16-3-3614 U.S. Purchasers' Questionnaire

OMB No. 3117-0016/USITC No. 16-3-3614; Expiration Date: 6/30/2017
(No response is required if currently valid OMB control number is not displayed)

U.S. PURCHASERS’ QUESTIONNAIRE
1-HYDROXYETHYLIDENE-1, 1-DIPHOSPHONIC ACID FROM CHINA
This questionnaire must be received by the Commission by JANUARY 17, 2017
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 1-hydroxyethylidene-1,
1-diphosphonic acid (“HEDP”) from China (Inv. Nos. 701-TA-558 and 731-TA-1316 (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)). Further information on this questionnaire can be obtained from Aimee Larsen
(202-205-3179, [email protected]).

Name of firm
Address
City

State

Zip Code

Website
Has your firm purchased HEDP (as defined on next page) from any source (domestic or foreign) at any time since
January 1, 2014?

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 U.S. International Trade Commission Drop Box by clicking on the
following link: https://dropbox.usitc.gov/oinv/. (PIN: HEDP)
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
submitting 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

Phone:
Signature

Email address

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U.S. Purchasers’ Questionnaire - HEDP

Page 2

PART I.—GENERAL INFORMATION
Background.--This proceeding was instituted in response to a petition filed on March 31, 2016, by
Compass Chemical International LLC, Smyrna, GA. 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 makes
an affirmative determination of subsidization and dumping. Questionnaires and other information
pertinent to this proceeding are available at:
http://www.usitc.gov/investigations/701731/2016/1_hydroxyethylidene_1_1_diphosphonic_acid_china
/final.htm
HEDP.-- The product covered by these investigations include all grades of aqueous, acidic (non–
neutralized) concentrations of 1–hydroxyethylidene–1,1–diphosphonic acid (“HEDP”), also referred to as
hydroxethlylidenendiphosphonic acid, hydroxyethanediphosphonic acid, acetodiphosphonic acid, and
etidronic acid. The CAS (Chemical Abstract Service) registry number for HEDP is 2809–21–4.
The merchandise subject to this investigation is currently classified in the Harmonized Tariff Schedule of
the United States (HTSUS) at subheading 2931.90.90. Merchandise covered by the scope may also be
imported under HTSUS subheadings 2811.19.6090, 2931.00.9043, 2931.90.9041, and 2931.90.9047.
While HTSUS subheadings are provided for convenience and customs purposes only, the written
description of the scope of this 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.
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. Purchasers’ Questionnaire - HEDP
I-1.

Page 3

OMB statistics.--Please report 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
25 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 your U.S. establishment(s) covered
by this questionnaire, if different from that listed on the cover page. 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 purchase of HEDP, including auxiliary
facilities operated in conjunction with (whether or not physically separate from) such facilities.

I-3.

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

Yes--List the following information.
Address

Extent of ownership
(percent)

Business Proprietary
U.S. Purchasers’ Questionnaire - HEDP
I-4.

Related SUBJECT importers/exporters.--Does your firm have any related firms, either domestic
or foreign, which import HEDP from China into the United States or which export HEDP from
China to the United States?
No

Yes--List the following information.

Firm name

I-5.

Address

Affiliation

Related NONSUBJECT importers/exporters.--Does your firm have any related firms, either
domestic or foreign, which import HEDP from countries other than China into the United States
or which export HEDP from countries other than China to the United States?
No

Yes--List the following information.

Firm name and country

I-6.

Page 4

Address

Affiliation

Related producers.--Does your firm have any related firms, either domestic or foreign, which
produce HEDP?
No
Firm name

Yes--List the following information.
Address

Affiliation

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U.S. Purchasers’ Questionnaire - HEDP

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PART II.--PURCHASES
Contact information.-- Please identify the responsible individual and the manner by which Commission
staff may contact that individual regarding the confidential information submitted in this questionnaire.
Name
Title
Email
Telephone
Fax
Purchases.— Report your firm’s total U.S. purchases of HEDP. (Do not include imports for which
your firm was the importer of record; such imports should be reported in your U.S. importer’s
questionnaire.)

II-1.

Item

2014

2015

2016

Quantity (in pounds)
Purchases of HEDP produced in-United States
China
All other countries1
Sources unknown
Total purchases
1

II-2.

