Full opinion text
OPINION TSOUCALAS, Senior Judge. This consolidated action concerns the claims raised by plaintiffs, NMB Singapore Ltd. and Pelmec Industries (PTE) Ltd. (collectively “NMB”), NSK-RHP Europe Ltd., RHP Bearings Ltd. and NSK Bearings Europe Ltd. (collectively “NSK-RHP”), SKF USA Inc., SKF Industrie S.p.A., SKF France S.A., SARMA and SKF GmbH (collectively “SKF”), NTN Bearing Corporation of America, American NTN Bearing Manufacturing Corporation, NTN Bower Corporation, NTN Driveshaft Incorporated, NTN-BCA Corporation and NTN Corporation (collectively “NTN”), and plaintiff-intervenors, The Barden Corporation (U.K.) Limited, The Barden Corporation, FAG Italia S.p.A., FAG Kugelfischer Georg Schafer AG and FAG Bearings Corporation (collectively “FAG”), who move pursuant to USCIT R. 56.2 for judgment upon the agency record challenging the United States International Trade Commission’s (“Commission” or «ITC”) five-year sunset review final determination, entitled Certain Bearings From China, France, Germany, Hungary, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom, 65 Fed.Reg. 39,925 (June 28, 2000), in which the ITC found inter alia that “revocation of the anti-dumping duty orders on ... .[ball] bearings from .,.. France, Germany, Italy, Japan, Singapore, and the United Kingdom would be likely to lead to continuation or recurrence of material injury to an industry in the United States within a reasonably foreseeable time.” The Commission’s complete determination was published in Certain Bearings From China,- France, Germany, Hungary, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom {“Final Determination”), Inv. Nos. AA1921-143, 731-TA-341, 731-TA-343-345, 731-TA-391-397, and 731-TA-399 (Review), USITC Pub. 3309 (June 2000). Specifically, NMB contends that the ITC erred in: (1) cumulating the subject imports from Singapore with other subject imports; and (2) determining that revocation of the antidumping duty orders with respect to subject imports would likely lead to continuation or recurrence of material injury. NSK-RHP contends that the ITC erred in: (1) not treating aerospace drive path bearings as a separate like product from ball bearings; (2) cumulating the subject imports from the United Kingdom with other subject imports; and (3) determining that revocation of the antidumping duty orders with respect to subject imports would likely lead to continuation or recurrence of material injury. SKF contends that the ITC erred in: (1) cumulating the subject imports from France, Germany, and Italy with other subject imports; and (2) determining that revocation of the antidumping duty orders with respect to subject imports would likely lead to continuation or recurrence of material injury. NTN contends that the ITC erred in: (1) not treating wheel hub units as a separate like product from ball bearings; (2) not treating aerospace drive path bearings as a separate like product from ball bearings; (3) cumulating the subject imports from Japan with other subject imports; (4) determining the conditions of competition in the domestic ball bearing industry; and (5) determining that revocation of the anti-dumping duty orders with respect to subject imports would likely lead to continuation or recurrence of material injury. FAG contends that the ITC erred in cumulating the subject imports from Italy and the United Kingdom with other subject imports. BACKGROUND In May 1989, the ITC determined that an industry in the United States was being materially injured as a result of less than fair value (“LFTV”) imports of ball bearings from France, Germany, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom. See Antifriction Bearings (Other Than Tapered Roller Bearings) and Parts Thereof from the Federal Republic of Germany, France, Italy, Japan, Romania, Singapore, Sweden, Thai land, and the United Kingdom (“Original Determination”), Inv. Nos. 303-TA-19 and 20 (Final) and 731-TA-391-399 (Final), USITC Pub. 2185 (May 1989). The Department of Commerce (“Commerce”) subsequently published antidumping duty orders covering the subject merchandise from the aforementioned countries on May 15, 1989. See Antidumping Duty Orders: Ball Bearings, Cylindrical Roller Bearings, and Spherical Plain Bearings and Parts Thereof From the Federal Republic of Germany, 54 Fed.Reg. 20,900; Anti-dumping Duty Orders: Ball Bearings, Cylindrical Roller Bearings, Spherical Plain Bearings, and Parts Thereof From France, 54 Fed.Reg. 20,902; Antidumping Duty Orders: Ball Bearings and Cylindrical Roller Bearings, and Parts Thereof From Italy, 54 Fed.Reg. 20,903; Anti-dumping Duty Orders: Ball Bearings, Cylindrical Roller Bearings, and Spherical Plain Bearings, and Parts Thereof From Japan, 54 Fed.Reg. 20,904; Antidumping Duty Order: Ball Bearings and Parts Thereof From Romania, 54 Fed.Reg. 20,-906; Antidumping Duty Order of Sales at Less Than Fair Value: Ball Bearings and Parts Thereof From Singapore, 54 Fed. Reg. 20,907; Antidumping Duty Orders: Ball Bearings, Cylindrical Roller Bearings, and Parts Thereof From Sweden, 54 Fed.Reg. 20,907; and Antidumping Duty Orders and Amendments to the Final Determinations of Sales at Less Than Fair Value: Ball Bearings, and Cylindrical Roller Bearings and Parts Thereof From the United Kingdom, 54 Fed.Reg. 20,910. On April 1, 1999, the Commission instituted five-year sunset reviews pursuant to 19 U.S.C. § 1675(e) (1994) to determine whether revocation of antidumping duty orders on certain bearings, including ball bearings from France, Germany, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom, would likely lead to continuation or recurrence of material injury. See Certain Bearings From China, France, Germany, Hungary, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom, 64 Fed.Reg. 15,783 (April 1, 1999). On July 2, 1999, the Commission determined that it would conduct full reviews. See Certain Bearings From China, France, Germany, Hungary, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom, 64 Fed.Reg. 38,471 (July 16, 1999). A revised notice regarding scheduling and a public hearing was published on December 1, 1999. See Certain Bearings From China, France, Germany, Hungary, Italy, Japan, Romania, Singapore, Sweden, and the United Kingdom, 64 Fed.Reg. 67,304 (December 1, 1999). The Commission held a hearing on March 21, 2000. See Final Determination, USITC Pub. 3309, Vol. 1 at 2. ' The Commission cumulated subject imports from France, Germany, Italy, Japan, Singapore and the United Kingdom, see id. at 33, and in June 2000, voted that revocation of the antidumping duty orders on the subject merchandise from those countries would likely lead to continuation or recurrence of material injury within a reasonably foreseeable time. See id. at 52. Plaintiffs inter alia challenge the Commission’s cumulation as well as the Commission’s affirmative determination upon cumulation. On November 3, 2000, this Court granted NMB’s motion for preliminary injunction. An oral argument was held before this Court on October 10, 2001. Additionally, this Court on August 2, 2002, granted NSK-RHP’s motion for preliminary injunction. JURISDICTION The Court has jurisdiction over this matter pursuant to 19 U.S.C. § 1516a(a)(2)(A)(i)(I) (2000) and 28 U.S.C. § 1581(e) (2000). STANDARD OF REVIEW The Court will uphold the Commission’s final determination in a full five-year sunset review unless it is “unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(1)(B)(i) (1994); see NTN Bearing Corp. of America v. United States, 24 CIT 385, 389-90, 104 F.Supp.2d 110, 115-16 (2000) (detailing the Court’s standard of review for agency determinations). “ ‘Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’ ” Matsushita Elec. Indus. Co. v. United States, 750 F.2d 927, 933 (Fed.Cir.1984) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S.Ct. 206, 83 L.Ed. 126 (1938)). “[T]he possibility of drawing two inconsistent conclusions from the [same] evidence does not” preclude the Court from holding that the agency finding is supported by substantial evidence. Consolo v. Federal Mar. Comm’n 383 U.S. 607, 620, 86 S.Ct. 1018, 16 L.Ed.2d 131 (1966). An agency determination will not-be “overturned merely because the plaintiff ‘is able to produce evidence ... in support of its own contentions and in opposition to the evidence supporting the agency’s determination.’ ” Torrington Co. v. United States, 14 CIT 507, 514, 745 F.Supp. 718, 723 (1990) (internal citation omitted), aff'd, 938 F.2d 1276 (Fed.Cir.1991). Additionally, to determine whether the Commission’s interpretation and application of a statute is “in accordance with law,” the Court must undertake the two-step analysis prescribed by Chevron U.S.A. Inc. v. Natural Resources Defense Council, Inc., 467 U.S. 837, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). Under the first step, the Court reviews the Commission’s construction of a statutory provision to determine whether “Congress has directly spoken to the precise question at issue.” Id. at 842, 104 S.Ct. 2778. “To ascertain whether Congress had an intention on the precise question at issue, [the Court] employ[s] the ‘traditional tools of statutory construction.’ ” Timex V.I., Inc. v. United States, 157 F.3d 879, 882 (Fed.Cir.1998) (citing Chevron, 467 U.S. at 843 n. 9, 104 S.Ct. 2778). “The first and foremost ‘tool’ to be used is the statute’s text, giving it its plain meaning. Because a statute’s text is Congress’ final expression of its intent, if the text answers the question, that is the end of the matter.” Id. (citations omitted). Beyond the statute’s text, the tools of statutory construction “include the statute’s structure, canons of statutory construction, and legislative history.” Id. (citations omitted); but see Floral Trade Council v. United States, 23 CIT 20, 22 n. 6, 41 F.Supp.2d 319, 323 n. 6 (1999) (noting that “[n]ot all rules of statutory construction rise to the level of a canon, however”) (citation omitted). If, after employing the first prong of Chevron, the Court determines that the statute is silent or ambiguous with respect to the specific issue, the question for the Court becomes whether the Commission’s construction of the statute is permissible. See Chevron, 467 U.S. at 843, 104 S.Ct. 2778. Essentially, this is an inquiry into the reasonableness of the Commission’s interpretation. See Fujitsu Gen. Ltd. v. United States, 88 F.3d 1034, 1038 (Fed.Cir.1996). Provided the Commission has acted rationally, the Court may not substitute its judgment for the agency’s. See Koyo Seiko Co. v. United States, 36 F.3d 1565, 1570 (Fed.Cir.1994) (holding that “a court must defer to an agency’s reasonable interpretation of a statute even if the court might have preferred another”); see also IPSCO, Inc. v. United States, 965 F.2d 1056, 1061 (Fed.Cir.1992). The “[C]ourt will sustain the determination if it is reasonable and supported by the record as a whole, including whatever fairly detracts from the substan-tiality of the evidence.” Negev Phosphates, Ltd. v. United States, 12 CIT 1074, 1077, 699 F.Supp. 938, 942 (1988) (citations omitted). In determining whether the Commission’s interpretation is reasonable, the Court considers the following non-exclusive list of factors: the express terms of the provisions at issue, the objectives of those provisions and the objectives of the antidumping scheme as a whole. See Mitsubishi Heavy Indus. v. United States, 22 CIT 541, 545, 15 F.Supp.2d 807, 813 (1998). DISCUSSION I. The Commission’s Like Product Determination A. Statutory Background In a five-year review, the ITC determines whether revocation of an anti-dumping duty order would likely “lead to continuation or recurrence of dumping ... [and] material injury.” 19 U.S.C. § 1675(c)(1). “To determine whether an industry in the United States is materially injured or threatened with material injury by reason of imports of the subject merchandise, the ITC must first define the ‘domestic like product’ and the ‘industry’ producing the product.” Chefline Corp. v. United States, 25 CIT -, -, 170 F.Supp.2d 1320, 1325 (2001). Title 19, United States Code, § 1677(10) defines “domestic like product” as “a product which is like, or in the absence of like, most similar in characteristics and uses with, the article subject to an investigation.” 19 U.S.C. § 1677(10) (1994). Section 1677(4)(A) of Title 19 defines “industry” as “the producers as a whole of a domestic like product, or those producers whose collective output of a domestic like product constitutes a major proportion of the total domestic production of the product.” 19 U.S.C. § 1677(4)(A) (1994). In defining the “like product,” the Commission typically considers: (1) physical characteristics and uses; (2) interchangeability of the products; (3) channels of distribution; (4) customer and producer perceptions of the products; (5) the use of common manufacturing facilities and personnel; and (6) price. See Timken v. United States, 20 CIT 76, 80, 913 F.Supp. 580, 584 (1996) (citing Aramide Maatschappij V.O.F. v. United States, 19 CIT 884, 885 (1995); Calabrian Corp. v. United States, 16 CIT 342, 346 n. 4, 794 F.Supp. 377, 382 n. 4 (1992); Torrington Co. v. United States, 14 CIT 648, 652, 747 F.Supp. 744, 749 (1990), aff'd, 938 F.2d 1278 (1991)). “The Commission generally disregards minor differences, and looks for clear dividing lines between like products.” Nippon Steel Corp. v. United States, 19 CIT 450, 455 (1995). Moreover, in its Rules of Practice and Procedure regarding sunset reviews, the Commission has stated: ' In appropriate circumstances, the Commission may revisit its original domestic like product ... determination[ ] in five-year reviews. For example, the Commission may revisit its like product determination when there have been significant changes in the products at issue since the original investigation or when domestic like product definitions differed for individual orders within a group concerning similar products. 63 Fed.Reg. 30,599, 30,602 (June 5, 1998); See also 19 U.S.C. § 1675a(a)(1)(A) (1994). B. Commission Findings “The Commission began its like product determination by reviewing the findings made in the Original Determination.” Def. U.S. ITC’s Mem. Opp’n Pis.’ Mot. J. Agency R. (Def.’s Mem.) at 13. 1. Original Determination In the Original Determination, the ITC “determined], consistent with [its] preliminary determination, that there [were] separate like products, within antifriction bearings generally, based upon the type of rolling element employed.” Original Determination, USITC Pub. 2185 at 16. The ITC found “six separate like products: (1) ball bearingsf;] (2) spherical roller bearings[;] (3) cylindrical roller bearings[;] (4) needle roller bearings[;] (5) spherical plain bearingsf;] and (6) slewing rings.” Id. at 33. Additionally, the Commission rejected arguments to treat wheel hub units and aerospace drive path (“ADP”) ball bearings as separate like products. See id. at 20-25. In particular, with respect to wheel hub units, the Commission stated: [The Commission] determined] that wheel hub units are not a separate like product. They are not significantly different from other ball bearings, especially other housed and mounted ball bearings, in terms of functional characteristics and applications. In addition, like other housed bearings, if the bearing in a wheel hub unit wears out, the entire unit must be replaced. Thus the unit itself is inseparable from its bearing functions. Moreover, none of the respondents agree as to the definition of this allegedly separate like product. Some make no distinction among the generations of wheel hub units, others define the product as generations 2 and 3, and still others define it as just generation 3. Such definitional vagueness was fatal, in [the Commission’s] view, to the evaluation of other candidates for separate like product treatment, such as “aerospace” bearings, and is similarly fatal here.... [The Commission] include[s] wheel hub units in the like product category corresponding to the type of rolling element employed therein. Specifically, in these investigations, they are ball bearings. Original Determination, USITC Pub. 2185 at 21-22 (citations omitted). With respect to ADP bearings, the Commission stated: ■ [The Commission] determined] that “aerospace” bearings, however defined, do not constitute a separate like product. Like product distinctions based solely upon end use are suspect, at least in investigations involving intermediate products such as bearings, in which there are literally thousands of separate products, none of which can be substituted for another in their specific applications. The use of high quality raw materials, extensive documentation of the production process to facilitate traceability, and technologically advanced production methods are common to all su-perprecision bearings and, thus, does ¿not distinguish aerospace bearings from other superprecision bearings that are not consumed by the aerospace industry. Original Determination, USITC Pub. 2185 at 24 (citations and emphasis omitted). 2. Final Determination: Wheel Hub Units During the five-year review at issue, NTN “advocated in response to the notice of institution and in [NTN’s] prehearing brief that the Commission treat wheel hub units as a separate like product.” Final Determination, USITC Pub. 3309, Vol. 1 at 8 (citations omitted); see also Def.’s Mem., App. Vol. 1, Doc. No. 129 (NTN’s Response to the Notice of Institution) at 23-24 and Doc. No. 602 (NTN’s Prehear-ing Brief) at 10-13. In the Final Determination, the Commission stated that “[t]he Commission in its 1989 determination [that is, Original Determination, USITC Pub. 2185 at 20-22] on antifriction bearings other than [tapered roller bearings] considered and rejected arguments that wheel hub units should be carved out as a separate like product from the general category of [ball bearings].” Final Determination, USITC Pub. 3309, Vol. 1 at 8 (citation omitted). 