MEMORANDUM OPINION
MUSGRAVE, Judge.
Previously, this Court found Hitachi America Ltd. ("HAL") and Hitachi, Ltd. ("Hitachi Japan") negligent with respect to the declared dutiable value(s) of 41 entries of 120 subway cars and parts imported between June 16, 1984 and May 27, 1987 for use by the Metropolitan Atlanta Rapid Transit Authority ("MARTA"). United States v. Hitachi America, Ltd., 21 CIT ___,
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