Second, monitoring the liquidation of entries subject to an antidumping duty order is a serious challenge even for importers who have access to complete information regarding an entry. See, e.g., Juice Farms, Inc. v. U.S., 68 F.3d 1344 (Fed. Cir. 1995) (holding Customs' violation of statutory suspension of liquidation not actionable by importer who discovered improper liquidations after protest period had expired). Defendant-Intervenors were themselves apparently unaware that their entries had been prematurely liquidated until notified by Commerce.

We have held that the Court of International Trade's authority to hear a claim under section 1581(a) depends upon the importer raising the claim in a valid protest filed with Customs within the prescribed 90-day period, or alternatively, in a protest coming within an exception that excuses a failure to meet the deadline. See Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345-46 (Fed. Cir. 1995). Section 1581(i) provides in pertinent part as follows:

The government appears to argue that the lack of a statutory provision for "reliquidation" in cases of erroneous Commerce instructions, indeed in any case outside the confines of section 1514(a), is an implied prohibition of the requested relief. According to the government, the inapplicability of section 1514(a) to the case at bar renders the case moot. Because "[l]iquidation is the `final computation or ascertainment of the duties or drawback accruing on an entry,'" Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345-46 (Fed. Cir. 1995), "reliquidation" is the re-calculation of the duties or drawback accruing on an entry. Section 1514(a) reads:

Thus, section 1514(a) precludes the CIT from reviewing a challenge to-and ordering reliquidation based on-an erroneous decision by U.S. Customs and Border Protection ("Customs" or "CBP") unless the statutory protest requirements are met. See, e.g., Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345 (Fed. Cir. 1995); Mitsubishi Elecs. Am., Inc. v. United States, 18 CIT 167, 172, 848 F.Supp. 193, 197 (1994). In litigation under 28 U.S.C. § 1581(c) seeking to challenge an antidumping or countervailing duty determination, the finality of liquidation is governed by a different statutory provision, 19 U.S.C. § 1516a.