OPINION
WALLACH, Judge.
I
PRELIMINARY STATEMENT
This is a civil penalties case in which the plaintiff United States (the "Government") alleges that defendants Owatonna Recognition, Inc. ("Owatonna") and Lin Mei Co. ("Lin Mei") participated in a double-invoicing system that caused merchandise to be entered or introduced into the United States by means of material and false documents, resulting in the undervaluation of imported lapel...
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