products is supported by substantial evidence;
3. Commerce’s decision to deduc t SeAH’s general and administrative expenses as selling expenses is unsupported by substantial evidence. Upon consideration of all pa pers and proceedings in th is action, it is hereby
ORDERED that Commerce shall file its remand de termination on or be fore November 4, 2019; and it is further
ORDERED that Commerce shall file the administrative record on or before November 18, 2019; and it is furtherConsol. Court No. 17-00091 Page 15

ORDERED that Parties’ comments in opposition to the remand deter mination shall be filed on or before Decembe r 4, 2019; and it is further
ORDERED that Parties’ comments in support of the remand dete rmination sha ll be filed on or before January 3, 2020; and it is further
ORDERED that the Joint Appendix shall be filed on or before January 10, 2020.

/s/ Jennifer Choe-Groves Jennifer Choe-Groves, Judge Dated: September 4, 2019 New York, New York