OPINION
GORDON, Judge:
In this action Plaintiff, Sears Holdings Management Corp., challenges the classification of imported merchandise within the Harmonized Tariff Schedule of the United States ("HTSUS") by U.S. Customs and Border Protection ("Customs"). Defendant moves to dismiss pursuant USCIT Rule 12(b)(1) for lack of subject matter jurisdiction, contending that Plaintiff failed to timely commence its action "within one hundred and eighty days after...
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