The Bristol Group is pleased to announce that Jennifer M. Smith has joined the firm as a Partner.

Mrs. Smith has counseled and represented clients in numerous industries since she entered private practice in 2010.  She has extensive experience in a wide range of international trade law matters, including antidumping and countervailing duty proceedings, customs, export controls, economic sanctions and embargoes, anti-boycott, trade adjustment assistance, and international and bilateral trade agreements, and dispute resolution processes.  She also advises clients on implementing import and export compliance programs and assists clients in performing import and export compliance reviews and due diligence reviews for mergers and acquisitions transactions.  Mrs. Smith has represented clients before numerous agencies, including the U.S.  Departments of Commerce, State, Treasury, and Labor; the U.S. International Trade Commission; U.S. Customs and Border Protection; and the Office of the U.S. Trade Representative.

Mrs. Smith received her J.D. from the from Georgetown University Law Center, and is a member of the State Bar of New York and the District of Columbia Bar. In April 2019, she was appointed to the U.S. NAFTA Chapter 19 Roster of Panelists to hear disputes under the trade remedy laws.

Mrs. Smith frequently writes articles and speaks at conferences and on webinars regarding international trade and import/export compliance issues.  She is a Co-Vice Chair of the Federal Circuit Bar Association International Trade Committee and a member of the Georgetown University Law Center International Trade Update Advisory Board.  Before entering private practice, Mrs. Smith clerked at the United States Court of International Trade for Chief Judge Jane A. Restani.

We are excited to welcome Jennifer as our colleague and to see her apply her expertise and experience to help The Bristol Group continue our mission of Defending American Manufacturing.



The Bristol Group PLLC can help American businesses and workers’ groups prepare comments on this proposed rule. Please let us know if you have any questions or would like to discuss this potentially significant – and from the perspective of U.S. manufacturers, beneficial – change.

For more information, please contact Adam Gordon or Jennifer Smith.

Nation’s Largest Staple Manufacturer Files Unfair Trade Actions Against China, Taiwan, and Korea

Kyocera Senco Industrial Tools., Inc. 
Jun 06, 2019, 11:43 ET

The nation’s largest staple manufacturer, Kyocera Senco Industrial Tools., Inc. (Senco), today filed petitions to stop China, Taiwan, and Korea from selling dumped and unfairly subsidized collated medium and heavy staples into the United States.

As part of its antidumping and countervailing petitions, the company is asking the Department of Commerce (DOC) and International Trade Commission (ITC) to impose duties on all three countries to offset unfair pricing, and additional duties against Chinese imports to offset unfair subsidies.


Opportunity for Comment on Proposed Rule to Target Currency Undervaluation as a Countervailable Subsidy in Trade Remedy Proceedings

May 28, 2019
By Jennifer M. Smith

Today, the U.S. Department of Commerce (“Commerce”) published a proposed rule that could reflect a potentially significant change to its regulations to allow for the imposition of tariffs known as countervailing duties (“CVDs”) on countries that undervalue their currency relative to the dollar. If this rule is enacted, U.S. parties — including producers, manufacturers, and labor unions — and Commerce itself could bring trade cases to challenge currency undervaluation as a subsidy. If successful, the U.S. government would impose CVDs to offset that subsidy. This would be a reversal of Commerce’s past practice, as Commerce previously has declined to initiate investigations into allegations of currency undervaluation. Yet there are some aspects of the proposed rule that may undercut its effectiveness, as noted below.

Commerce has invited written comments from the public on this proposed rule by June 27, 2019. Interested parties can comment on any or all aspects of the proposed rule. Commerce also invited comments on “whether there are other options under the existing law to examine potential currency-related subsidies.” Some analysts indeed believe that currency manipulation satisfies the criteria for a countervailable subsidy under existing law.

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Antidumping and Countervailing Duty Litigation

AD and CVD cases, which are litigated simultaneously before the U.S. Department of Commerce and the U.S. International Trade Commission, involve complex legal, economic, policy and accounting issues.

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While technically challenging, AD and CVD cases generate important benefits as soon as they are filed, allowing a domestic industry to benefit in terms of both pricing and market share. Once imposed, AD and CVD orders are periodically reviewed, but will remain in place indefinitely.

For our clients, success in these cases results in special duties being imposed on specific imports. This “levels the playing field” and allows our clients to recover from harm caused by unfairly traded imports, earn a reasonable return, invest in their operations, and preserve jobs and manufacturing in the United States.

