14-1-3333 U.S. Producer Questionnaire

Information collections for import injury investigations (producers, importers, purchasers, and foreign producer questionnaires and institution notices for 5-year reviews)

US Producer Questionnaire - Certain Steel Nails Final

Certain Steel Nails From Korea, Malaysia, Oman, Taiwan, and Vietnam, Inv. Nos. 701-TA-516-519 and 521 and 731-TA-1252-1255 and 1257 (Final)

OMB: 3117-0016

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OMB No. 3117-0016/USITC No. 15-1-3333; Expiration Date: 6/30/2017
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U.S. PRODUCERS’ QUESTIONNAIRE

CERTAIN STEEL NAILS FROM KOREA, MALAYSIA, OMAN, TAIWAN, AND
VIETNAM
This questionnaire must be received by the Commission by March 20, 2015
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 investigations concerning certain steel nails from Korea,
Malaysia, Oman, Taiwan, and Vietnam (Inv. No. 701–TA–516–519 and 521 and 731–TA–1252–1255 and 1257 (Final)).
The information requested in the questionnaire is requested under the authority of the Tariff Act of 1930, title VII. This
report is mandatory and failure to reply as directed can result in a subpoena or other order to compel the submission of
records or information in your firm’s possession (19 U.S.C. § 1333(a)).

Name of firm
Address
City

State

Zip Code

Website
Has your firm produced certain steel nails (as defined on next page) at any time since January 1, 2012?

(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 U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: NAIL)
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 acknowledge that information submitted in this questionnaire response and throughout this proceeding may be used by the
Commission, its employees, and contract personnel who are acting in the capacity of Commission employees, for developing or
maintaining the records of this proceeding or related proceedings for which this information is submitted, or in internal audits and
proceedings relating to the programs and operations of the Commission pursuant to 5 U.S.C. Appendix 3. I understand that all
contract personnel will sign non-disclosure agreements.
Name of Authorized Official

Title of Authorized Official

Date

Phone:
Signature

Fax:

Email address

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U.S. Producers’ Questionnaire – Certain Steel Nails

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PART I.—GENERAL INFORMATION
Background. This proceeding was instituted in response to a petition filed on May 29, 2014, by Mid
Continent Nail Corporation (Poplar Bluff, MO). Antidumping and/or countervailing 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 makes
an affirmative determination of dumping and/or subsidization. Questionnaires and other information
pertinent to this proceeding are available at
http://www.usitc.gov/investigations/701731/2014/certain_steel_nails_korea_malaysia_oman_taiwan_a
nd/final.htm.
Certain steel nails or “subject product” covered by these investigations is certain steel nails having a
shaft length not to exceed 12 inches. Certain steel nails include, but are not limited to, nails made from
round wire and nails that are cut from plate. Certain steel nails may be made of one piece construction
or constructed of two or more pieces. Certain steel nails may be produced from any type of steel, and
may have any type of surface finish, head type, shank, point type, shaft length and shaft diameter.
Finishes include, but are not limited to, coating in vinyl, zinc (galvanized, including but not limited to
electroplating or hot dipping one or more times), phosphate cement, and paint. Certain steel nails may
have one or more surface finishes. Head styles include, but are not limited to, flat, projection, cupped,
oval, brad, headless, double, countersunk, and sinker. Shank styles include, but are not limited to,
smooth, barbed, screw threaded, ring shank and fluted. Screw-threaded nails subjected to this
proceeding are driven using direct force and not by turning the fastener using a tool that engages with
the head. Point styles include, but are not limited to, diamond, blunt, needle, chisel and no point.
Certain steel nails remain subject to the order whether imported alone or in combination with other
articles.
Excluded from the scope of the order are steel roofing nails specifically certified at the time of entry to
satisfy the specifications of certain Type I, Style 20 nails as identified in Tables 29 through 33 of ASTM
Standard F 1667 (2013 revision). Also excluded from the scope of the order are fasteners suitable for use
in powder-actuated hand tools, not threaded and threaded, which are currently classified under
HTSUS 7317.00.20. and 7317.00.30. Also excluded from the scope of the order are fasteners having a
case hardness greater than or equal to 50 HRC, a carbon content greater than or equal to 0.5 percent, a
round head, a secondary reduced-diameter raised head section, a centered shank, and a smooth
symmetrical point, suitable for use in gas-actuated hand tools. Also excluded from the scope of the
order are corrugated nails. A corrugated nail is made of a small strip of corrugated steel with sharp
points on the side. Also excluded from the scope of the order are thumb tacks, which are currently
classified under HTSUS 7317.00.10.00.
Certain steel nails subject to this proceeding are currently classified under the Harmonized Tariff
Schedule of the United States (“HTSUS”) subheadings 7317.00.55, 7317.00.65 and 7317.00.75. While
the HTSUS subheadings are provided for convenience and customs purposes, the written description of
the scope of this order 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

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U.S. Producers’ Questionnaire – Certain Steel Nails

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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.
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.

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U.S. Producers’ Questionnaire – Certain Steel Nails
I-1a.

Page 4

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
50 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-1b.