3. Final Determination: ADP Bearings Additionally, during the five-year review at issue, “[s]everal parties argue[d] throughout these reviews that aerospace drive path ... ball bearings ... comprise separate like products.” Final Determination, USITC Pub. 3309, Vol. 1 at 8. In particular, the parties argued that “the Commission in its [Original Determination, USITC Pub. 2185 at 22-25] did not consider the like product issue with respect to the narrow category of ADP bearings as defined in the Commission’s questionnaires and that the prevalent use today of specialty steels to make ADP bearings is a major development since the orders were imposed.” Id. at 9 (citation omitted). Subsequently, the ITC considered whether ADP ball bearings constituted a separate like product and determined: [The Commission] do[es] not find that ADP bearings comprise a separate domestic like product. While the record indicates some differences in physical characteristics, end uses, interchangeability, price, and facilities between ADP bearings and other [ball bearings] ..., [the Commission] find[s] that the similarities outweigh these differences. The record shows that the special materials and special machinery and facilities used to produce ADP bearings are also used in the production of other highly specialized bearings and that other types of precision and non-precision bearings may command prices as high as those for ADP bearings. With respect to interchangeability, all bearings, and not ADP bearings in particular, are only interchangeable with other bearings on a parts number basis. Customer perception is of limited use in distinguishing ADP bearings as a separate product category, given that purchasers typically buy all types of bearings by part number and are familiar only with the specifications of the particular products they purchase. In addition, while ADP bearings are sold only to OEMs [original equipment manufacturers], so is the majority of [United States] producers’ sales of non-ADP ball ... bearings, with [United States] producers shipping 79.1 percent of their [United States] [ball bearing] shipments ... to OEMs. In cases such as the present one, where the domestically manufactured merchandise is made up of a continuum of similar products, [the Commission] normally do[es] not consider each item of merchandise to be a separate domestic like product that is only “like” its counterpart in the scope, but considers] the continuum itself to constitute the domestic like product. Given the “continuum” nature of bearings, then, [the Commission] concluded] that there is no clear dividing line between ADP bearings and all other types of bearings. Final Determination, USITC Pub. 3809, Yol. 1 at 12-13 (citations omitted). C. Analysis 1. Contentions of the Parties: Wheel Hub Units NTN contends that the “ITC erred when it failed to treat wheel hub units as separate like products from ball bearings.” PI. NTN’s Mot. and Mem. Supp. J. Agency R. (NTN’s Mot.) at 69. In particular, NTN argues that the Commission “failed to provide any discernible reasoning whatsoever for [its] decision [not to treat wheel hub units as separate like products from ball bearings], and failed to address the record evidence presented in this review.” Id. at 69-70. Relying on Bowman Transp., Inc. v. Arkansas-Best Freight Sys., Inc., 419 U.S. 281, 285, 95 S.Ct. 438, 42 L.Ed.2d 447 (1974), NTN maintains that the Commission’s Final Determination “violates the mandate that agencies ‘articulate a rational connection between the facts found and the choice made.’ ” NTN’s Mot. at 70; see also id. at 70-71 (citing Taiwan Semiconductor Indus. Ass’n v. United States, 23 CIT 410, 418, 59 F.Supp.2d 1324, 1332 (1999), aff'd, 266 F.3d 1339 (Fed.Cir.2001), reh’g denied, 2001 U.S.App. LEXIS 27637, * (Fed. Cir. Dec. 4, 2001); Asociacion Colombiana de Exportadores de Flores v. United States, 12 CIT 1174, 1177, 704 F.Supp. 1068, 1071 (1988); Burlington Truck Lines, Inc. v. United States, 371 U.S. 156, 167-68, 83 S.Ct. 239, 9 L.Ed.2d 207 (1962)). Moreover, NTN asserts that although the Commission cited to the Original Determination in the Commission’s Final Determination, the Commission “does not indicate that the findings from [the Original Determination ] apply to the separate facts of the record for [the] investigation” at bar, that is, the Final Determination. NTN’s Mot. at 71 (citing ACCIAI Speciali Terni v. United States, 24 CIT 1064, 1080, 118 F.Supp.2d 1298, 1312-13 (2000), dismissed, 4 Fed.Appx. 822, 2001 U.S.App. LEXIS 1651 (Fed.Cir. Jan. 23, 2001)). NTN, therefore, requests that this Court remand this issue to the ITC with instructions “that the ITC provide a rationale for its failure to treat wheel hub units as separate like products from ball bearings.” NTN’s Mot. at 71. Next, NTN argues that the record evidence indicates that wheel hub units should be treated as separate like products from ball