Brussels, May 6, 2020 – Pursuant to Commission Rule 201.14(b)(2), the Fair Standards Alliance (FSA) respectfully requests the Commission’s leave to file “Statement Of Third Party Fair Standards Alliance In Response To The Commission’s Notice Of Request For Statements On The Public Interest” in Investigation No. 337-TA-1138 out of time. The Commission’s filing deadline was yesterday, May 5, 2020. FSA timely filed its Statement on May 5, 2020 (at 3:18p.m.), but we were notified by Attorney-Case Manager Ryan Glazer that FSA needed to refile its Statement with double-spacing because it was over two pages. We accordingly reformatted the Statement and re-submitted it, unfortunately after the filing deadline of 5:15 p.m. (at 5:35p.m.). On May 6, 2020, Mr. Glazer informed us that we needed to refile the Statement together with a letter requesting permission to file out of time.
FSA requests that the Commission accept our filing one day late because this is the first time our trade association has filed in an investigation at the U.S. International Trade Commission. It was, consequently, the first time we had used the Commission’s Electronic Document Information System, and we were unfortunately not sufficiently familiar with the procedure. The six-hour time difference between Washington, D.C. and Brussels, where we are located, further contributed to our missing the deadline. Given the importance of the topic at issue and the insights we hope we can bring from a broader public interest perspective, representing 47 large and small innovating companies around the globe, we hope you can accept our request. We will, of course, make sure to timely file any future submissions with the Commission.
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