TAA information release.--In the event that the U.S. International Trade Commission (USITC)
makes an affirmative final determination in this proceeding, do you consent to the USITC's
release of your contact information (company name, address, contact person, telephone
number, email address) appearing on the front page of this questionnaire to the Departments of
Commerce, Labor, and Agriculture, as applicable, so that your firm and its workers can be made
eligible for benefits under the Trade Adjustment Assistance program?
Yes

I-2.

Establishments covered.--Provide the city, state, zip code, and brief description of each
establishment covered by this questionnaire. If your firm is publicly traded, please specify the
stock exchange and trading symbol in the footnote to the table. Firms operating more than one
establishment should combine the data for all establishments into a single report.
“Establishment”--Each facility of a firm involved in the production of the subject product,
including auxiliary facilities operated in conjunction with (whether or not physically separate
from) such facilities.
Establishments
covered1

City, State

Zip (5 digit)

1
2
3
4
5
6
1

Additional discussion on establishments consolidated in this questionnaire:

Description

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U.S. Producers’ Questionnaire – Certain Steel Nails
I-3.

Page 5

Petition support.--Does your firm support or oppose the petition?
Country

Support

Oppose

Take no position

Korea
Malaysia
Oman
Taiwan
Vietnam

I-4.

Ownership.--Is your firm owned, in whole or in part, by any other firm?
No

Firm name

I-5.

Address

Extent of
ownership
(percent)

Related importers/exporters.--Does your firm have any related firms, either domestic or
foreign, that are engaged in importing the subject product from any subject country into the
United States or that are engaged in exporting the subject product from any subject country to
the United States?
No
Firm name

I-6.

Yes--List the following information.

Yes--List the following information.
Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, that are
engaged in the production of the subject product?
No
Firm name

Yes--List the following information.
Address

Affiliation

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PART II.--TRADE AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Fred Ruggles (202-205-3187,
[email protected]). 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
Fax

II-2.

Changes in operations.--Please indicate whether your firm has experienced any of the following
changes in relation to the production of the subject product since January 1, 2012.
(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)

(please describe)

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-3a.

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Production using same machinery.-- Please report your firm’s production of products made on
the same equipment and machinery used to produce the subject product, and the combined
production capacity on this shared equipment and machinery in the periods indicated.
“Average production capacity” or “capacity” – The level of production that your
establishment(s) could reasonably have expected to attain during the specified periods. 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 U.S. establishment(s), including production consumed
internally within your firm and production for another firm under a toll agreement.
(Quantity in short tons)
Calendar years
Item

2012

2013

2014

Overall production capacity
Production of:
Subject product (i.e., certain
nails) 1
Other products
Total
1
2

Data entered for production of certain steel nails will populate here once reported in question II-7.
Please identify these products:

II-3b.

Operating parameters.--The production capacity reported in II-3a is based on operating
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.

hours

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-3e.

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Product shifting.—
(e)

Is your firm able to switch production (capacity) between subject product and other
products using the same equipment and/or labor?
No

(f)

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.

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-4a.

Page 9

Tolling.--Since January 1, 2012, has your firm been involved in a toll agreement regarding the
production of the subject product?
“Toll agreement”--Agreement between two firms whereby the first firm furnishes the raw
materials and the second firm uses the raw materials to produce a product that it then returns
to the first firm with a charge for processing costs, overhead, etc.
No Proceed to question II-5
Yes--Please describe the toll arrangement(s) and name the firm(s) involved

II-4b.

In-house manufacturing facility versus Tolling. – Does your firm have the in-house capability to
perform the following production processes for manufacturing certain steel nails, and has your
firm actually performed these production processes in-house from 2012 - 2014:

Process

Capability (Yes/No)

Actual production
(Yes/No)

Complete nail making process
Hot dip galvanizing process
Electro-plating process
Heat Treatment process
Sinker coating process
Packing process for small packaged nails ( 1 lb/ 5 lb
boxes)
II-4c.

Tolling information.--If your firm has been involved in a toll agreement regarding the
production of the subject product at some point since January 1, 2012, please provide the
following information:

Process
Complete nail making process
Hot dip galvanizing process
Electro-plating process
Heat Treatment process
Sinker coating Process
Packing process for small
packaged nails ( 1 lb/ 5 lb
boxes)

Capability
(Yes/No)

Quantity (short tons)
If yes firm name

2012

2013

2014

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-5.

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Foreign trade zones.-Firm's FTZ operations.--Does your firm produce subject product in and/or admit subject
product into a foreign trade zone (FTZ)?

(a)

“Foreign trade zone” is a designated location in the United States where firms utilize
special procedures that allow delayed or reduced customs duty payments on foreign
merchandise. A foreign trade zone must be designed as such pursuant to the rules and
procedures set forth in the Foreign-Trade Zones Act.
No

Yes--Describe the nature of your firms operations in FTZs and
identify the specific FTZ site(s).

Other firms' FTZ operations.--To your knowledge, do any firms in the United States
import subject product into a foreign trade zone (FTZ) for use in distribution of subject
product and/or the production of downstream articles?

(b)

No/Don’t know

II-6.

Yes--Identify the firms and the FTZs.

Importer.--Since January 1, 2012, has your firm imported subject product?
“Importer” – The person or firm primarily liable for the payment of any duties on the
merchandise, or an authorized agent acting on his behalf. The importer may be the consignee,
or the importer of record.
No

Yes--COMPLETE AND RETURN A U.S. IMPORTERS’ QUESTIONNAIRE

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-7.