0

0

Please identify these countries:

Changes in purchasing patterns.--Please indicate how the shares of your firm’s purchases of
HEDP from different sources have changed since January 1, 2014.

Source of
purchases
United States
China
All other countries
Sources unknown

Did not
purchase Decreased Increased Constant Fluctuated

Explanation for trend

0

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II-3.

Purchases from one country only.--If your firm has purchased HEDP from only one country,
please explain the reasons for doing so.

II-4.

Supplier identification.--Please list your firm’s FIVE largest suppliers for HEDP since January 1,
2014. Also, provide the share of the quantity of your firm’s total purchases of HEDP that each of
these suppliers accounted for in 2016.

No.

Supplier’s name

City and state

Share of quantity of
2016 purchases

1

%

2

%

3

%

4

%

5

%

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PART III.--MARKET CHARACTERISTICS AND PURCHASING PRACTICES
III-1.

Firm type.--Which of the following best describes your firm as a purchaser of HEDP (check all
that apply)?
End user

Compounder/
formulator

Distributor

Other

Describe other

If your firm is a distributor of HEDP, please answer questions III-2 and III-3.
III-2.

Competition for sales.--Does your firm compete for sales to customers with the manufacturers
or importers from which your firm purchases HEDP?
No

III-3.

Yes

If yes, please describe.

Types of customers.--What are the major types of consumers to which your firm sells HEDP?

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If your firm is an end user of HEDP, please answer questions III-4 and III-5.
III-4.

End uses.--List the top 3 products your firm makes using HEDP and estimate the percent of your
total production cost that is accounted for by HEDP and by other inputs (such as labor, energy,
and other raw materials).
Share of total cost in each of the product(s) your
firm produces accounted for by
Product(s) your firm
produces

III-5.

HEDP

Total
(should
sum to
100.0%
across)

Other inputs
% +

%

=

0.0 %

% +

%

=

0.0 %

% +

%

=

0.0 %

Demand for end use products.-(a)

Has the demand for your firm’s final products incorporating HEDP changed since
January 1, 2014?
Increased

(b)

No change

Decreased

Fluctuated

Has this had any effect on your firm’s demand for HEDP?
No

Yes

Explain

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U.S. Purchasers’ Questionnaire - HEDP
III-6.

Page 9

Substitutes.--Can other products be substituted for HEDP?
No

Substitute

Yes--Please fill out the table.

End use in which this
substitute is used

Have changes in the price of this substitute
affected the price for HEDP?
No Yes

Explanation

1.
2.
3.
III-7.

Demand trends.-- Indicate how demand within the United States and outside of the United
States (if known) for HEDP has changed since January 1, 2014. Explain any trends and describe
the principal factors that have affected these changes in demand.

Market

Overall
increase

No
change

Fluctuate
Overall
with no
decrease clear trend

Explanation and factors

Within the United
States
Outside the United
States
III-8.

Importance of purchasing domestic product.--Please fill out the table below, estimating the
percentage of your firm’s total 2016 purchases of HEDP that required HEDP produced in the
United States.

Purchases that did not require domestic product
Purchases that were required by law or regulation to be domestic product
(e.g., government purchases under “Buy American” provisions)
Purchases that were not required by law or regulation, but were required by
your customers to be domestic product
Purchases that were required to be domestic product for other reasons
(explain:
)
Total (should sum to 100.0%)

Estimated percentage of
your firm’s total 2016
purchases of HEDP
%
%
%
%
0.0 %

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U.S. Purchasers’ Questionnaire - HEDP
III-9.

Page 10

Conditions of competition.-(a)

Is the HEDP market subject to business cycles (other than general economy-wide
conditions) and/or other conditions of competition distinctive to HEDP?

Check all that apply.

Please describe.

No

Skip to question III-10.

Yes-Business cycles (e.g.
seasonal business)
Yes-Other distinctive
conditions of competition
(b)

Have there been any changes in the business cycles or conditions of competition for
HEDP since January 1, 2014?
No

Yes

If yes, describe.

III-10. Decisions based on producer and country-of-origin.--How often does your firm, and if known,
do your customers, make purchasing decisions involving HEDP based on its producer or country
of origin?
Always

Usually

Sometimes

Never

Decision based on producer
Your firm
Your customers
Decision based on country of origin
Your firm
Your customers

If at least sometimes, explain.

