# Cold-Rolled Carbon Steel Flat Products From the Netherlands: Preliminary Results of Antidumping Duty Administrative Review

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## Record

- **Collection:** Federal Register
- **Document type:** Notice
- **Published:** September 4, 1998
- **Citation:** 63 FR 47227

## Text

DEPARTMENT OF COMMERCE

International Trade Administration
[A-421-804]

Cold-Rolled Carbon Steel Flat Products From the Netherlands:
Preliminary Results of Antidumping Duty Administrative Review

AGENCY: Import Administration, International Trade Administration,
Department of Commerce.

[[Page 47228]]

ACTION: Notice of preliminary results of antidumping duty
administrative review.

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SUMMARY: In response to requests from the petitioners and respondent,
the Department of Commerce (the Department) is conducting an
administrative review of the antidumping duty order on cold-rolled
carbon steel flat products from the Netherlands. The review covers one
manufacturer/exporter of the subject merchandise to the United States
and the period August 1, 1996 through July 31, 1997.
We have preliminarily determined that respondent has made sales
below normal value during the period of review. If these preliminary
results are adopted in our final results of review, we will instruct
the U.S. Customs Service to assess antidumping duties on all
appropriate entries.
Interested parties are invited to comment on these preliminary
results. Parties who submit argument in this proceeding are requested
to submit with the argument (1) a statement of the issue and (2) a
brief summary of the argument (no longer than five pages, including
footnotes).

EFFECTIVE DATE: September 4, 1998.

FOR FURTHER INFORMATION CONTACT: Helen M. Kramer or Linda Ludwig,
Import Administration, International Trade Administration, U.S.
Department of Commerce, 14th Street and Constitution Avenue, N.W.,
Washington, D.C. 20230; telephone (202) 482-0405 or 482-3833,
respectively.

APPLICABLE STATUTE: Unless otherwise indicated, all citations to the
Trade and Tariff Act of 1930, as amended (the Act) are references to
the provisions effective January 1, 1995, the effective date of the
amendments made to the Act by the Uruguay Round Agreements Act of 1994
(URAA). In addition, unless otherwise indicated, all references to the
Department's regulations are to 19 CFR Part 351 (1998).

SUPPLEMENTARY INFORMATION:

Background

The Department of Commerce published an antidumping duty order on
cold-rolled carbon steel flat products from the Netherlands on August
19, 1993 (58 FR 44172). The Department published a notice of
``Opportunity To Request Administrative Review'' of the antidumping
duty order for the 1996/1997 review period on August 4, 1997 (62 FR
41925). On August 29, 1997, both the respondent, Hoogovens Staal BV,
and petitioners (Bethlehem Steel Corporation, U.S. Steel Company (a
Unit of USX Corporation), Inland Steel Industries, Inc., Geneva Steel,
Gulf States Steel Inc. of Alabama, Sharon Steel Corporation, and Lukens
Steel Company) filed requests for review. We published a notice of
initiation of the review on September 25, 1997 (62 FR 50292).
Due to the complexity of issues involved in this case, the
Department extended the time limit for completion of the preliminary
results until August 31, 1998, in accordance with section 751(a)(3)(A)
of the Act (19 U.S.C. 1675 (a)(3)(A)). The deadline for the final
results of this review will continue to be 120 days after the date of
publication of this notice. The Department is conducting this review in
accordance with section 751 of the Act.

