MEMORANDUM OPINION
ROSEMARY M. COLLYER, District Judge.
In approximately 1989, various U.S. producers of ferrosilicon, a material used in making steel, entered into an illegal price fixing arrangement for domestic sales. Some of these producers then petitioned the International Trade Commission ("ITC") to impose import tariffs on foreign ferrosilicon for alleged unfair "dumping" of those products at low...
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