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III-11. Availability of supply.--Has the availability of HEDP in the U.S. market changed since January 1,
2014?
Availability in the U.S.
Please explain, noting the countries and reasons for the
market
No Yes changes.
U.S.-produced product
Subject imports
Nonsubject imports
III-12. Supply constraints.--Has any firm refused, declined, or been unable to supply your firm with
HEDP since January 1, 2014 (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.

III-13. Purchasing frequency.-(a)

How frequently does your firm make purchases of HEDP (check one)?
Daily

(b)

Weekly

Monthly

Quarterly

Annually

Other

If other, specify

Has this purchasing frequency changed since January 1, 2014?
No

Yes

If yes, please describe.

III-14. Number of suppliers contacted.--How many suppliers does your firm generally contact before
making a purchase? Between
and
firms
III-15. Supplier negotiations.--Does your firm’s purchases of HEDP usually involve negotiations
between supplier and purchaser?

No

Yes

If yes, explain the factors your firm generally negotiates and note
whether your firm quotes competing prices during negotiations.

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III-16. Change in suppliers.--Has your firm changed suppliers since January 1, 2014?

No

Yes

If yes, please list the supplier(s), whether the firm was added or
dropped, and the reasons for the change.

III-17. New suppliers.--Are you aware of any new suppliers, either foreign or domestic, that have
entered the market since January 1, 2014?
No

Yes

If yes, please identify the firms.

III-18. Supplier qualification.--Do you require your suppliers to be or to become certified or qualified
to sell HEDP to your firm?
If yes, provide the following information.
• The number of days to qualify a new supplier.
• A general description of the certification or qualification process. Also, a brief
description of the factors that you consider when qualifying a new supplier (e.g., quality
of product, reliability of supplier, etc.).

No

Yes

Number
of days Process and factors

III-19. Failure to certify.--Since January 1, 2014, have any domestic or foreign producers failed in their
attempts to certify or qualify their HEDP with your firm or have any producers lost their
approved status?

No

Yes

If yes, please identify these firms, the countries where they are located,
and the reasons why they failed the certification/qualification.

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III-20. Major purchasing factors.--Please list, in order of their importance, the main factors your firm
considers in deciding from whom to purchase HEDP (examples include availability, extension of
credit, contracts, price, quality, range of supplier’s product line, traditional supplier, etc.).
1.
2.
3.
Please list any other factors that are very important in your purchase decisions:
III-21. Purchasing factors.--Please rate the importance of the following factors in your firm’s
purchasing decisions for HEDP.

Factor

Very
important

Somewhat
important

Not
important

Availability
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Packaging
Price
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs
III-22. Quality characteristics.--What characteristics does your firm consider when determining the
quality of HEDP?

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III-23. Frequency of decisions based on price.--How often does your firm purchase the HEDP that is
offered at the lowest price?
Always

Usually

Sometimes

Never

III-24. Price leaders.— A price leader is defined as (1) one or more firms that initiate a price change,
either upward or downward, that is followed by other firms, or (2) one or more firms that have a
significant impact on prices. A price leader is not necessarily the lowest-priced supplier.
Please list the names of any firms you considered price leaders in the HEDP market since
January 1, 2014.
Firm(s)

Describe how the firm(s) exhibited price leadership

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III-25. Purchasing subject imports rather than domestic products.—
(a)

Since January 2014, did your firm purchase imports of HEDP from China instead of U.S.produced HEDP?
Yes
(also respond to parts (b) and (c))

(b)

No
(If “No”, skip to next question)

If you responded “Yes” to part (a), was the imported product priced lower than the
domestic product?
Yes

(c)

No

If you responded “Yes” to part (a), was price a primary reason for purchasing subject
imports rather than domestic product?

