19-4-4096 Foreign producers' questionnaire

OMB No. 3117-0016/USITC No. 19-4-4096; Expiration Date: 6/30/2020
(No response is required if currently valid OMB control number is not displayed)

FOREIGN PRODUCERS’/EXPORTERS’ QUESTIONNAIRE
VERTICAL METAL FILE CABINETS FROM CHINA
This questionnaire must be received by the Commission by September 4, 2019
See last page for filing instructions.
The information called for in this questionnaire is for use by the United States International Trade Commission in
connection with its countervailing duty and antidumping duty investigations concerning vertical metal file
cabinets “VMFCs” from China (Inv. Nos. 701-TA-623 and 731-TA-1449 (Final)). The information requested in the
questionnaire is requested under the authority of the Tariff Act of 1930, title VII.

Name of firm
Address
Website
Has your firm produced or exported vertical metal file cabinets (as defined on next page) in China at any time
since January 1, 2016?

NO

(Sign the certification below and promptly return only this page of the questionnaire to the Commission)

YES

(Complete all parts of the questionnaire, and return the entire questionnaire to the Commission)

Return questionnaire via the Commission Drop Box by clicking on the following link:
https://dropbox.usitc.gov/oinv/. (PIN: FILE)
CERTIFICATION
I certify that the information herein supplied in response to this questionnaire is complete and correct to the best of my
knowledge and belief and understand that the information submitted is subject to audit and verification by the Commission. By
means of this certification I also grant consent for the Commission, and its employees and contract personnel, to use the
information provided in this questionnaire and throughout this proceeding in any other import-injury proceedings conducted by
the Commission on the same or similar merchandise.
I, the undersigned, acknowledge that information submitted in response to this request for information and throughout this
proceeding or other proceedings may be disclosed to and used: (i) by the Commission, its employees and Offices, and contract
personnel (a) for developing or maintaining the records of this or a related proceeding, or (b) in internal investigations, audits,
reviews, and evaluations relating to the programs, personnel, and operations of the Commission including under 5 U.S.C.
Appendix 3; or (ii) by U.S. government employees and contract personnel, solely for cybersecurity purposes. I understand that all
contract personnel will sign appropriate nondisclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Signature

Phone

Email address

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)

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PART I.—GENERAL INFORMATION
Background.-- This proceeding was instituted in response to a petition filed on April 30, 2019, by Hirsh
Industries LLC, West Des Moines, Iowa. Countervailing and antidumping duties may be assessed on the
subject imports as a result of these proceedings if the Commission makes an affirmative determination
of injury, threat, or material retardation, and if the U.S. Department of Commerce (“Commerce”) makes
an affirmative determination of subsidization and/or dumping. Questionnaires and other information
pertinent to this proceeding are available at
https://www.usitc.gov/investigations/701731/2019/vertical_metal_file_cabinets_china/preliminary.htm
Vertical metal file cabinets “VMFCs” covered by these investigations are freestanding vertical metal file
cabinets containing two or more extendable file storage elements and having an actual width of 25
inches or less.
The subject vertical metal file cabinets have bodies made of carbon and/or alloy steel and or other
metals, regardless of whether painted, powder coated, or galvanized or otherwise coated for corrosion
protection or aesthetic appearance. The subject vertical metal file cabinets must have two or more
extendable elements for file storage (e.g., file drawers) of a height that permits hanging files of either
letter (8.5” x 11”) or legal (8.5” x 14”) sized documents.
An “extendable element” is defined as a movable load-bearing storage component including, but not
limited to, drawers and filing frames. Extendable elements typically have suspension systems, consisting
of glide blocks or ball bearing glides, to facilitate opening and closing.
The subject vertical metal file cabinets typically come in models with two, three, four, or five-file
drawers. The inclusion of one or more additional non-file-sized extendable storage elements, not sized
for storage files (e.g., box or pencil drawers), does not remove an otherwise in-scope product from the
scope as long as the combined height of the non-file-sized extendable storage elements does not exceed
six inches. The inclusion of an integrated storage area that is not extendable (e.g., a cubby) and has an
actual height of six inches or less, also does not remove a subject vertical metal file cabinet from the
scope. Accessories packaged with a subject vertical file cabinet, such as separate printer stands or shelf
kits that sit on top of the in-scope vertical file cabinet are not considered integrated storage.
“Freestanding” means the unit has a solid top and does not have an open top or a top with holes
punched in it that would permit the unit to be attached to, hung from, or otherwise used to support a
desktop or other work surface. The ability to anchor a vertical file cabinet to a wall for stability or to
prevent it from tipping over does not exclude the unit from the scope.
The addition of mobility elements such as casters, wheels, or a dolly does not remove the product from
the scope. Packaging a subject vertical metal file cabinet with other accessories, including, but not
limited to, locks, leveling glides, caster kits, drawer accessories (e.g., including but not limited to
follower wires, follower blocks, file compressors, hanger rails, pencil trays, and hanging file folders),
printer stand, shelf kit and magnetic hooks, also does not remove the product from the scope. Vertical
metal file cabinets are also in scope whether they are imported assembled or unassembled with all
essential parts and components included.
Excluded from the scope are lateral metal file cabinets. Lateral metal file cabinets have a width that is
greater than the body depth, and have a body with an actual width that is more than 25 inches wide.
Also excluded from the scope are pedestal file cabinets. Pedestal file cabinets are metal file cabinets
with body depths that are greater than or equal to their width, are under 31 inches in actual height, and