Scope of the Review

The products covered by this review include cold-rolled (cold-
reduced) carbon steel flat-rolled products, of rectangular shape,
neither clad, plated nor coated with metal, whether or not painted,
varnished or coated with plastics or other nonmetallic substances, in
coils (whether or not in successively superimposed layers) and of a
width of 0.5 inch or greater, or in straight lengths which, if of a
thickness less than 4.75 millimeters, are of a width of 0.5 inch or
greater and which measures at least 10 times the thickness or if of a
thickness of 4.75 millimeters or more are of a width which exceeds 150
millimeters and measures at least twice the thickness, as currently
classifiable in the Harmonized Tariff Schedule (HTS) under item numbers
7209.15.0000, 7209.16.0030, 7209.16.0060, 7209.16.0090, 7209.17.0030,
7209.17.0060, 7209.17.0090, 7209.18.1530, 7209.18.1560, 7209.18.2550,
7209.18.6000, 7209.25.0000, 7209.26.0000, 7209.27.0000, 7209.28.0000,
7209.90.0000, 7210.70.3000, 7210.90.9000, 7211.23.1500, 7211.23.2000,
7211.23.3000, 7211.23.4500, 7211.23.6030, 7211.23.6060, 7211.23.6085,
7211.29.2030, 7211.29.2090, 7211.29.4500, 7211.29.6030, 7211.29.6080,
7211.90.0000, 7212.40.1000, 7212.40.5000, 7212.50.0000, 7215.50.0015,
7215.50.0060, 7215.50.0090, 7215.90.5000, 7217.10.1000, 7217.10.2000,
7217.10.3000, 7217.10.7000, 7217.90.1000, 7217.90.5030, 7217.90.5060,
and 7217.90.5090. Included in this review are flat-rolled products of
nonrectangular cross-section where such cross-section is achieved
subsequent to the rolling process (i.e., products which have been
``worked after rolling'')--for example, products which have been
beveled or rounded at the edges. Excluded from this review is certain
shadow mask steel, i.e., aluminum-killed, cold-rolled steel coil that
is open-coil annealed, has a carbon content of less than 0.002 percent,
is of 0.003 to 0.012 inch in thickness, 15 to 30 inches in width, and
has an ultra flat, isotropic surface. These HTS item numbers are
provided for convenience and Customs purposes. The written description
remains dispositive.

Verification

As provided in section 782(i)(3) of the Act, we verified
information provided by Hoogovens at its headquarters in Beverwijk and
IJmuiden, the Netherlands, using standard verification procedures,
including inspection of the manufacturing facilities, examination of
relevant sales and financial records, and selection of original
documentation containing relevant information. We also verified
information provided by Hoogovens Steel USA, Inc. at its office in
Scarsdale, New York.

Export Price (EP)

In calculating the U.S. starting price, the Department considered
whether respondent's sales reported as export price (EP) sales are more
appropriately characterized as CEP sales, as argued by petitioners in
their letter to the Department dated July 10, 1998. Respondent offered
a rebuttal to petitioners' argument in a letter dated August 6, 1998.
In previous reviews the Department accepted the characterization of
these sales as reported. Certain Cold-Rolled Carbon Steel Flat Products
From the Netherlands; Final Results of Antidumping Duty Administrative
Review, 61 FR 48465 (September 13, 1996); 62 FR 18476 (April 15, 1997);
63 FR 13204 (March 18, 1998).
To ensure proper application of the statutory definitions of EP and
CEP, where a U.S. affiliate is involved in making a sale, we consider
the sale to be CEP unless the record demonstrates that the U.S.
affiliate's involvement in making the sale is incidental or ancillary.
Thus, whenever sales are made prior to importation through an
affiliated sales agent in the United States, the Department typically
determines whether to characterize the sales as EP sales based upon the
following criteria: (1) whether the merchandise was shipped directly to
the unaffiliated buyer, without being introduced into the affiliated
selling agent's inventory; (2) whether this

[[Page 47229]]

