PLEASE TAKE NOTICE that, pursuant to Rule 75(c) of the Rules of the United States Court of International Trade, the undersigned, Emma Bond, has been substituted as attorney of record for all defendants in this action in place of Elizabeth Speck.

Dated: March 6, 2024

The individual attorney in the Government who is responsible for the litigation is Emma E. Bond.

Respectfully Submitted,

Trial Attorney U.S. Department of Justice Civil Division P.O.

Pursuant to paragraph 4(d)(i) of the Court’s Administrative Order No. 02-01 and United States Court of International Trade (USCIT R.) Rule 7(b), defendants, the United States et al., respectfully submit this consent motion for errata to correct the following minor citation errors in Defendants’ Motion to Dismiss, or, Alternatively, Motion for Judgment on the Agency Record, ECF No. 314, filed on June 1, 2021 (Def.

On October 5, 2021, Matthew Nicely consented to this motion on behalf of the plaintiffs’ steering committee.

For these reasons, we respectfully request that the Court grant this motion to correct minor errors in our briefs and replace the as-corrected version of page 38 of our opening brief (ECF No. 314), and page 18 of our reply (ECF No. 412), with the attached corrected versions.

Trial Attorney Commercial Litigation Branch Civil Division Department of Justice P.O.

Trial Attorneys Commercial Litigation Branch Civil Division Department of Justice P.O.

Before: Mark A. Barnett, Claire R. Kelly and Jennifer Choe-Groves, Judges Court No. 21-00052

Notwithstanding the Preliminary Injunction and Temporary Restraining

Order entered by this court on July 6, 2021 (ECF No. 330) (“Preliminary Injunction”), as amended, and recognizing the joint and separate status reports provided by Defendants and Plaintiffs (ECF Nos. 343, 345, 354, 355, 365, 393, 395, and 406), the joint status conferences held by the court (ECF Nos. 334, 350, 356, and 398), and the representations of the Parties made therein, it is hereby: ORDERED that, in light of Defendants’ representation to the Court that it must accept the option to stipulate to refund any duties found to have been illegally collected for all Subject Entries (as that term is defined in the Preliminary Injunction), Defendants shall liquidate those entries in the ordinary course and, should the Court find that the List 3 and/or List 4A duties have been illegally collected, and should that decision become final and conclusive, including all appeals, Defendants shall reliquidate any Subject Entry in accordance with a final court decision in this case without the assessment of List 3 and List 4A duties or otherwise refund to Plaintiffs such duties, with interest, as provided by law.

Page 2 only apply to entries that were unliquidated at the time of the Preliminary Injunction, and to entries entered on or after July 6, 2021; it is further ORDERED that the requirement for Defendants to establish a repository, as contained in the fifth ORDERED paragraph of the Preliminary Injunction, is hereby VACATED; and it is further ORDERED that the Temporary Restraining Order issued in the eighth ORDERED paragraph of the Preliminary Injunction, as amended, is hereby

This Order is without prejudice to the issue of whether, in the event the List 3 and/or List 4A duties are found to have been illegally collected, refunds will be limited to Plaintiffs in the Section 301 Cases that are the importers of record who paid the List 3 and/or List 4A duties.

Case No. 21-00052 ::: In Re Section 301 Cases

Having considered Motion to Withdraw as Counsel of Record and Terminate ECF Notifications for Melissa L. Duffy and Jean Chang for plaintiffs Terex Global GmbH, Terex USA, LLC, Terex South Dakota, Inc., Genie Industries, Powerscreen USA, LLC, Sealed Air Corporation, Austin Foam Plastics, Inc., Fagerdala Packaging, Inc. (Indiana), Gatekeeper Systems, Inc., Mercer Foods, LLC, Myers Emergency Power Systems, LLC, VPET USA, Inc., Multy Home LP, Global Industries, Inc., Global Upholstery Co., Inc., and Teknion Limited (all plaintiffs collectively, “Plaintiffs”), the Court hereby GRANTS said Motion.

It is therefore ORDERED that Melissa L. Duffy and Jean Chang are withdrawn as counsel for Plaintiffs, and relieved of any further responsibility to act as counsel for Plaintiffs in this action.

It is further ORDERED that Melissa L. Duffy and Jean Chang shall be removed from the electronic service list in this case.

Hon.

Before: Mark A. Barnett, Claire R. Kelly and Jennifer Choe-Groves, Judges Court No. 21-00052

Upon consideration of the Joint Status Report filed on August 9, 2021, see ECF

No. 365, it is ORDERED that Defendants’ time to establish a repository is extended from August 20, 2021 to September 3, 2021; and it is further ORDERED that Defendants’ and Plaintiffs’ time to submit additional proposed modifications to the preliminary injunction ordered on July 6, 2021, ECF No. 330 (the “Preliminary Injunction Order”), is extended from August 20, 2021 to September 3, 2021; and it is further ORDERED that the temporary restraint period established by the Preliminary Injunction Order and modified by the court’s Order dated July 20, 2021, see ECF No. 344, is extended from September 2, 2021 to October 4, 2021.