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have the following characteristics: (1) an open top or other the means for the cabinet to be attached to
or hung from a desktop or other work surface such as holes punched in the top (i.e., not freestanding);
or (2) freestanding file cabinets that have all of the following: (a) at least a 90 percent drawer extension
for all extendable file storage elements; (b) a central locking system; (c) a minimum weight density of 9.5
lbs./cubic foot; and (d) casters or leveling glides.
“Percentage drawer extension” is defined as the drawer travel distance divided by the inside depth
dimension of the drawer. Inside depth of drawer is measured from the inside of the drawer face to the
inside face of the drawer back. Drawer extension is the distance the drawer travels from the closed
position to the maximum travel position which is limited by the out stops. In situations where drawers
do not include an outstop, the drawer is extended until the drawer back is 3-l/2 inches from the closed
position of inside face of the drawer front. The “weight density” is calculated by dividing the cabinet’s
actual weight by its volume in cubic feet (the multiple of the product’s actual width, depth, and height).
A “central locking system” locks all drawers in a unit.
Also excluded from the scope are fire proof or fire-resistant file cabinets that meet Underwriters
Laboratories (UL) fire protection standard 72, class 350, which covers the test procedures applicable to
fire-resistant equipment intended to protect paper records.
The merchandise subject to the investigation is classified under Harmonized Tariff Schedule of the
United States (HTSUS) subheading 9403.10.0020. The subject merchandise may also enter under HTSUS
subheadings 9403.10.0040, 9403.20.0080, and 9403.20.0090. While HTSUS subheadings are provided
for convenience and customs purposes, the written description of the scope of the investigation is
dispositive.
Reporting of information.--If information is not readily available from your records, provide carefully
prepared estimates. If your firm is completing more than one questionnaire (i.e., a producer, importer,
and/or purchaser questionnaire), you need not respond to duplicated questions.
Confidentiality.--The commercial and financial data furnished in response to this questionnaire that
reveal the individual operations of your firm will be treated as confidential by the Commission to the
extent that such data are not otherwise available to the public and will not be disclosed except as may
be required by law (see 19 U.S.C. § 1677f). Such confidential information will not be published in a
manner that will reveal the individual operations of your firm; however, general characterizations of
numerical business proprietary information (such as discussion of trends) will be treated as confidential
business information only at the request of the submitter for good cause shown.
Verification.-- The information submitted in this questionnaire is subject to audit and verification by the
Commission. To facilitate possible verification of data, please keep all files, worksheets, and supporting
documents used in the preparation of the questionnaire response. Please also retain a copy of the final
document that you submit.

