ITWTF Americas
June, 2003 - ITWTF Americas
Re: Petition by IIMAK to US Government to Investigate Potential Foreign Violation of Trade Laws.
For Our Valued Customer,
On May 30th, IIMAK filed a request (a "petition") with the U.S. government seeking an investigation into IIMAK's allegations that manufacturers in Japan, South Korea, and France of thermal transfer ribbon ("TTR") products are unfairly pricing -- "dumping" -- sales of TTR in the United States. Since the investigation is just beginning and much of the information is still being communicated to all parties involved, we wanted to share the following information regarding the investigation.
We at ITW believe that we are fairly pricing our sales of TTR in the United States and all other marketplaces throughout the world. We are selling our TTR profitably and above our costs in the United States and all other countries around the world. In the event this investigation continues, we hope to have the opportunity to demonstrate these facts and rebut IIMAK's claims, even though we understand that the U.S. antidumping law and these types of proceedings are very complex, and IIMAK's action may have an impact on the marketplace.
The first stage of the proceeding is an investigation by the U.S. International Trade Commission ("ITC") into IIMAK's claims that the U.S. TTR industry is harmed by the imports from France, Japan, and Korea. Many companies, including importers and producers, will be required to answer lengthy questionnaires from the ITC and there will be a hearing at the ITC later this month. By early July, the ITC will decide whether to terminate the case or allow it to proceed to a next phase of investigation. If it proceeds, the U.S. Department of Commerce ("DOC") will investigate whether the imports from Japan, Korea, and France are priced unfairly. If the case reaches that stage, we will of course make every effort to show that ITW's sales practices are fair, although we understand that the DOC procedures and calculation methods are very complicated and its investigation would last several months.
You should also understand that if IIMAK's case results in a finding of injury by the ITC and a finding of dumping by the DOC, any possible liability to pay "antidumping duties" on the imports would be borne by importers and would apply only to future imports. Moreover, you should understand that such antidumping relief will not necessarily require that importers change their U.S. prices.
Once again, we believe that we are selling at fair prices in the United States and all of our markets. We will fully commit the resources of our organization to fulfill our requirements in the investigation, and we will continue to share information that we feel is important to you, our customers and distribution partners. The service and performance of our organization will not be affected by this information gathering process.
We will continue to offer competitive and fairly priced products to your team in the interests of ensuring profitable growth for your organization in the TTR marketplace.
With Regards,
Peter Gallette
General Manager
ITW Thermal Films - The Americas
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