Opinion and Order
MALETZ, Judge:
This matter is before the court on defendant's motion to dismiss the complaint. Plaintiff Cheng Shin Rubber Industry Company, Ltd. (Cheng Shin) is a Taiwanese manufacturer of bicycle tires and tubes subject to a countervailing duty order issued on February 17, 1982. 47 Fed.Reg. 6913. In the present action Cheng Shin challenges the final affirmative determination by the International Trade Administration of the Department...
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