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Release of information.--The information provided by your firm in response to this questionnaire, as
well as any other business proprietary information submitted by your firm to the Commission in
connection with this proceeding, may become subject to, and released under, the administrative
protective order provisions of the Tariff Act of 1930 (19 U.S.C. § 1677f) and section 207.7 of the
Commission’s Rules of Practice and Procedure (19 CFR § 207.7). This means that certain lawyers and
other authorized individuals may temporarily be given access to the information for use in connection
with this proceeding or other import-injury proceedings conducted by the Commission on the same or
similar merchandise; those individuals would be subject to severe penalties if the information were
divulged to unauthorized individuals.
Valid number error messages.--If you are completing this form in a country that uses periods (“.”) to
delineate multiples of 1000 (e.g., one million would appear as $1.000.000 rather than $1,000,000), you
may be unable to enter in numbers greater than 999 in numeric form fields. The solution to this data
entry issue is to temporarily change your operating system’s number formatting to be consistent with
the U.S. number formatting system while you complete this form. Detailed instructions on how to
resolve this issue is provided at the end of this questionnaire and is available upon request from
Lawrence Jones (202-205-3358, lawrence.jones@usitc.gov).
D-GRIDS tool.--The Commission has a tool that firms can use to move data from their own MS Excel
compilation files into self-contained data tables within this MS Word questionnaire, thereby reducing
the amount of cell-by-cell data entry that would be required to complete this form. This tool is a macroenabled MS Excel file available for download from the Commission's generic questionnaires webpage
(https://www.usitc.gov/trade_remedy/question.htm) called the "D-GRIDs tool." Use of this tool to help
your firm complete this questionnaire is optional. Firms opting to use the D-GRIDs tool to populate their
data into this questionnaire will need the D-GRIDs specification sheet PDF file specific to this proceeding
(available on the case page which is linked under the "Background" above) which includes the necessary
references relating to this questionnaire, as well as the macro-enable MS Excel D-GRIDs tool itself from
the generic questionnaires page. More detailed instructions on how to use the D-GRIDs tool are
available within the D-GRIDs tool itself.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
I-1.

Page 5

OMB statistics.--Please report below the actual number of hours required and the cost to your
firm of completing this questionnaire
Hours

Dollars

The questions in this questionnaire have been reviewed with market participants to ensure that
issues of concern are adequately addressed and that data requests are sufficient, meaningful,
and as limited as possible. Public reporting burden for this questionnaire is estimated to average
20 hours per response, including the time for reviewing instructions, gathering data, and
completing and reviewing the questionnaire.
We welcome comments regarding the accuracy of this burden estimate, suggestions for
reducing the burden, and any suggestions for improving this questionnaire. Please attach such
comments to your response or send to the Office of Investigations, USITC, 500 E St. SW,
Washington, DC 20436.
I-2.

Establishments covered.--Provide the name and address of establishment(s) covered by this
questionnaire. If your firm is publicly traded, please specify the stock exchange and trading
symbol.
“Establishment”-- Each facility of a firm in China involved in the production or export of VMFCs,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities. Firms operating more than one establishment in China should combine the
data for all establishments into a single report.

I-3.

Related producers.--Does your firm or any related firm produce, have the capability to produce,
or have any plans to produce VMFCs in the United States or other countries?

No

Yes

If yes, please name the firm(s) and country(ies) below and, if U.S.
producer(s), ensure that they complete the Commission’s producer
questionnaire.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
I-4.

Related U.S. importers.--Does your firm or any related firm import or have any plans to import
VMFCs into the United States?

