Consequently, the court dismissed JVC's suit for lack of subject matter jurisdiction.See id. at 915. As further justification for dismissing JVC's claim, the Court of International Trade cited the case of Juice Farms, Inc. v. United States, 68 F.3d 1344 (Fed. Cir. 1995). See US JVC Corp., 15 F. Supp.2d at 912-13 n. 10.

This jurisdictional grant is not unqualified, however, and must be read to incorporate the requirements of 19 U.S.C. § 1514. Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345 (Fed. Cir. 1995). Section 1514(a) provides that "decisions of the Customs Service, including the legality of all orders and findings entering into the same, as to . . . the liquidation or reliquidation of an entry . . . shall be final and conclusive upon all persons (including the United States and any officer thereof) unless a protest is filed in accordance with this section.

A decision to liquidate, including the legality of the liquidation itself, becomes final unless a protest of the decision is filed within 90 days of the entry of liquidation. 19 U.S.C. § 1514; see Juice Farms, Inc. v. United States, 68 F.3d 1344, 1346 (Fed. Cir. 1995) (parties bound by even erroneous, illegal liquidation not protested within 90 days); United States v. A.N. Deringer, Inc., 66 C.C.P.A. 50, 593 F.2d 1015, 1020 (1979) (any protest of liquidation, including a challenge to its legality, must occur within 90 days). This court may hear a challenge to a denied timely protest of liquidation.

Upon challenge, the plaintiff bears the burden of demonstrating that jurisdiction exists. Juice Farms, Inc. v. United States, 68 F.3d 1344, 1345 (Fed. Cir. 1995). Plaintiff claims this Court has jurisdiction pursuant to 28 U.S.C. § 1581(a).

Because a remedy would have been available under § 1581(a) had the importers timely protested Customs' classification decisions, ARP and Harrison cannot invoke the Court of International Trade's residual jurisdiction under § 1581(i) unless they show that the relief in § 1581(a) would have been manifestly inadequate. Juice Farms, Inc. v. United States , 68 F.3d 1344, 1346 (Fed. Cir. 1995). But neither ARP nor Harrison can meet this burden because "a remedy is not inadequate ‘simply because [the importer] failed to invoke it within the time frame [that is] prescribe[d].’ "

Id. at 1347, 1349. The court concluded that, under our decision in Juice Farms, Inc. v. United States, 68 F.3d 1344 (Fed.Cir.1995), the 2005 reliquidations became final, “whether legal or not,” once AHAC failed to challenge them in court. Am. Home, 964 F.Supp.2d at 1347 (quoting Juice Farms, 68 F.3d at 1346).

Without timely protest, all liquidations become final and conclusive under 19 U.S.C. § 1514." Juice Farms, Inc. v. United States, 68 F.3d 1344, 1346 (Fed. Cir. 1995). In Juice Farms, Customs erroneously liquidated twenty entries of orange juice while suspension orders were in effect.

"[Such] bulletin notices supply sufficient notice and thus trigger the ninety-day period for protests." Juice Farms, Inc. v. United States, 68 F.3d 1344, 1346 (Fed. Cir. 1995). Fujitsu filed Protest No. 2704-98- 100059 on February 11, 1998, challenging Customs' assessment of interest on the subject entries liquidated on November 14, 1997, and December 5, 1997.

We review the CIT's “decision to grant the Government's motion to dismiss [for lack of subject matter jurisdiction] de novo as a question of law.” Juice Farms, Inc. v. United States , 68 F.3d 1344, 1345 (Fed. Cir. 1995). “[T]he party invoking [the CIT's] jurisdiction bears the burden of establishing it.” Norsk Hydro Can., Inc. v. United States , 472 F.3d 1347, 1355 (Fed. Cir. 2006).

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: