Sgl Carbon LLC v. United States, 2012 WL 562193

Consolidated action challenging the Final Results in the first administrative review of the antidumping duty order on small diameter graphite electrodes from China.
Domestic Producers allege corrections of four ministerial errors in the Final Results would show greater dumping than stated; intervenors (Fushun Jinly and Fangda Group) and Muzi also involved in related actions.
Commerce had sought leave to publish amended final results to correct the four ministerial errors, but the District Court initially denied the motion on Oct. 26, 2011.
Fushun Jinly, Fangda Group intervened and later filed their own action; both actions were consolidated with the Domestic Producers' case.
Court grants motion for reconsideration and authorizes Commerce to publish amended final results correcting the ministerial errors, finding errors plainly ministerial and promoting judicial economy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the errors are ministerial and corrigible administratively	Domestic Producers contend errors are non-ministerial or prejudicial to them.	Intervenors/government argue errors are ministerial and correction is appropriate.	Yes; errors are ministerial and corrigible.
Whether the court should grant leave to publish amended final results despite pending litigation	Domestic Producers fear delay and prejudice from amendments.	Government asserts corrective amendments promote efficiency and reduce prejudice.	Yes; leave granted to publish amended final results.
Whether exhaustion of administrative remedies bars relief	Domestic Producers claim exhaustion applies to all errors.	Court may grant relief notwithstanding exhaustion where remand for other issues is already warranted.	No complete exhaustion bar; relief allowed.
Whether correction would prejudice the Domestic Producers	Amended results could complicate litigation and prejudice Domestic Producers.	Corrections would not prejudice; they would alleviate ongoing prejudice to Chinese producers.	No cognizable prejudice; corrections approved.

Ntn Bearing Corp. v. United States, 74 F.3d 1204 (Fed.Cir.1995) (ministerial errors correction and judicial review context)
CEMEX, S.A. v. United States, 133 F.3d 897 (Fed.Cir.1998) (remand and ministerial errors; exhaustion discretion)
Federal-Mogul Corp. v. United States, 16 CIT 975 (1992) (correction of clerical errors; efficiency of admin process)
Hyundai Elecs. Indus. Co. v. United States, 395 F.Supp.2d 1231 (2005) (ministerial errors and units of measure; corrective action)
Shandong Huarong Gen. Corp. v. United States, 159 F.Supp.2d 714 (2001) (ministerial vs. substantive errors; administrative correction)
Koyo Seiko Co. v. United States, 746 F.Supp.1108 (1990) (administrative corrections of ministerial errors)