No

I-5.

Yes

2
3
4
5

If yes, please name the firm(s) below and ensure that they complete the
Commission’s importer questionnaire.

U.S. importers.--Please provide the names, contacts, telephone numbers, and e-mail addresses
of the FIVE largest U.S. importers of your firm’s VMFCs in 2018.

Importer’s name
1

Page 6

Contact person

Email

Telephone

Share of your
firm’s 2018 U.S.
exports (%)

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lawrence Jones (202-2053358, lawrence.jones@usitc.gov). Supply all data requested on a calendar-year basis.
II-1.

Contact information.--Please identify the responsible individual and the manner by which
Commission staff may contact that individual regarding the confidential information submitted
in part II.
Name
Title
Email
Telephone

II-2a.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of VMFCs since January 1, 2016.
(check as many as appropriate)
plant openings
plant closings
relocations
expansions
acquisitions
consolidations
prolonged shutdowns or
production curtailments
revised labor agreements
other (e.g., technology)

(If checked, please describe; leave blank if not applicable)

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-2b.

Anticipated changes in operations.--Does your firm anticipate any changes in the character of
its operations or organization (as noted above) relating to the production of VMFCs in the
future?

No

II-3a.

Page 8

Yes

If yes, supply details as to the time, nature, and significance of such
changes and provide underlying assumptions.

Production using same machinery.-- Please report your firm’s production of products using the
same equipment, machinery, or employees as used to produce VMFCs, and the combined
production capacity on this shared equipment, machinery, or employees in the periods
indicated.
“Overall production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup).
Note.--If your firm does not produce any out-of-scope merchandise on the same machinery and
equipment as scope merchandise then the "overall production capacity" numbers reported in
this question should be exactly equal to the "average production capacity" numbers reported in
question II-8. If, however, your firm does produce out-of-scope merchandise using the same
machinery and equipment as scope merchandise, then the "average production capacity"
reported in question II-8 should exclude the portion of "overall production capacity" that was
used to produce this out-of-scope merchandise.
“Production” --All production in your establishment(s) in China, including production consumed
internally within your firm.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-3a.

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Production using same machinery.--Continued
Quantity (in units)
Calendar years
Item

Overall production capacity

2016

2017

January-June
2018

2018

2019

1

Production of:
VMFCs2

0

0

0

0

0

0

0

0

0

0

Out-of-scope products.-Lateral metal file cabinets
Pedestal metal file cabinets
Other products3
Total production using same
machinery or workers
1

Data reported for capacity (first line) should be greater than data reported for total production (last line).
Data entered for production of VMFCs will populate here once reported in question II-8.
3
Please identify these products:
.
2

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on the following
operating paramaters:
Hours per week

Weeks per year

II-3c.

Capacity calculation.--Please describe the methodology used to calculate overall production
capacity reported in II-3a, and explain any changes in reported capacity.

II-3d.

Production constraints.--Please describe the constraint(s) that set the limit(s) on your firm’s
production capacity.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-3e.

Page 10

Product shifting.—
(i).

Is your firm able to switch production capacity between VMFCs and other products using
the same equipment and/or labor?

No

(ii).

Yes

If yes—(i.e., have produced other products or are able to produce other
products), please identify other actual or potential products.

Please describe the factors that affect your firm’s ability to shift production capacity
between products (e.g., time, cost, relative price change, etc.), and the degree to which
these factors enhance or constrain such shifts.

II-4.

Share of sales.--What percentage of your firm’s total sales in its most recent fiscal year was
represented by sales of VMFCs?
percent.

II-5.

Firm's estimated share of production in China.--Please estimate the percentage of total production
of VMFCs in China accounted for by your firm’s production in 2018.
percent.

II-6.

Firm's estimated share of country's exports.--Please estimate the percentage of total exports to
the United States of VMFC from China accounted for by your firm’s exports in 2018.
percent.

II-7.