procedure is the customary sales channel between the parties; and (3)
whether the affiliated selling agent located in the United States acts
only as a processor of documentation and a communications link between
the foreign producer and the unaffiliated buyer. See, e.g., Notice of
Final Determination of Sales at Less Than Fair Value: Newspaper
Printing Presses From Germany, 61 FR 38175 (July 23, 1996); Certain
Corrosion Resistant Carbon Steel Flat Products From Korea: Final
Results of Antidumping Administrative Review, 61 FR 18547, 18551 (April
26, 1996); Certain Cut-To-Length Carbon Steel Plate From Germany: Final
Results of Antidumping Duty Administrative Review, 62 FR 18390 (April
15, 1997); Certain Cold-Rolled and Corrosion Resistant Carbon Steel
Flat Products From Korea: Final Results of Antidumping Duty
Administrative Reviews, 63 FR 13170, 13177 (March 18, 1998).
The Department found that the sales through Hoogovens Steel USA,
Inc. (HSUSA) satisfy these criteria. The subject merchandise is shipped
directly from Hoogovens' mill to customers in the United States. HSUSA
does not take title to the merchandise and does not maintain
inventories of subject merchandise. This procedure is the customary
sales channel between the parties, and the Department found no
exceptions to this rule. The analysis of the third criterion is more
complex. In this case the producer sells directly to the U.S. customer.
The affiliate does not issue invoices, conduct customer credit checks,
or finance sales, and rarely handles receipt of payment for Hoogovens'
sales. Rather, Hoogovens creates and maintains most of the
documentation for U.S. sales in the Netherlands. With respect to
negotiations and price setting, the record is less clear. On the one
hand, Hoogovens has stated that HSUSA negotiates prices with U.S.
customers, subject to Hoogovens' approval. On the other hand, HSUSA
does not have the authority to set prices or quantities. Under the
terms of the agency agreement between Hoogovens and HSUSA, HSUSA is
responsible for conducting market research, finding new customers, and
soliciting orders. However, the agency agreement provides that in
performance of these activities on behalf of Hoogovens, HSUSA has no
authority to conclude contracts on Hoogovens' behalf. HSUSA cannot
negotiate above the prices set by Hoogovens and its compensation does
not depend on the price, quantity or profitability of sales. The record
shows that Hoogovens is directly and continuously involved in
negotiations and other communications with unaffiliated customers, and
is solely responsible for providing technical service. See Verification
at Hoogovens Steel USA, Inc., July 15, 1998, page 3 and Verification
Exhibits 4 and 6. HSUSA serves as a communications link in relaying
price quotes and other information, as well as quality complaints,
between Hoogovens and customers. HSUSA regularly visits U.S. customers,
both alone and in the company of Hoogovens officials from the
Netherlands, and participates in meetings with U.S. customers that take
place in the Netherlands. Based upon the information on the record, the
Department preliminarily concludes that HSUSA's role is ancillary to
the sales made in the Netherlands.
We note that this is a very complex and difficult issue. While we
have preliminarily determined to treat the transactions through HSUSA
as EP sales, we note that certain record evidence could be argued to
support treating these transactions as CEP sales. The Department
invites parties to submit information and comment on this issue. Any
such information or argument should be included in parties' case and
rebuttal briefs. We intend to examine this issue carefully for the
final results of this review. Any information or arguments parties
provide will be fully analyzed in making this final decision. Parties
are encouraged to provide any relevant information and arguments on
this issue to ensure that the Department's final determination as to
whether Hoogovens' sales to unaffiliated customers should be treated as
EP or CEP is based on a complete and thorough record.
We calculated EP based on the delivered, duty-paid price to
unaffiliated customers in the United States. We made adjustments for
discounts and post-sale price adjustments. We made deductions, where
applicable, for foreign inland freight, ocean freight and marine
insurance, brokerage and handling, U.S. inland freight, post-sale
warehousing, and U.S. customs duties in accordance with section 772(c)
of the Act. For EP sales, we rejected the reported imputed credit
expenses based on the weighted average interest rate on short term
dollar-denominated loans taken out in the Netherlands. We recalculated
these U.S. credit expenses using the weighted average interest rate on
HSUSA's short term borrowings in the United States during the POR.

Constructed Export Price (CEP)

We based CEP on the delivered price to unaffiliated customers in
the United States. We made deductions for foreign inland freight, ocean
freight and marine insurance, brokerage and handling, U.S. inland
freight, and U.S. customs duties. In accordance with section 772(d)(1)
of the Act, we calculated the CEP by deducting selling expenses
associated with economic activities occurring in the United States,
including credit expenses, indirect selling expenses, and inventory
carrying costs. In accordance with section 772(d)(2) of the Act, for
sales made through the affiliated Rafferty-Brown companies, we also
deducted the cost of further manufacturing, including repacking
expenses. Finally, we made an adjustment for an amount of profit
allocated to these expenses in accordance with section 772(d)(3) of the
Act.
In the absence of cost of production (COP) data for certain home
market sales,1 we estimated COP for calculation of the CEP
profit allocation and the home market profit rate for CV as follows:
---------------------------------------------------------------------------

\1\ Hoogovens reported CV data, which provide the cost of
manufacturing the products sold in the United States. As the product
mix is very different in the home market, the CV data are not
representative of total costs.
---------------------------------------------------------------------------

1. We estimated the home market fixed costs by calculating the
weighted average ratio of fixed costs to variable costs for U.S. sales
(using the reported VCOMU and TCOMU variables) and multiplying the
reported home market variable costs (VCOMH) by this ratio.
2. We obtained the total cost of manufacturing (COM) by adding the
reported total variable costs and the estimated fixed costs.
3. We obtained general and administrative expenses and interest
expenses from the constructed value (CV) data base and added them to
the total COM to obtain COP.