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Production, shipment and inventory data.--Report your firm’s production capacity, production,
shipments, and inventories related to the production of subject product in its U.S.
establishment(s) during the specified periods.
“U.S. commercial shipments” –Shipments made within the United States as a result of an arm’s
length commercial transaction in the ordinary course of business. Report net values (i.e., gross
sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods) in U.S. dollars, f.o.b. your point of shipment.
“Internal consumption” – Product consumed internally by your firm.
“Transfers to related firms” –Shipments made to related domestic firms. Such transactions

are valued at fair market value.

“Related firm” –A firm that your firm solely or jointly owns, manages, or otherwise controls.
Such transactions are valued at fair market value.
“Export shipments” –Shipments to destinations outside the United States, including shipments
to related firms.
“Inventories”— Finished goods inventory, not raw materials or work-in-progress.

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-7.

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Production, shipment and inventory data.-Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2012

2013

2014

Average production capacity (quantity)
(A)
Beginning-of-period inventories
(quantity) (B)
Production (quantity) (C)
U.S. shipments:
Commercial shipments:
Quantity (D)
Value (E)
Internal consumption:
Quantity (F)
Value2 (G)
Transfers to related firms:
Quantity (H)
Value2 (I)
Export shipments:3
Quantity (J)
Value (K)
End-of-period inventories4 (quantity) (L)
1

The production capacity (see definitions in instruction booklet) 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 (use additional pages as necessary).
2
Internal consumption and transfers to related firms must be valued at fair market value. In the event that your firm
uses a different basis for valuing these transactions, please specify that basis (e.g., cost, cost plus, etc.) and provide value
data using that basis for each of the periods noted above:
3
Identify your firm’s principal export markets:
.

RECONCILIATION OF SHIPMENTS, PRODUCTION, AND INVENTORY.--Generally, the data reported for the end-ofperiod inventories (i.e., line L) 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, F, H, and J). 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.
Calendar years
Reconciliation
B + C – D – F – H – J – L = should equal
zero ("0") or provide an explanation.1
1

2012

2013
0

2014
0

Explanation if the calculated fields above are returning values other than zero (i.e., “0”) but are
nonetheless accurate.

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-8.

Page 13

Channels of distribution.-- Report your firm’s commercial U.S. shipments by channel of
distribution.
Quantity (in short tons) and value (in $1,000)
Calendar years
Item

2012

2013

2014

Channels of distribution:
Commercial U.S. shipments:
To distributors (quantity) (M)
To end users (quantity) (N)
Calendar years
Reconciliation
M + N – D = zero ("0"), if not revise.

2012

2013
0

2014
0

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-9.

Page 14

Employment data.--Report your firm’s employment-related data related to the production of
certain steel nails and provide any explanation for any trends in these data.
“Production Related Workers” (PRWs) includes working supervisors and all nonsupervisory
workers (including group leaders and trainees) engaged in fabricating, processing, assembling,
inspecting, receiving, storage, handling, packing, warehousing, shipping, trucking, hauling,
maintenance, repair, janitorial and guard services, product development, auxiliary production
for plant’s own use (e.g., power plant), recordkeeping, and other services closely associated with
the above production operations.
Average number employed may be computed by adding the number of employees, both full
time and part time, for the 12 pay periods ending closest to the 15th of the month and divide
that total by 12. For the January to June periods, calculate similarly and divide by 2.
“Hours worked” includes time paid for sick leave, holidays, and vacation time. Include overtime
hours actually worked; do not convert overtime pay to its equivalent in straight time hours.
“Wages paid” –Total wages paid before deductions of any kind (e.g., withholding taxes, old-age
and unemployment insurance, group insurance, union dues, bonds, etc.). Include wages paid
directly by your firm for overtime, holidays, vacations, and sick leave.

Calendar years
Item

2012

2013

2014

Average number of PRWs
(number)
Hours worked by PRWs
(1,000 hours)
Wages paid to PRWs (value)
Explanation of trends:

II-10.

Related firms.--If your firm reported transfers to related firms in question II-7, please indicate
the nature of the relationship between your firm and the related firms (e.g., joint venture,
wholly owned subsidiary), whether the transfers were priced at market value or by a nonmarket formula, whether your firm retained marketing rights to all transfers, and whether the
related firms also processed inputs from sources other than your firm.

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-11.

Page 15

Purchases.--Other than direct imports, has your firm otherwise purchased certain steel nails
since January 1, 2012?
“Purchase” – A transaction to buy product from a U.S. corporate entity such as another U.S.
producer, a U.S. distributor, or a U.S. firm that has directly imported the product.
“Direct import” –A transaction to buy from a foreign producer where your firm is the importer
of record or consignee.
No

Yes--Report such purchases below and explain the reasons for your firms'
purchases:

(Quantity in short tons, value in $1,000)
Calendar years
Item

2012

2013

2014

Purchases from U.S.
importers1 of subject product
from—
Korea
Malaysia
Oman
Taiwan
Vietnam
All other countries
Purchases from domestic
producers2
Purchases from other
sources2
1

Please list the name of the importer(s) from which your firm purchased this product. If your firm’s import
suppliers differ by source, please identify the source for each listed supplier.
.
2
Please list the name of the producer(s) or other U.S. distributor(s) from which your firm purchased this
product..
.

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II-12.

Other explanations.--If your firm would like to further explain a response to a question in Part II
that did not provide a narrative box, 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.

II-13.

U.S. shipments by type and finish.--Please provide the quantity and value of your firm’s U.S.
shipments of certain steel nails during 2014 by type and finish.
Quantity (short tons)
Collated.-Bright (no finish)
Galvanized
Other
Subtotal, collated
Uncollated.-Bright (no finish)
Galvanized
Other
Subtotal, uncollated
Total
Reconciliation of total1
1

Value ($1,000)

0
0
0

The reconciliation line tests whether the data reported in this question match the data reported in
question II-7 for U.S. shipments. If the reconciliation line returns a value other than zero ("0"), please
revise your data prior to submission to the Commission.

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U.S. Producers’ Questionnaire – Certain Steel Nails
II-14.

Page 17

U.S. shipments by type and form.--Please provide the quantity and value of your firm’s U.S.
shipments of certain steel nails during 2014 by type and form.
Quantity (short tons)
Collated.-Common nail (e.g., framing, decking, box,
sinkers)
Finishing nail
Drywall nail
Flooring nail
Pallet nail
Concrete/masonry
All other products not listed above1
Subtotal, collated
Uncollated.-Common nail (e.g., framing, decking, box,
sinkers)
Finishing nail
Drywall nail
Flooring nail
Pallet nail
Concrete/masonry
All other products not listed above1
Subtotal, uncollated
Total
Reconciliation of total2
1

Value ($1,000)

0
0
0

Please list these products
The reconciliation line tests whether the data reported in this question match the data reported in
question II-7 for U.S. shipments. If the reconciliation line returns a value other than zero ("0"), please
revise your data prior to submission to the Commission.
2

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PART III.--FINANCIAL INFORMATION
Address questions on this part of the questionnaire to Mary Klir (202-205-3247, [email protected]).
III-1.

III-2.

Accounting system.--Briefly describe your firm’s financial accounting system.
A.

When does your firm’s fiscal year end (month and day)?
If your firm’s fiscal year changed during the data-collection period, explain:

B.1.

Describe the lowest level of operations (e.g., plant, division, company-wide) for
which financial statements are prepared that include certain steel nails:

Does your firm prepare profit/loss statements for certain steel nails:
Yes
No
How often did your firm (or parent company) prepare financial statements
(including annual reports, 10Ks)? Please check relevant items below.
Audited,
unaudited,
annual reports,
10Ks,
10Qs,
Monthly,
quarterly,
semi-annually,
annually
Accounting basis:
GAAP,
cash,
tax, or
other comprehensive
basis of accounting (specify)

Note: The Commission may request that your company submit copies of its financial statements,
including internal profit-and-loss statements for the division or product group that includes
certain steel nails, as well as those statements and worksheets used to compile data for your
firm’s questionnaire response.

III-3.

Cost accounting system.--Briefly describe your firm’s cost accounting system (e.g., standard
cost, job order cost, etc.).

III-4.

Allocation basis.--Briefly describe your firm’s allocation basis, if any, for COGS, SG&A, and
interest expense and other income and expenses.

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U.S. Producers’ Questionnaire – Certain Steel Nails
III-5.

Page 19

Other products.--Please list the products your firm produced in the facilities in which your firm
produced the subject product, and provide the share of net sales accounted for by these other
products in your firm’s most recent fiscal year.
Products

Share of sales

Certain Steel Nails

%
%
%
%
%

III-6.

Does your firm purchase inputs (raw materials, labor, energy, or any other services) used in the
production of the subject product from any related parties?
Yes--Continue to question III-7.

III-7.

No--Continue to question III-9a.

Inputs from related parties.--Please identify the inputs used in the production of the subject
product that your firm purchases from related parties and that are reflected in table III-9a. For
“share of total COGS” please report this information by relevant input on the basis of your most
recently completed fiscal year. For “input valuation” please describe the basis, as recorded in
your company’s own accounting system, of the purchase cost from the related party; e.g., the
related party’s actual cost, cost plus, negotiated transfer price to approximate fair market value.
Input

Related party

Share of total COGS

Input valuation as recorded in the firm’s accounting books and records

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U.S. Producers’ Questionnaire – Certain Steel Nails
III-8.

Page 20

Inputs purchased from related parties.--Please confirm that the inputs purchased from related
parties, as identified in III-7, were reported in III-9a (financial results on certain steel nails) in a
manner consistent with your firm’s accounting books and records.
Yes
No--In the space below, please report the valuation basis of inputs purchased from related
parties as reported in table III-9a.