Third country trade actions.—Are the VMFCs exported by your firm subject to
antidumping/countervailing duty/safeguard findings, remedies, or proceedings in other
countries?

No

Yes

If yes--List the products(s), countries affected, and the date of such
findings/remedies/proceedings.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-8.

Page 11

Trade data.--Report your firm’s production capacity, production, shipments, and inventories
related to the production of VMFCs in your establishment(s) in China during the specified
periods. Do not include resales of VMFCs that your firm did not produce in this question; those
data to the degree they are exported to the United States should only be reported in question II9.
Do not submit data by manufacturing facility if they are in the same country. If your firm has
multiple manufacturing establishments within one country, you are required to combine data
for those establishments within one foreign producer questionnaire response.
“Average production capacity” or “capacity” –The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods for all
products manufactured in that establishment using the same manufacturing equipment.
Assume normal operating conditions (i.e., using equipment and machinery in place and ready to
operate; normal operating levels (hours per week/weeks per year) and time for downtime,
maintenance, repair, and cleanup; and a typical or representative product mix).
“Production” --All production in your establishment(s) in China, including production consumed
internally within your firm.
“Shipments”--Shipments of products produced in your establishment(s) in China. Quantities
reported should be net of returns.
“Home market commercial shipments”--Shipments, other than internal consumption and
transfers to related firms, within China.
“Home market internal consumption/transfers to related firms”--Shipments made to
related firms in China, including product consumed internally by your firm.
“Export shipments”--Shipments to destinations outside of the country indicated on page 1
(China), including shipments to related firms.
“Inventories”--Finished goods inventory, not raw materials or work-in-progress.
Note: As requested in Part I of this questionnaire, please keep all supporting documents/records
used in the preparation of the trade data, as Commission staff may contact your firm regarding
questions on the trade data. The Commission may also request that your company submit copies
of the supporting documents/records (such as production and sales schedules, inventory records,
etc.) used to compile these data.

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-8.

Page 12

Trade data.--Continued.
Quantity (in units)
Projections1

Actual experience
Item

Calendar year
2016

2017

January-June
2018

2018

Calendar year

2019

2019

2020

2

Average production capacity (A)
Beginning-of-period inventories
(B)
Production (C)
Home market shipments:
Internal
consumption/transfers (D)
Commercial shipments (E)
Exports to the United States (F)
Exports to all other markets3 (G)
Total exports (H) (should equal
F+G)
Total shipments (I) (should
equal D+E+F+G)

0

0

0

0

0

0

0

0

0

0

0

0

0

0

End-of-period inventories (J)
1

Please explain the basis for your firm’s projections:
.
The production capacity reported is based on operating
hours per week,
weeks per year. Please describe the
methodology used to calculate production capacity, and explain any changes in reported capacity:
.
3
Identify principal other export markets:
.
2

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the
end-of-period inventories (i.e., line J) should be equal to the beginning-of-period inventories (i.e., line B),
plus production (i.e., line C), less total shipments (i.e., lines D, E, F, and G). Please ensure that any
differences are not due to data entry errors in completing this form, but rather actually reflect your firm’s
records; and also provide any likely explanations for any differences (e.g., theft, loss, damage, record
systems issues, etc.) if they exist.
Actual experience
Calendar year
Item

2016

2017

Projections
January-June

2018

2018

2019

Calendar year
2019

B + C - D - E - F - G - J = should equal
zero ("0") or provide an explanation.1
0
0
0
0
0
0
1
Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are nonetheless
accurate:

2020
0

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Foreign Producers’ Questionnaire – Vertical metal file cabinets (Final)
II-9.

Page 13

Exports to the United States not produced by your firm.--Report your firm’s exports to the
United States of VMFCs that were produced in China but not by your firm during the specified
periods. Note these data should not be included in question II-8.
Quantity (in units)
Actual experience
Calendar year
Item

2016

2017

Projections
January-June

2018

2018

2019

Calendar year
2019

Exports of VMFCs to the United
States not produced by your firm1
1

List the producer(s) :

II-10.