Normal Value (NV)

In order to determine whether sales of the foreign like product in
the home market are a viable basis for calculating NV, we compared the
volume of home market sales of the foreign like product to the volume
of subject merchandise sold in the United States, in accordance with
section 773(a)(1)(C) of the Act. Hoogovens' aggregate volume of home
market sales of the foreign like product was greater than five percent
of its respective aggregate volume of U.S. sales of the subject
merchandise. Therefore, we have based NV on home market sales.

[[Page 47230]]

Hoogovens made sales to both affiliated and unaffiliated customers
in the home market during the period of review. We included sales to
affiliated customers when we determined those sales to be at arms
length (i.e., at weighted average prices that were 99.5 percent or more
of weighted average prices for identical products sold to unaffiliated
customers in the home market). When the weighted average price to an
affiliated customer was less than 99.5 percent of the weighted average
price to unaffiliated customers, or there were no sales of identical
merchandise to unaffiliated customers, we excluded sales to that
affiliated customer from our calculation of NV. See e.g., Rules and
Regulations, Antidumping Duties; Countervailing Duties 62 FR 27296,
27355 (May 19, 1997): ``The Department's current policy is to consider
transactions between affiliated parties as `arm's length' if the prices
to affiliated purchasers are on average at least 99.5 percent of the
prices charged to unaffiliated purchasers.''
Home market prices were based on the packed, ex-factory or
delivered prices to customers. We made deductions to NV for inland
freight, early payment discounts, rebates, credit expenses, and
packing. We made deductions or additions, as appropriate, for post-sale
price adjustments. Where CV was used as the basis of NV, we deducted
direct selling expenses (comprised of credit and warranty/technical
service expenses).

Level of Trade

In accordance with section 773(a)(1)(B) of the Act, to the extent
practicable, we determine NV based on sales in the comparison market at
the same level of trade (``LOT'') as the EP or CEP transaction. The NV
LOT is that of the starting-price sales in the comparison market or,
when NV is based on CV, that of the sales from which we derive selling,
general and administrative expenses and profit. For EP, the U.S. LOT is
also the level of the starting-price sale, which is usually from
exporter to importer. In this case, the exporter sells directly to
unaffiliated customers. For CEP, it is the level of the constructed
sale from the exporter to the importer.
To determine whether NV sales are at a different LOT than EP or
CEP, we examine stages in the marketing process and selling functions
along the chain of distribution between the producer and the
unaffiliated customer. If the comparison-market sales are at a
different LOT, and the difference affects price comparability, as
manifested in a pattern of consistent price differences between the
sales on which NV is based and comparison-market sales at the LOT of
the export transaction, we make an LOT adjustment under section
773(a)(7)(A) of the Act. We determine any effect on price comparability
by examining sales at different levels of trade in the home market (or
the third country market) used to calculate NV. Any price effect must
be manifested in a pattern of consistent price differences between home
market (or third-country) sales used for comparison and sales at the
equivalent LOT of the export transaction. To quantify the price
differences, we calculate the difference in the weighted average of the
net prices of the same models sold at different levels of trade in the
home market. Net prices are used because any difference will be due to
differences in LOT rather than other factors. We use the average
percentage difference between these weighted averages to adjust NV when
the LOT of NV is different from that of the export sale. If there is no
pattern of price differences, then the difference in LOT does not have
a price effect and no adjustment is necessary.
In the case of CEP sales, Section 773 (b)(7)(B) of the statute also
provides for an adjustment to NV if it is compared to U.S. sales at a
different LOT, provided the NV is more remote from the factory than the
CEP sales and we are unable to determine whether the difference in
levels of trade between CEP and NV affects the comparability of their
prices. This latter situation might occur when there is no home market
(or third-country) LOT equivalent to the U.S. sales level, or where
there is an equivalent home market (or third-country) level, but the
data are insufficient to support a conclusion on price effect. This
adjustment, the CEP offset, is the lower of the (1) indirect selling
expenses of the home market (or third-country) sale; or (2) indirect
selling expenses deducted from the starting price used to calculate
CEP. The CEP offset is not automatic each time we use CEP. The CEP
offset is made only when the LOT of the home market (or third country)
sale is more advanced than the LOT of the U.S. CEP sale and there is
not an appropriate basis for determining whether there is an effect on
price comparability.
To examine LOT in this review, we requested detailed information
concerning the selling functions associated with sales to service
centers and to several categories of end-users in each of Hoogovens'
markets and interviewed sales, technical service and research managers.
The information gathered indicated that there are no significant
differences among the selling functions performed and services offered
to service centers and end-user customers in either the home or U.S.
markets. In both markets, the larger customers received more frequent
visits from sales personnel. In the home market, a higher level of
service was provided to automotive customers than to other end-users,
but the sales were at the same stage of marketing as all other home
market sales. Hoogovens stated it cannot differentiate among the
selling functions performed and services offered to different classes
of home market or export price customers. However, Hoogovens claimed it
has no home market sales at a LOT equivalent to the CEP LOT, alleging:
While the CEP sale has been adjusted to create, in effect, an
ex-factory level of trade, the starting price of the home market
sales reflects many selling activities not reflected in the adjusted
CEP price. These include indirect selling activities, indirect
warranty and technical service expenses, and inventory carrying
costs incurred on home market sales.

