Glycine & More, Inc. v. United States, 181 F. Supp. 3d 1360

Glycine & More challenged Commerce's Final Results in the antidumping duty administrative review of glycine from the PRC, where Baoding Mantong Fine Chemistry Co., Ltd. was the sole respondent.
Baoding sought to withdraw its review request, but Commerce initially denied the withdrawal, citing lack of extraordinary circumstances and applying 90-day withdrawal rules.
Commerce later issued the Remand Redetermination extending the withdrawal deadline, accepting Baoding's untimely withdrawal, and rescinding the review with respect to Baoding, all 'under protest.'
Glycine & More previously obtained a court ruling that Commerce's interpretation of 19 C.F.R. § 351.213(d)(1) was unreasonable and that the Department must consider overall circumstances, not just the 90-day rule, when deciding withdrawals.
The Remand Redetermination argued Commerce should maintain broad discretion and that Glycine & More did not foreclose extending the deadline to accommodate pending prior-review results.
The court ultimately upheld the Remand Redetermination, affirming the extension and rescission of the Baoding-related portion of the review, while noting some disagreements with specific statements in the Remand Redetermination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the 90-day withdrawal rule may be extended for Baoding.	Glycine & More contends extension was required by the prior ruling.	Commerce has wide discretion and may deny extensions absent new, compelling circumstances.	Extension upheld; withdrawal accepted and review rescinded.
Whether Commerce correctly interpreted Glycine & More regarding extensions and discretion.	Glycine requires careful consideration of circumstances allowing withdrawal.	Remand Redetermination properly interprets the regulation to preserve discretion.	Remand interpretation consistent with substantial evidence; proper interpretation affirmed.
Whether GEO’s objections to the Remand Redetermination have merit requiring remand again.	Glycine & More boundaries permit acceptance of Baoding’s withdrawal without further remand.	RemandRedetermination addressed new arguments and should stand.	GEO's objections rejected; no remand required.

Glycine & More, Inc. v. United States, 39 CIT __, 107 F. Supp. 3d 1356 (2015) (controls interpretation of 351.213(d)(1) and withdrawal extensions; requires considering full record)