Productos Laminados de Monterrey S.A. de C.V. v. United States, 581 F.Supp.3d 1349

Prolamsa, a Mexican producer/exporter of heavy walled rectangular welded carbon steel pipes and tubes (HWR), was subject to a 2016 antidumping duty order.
Commerce’s second administrative review initially assigned Prolamsa a 7.47% weighted-average dumping margin in the Final Results.
Prolamsa argued Commerce should grant a level-of-trade (LOT) adjustment because its home-market (HM) Channel 4 (OEM/custom parts) sales involved distinct, more intensive selling activities than HM Channels 1–3 (commercial sales).
The Court in Productos Laminados de Monterrey v. United States (Prolamsa I) remanded, finding Commerce’s rejection of the two-LOT claim unsupported by substantial evidence.
On remand Commerce found two HM LOTs, made an LOT adjustment, and recalculated Prolamsa’s margin as 0.89% (Remand Redetermination); the government supports this result, while intervenor Nucor opposes it.
The Court sustained the Remand Redetermination, holding Commerce’s LOT finding and adjustment are supported by substantial evidence.

Issue	Plaintiff's Argument	Defendant / Intervenor's Argument	Held
Whether Commerce lawfully denied a LOT adjustment in the Final Results	Prolamsa: HM Channel 4 sales are a distinct LOT and require an LOT adjustment	Commerce/US: On remand supports LOT finding; Nucor: contends the record is insufficient for LOT	Court: Remand Redetermination showing two HM LOTs and an LOT adjustment is supported by substantial evidence; sustain remand
Whether the record contains adequate quantitative evidence to show different LOTs	Prolamsa: provided quantitative metrics (selling expenses, salaries, inventory turnover, headcount) showing higher intensity for Channel 4	Nucor: data do not link higher selling expenses to price differences; evidentiary gaps and inferences are speculative	Court: Substantial record evidence (qualitative + quantitative) sufficed; statute does not require more particularized linkage Nucor demands
Whether price differences reflect higher manufacturing (DIFMER) costs rather than LOT	Prolamsa: price premium reflects both custom manufacturing and additional, OEM-specific selling activities	Nucor: price premium is due to custom manufacturing costs and should be addressed as DIFMER, not LOT	Court: Commerce permissibly attributed price premium in part to different selling activities and applied LOT adjustment; DIFMER argument did not preclude LOT and was unpersuasive

SKF USA, Inc. v. United States, 537 F.3d 1373 (Fed. Cir. 2008) (defining "substantial evidence" standard of review)
Consol. Edison Co. v. NLRB, 305 U.S. 197 (1938) (standard for substantial-evidence review)
Productos Laminados de Monterrey S.A. de C.V. v. United States, 554 F. Supp. 3d 1355 (CIT 2021) (Prolamsa I) (Court remanded Commerce’s Final Results for reconsideration of LOT issues)