1. “Under 19 U.S.C. §§ 1337(a)(2) and (a)(3)(B), does the statutory language require that ‘labor or capital’ include only labor or capital that establishes an ‘industry,’ consistent with the statute’s plain language and purpose to provide trade relief to only U.S. industries, or does the statute require inclusion of all labor or capital?”
2. “Did the panel overlook certain relevant tools of statutory interpretation by reading the terms labor and capital in isolation without regard to the whole text and overall statutory scheme of 19 U.S.C. § 1337, contrary to King v. Burwell, 576 U.S. 473 (2015), and Hibbs v. Winn, 542 U.S. 88 (2004), thus rendering the statutory term ‘industry’ meaningless?”