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III-9a. Operations on certain steel nails.--Report the revenue and related cost information requested
below on the certain steel nails operations of your firm’s U.S. establishment(s).1 Do not report
resales of products. Note that internal consumption and transfers to related firms must be
valued at fair market value. Input purchases from related parties should be consistent with
and based on information in the firm’s accounting books and records. Provide data for your
firm’s three most recently completed fiscal years.
Quantity (in short tons) and value (in $1,000)
Fiscal years ended-Item

2012

2013

2014

Net sales quantities:
Commercial sales (“CS”)
Internal consumption (“IC”)
Transfers to related firms
(“Transfers”)
Total net sales quantities

Net sales values:
Commercial sales
Internal consumption
Transfers to related firms
Total net sales values
3

Cost of goods sold (COGS):
Raw materials
Direct labor
Other factory costs
Total COGS
Gross profit or (loss)

Selling, general, and administrative
(SG&A) expenses:
Selling expenses
General and administrative expenses
Total SG&A expenses
Operating income (loss)
Other expenses and income:
Interest expense
All other expense items
All other income items
Net income or (loss) before income
taxes
Depreciation/amortization included
above
1

Include only sales (whether domestic or export) and costs related to your U.S. manufacturing operations.
Less discounts, returns, allowances, and prepaid freight. The quantities and values should approximate the
corresponding shipment quantities and values reported in Part II of this questionnaire.
3
COGS (whether for domestic or export sales) should include costs associated with CS, IC, and Transfers.
2

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III-9b. Financial data reconciliation.--The calculable line items from question III-9a (i.e., total net sales
quantities and values, total COGS, gross profit (or loss), total SG&A, and net income (or loss))
have been calculated from the data submitted in the other line items. Do the calculated fields
return the correct data according to your firm's financial records ignoring non-material
differences that may arise due to rounding?
Yes

No--If the calculated fields do not show the correct data, please double check the
feeder data for data entry errors and revise.
Also, check signs accorded to the post operating income line items; the two
expense line items should report positive numbers (i.e., expenses are
positive and incomes or reversals are negative--instances of the latter
should be rare in those lines) while the income line item also in most
instances should have its value be a positive number (i.e., income is positive,
expenses or reversals are negative).
If after reviewing and potentially revising the feeder data your firm has
provided, the differences between your records and the calculated fields
persist please identify and discuss the differences in the space below.

III-10. Nonrecurring items (charges and gains) included in the subject product financial results.--For
each annual and interim period for which financial results are reported in question III-9a, please
specify all material (significant) nonrecurring items (charges and gains) in the schedule below,
the specific table III-9a line item where the nonrecurring items are included, a brief description
of the relevant nonrecurring items, and the associated values (in $1,000), as reflected in table
III-9a; i.e., if an aggregate nonrecurring item has been allocated to table III-9a, only the allocated
value amount included in table III-9a should be reported in the schedule below. Note: The
Commission’s objective here is to gather information only on material (significant) nonrecurring
items which impacted the reported financial results of the subject product in table III-9a.
Fiscal years ended-2012

2013

2014

Nonrecurring item: In this column please provide Nonrecurring item: In these columns please report the amount of
a brief description of each nonrecurring item and the relevant nonrecurring item reported in table III-9a.
indicate the specific line item in table III-9a where
the nonrecurring item is classified.
Value ($1,000)
1.

, classified

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III-11. Classification of identified nonrecurring items (charges and gains) in the accounting books and
records of the company.--If non-recurring items were reported in table III-10 above, please
identify where your company recorded these items in your accounting books and records in the
normal course of business; i.e., III-10 information designates where these items are reported in
table III-9a.

III-12. Asset values.--Report the total assets (i.e., both current and long-term assets) associated with
the production, warehousing, and sale of the subject product. If your firm does not maintain
some or all of the specific asset information necessary to calculate total assets for the subject
product in the normal course of business, please estimate this information based upon a
method (such as production, sales, or costs) that is consistent with your firm’s cost allocations in
the previous question. Provide data as of the end of your firm’s three most recently completed
fiscal years.
Note: Total assets should reflect net assets after any accumulated depreciation and allowances
deducted.
Total assets should be allocated to the subject products if these assets are also related to other
products. Please provide a brief explanation if there are any substantial changes in total asset
value during the period; e.g., due to asset write-offs, revaluation, and major purchases.
Value (in $1,000)
Fiscal years ended-Item
Total assets (net)
1

2012

2013

2014

Describe

III-13a. Capital expenditures and research and development expenses.--Report your firm’s capital
expenditures and research and development expenses on the subject product. Provide data
for your firm’s three most recently completed fiscal years.
Value (in $1,000)
Fiscal years ended-Item

2012

2013

2014

Capital expenditures
Research and development
expenses
III-13b. Capital expenditures.--Please describe your firm’s capital expenditures on the subject product.

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III-14. Data consistency and reconciliation.--Please indicate whether your firm’s financial data for
questions III-9a, 12, and 13a are based on a calendar year or on your firm’s fiscal year:
Calendar year

Fiscal year

Specify fiscal year

Please note the quantities and values reported in question III-9a should reconcile with the data
reported in question II-7 (including export shipments) as long as they are reported on a calendar
year basis.
Do these data in question III-9a reconcile with data in question II-7?
Yes

If no, please explain.