Yes

If Yes, estimate the quantity
of Chinese imports purchased
instead of domestic product
since January 2014
(in pounds)

No

If No, please indicate the
reason your firm purchased
Chinese imports instead of
domestic product

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III-26. U.S. producers and import competition.—
(a)

Since January 1, 2014, in connection with a sale or offer to sell HEDP to your firm, did
U.S. producers reduce their prices of domestically produced HEDP in order to compete
with lower-priced imports of HEDP from China?
Yes (also respond to
question part (b))

(b)

No (If “No”, skip to next
question)

Don’t know

If your firm responded “yes”, please provide an estimate of the reduction in U.S.
producers’ prices, and any additional explanations, such as timing (e.g., months/years),
frequency of price reductions, or other market/competitive factors.
Estimated
reduction in U.S.
prices
(percent)
%

Additional explanation, including such information as
timing (e.g., months/years), frequency of price
reductions, or other market/competitive factors

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PART IV.—PRODUCT COMPARISONS
IV-1.

Country knowledge.--Please indicate the countries of origin for HEDP for which your firm has
actual marketing/pricing knowledge.
United
States

IV-2.

China

India

Other
countries

Other countries (specify)

Interchangeability.--Is HEDP 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

China

India

Other countries

United States
China
India
For any country-pair producing HEDP that is sometimes or never interchangeable, identify the
country-pair and explain the factors that limit or preclude interchangeable use:

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U.S. Purchasers’ Questionnaire - HEDP
IV-3.

Page 18

Factors other than price.--Are differences other than price (e.g., quality, availability,
transportation network, product range, technical support, etc.) between HEDP produced in the
United States and in other countries a significant factor in your firm’s purchases 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

China

India

Other countries

United States
China
India
For any country-pair for which factors other than price always or frequently are a significant
factor in your firm’s sales of HEDP, identify the country-pair and report the advantages or
disadvantages imparted by such factors:

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U.S. Purchasers’ Questionnaire - HEDP
IV-4.

Country preferences.--Do you or your customers ever specifically order HEDP from one country
in particular over other possible sources of supply?
No

IV-5.

Yes

If yes, identify the countries and explain.

Availability of merchandise.--Are certain grades/types/sizes of HEDP only available from certain
country sources?
No

IV-6.

Page 19

Yes

If yes, please identify the countries and the grade/type/size.

Choice of product not based on price.--If you purchased HEDP from one country source
although a comparable product was available from another country source at a lower price,
please explain your reasons for doing so (please specify by country).

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U.S. Purchasers’ Questionnaire - HEDP
IV-7.

Page 20

Factor country comparisons.--For the factors listed below, please rate how HEDP produced in
each country you identified in your response to the first question in Part IV compares with HEDP
produced in each of the other countries you identified.

If you are unfamiliar with the product from a particular country, please leave the boxes for those
country comparisons blank.

Inferior

Comparable

Superior

Inferior

Comparable

Superior

Inferior

Comparable

Factor

Superior

HEDP from
HEDP from
HEDP from
United States
United States
United States
compared to HEDP compared to HEDP compared to HEDP
from
from
from
China
India
All Other Sources

Availability
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Packaging
Price1
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs1
1

A rating of superior on price and U.S. transportation costs indicates that the first country generally has lower
prices/U.S. transportation costs than the second country.

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Factor country comparisons.—Continued.

Inferior

HEDP from
China compared to
HEDP from
All Other Sources
Comparable

Inferior

Comparable

Factor

Superior

HEDP from
China
compared to
HEDP from
India

Superior

IV-7.

Availability
Delivery terms
Delivery time
Discounts offered
Extension of credit
Minimum quantity requirements
Packaging
Price1
Product consistency
Product range
Quality meets industry standards
Quality exceeds industry standards
Reliability of supply
Technical support/service
U.S. transportation costs1
1

A rating of superior on price and U.S. transportation costs indicates that the first country
generally has lower prices/U.S. transportation costs than the second country.

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U.S. Purchasers’ Questionnaire - HEDP
IV-8.

Page 22

Minimum quality.--How often does HEDP from the following countries meet minimum quality
specifications for your uses or your customers’ uses?

Source

Always

Usually

Sometimes

Rarely or
never

Don’t
know

United States
China
India
Other:
IV-9.

Other explanations.--If your firm would like to further explain a response to any question that
did not provide a narrative response box, please note the question number and the explanation
in the space provided below.

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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: LINK
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: XXXX

• E-mail.—E-mail the MS Word questionnaire to [email protected]; 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 does not purchase 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, it is 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 your firm submits (see
19 CFR § 207.7). Service of the questionnaire must be made in paper form.