Zhejiang Dingli Machinery Co. v. United States

What happened

Zhejiang Dingli Machinery Co. v. United States, No. 1:24-cv-00221-MMB, is a challenge by a Chinese producer to the first administrative review of the antidumping order on mobile access equipment from China. Dingli contested the Department of Commerce's choice of Turkey as the primary surrogate country, arguing in part that Turkish data were distorted by hyperinflation. Its counsel of record was Grunfeld, Desiderio, Lebowitz, Silverman & Klestadt LLP.

Dingli's corrected opening brief, ECF 52, said Commerce had disregarded the de-dollarization of the Turkish economy, "which was recognized by Commerce in the Canadian AD investigation on Turkish rebar." It went on to say that the record "does not contain any information contradicting Commerce's factual findings in the Canadian investigation." The Canadian proceeding was conducted by the Canadian government under Canadian law.

The court found that neither statement cited any evidence, record or otherwise, and that the brief did not explain what role the U.S. agency supposedly played in a foreign investigation. The one citation offered was to Dingli's own administrative case brief, and the court noted that "A case brief is not evidence, and the case brief itself makes no mention of any involvement by Commerce."

What the court did

On September 22, Judge M. Miller Baker issued an order to show cause, ECF 58. Its central sentence reads: "The statements quoted above are so outlandish as to appear to be the product of hallucination, either by a human being or by artificial intelligence." The order is framed as a question, not a finding. It directed that:

• within 14 days, Dingli file a statement substantiating, with evidence, that Commerce participated and made factual findings in the Canadian investigation, and explaining the agency's role;
• if it could not, Dingli show cause why the court should not sanction it, its counsel or both for violating USCIT Rule 11(b)(3), citing also Rule 11(c)(1);
• in that case, it also submit declarations explaining "who (or what, including artificial intelligence or other software program) participated in writing and editing the brief," including who or what wrote the quoted statements, covering employees of both Dingli and its counsel.

The next day the court issued Slip Op. 26-119, ECF 59, which denied Dingli's motion for judgment on the agency record and sustained Commerce's determination in both related cases, Nos. 24-219 and 24-221. On the Canadian argument, the opinion said: "Bizarrely, Dingli injects an argument about the Canadian government's antidumping investigation of Turkish rebar." It held that Commerce reasonably deemed the foreign analysis irrelevant. The opinion does not mention the show-cause order.

Where it stands

Zhejiang Dingli is pending on the show-cause question. The response was due within 14 days of the order, around October 6. Law360 reported on October 7 that counsel told the court the errors were mistakes and did not involve AI; this record has not read that filing, so the account is reported, not confirmed.

No ruling on the order had been located as of October 21. The court has not found that AI was used, that anyone acted improperly, or that Rule 11 was violated. The merits judgment is separate, and any appeal from it was not located.

The obligation it engaged

Clause 4 of the Standard, checkability before adoption, is the clause Zhejiang Dingli engages first: a factual claim about what an agency found must be traceable to a page of the record before it goes into a filing. Clause 7, contemporaneous record, and Clause 8, disclosure, describe what the court asked for, an account of who or what wrote each passage. These clauses are mapped to the conduct the order describes; the matter is unresolved and no wrongdoing has been found.

The lesson for an expert witness is specific. Experts in trade cases often characterize findings by agencies at home and abroad. Each such statement should cite the determination and page it comes from, and the expert should be able to say, from a drafting log, who wrote the sentence and whether any software contributed to it.

Sources

• U.S. Court of International Trade (copy hosted for the AI Hallucination Cases database) · September 22, 2026
  Order to Show Cause, ECF 58, No. 24-00221-MMB
• U.S. Court of International Trade · September 23, 2026
  Slip Op. 26-119, Coalition of American Manufacturers of Mobile Access Equipment v. United States and Zhejiang Dingli Machinery Co. v. United States, Nos. 24-00219, 24-00221 (ECF 59)

What could not be confirmed

Counsel's show-cause response was not opened; its content (errors were mistakes, not AI) is as reported by Law360 on 2026-10-07, and the Law360 article itself was not opened. No ruling on the order to show cause was located as of 2026-10-21. The response deadline of about October 6 is computed from the order's 14-day period. The Law360 report is not listed as a source because its URL was not located.