III-15. Effects of imports.--Since January 1, 2012, has your firm experienced any actual negative effects
on its return on investment or its growth, investment, ability to raise capital, existing
development and production efforts (including efforts to develop a derivative or more advanced
version of the product), or the scale of capital investments as a result of imports of the subject
product from Korea, Malaysia, Oman, Taiwan, and Vietnam?
No

Yes--My firm has experienced actual negative effects as follows:
Cancellation, postponement, or rejection of expansion projects
Denial or rejection of investment proposal
Reduction in the size of capital investments
Rejection of bank loans
Lowering of credit rating
Problem related to the issue of stocks or bonds
Other (specify):

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III-16a. Anticipated effects of imports.--Does your firm anticipate any negative effects due to imports of
the subject product from Korea, Malaysia, Oman, Taiwan, and Vietnam?
No

Yes

If yes, my firm anticipates negative effects as follows:

III-16b. Does your firm’s response differ by country?
No

Yes

If yes, indicate which country and why:

III-17. Other explanations:--If your firm would like to further explain a response to a question in Part III
that did not provide a narrative box, 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.

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PART IV.--PRICING AND RELATED INFORMATION
Further information on this part of the questionnaire can be obtained from Lauren Gamache (202-2053489, [email protected]).
IV-1.

Contact information.--Please identify the individual that Commission staff may contact
regarding the confidential information submitted in part IV.
Name
Title
Email
Telephone
Fax

PRICE DATA
IV-2.

This question requests quarterly quantity and value data for your firm’s commercial shipments
to unrelated U.S. customers since January 1, 2012 of the following products produced by your
firm.
Product 1.-- Nominal 3” x 0.131” (10.25 gauge), bright smooth shank, 20-22 degree plasticstrip collated nails
Product 2.-- Nominal 3” x 0.120” (11 gauge), bright smooth shank, 20-22 degree plastic-strip
collated nails
Product 3.-- Nominal 2 3/8” x 0.113” (11.5 gauge), bright smooth shank, 20-22 degree plasticstrip collated nails
Product 4.-- Nominal 3 1/4” x 0.131” (10.25 gauge), bright smooth shank, 20-22 degree plastic
strip collated nails
Product 5.-- Nominal 3” X 0.148” (9 gauge), bright smooth shank, 20-22 degree plastic strip
collated nails
Product 6.-- Nominal 2 ½” x 0.131” (10.25 gauge), bright smooth shank, 20-22 degree plastic
strip collated nails
Product 7.-- Nominal 2” x 0.113” (11.5 gauge), bright drive screw (threaded) shank, machine
grade bulk nails
Product 8.-- Nominal 2” x 0.099” (12. 5 gauge), bright screw (threaded), 15 degree wire coil
collated nails
Product 9.-- Nominal 2 ¼” x 0.113” (11.5 gauge), bright drive screw (threaded) shank,
machine grade bulk nails.

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Product 10.-- Nominal 3” (nail shaft length)1 x 0.162” (8 gauge) bright smooth shank
nail, double-headed or duplex head, 50 pound bulk box
Product 11.-- Nominal 1 ½” x 0.131” (10.25 gauge), bright smooth shank, 30-33 degree paper
strip collated nails
Product 12.-- Nominal 2 ½” x 0.148” (9 gauge), bright smooth shank, 30-33 degree paper strip
collated nails
Please note that values should be f.o.b., U.S. point of shipment and should not include U.S.-inland
transportation costs. Values should reflect the final net amount paid to your firm (i.e., should be net
of all deductions for discounts or rebates).
During January 2012-December 2014, did your firm produce and sell to unrelated U.S.
customers any of the above listed products (or any products that were competitive with these
products)?
Yes.--Please complete the following pricing data table(s) as appropriate.
No.--Skip to question IV-3.

The length of the duplex nail shaft is measured from the bottom of the lower shoulder to the point, rather than
from the head on top of the nail.

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IV-2a. Price data.--Report below the quarterly price data1 for pricing products2 produced and sold by
your firm.
Report quantity data in thousand count of nails (1,000 nails) for products 1-6. Report value in actual
dollars (not 1,000s).

Product 1
Quantity
Value
(1,000 nails)
(dollars)

Product 2
Quantity
Value
(1,000 nails)
(dollars)

Product 3
Quantity
Value
(1,000 nails)
(dollars)

Product 4
Quantity
Value
(1,000 nails)
(dollars)

Product 5
Quantity
Value
(1,000 nails)
(dollars)

Product 6
Quantity
Value
(1,000 nails)
(dollars)

Period of shipment
2012:
January-March
April-June
July-September
October-December
2013:
January-March
April-June
July-September
October-December
2014:
January-March
April-June
July-September
October-December
1
Net values (i.e., gross sales values less all discounts, allowances, rebates, prepaid freight, and the value of returned
goods), f.o.b. your firm’s U.S. point of shipment.
2
Pricing product definitions are provided on the first page of Part IV.

Note.--If your firm’s product does not exactly meet the product specifications but is competitive with the specified product,
provide a description of your firm’s product. Also, please explain any anomalies in your firm’s reported pricing data.

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IV-2a. Continued.
Report quantity data in actual short tons for products 7, 9, and 10, and in thousand count of nails
(1,000 nails) for products 8, 11, and 12. Report value in actual dollars (not 1,000s).

Product 7
Quantity
Value
(short tons)
(dollars)

Product 8
Quantity
Value
(1,000 nails)
(dollars)

Product 9
Quantity
Value
(short tons)
(dollars)

Product 10
Quantity
Value
(short tons)
(dollars)

Product 11
Quantity
Value
(1,000 nails)
(dollars)

Product 12
Quantity
Value
(1,000 nails)
(dollars)

IV-2b. Pricing data methodology.—Please describe the method and the kinds of documents/records
that were used to compile your price data.

