The court and Commerce have previously rejected adjustments related to foreign currency hedging. See, e.g.,Thyssen Stahl AG v. United States, 19 CIT 605, 614-15, 886 F. Supp. 23, 31 (1995), aff'd without op., Thyssen Stahl AG v. AK Steel Corp., 155 F.3d 574 (Fed. Cir. 1998); Certain Welded Carbon Steel Pipes and Tubes from Thailand, 65 Fed. Reg. 60,910 (October 13, 2000) (no hedging contract was directly tied to the sale in question, therefore the Department did not allow exchange rate loss adjustment). Further, "[t]o claim a circumstance of sale adjustment to foreign market value, expenses must be related to the sales of the products under investigation, rather than to sales generally."
Commerce quite reasonably chose to sample the Hand Tools Departments' sales documentation by requesting such documentation for only a single month, and having issued that request, it was entitled to FMEC's full compliance. Cf. Thyssen Stahl AG v. United States, 19 CIT 605, 606, 608, 886 F. Supp. 23, 25, 26-27 (sustaining determination that respondent failed verification where respondent "provided only one, self-selected, freight invoice to support its calculations"). Of course, this presumes the verifiers' good faith.