Section A response (October 6, 1997), p. 13.
We disagree with Hoogovens' claim that the prices used to determine
NV reflect many selling activities not reflected in CEP. In calculating
CEP, the Department deducted the imputed credit expenses incurred by
the Rafferty-Brown companies as direct selling expenses. In accordance
with section 772(d)(1), the Department deducted indirect selling
expenses (ISE), including imputed inventory carrying costs (ICC)
incurred in the United States by the Rafferty-Brown companies for sales
to the first unaffiliated buyers. The Department did not deduct ISE
incurred in the Netherlands (reported in computer data fields DINDIRSU
and DINVCARU), nor expenses of the U.S. sales office from the adjusted
CEP, on the grounds that these are expenses associated with the sale to
Hoogovens U.S. affiliates, rather than with the sales by the affiliates
to the first unaffiliated buyers. Thus, the CEP includes Hoogovens'
warranty and technical service expenses for U.S. sales, as well as ISE,
including the expenses of the sales offices in IJmuiden and New York
incurred in connection with the sales to the affiliated service
centers.
Hoogovens' starting price for home market sales includes direct
warranty and technical service expenses, ICC, the expenses of the sales
office in IJmuiden, and other indirect selling expenses incurred for
home market sales. Thus, for the purposes of the LOT analysis, there is
no distinguishable difference between the selling functions included

[[Page 47231]]

in the home market starting price and the selling functions included in
the CEP. On the basis of this analysis, the Department has determined
that there is no basis for Hoogovens' claim that home market sales are
at a different, more advanced LOT than the adjusted CEP sales. The
Department therefore has determined for these preliminary results that
Hoogovens' sales are made at one LOT in both markets.
We note that this is a very complex and difficult issue. While we
have preliminarily determined to treat all home market and U.S. sales
as at the same LOT, we note that this is a change from the prior review
period. The Department invites parties to submit information and
comment on this issue. Any such information or argument should be
included in parties' case and rebuttal briefs. We intend to examine
this issue carefully for the final results of this review. Any
information or arguments parties provide will be fully analyzed in
making this final decision. Parties are encouraged to provide any
relevant information and arguments on this issue to ensure that the
Department's final determination as to whether all of Hoogovens' home
market and U.S. sales are at the same LOT is based on a complete and
thorough record.

Sales Comparisons

To determine whether sales of cold-rolled carbon steel flat
products in the United States were made at less than fair value, we
compared EP or CEP to NV, as described in the ``Export Price,''
``Constructed Export Price'' and ``Normal Value'' sections of this
notice. In accordance with section 777(A) of the Act, we calculated
monthly weighted-average prices for NV and compared these to individual
U.S. transactions. When there were no contemporaneous home market sales
of the foreign like product, we used CV as the basis for normal value,
in accordance with section 773(a)(4) of the Act. All the sales to which
CV was applied were CEP sales of secondary merchandise. We calculated
CV in accordance with section 773(e) of the Act and the methodology
enunciated in the Memorandum of April 19, 1995, entitled ``Treatment of
Non-Prime Merchandise for the First Administrative Review of Certain
Carbon Steel Flat Products.'' We included the cost of manufacture, and
selling, general and administrative expenses (SG&A). In accordance with
section 773(e)(2)(A) of the Act, we based SG&A expenses and profit on
the amounts incurred and realized by the respondent in connection with
the production and sale of the foreign like product in the ordinary
course of trade for consumption in the home market. For selling
expenses, we used the weighted average home market selling expenses. We
calculated profit by subtracting the weighted average total cost of
production (estimated as described above) from the total weighted
average sales revenue. We adjusted CV for credit and warranty expenses.