Business Proprietary
U.S. Producers’ Questionnaire – Certain Steel Nails
IV-3.

Price setting.-- How does your firm determine the prices that it charges for sales of certain steel
nails (check all that apply)? If your firm issues price lists, please submit sample pages of a recent
list.
Transaction
by
transaction

IV-4.

Contracts

Other

If other, describe

Annual
total
volume
discounts

No
discount
policy

Other

Describe

Pricing terms.-(a)

What are your firm’s typical sales terms for its U.S.-produced certain steel nails?
Net 30
days

(b)

Net 60
days

2/10 net
30 days

Other

Other (specify)

On what basis are your firm’s prices of domestic certain steel nails usually quoted (check
one)?
Delivered

IV-6.

Set
price
lists

Discount policy.-- Please indicate and describe your firm’s discount policies (check all that
apply).

Quantity
discounts

IV-5.

Page 30

F.o.b.

If f.o.b., specify point

Contract versus spot.--Approximately what share of your firm’s sales of its U.S.-produced
certain steel nails in 2014 was on a (1) long-term contract basis, (2) annual contract basis, (3)
short-term contract basis, and (4) spot sales basis?

Share of your
2014 sales

Long-term
contracts
(multiple
deliveries for
more than 12
months)
%

Type of sale
Short-term
Annual
contracts
contracts
(multiple
(multiple
deliveries for
deliveries for 12
less than 12
months)
months)
%

Total
(should
sum to
100.0%)

Spot sales
(for a single
delivery)
%

0.0

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U.S. Producers’ Questionnaire – Certain Steel Nails
IV-7.

Page 31

Contract provisions.— Please fill out the table regarding your firm’s typical sales contracts for
U.S.-produced certain steel nails (or check “not applicable” if your firm does not sell on a longterm, short-term and/or annual contract basis).

Typical sales
contract provisions

Item

Average contract
duration

# of days

Short-term contracts
(multiple deliveries
for less than 12
months)

Annual contracts
(multiple
deliveries for 12
months)

Long-term contracts
(multiple deliveries for
more than 12 months)

365

Yes

Price renegotiation
(during contract
period)

No
Quantity

Fixed quantity
and/or price

Price
Both
Yes

Meet or release
provision

Not applicable
IV-8.

Lead times.--What is your firm’s share of sales both from inventory and produced to order and
what is the typical lead time between a customer’s order and the date of delivery for your firm’s
sales of its U.S.-produced certain steel nails?

Source

Share of 2014
sales

From inventory

Produced to order

Total (should sum to 100.0%)

0.0 %

Lead time (days)

Business Proprietary
U.S. Producers’ Questionnaire – Certain Steel Nails
IV-9.

Shipping information.-(a)

What is the approximate percentage of the total delivered cost of U.S.-produced certain
steel nails that is accounted for by U.S. inland transportation costs?
percent

(b)

Who generally arranges the transportation to your firm’s customers’ locations?
Your firm
Purchaser (check one)

(c)

Indicate the approximate percentage of your firm’s sales of certain steel nails that are
delivered the following distances from its production facility.
Distance from production facility

Within 100 miles

101 to 1,000 miles

Over 1,000 miles

Total (should sum to 100.0%)
V-10.

Page 32

0.0

Geographical shipments.-- In which U.S. geographic market area(s) has your firm sold its U.S.produced certain steel nails since January 1, 2012 (check all that apply)?
Geographic area
Northeast.–CT, ME, MA, NH, NJ, NY, PA, RI, and VT.
Midwest.–IL, IN, IA, KS, MI, MN, MO, NE, ND, OH, SD, and WI.
Southeast.–AL, DE, DC, FL, GA, KY, MD, MS, NC, SC, TN, VA, and WV.
Central Southwest.–AR, LA, OK, and TX.
Mountains.–AZ, CO, ID, MT, NV, NM, UT, and WY.
Pacific Coast.–CA, OR, and WA.
Other.–All other markets in the United States not previously listed,
including AK, HI, PR, and VI, among others.

√ if applicable

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IV-11. End uses.--List the end uses of the certain steel nails that your firm manufactures. For each enduse product, what percentage of the total cost is accounted for by certain steel nails and other
inputs?
Share of total cost of end use product
accounted for by
End use product

Certain steel nails

Total
(should sum to
100.0% across)

Other inputs

0.0 %

IV-12. Substitutes.-- Can other products be substituted for certain steel nails?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the prices of this
substitute affected the price for certain
steel nails?
No Yes

Explanation

1.
2.
3.
IV-13. Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for certain steel nails has changed since January 1, 2012. Explain any trends
and describe the principal factors that have affected these changes in demand.

Market
Within
the United
States
Outside
the United
States

Overall
increase

No
Overall
change decrease

Fluctuate
with no
clear trend

Explanation and factors

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IV-14. Product changes.--Have there been any significant changes in the product range, product mix,
or marketing of certain steel nails since January 1, 2012?
No

Yes

If yes, please describe and quantify if possible.

