MEMORANDUM OPINION
MUSGRAVE, Judge.
Plaintiff Saha Thai Steel Pipe Co., Ltd. ("Saha") challenges two aspects of the final determination by the International Trade Administration, United States Department of Commerce (the "ITA" or the "Department" or "Commerce"), in the 1988 countervailing duty administrative review ("1988 Review") involving carbon steel pipes and tubes from Thailand. See Certain Circular Welded Carbon Steel Pipes and Tubes from Thailand...
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