1 Antidumping Proceedings: Calculation of the Weighted Average Dumping Margin
During An Antidumping Duty Investigation, 71 Fed. Reg. 11,189 (March 6, 2006) (“Request for
May 4, 2006
Via HAND DELIVERY
Assistant Secretary for Import Administration
U.S. Department of Commerce
HCHB Room 1870 - Central Records Unit
Pennsylvania Avenue and Fourteenth Street, NW
Washington, D.C. 20230
Weighted-Average Dumping Margin
Dear Assistant Secretary Spooner:
On behalf of Corus Group plc (“Corus”) and Arcelor S.A., and its subsidiaries and affiliated
companies (collectively “Arcelor”) and pursuant to the Department of Commerce’s (“the
Department’s”) request for comments,1 we submit the following rebuttal comments on the Department’s
proposal to abandon an average-to-average price comparison methodology that excludes the results of
comparisons for which the average export price exceeds normal value (“zeroing”) and request for
comments on alternative comparison methodologies to be used in investigations in light of the WTO
panel report in United States - Zeroing.
As requested by the Department, Corus and Arcelor are enclosing one original and six copies of
this rebuttal submission as well as an electronic version in Word Perfect format on a CD-ROM. Please
do not hesitate to contact the undersigned if you should have any questions.
Richard O. Cunningham
William G. Isasi
STEPTOE & JOHNSON LLP
1330 Connecticut Ave., N.W.
Washington, D.C. 20036
Counsel for Corus Group plc
Robert S. LaRussa
Richard W. Moreland, Sr. Int’l Trade Advisor
SHEARMAN & STERLING LLP
801 Pennsylvania Ave., N.W.
Washington, DC 20004
Counsel for Arcelor S.A.
Dated: May 4, 2006
REBUTTAL RESPONSE BY CORUS AND ARCELOR
TO THE DEPARTMENT OF COMMERCE’S MARCH 6, 2006 REQUEST FOR COMMENTS
ON THE PROPOSAL TO ABANDON ZEROING
IN WEIGHTED-AVERAGE-TO-WEIGHTED-AVERAGE PRICE COMPARISONS IN INVESTIGATIONS
AND CONSIDERATION OF APPROPRIATE METHODOLOGIES TO BE AP