IV-15. Conditions of competition.-(a) Is the certain steel nails market subject to business cycles (other than general economywide conditions) and/or other conditions of competition distinctive to certain steel nails?
If yes, describe.
Check all that apply.

Please describe.

Skip to question IV-16.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b) If yes, have there been any changes in the business cycles or conditions of competition for
certain steel nails since January 1, 2012?
No

Yes

If yes, describe.

IV-16. Supply constraints.--Has your firm refused, declined, or been unable to supply certain steel nails
since January 1, 2012 (examples include placing customers on allocation or “controlled order
entry,” declining to accept new customers or renew existing customers, delivering less than the
quantity promised, been unable to meet timely shipment commitments, etc.)?
No

Yes

If yes, please describe.

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IV-17. Raw materials.--How have certain steel nails raw materials prices changed since January 1,
2012?

Overall
increase

Fluctuate
with no Explain, noting how raw material price changes
clear
have affected your firm’s selling prices for certain
No
Overall
change decrease
trend
steel nails.

IV-18. Private labeling.-(a) Have your firm’s customers requested private labeled certain steel nails since January 1,
2012?

Yes

Share of 2014 U.S. commercial
shipments of U.S. produced
certain steel nails that were
private labeled
%

(b) Has your firm refused, declined, or been unable to supply its customers’ private labeling
requests for certain steel nails since January 1, 2012?
No

Yes

If yes, please describe.

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IV-19. Interchangeability.--Are certain steel nails produced in the United States and in other countries
interchangeable (i.e., can they physically be used in the same applications)?
Please indicate A, F, S, N, or 0 in the table below:
A = the products from a specified country-pair are always interchangeable
F = the products are frequently interchangeable
S = the products are sometimes interchangeable
N = the products are never interchangeable
0 = no familiarity with products from a specified country-pair

Country-pair

Korea

Malaysia

Oman

Taiwan

Vietnam

China

Other
countries

United States
Korea
Malaysia
Oman
Taiwan
Vietnam
China
For any country-pair producing certain steel nails that is sometimes or never interchangeable,
identify the country-pair and explain the factors that limit or preclude interchangeable use:

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IV-20. Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between certain steel nails
produced in the United States and in other countries a significant factor in your firm’s sales of
the products?
Please indicate A, F, S, N, or 0 in the table below:
A = such differences are always significant
F = such differences are frequently significant
S = such differences are sometimes significant
N = such differences are never significant
0 = no familiarity with products from a specified country-pair

Country-pair

Korea

Malaysia

Oman

Taiwan

Vietnam

China

Other
countries

United States
Korea
Malaysia
Oman
Taiwan
Vietnam
China
For any country-pair for which factors other than price always or frequently are a significant factor
in your firm’s sales of certain steel nails, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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IV-21. Customer identification.-- List the names and contact information for your firm’s 10 largest U.S.
customers for certain steel nails since January 1, 2012. Indicate the share of the quantity of your
firm’s total shipments of certain steel nails that each of these customers accounted for in 2014.

Customer’s name

1
2
3
4
5
6
7
8
9
10

City

State

Share of 2014
sales (%)

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IV-22. Competition from imports.-(a)

Lost revenue.--Since January 1, 2012: To avoid losing sales to competitors selling
subject product from Korea, Malaysia, Oman, Taiwan, and Vietnam, did your firm:
No

Yes

Reduce prices
Roll back announced price increases
(b)

Lost sales.--Since January 1, 2012: Did your firm lose sales of subject product to imports
of this product from Korea, Malaysia, Oman, Taiwan, and Vietnam?
No

(c)

Yes

The submission of lost sales/lost revenue allegations is to be completed only by NONPETITIONERS. (Note: petitioners may provide allegations involving quotes made
AFTER the filing of the petition.) Please do not resubmit allegations provided
previously.
If you indicated “yes” to any of the above, you can provide the Commission with
additional information by downloading and completing the lost sales/lost revenues
worksheet at http://usitc.gov/trade_remedy/question.htm. Note that the Commission
may contact the firms named to verify the allegations reported.
Is your firm submitting the lost sales/lost revenues worksheet?
No—Please explain.
Yes—Please complete the worksheet and submit via the Commission dropbox.
https://dropbox.usitc.gov/oinv/. (PIN: NAIL)

IV-23. Other explanations.-- If your firm would like to further explain a response to a question in Part
IV that did not provide a narrative response box, 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.

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Page 40

HOW TO FILE YOUR QUESTIONNAIRE RESPONSE
This questionnaire is available as a “fillable” form in MS Word format on the
Commission’s website at:
http://www.usitc.gov/investigations/701731/2014/certain_steel_nails_korea_malaysia_
oman_taiwan_and/final.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: NAIL
• E-mail.—E-mail your questionnaire to [email protected]; include a scanned copy of the
signed certification page (page 1). Please note that submitting your questionnaire by e-mail may

subject your firm’s business proprietary information to transmission over an unsecure environment and
to possible disclosure. If you choose this option, the Commission warns you that any risk involving
possible disclosure of such information is assumed by the submitter and not by the Commission.

If your firm does not produce 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 (202-205-1803). 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.

File Type	application/pdf
File Title	US producer questionnaire
Subject	Title 7 investigations
Author	USITC
File Modified	2015-02-19
File Created	2015-02-19