Tau-Ken Temir LLP v. United States

United States Court of Appeals for the Federal Circuit · August 4, 2025 · No. 22-2204

Summary

The United States Court of Appeals for the Federal Circuit reviews the U.S. Court of International Trade's decision upholding the Department of Commerce's rejection of Tau-Ken Temir LLP's questionnaire response as untimely in a countervailing duty investigation. The appellate court finds that Commerce abused its discretion in rejecting the submission, which was filed shortly after an automatic extension triggered by a late-day extension request, and vacates the judgment for remand.

Court
United States Court of Appeals for the Federal Circuit
Writing for the Court
PROST; DYK; HUGHES
Jurisdiction
United States Court of Appeals for the Federal Circuit
Decision date
August 4, 2025
Docket number
22-2204
Procedural posture
Appeal from United States Court of International Trade
Standard of review
De novo review of Commerce’s countervailing‑duty determination under 19 U.S.C. §1516a(b)(1)(B)(i) and the APA
Precedential value
published
Parties
Tau-Ken Temir LLP, JSC NMC Tau-Ken Samruk, Ministry of Trade and Integration of the Republic of Kazakhstan v. United States, Globe Specialty Metals, Inc., Mississippi Silicon LLC
Disposition
vacated_and_remanded

Topics

administrative lawjudicial review of agency actionagency adjudicationexhaustion of remedies

Practice areas

administrative lawcommercial litigation

Questions Presented

  1. Whether Commerce abused its discretion in rejecting Tau‑Ken’s September 16 submission as untimely
  2. Whether the one‑day extension request filed on September 15 was timely and should have been granted

Holdings

  1. Commerce abused its discretion in rejecting the September 16 submission; the Trade Court’s judgment is vacated and the case remanded with instructions that Commerce must accept the submission and proceed with the CVD investigation

Key quotations

We conclude that Commerce abused its discretion in rejecting Tau‑Ken’s September 16 submission. (at 26)
Commerce must accept the September 16 submission and proceed with its CVD investigation accordingly. (at 26)

Factual background

Commerce initiated a countervailing‑duty investigation of Kazakhstani silicon metal. Tau‑Ken filed several timely questionnaire responses but sought extensions for the subsidy portion. After a series of partial extensions, Commerce set a deadline of September 16 8:30 a.m. Tau‑Ken’s counsel began filing at 5:31 a.m. but did not complete the submission until 10:11 a.m., 1 hour 41 minutes late. Commerce rejected the submission as untimely and issued an adverse inference, which the Trade Court upheld.

Procedural history

The Trade Court sustained the Department of Commerce’s final determination that Tau‑Ken received a countervailable subsidy rate of 160% because its questionnaire response was filed untimely. Tau‑Ken appealed that judgment to the Federal Circuit.

Remand instructions

Commerce must accept the September 16 submission and proceed with its countervailing‑duty investigation accordingly.

Court Document

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