MEMORANDUM AND ORDER
CARMAN, Judge:
Plaintiff, on behalf of former employees of Great Western Sugar Company (Great Western), seeks reversal on review of a final determination by the Secretary of Labor (Secretary) denying certification of eligibility for benefits under the worker adjustment assistance program of the Trade Act of 1974, tit. II, §§ 221-249, 284, (the Trade Act), 19 U.S.C. §§ 2271-2321, 2395 (1982 and Supp. IV 1986).
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