.

Other explanations.--If your firm would like to further explain a response to a question in Part II
for which a narrative box was not provided, please note the question number and the
explanation in the space provided below. Please also use this space to highlight any issues your
firm had in providing the data in this section, including but not limited to technical issues with
the MS Word questionnaire.

2020

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Correcting Valid number error messages.--If you are completing a Commission

questionnaire in a country that uses periods (“.”) to delineate multiples of 1000 (e.g., one million would
appear as $1.000.000 instead of as $1,000,000), you may be unable to enter in numbers greater than
999 in numeric form fields. This issues stem from your computer number formatting setting (e.g., not
the MS Word document itself, but the computer from which you are opening up the document). In the
United States commas (,) delineate multiples of 1000 and periods (.) delineate fractions less than one.
Many EU countries use the reverse where multiples of 1000 are delineated with periods (.) and
fractions less than one are delineated with commas (,). The US International Trade Commission’s
questionnaires are set-up in the United States with the U.S. number formatting. When this formatting
interacts with a computer set to EU number formatting, we believe this may cause this issue.
The solution to this data entry issue is to temporarily change your operating system’s number
formatting to be consistent with the U.S. number formatting system while you complete the
questionnaire.
To temporarily change your computer’s number settings to U.S. settings, please do the following (for
Microsoft Windows Operating system):






START
Control Panel
Region and Language (under Clock, Language, and Region category)
Format tab
Change the Format from your existing one (e.g. “Italian (Italy)”) to “English (United States)” (see
screen shots below)

When you do this the number “twelve million dollars and thirty five cents” would change from
$12.000.000,35 (Italy format) to $12,000,000.35 (U.S. format), and then there will be no conflict with
the USITC foreign producer questionnaire form. When you finish reporting the data then you can close
the questionnaire and switch back to Italy settings.

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HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
https://www.usitc.gov/investigations/701731/2019/vertical_metal_file_cabinets_china/
preliminary.htm
Please do not attempt to modify the format or permissions of the questionnaire
document. Please submit the completed questionnaire using one of the methods noted
below. If your firm is unable to complete the MS Word questionnaire or cannot use one
of the electronic methods of submission, please contact the Commission for further
instructions.
• Upload via Secure Drop Box.—Upload the MS Word questionnaire along with a scanned copy of the
signed certification page (page 1) through the Commission’s secure upload facility:
Web address: https://dropbox.usitc.gov/oinv/

Pin: FILE

• E-mail.—E-mail your questionnaire to Lawrence.jones@usitc.gov; include a scanned copy of the signed
certification page (page 1). Submitters are strongly encouraged to encrypt nonpublic documents that are
electronically transmitted to the Commission to protect your sensitive information from unauthorized
disclosure. The USITC secure drop-box system and the Electronic Document Information System (EDIS)
use Federal Information Processing Standards (FIPS) 140-2 cryptographic algorithms to encrypt data in
transit. Submitting your nonpublic documents by a means that does not use these encryption algorithms
(such as by email) may subject your firm’s nonpublic information to unauthorized disclosure during
transmission. If you choose a non-encrypted method of electronic transmission, the Commission warns
you that the risk of such possible unauthorized disclosure is assumed by you and not by the Commission.
If your firm did not produce or export this product, please fill out page 1, print, sign, and submit a
scanned copy to the Commission.
Parties to this proceeding.—If your firm is a party to this proceeding, you are required to serve a copy of
the completed questionnaire on parties to the proceeding that are subject to administrative protective
order (see 19 CFR § 207.7). A list of such parties may be obtained from the Commission’s Secretary (202205-1803). A certificate of service must accompany the completed questionnaire you submit (see 19 CFR
§ 207.7). Service of the questionnaire must be made in paper form.