Reimbursement

Section 351.402(f) of the antidumping regulations requires the
Department to deduct from EP or CEP the amount of any antidumping duty
that is reimbursed to the importer. Based on verified evidence on the
record in this review, including the revised agency agreement between
Hoogovens and Hoogovens Steel USA, Inc. (HSUSA) and the refund to
Hoogovens by HSUSA of a portion of the cash deposits advanced equal to
the Department's calculation of the antidumping duties to be assessed
in the third administrative review, the Department has preliminarily
determined that HSUSA is solely responsible for the payment of
antidumping duties. Further, evidence on the record in this review
shows that as a result of corporate restructuring, HSUSA has sufficient
assets to establish its ability to pay the antidumping duties to be
assessed. Therefore, for this period of review, we have determined that
Hoogovens has not reimbursed HSUSA for antidumping duties to be
assessed.

Preliminary Results of Review

We preliminarily determine that the following margin exists for the
period August 1, 1996 through July 31, 1997:

------------------------------------------------------------------------
Margin
Company (percent)
------------------------------------------------------------------------
Hoogovens Staal BV......................................... 0.95
------------------------------------------------------------------------

Parties to this proceeding may request disclosure within five days
of publication of this notice and any interested party may request a
hearing within 30 days of publication. Any hearing, if requested, will
be held 44 days after the date of publication, or the first working day
thereafter. Interested parties may submit case briefs and/or written
comments no later than 30 days after the date of publication. Rebuttal
briefs and rebuttals to written comments, limited to issues raised in
such briefs or comments, may be filed no later than 37 days after the
date of publication. The Department will publish the final results of
this administrative review, which will include the results of its
analysis of issues raised in any such written comments or at a hearing,
within 120 days after the publication of this notice.
The Department shall determine, and Customs shall assess,
antidumping duties on all appropriate entries. For assessment purposes,
the duty assessment rate will be a specific amount per metric ton. The
Department will issue appraisement instructions directly to Customs.
The final results of this review shall be the basis for the assessment
of antidumping duties on entries of merchandise covered by this review
and for future deposits of estimated duties.
Furthermore, the following deposit requirements will be effective
upon completion of the final results of this administrative review for
all shipments of cold-rolled carbon steel flat products from the
Netherlands entered, or withdrawn from warehouse, for consumption on or
after the publication date of the final results of this administrative
review, as provided by section 751(a)(1) of the Act: (1) the cash
deposit rate for the reviewed firm will be the rate established in the
final results of administrative review, except if the rate is less than
0.5 percent, and therefore, de minimis within the meaning of 19 CFR
351.106, in which case the cash deposit rate will be zero; (2) if the
exporter is not a firm covered in this review or the original
investigation, but the manufacturer is, the cash deposit rate will be
that established for the manufacturer of the merchandise in the final
results of this review; and (3) if neither the exporter nor the
manufacturer is a firm covered in this or any previous review or the
original fair value investigation, the cash deposit rate will be 19.32
percent.
This notice also serves as a preliminary reminder to importers of
their responsibility under 19 CFR 351.402(f) to file a certificate
regarding the reimbursement of antidumping duties prior to liquidation
of the relevant entries during these review periods. Failure to comply
with this requirement could result in the Secretary's presumption that
reimbursement of antidumping duties occurred and the subsequent
assessment of double antidumping duties.
This administrative review and notice are in accordance with
sections 751(a)(1) and 777(i)(1) of the Act.

Dated: August 31, 1998.
Joseph A. Spetrini,
Acting Assistant Secretary for Import Administration.
[FR Doc. 98-23930 Filed 9-3-98; 8:45 am]
BILLING CODE 3510-DS-P

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A98-23930. Public record. Not legal advice.