OPINION
GORDON, Judge.
Plaintiffs commenced this action to challenge as unlawful the liquidation instructions issued by the United States Department of Commerce ("Commerce") pursuant to the final results of an administrative review of an antidumping duty order and to void the resulting liquidations. Defendant moves to dismiss for lack of subject matter jurisdiction pursuant to USCIT R. 12(b)(1) or for failure to state a claim upon which relief can be granted...
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