Legislative and Regulatory Affairs

The laws and regulations governing international trade matters are always evolving and have a direct and immediate effect on our clients’ interests.

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For our clients, we monitor and participate in the development of changes to important laws and regulations. Whether concerning the creation of new laws (such as the Enforce and Protect Act of 2015) to improve the enforcement and operation of our trade laws, the propriety of allowing significant changes to China’s status as a non-market economy country, or the operation of numerous technical aspects of the AD and CVD laws, our professionals are actively engaged in ensuring that U.S. law best reflects our clients’ interests.

In this as in so many areas, the best approach often is not the most visible approach. With this in mind, we craft results-oriented, cost-effective strategies that recognize and emphasize the benefits of quiet diplomacy as well as assertive public action. The benefits of our approach have been demonstrated repeatedly for our clients.

Import/Export Controls and Sanctions Compliance

A complex array of U.S. laws and regulations govern importing, exporting, and other international transactions.  We help clients understand, navigate, and comply with such laws and regulations.

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Specifically, we can advise clients regarding:

 · Customs Matters, including determining the correct classification, valuation, country of origin, and applicable duties and fees for imported merchandise; identifying and addressing potential evasion of AD/CVD orders; compliance with free trade agreements, trade preferences, and other duty-free programs; duty drawback and other mechanisms for reducing duties; and administrative processes;

 · Import and Export Controls, which restrict, and in some instances require licenses for, imports and exports of certain goods, services, software, or technology (including releasing certain technology to foreign nationals);

 · Economic Sanctions and Embargoes, which restrict transactions with certain countries, individuals, and entities for national security and foreign policy reasons;

 · Anti-Boycott Regulations, which impose reporting requirements regarding, and in some instances prohibit, compliance with foreign boycotts in which the U.S. does not participate as well as certain forms of discrimination; and

 · The Foreign Corrupt Practices Act (FCPA), which prohibits payments to foreign officials with the aim of influencing or inducing them or securing or maintaining business.

 We can design and help clients implement customized compliance programs and training for personnel to prevent potential violations, screen potential parties to international transactions to determine whether they are subject to restrictions, and conduct due diligence reviews for potential mergers and acquisitions.

 Violations of these laws and regulations may result in significant penalties. The U.S. government has prioritized enforcement and imposed record-breaking penalties in recent years.

In the unfortunate instance where a potential violation may have occurred, we can investigate the matter and provide advice regarding addressing a potential enforcement action and potential ways to mitigate penalties, which may include disclosure of an apparent violation


Adam H. Gordon,
Managing Partner


Jennifer M. Smith,


Ping Gong,


Our Record of Success

The Bristol Group has an exceptional record of successes for American manufacturers. We have represented nearly a dozen different U.S. industries in 28 antidumping and countervailing duty investigations and related proceedings, nearly all of which have results in successful outcomes for our clients. We have brought or defended over 72 appeals, again compiling a deep record of successful decisions.

As one example, for nearly 10 years we have represented the U.S. steel nail industry and its members. Since 2005, repeated waves of unfairly traded imports have injured the U.S. industry, forcing some producers out of the market entirely and requiring others to curtail operations and cut jobs. We have won eight different cases over nearly 10 years to combat imports first from China (2008), the United Arab Emirates (2012), and then Korea, Malaysia, Taiwan, Oman, and Vietnam (two cases) (all completed in 2015). Our work in these cases resulted in the imposition of special antidumping and countervailing duties ranging in amounts up to 324%, meaning that U.S. Customs and Border Protection collects $3.24 in additional duties for each $1 of steel nails brought in by importers.

Companies filing antidumping (AD) and/or countervailing duty (CVD) cases typically experience important benefits ever before the case is completed. Once a case is filed, pricing in the U.S. market typically improves and the domestic industry typically regains market share. These effects are expected and will not undermine your chances of overall success.

In addition to the cases we have successfully brought for the U.S. nail industry, The Bristol Group has represented industries as varies those producing decorative tissue and crepe paper, saccharin, carbon and alloy steel wire rod, stainless steel, preserved mushrooms, solar panels and business jet aircraft. For all of our clients in these and other industries, we have brought a consistent and deep commitment to addressing their needs and ensuring their long-term success./p>

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We can also be reached at (202) 991-2700.