Curtis' trade remedies lawyers have achieved numerous successes for clients in DOC trade remedies proceedings. In several cases, we have achieved de minimis dumping margins and countervailing duty margins, which allowed our clients to avoid the continuing burden of trade restrictive orders. In many other trade remedy cases, our clients obtained the lowest margins of the various foreign respondents participating in the investigation.
Clients benefit from our ability to undertake sophisticated quantitative analyses in-house to maximize defense efforts while controlling client costs. A team of non-lawyer specialists, including former DOC officials, continuously run simulations on client databases during the preparation of responses. This allows our lawyers to focus on developing methodologies and presentations that provide the lowest possible dumping margins and countervailing duty margins in trade remedies cases. Based on these simulations, we can advise clients what to expect from the investigation much earlier in the process, and suggest alternative approaches if the margins are commercially unacceptable.
Administrative reviews are an area in which we have particular experience. In those cases in which our clients are subject to an antidumping duty order or a countervailing duty order, we work with the client to obtain the best possible result in the annual administrative review process. We have successfully implemented administrative review strategies that allowed our clients to establish successive “zero margins” resulting in order revocations. To help our clients with antidumping review planning, we developed a proprietary software process that clients use to monitor and control effectively their ongoing dumping liabilities.
We do all of this work in-house, unlike many law firms that subcontract the heart of their trade remedy legal defense work to non-lawyer consultants and others. Our belief is that lawyers cannot adequately defend the client’s interests without being completely immersed in the facts and margin methodologies. If there are key accounting or economic issues, our lawyers grapple with them until they are mastered. This approach has allowed us to pioneer new ground in the application of the antidumping law to hyperinflationary economies, to win key battles over the allocation of research and development expenses, and to craft creative approaches to the treatment of indirect expenses.