bearings because: (1) “wheel hub units have significantly different physical characteristics and end uses from ball bearings ... [that is,] the incorporation of a hub onto which wheels are mounted, special heat treating, low carbon steel as a raw input, and in some cases splined inner rings[,]” id. at 73 (citing PI. NTN’s Pub. Appendices Mot. and Mem. Supp. J. Agency R. (“NTN’s App.”) 9 (NTN’s Prehear-ing Brief) at 10-11); (2) “regarding interchangeability, ... because of their unique construction and unique application, no other bearing product can be substituted for a wheel hub unit[,]” NTN’s Mot. at 73 (citing NTN’s App. 9 at 11); (3) “[r]egard-ing the channels of distribution utilized for wheel hub units, ... [w]heel hub units are sold essentially only to original equipment manufacturers ..., and are typically sold through the automotive parts division, rather than general sales divisions ... and ... typically do not even appear in general bearing catalogs[,]” NTN’s Mot. at 73-74 (citing NTN’s App. 9 at 11-12); (4) “regarding the production facilities, processes, and employees used in the production of wheel hub units, ... the production process [for wheel hub units] is significantly different from the process for ball bearings!,]” NTN’s Mot. at 74 (citing NTN’s App. 9 at 12); and (5) “wheel hub units are priced completely different from ball bearings.” Id. Finally, NTN contends that the Commission drew an unjustified adverse inference because NTN failed to address the like product treatment of wheel hub units at the hearing or in NTN’s posthearing brief. See NTN’s Mot. at 74-76. NTN maintains that: (1) NTN’s Response to the Notice of Institution and prehearing brief “are documents on the record for this matter!,]” id. at 72 (citing 19 U.S.C. § 1516a(b)(2)(A) (1994) and ACCIAI, 24 CIT at 1071, 118 F.Supp.2d at 1305); (2) “the hearing, which was scheduled for one day only, included over 30 filed appearances in support of revocation alone, and very strict time limits on the presentation of information!,]” NTN’s Mot. at 75; and (3) “19 C.F.R. § 201.13(i)(1) (1996) clearly indicates that ‘information produced at the hearing and arguments thereon may be presented to the Commission ... ’ in post-hearing briefs. Therefore, because NTN was unable to raise this issue at the hearing, it was also unable to raise the issue in its post-hearing brief.” Id. The Commission responds that the “Commission’s determination to include wheel hub units in the domestic like product of ball bearings was supported by substantial evidence and in accordance with law.” Def.’s Mem. at 36. Specifically, the Commission asserts that: (1) “the Commission is not required to indicate in its determination that it considered each specific item of evidence!,]” id. at 38 (citing Granges Metallverken v. United States, 13 CIT 471, 478-79, 716 F.Supp. 17, 24 (1989), and Rhone Poulenc, S.A. v. United States, 8 CIT 47, 55, 592 F.Supp. 1318, 1326 (1984)); (2) “[i]n a five-year review, the Commission does not have an obligation, in the absence of new information, to conduct a re-evaluation of a like product issue that it had considered and resolved in the course of the original review absent substantiated circumstances warranting such a review[,]” Def.’s Mem. at 38 (citing Rules of Practice and Procedure, 63 Fed.Reg. at 30,602); (3) unlike the proponents of a separate like product definition for ADP ball bearings, “NTN did not offer any information to indicate that significant changes in the product [that is, wheel hub units] had occurred, warranting a review of the determination,]” Def.’s Mem. at 39; and (4) “the Commission had an unambiguous statement from the only domestic producer of wheel hub units that the product was properly classified as a ball bearing.” Id. (citing Def.’s Mem., App. Vol. 1, Doc. No. 12 at 8 (confidential version)). Additionally, the Commission responds to NTN’s assertion that the Commission drew an adverse inference against NTN since NTN failed to address the like product treatment of wheel hub units at the hearing or posthearing brief by stating that “wheel hub units were mentioned several times by parties in favor of continuation and in favor of revocation ... [and][g]iven that a party had raised the topic, respondent NTN could have responded to the ‘information produced at the hearing and arguments thereon’ in its posthearing brief had it wished to do so.” Def.’s Mem. at 40; see also id. n. 155 (citing Def.’s Mem., App. Vol. 1, Doc. No. 710 at 46, 156, 179, 312, 366 and 392). Moreover, the Commission maintains that NTN fails to point to any evidence that was not available to the Commission in the Original Determination. See Def.’s Mem. at 40. Timken generally agrees with the Commission and maintains that “NTN’s pre-hearing submission ... did not identify any post-investigation changes which might have formed a basis for the Commission to revisit its original determination on the issue.” [Timken’s] Br. Resp. Pis.’ R. 56.2 Mot. J. Agency R. (“Timken’s Resp.”) at 70; see also id. at n. 25 (citation omitted) (“NTN’s prehearing brief discussion was limited to a review of the six factor test also used by the Commission in the original [determination], in support of a determination that wheel hub units were not a separate like product”). Timken further maintains that NTN incorrectly cited to 19 C.F.R. § 201.13(i)(l) for NTN’s proposition that since NTN was unable to raise the wheel hub units issue at the hearing, it was also unable to raise the issue in its post-hearing brief. See Timken’s Resp. at 71-72. Moreover, Timken argues that NTN’s “assertion that the Commission’s decision might be based on adverse inferences against NTN due to [NTN’s] failure to raise the [wheel hub unit] like product issue at the hearing or in [NTN’s] post-hearing brief is baseless” because “the Commission declined to revisit whether [wheel hub units] constituted a separate like product [since] it had already done so in [the] original [determination] and no evidence suggested that re-examination of the issue was warranted.” Id. at 73. 2. Analysis: Wheel Hub Units As a preliminary matter, the Court finds that the Commission’s explanation (that the Commission did not conduct a reevaluation of the like product issue with respect to wheel hub units because there was an absence of new information warranting reconsideration) and the Commission’s reference to the Rides of Practice and Procedure, 63 Fed.Reg. at 30,602, do not amount to post hoc rationalizations. See Hoogovens Staal BV v. United States, 24 CIT 44, 60, 86 F.Supp.2d 1317, 1331 (2000) (holding that “a reviewing court must evaluate the validity of an agency’s decision on the basis of the reasoning presented in the decision itself. An agency determination ‘cannot be upheld merely because findings might have been made and considerations disclosed which would justify its order ...’”) (quoting SEC v. Chenery Corp., 318 U.S. 80, 94, 63 S.Ct. 454, 87 L.Ed. 626 (1943)); see also Burlington Truck, 371 U.S. at 168-69, 83 S.Ct. 239 (“The courts may not accept ... counsel’s post hoc rationalizations for agency action; ... an agency’s discretionary order [must] be upheld, if at all, on the same basis articulated in the order by the agency itself’). Next, the Court disagrees with NTN that the Commission failed to provide a discernible reasoning for its determination not to treat wheel hub units as separate like products from ball bearings and failed to address the record evidence presented in this review. Pursuant to 19 U.S.C. § 1675a(a)(1)(A), “[t]he Commission shall take into account ... its prior injury determinations.... ” “The Commission has interpreted [19 U.S.C.] § 1675a(a)(1)(A) to include its prior like product determinations.” Chefline, 25 CIT at -, 170 F.Supp.2d at 1326 (citations omitted); see also Rules of Practice and Procedure, 63 Fed.Reg. at 30,602 (“the Commission may revisit its like product determination when there have been significant changes in the products at issue since the original investigation”) (emphasis supplied). Moreover, “a domestic like product finding in one investigation is not dispositive of another like product investigation.” ACCIAI, 24 CIT at 1070, 118 F.Supp.2d at 1304 (citing Nippon, 19 CIT at 454-55). However, the Court in AC-CIAI, 24 CIT at 1071, 118 F.Supp.2d at 1304-05 further stated: Where ... the ITC has addressed similar or identical facts, no statute or case authority prohibits it from drawing upon its previous work in addressing the issue at hand.... [T]o find otherwise would require the ITC to ignore its institutional experience and make each like product determination in a vacuum' — -an impractical conclusion which cannot be reasonably endorsed. In the case at bar, the Commission stated in its Final Determination: NTN ... advocated in response to the notice of institution and in their prehear-ing brief that the Commission treat wheel hub units as a separate like product but did not pursue this argument at the hearing or afterwards. [Citing NTN’s Response to the Notice of Institution at 22-24 and NTN’s Prehearing Brief at 10-12]. The Commission in its 1989 determination [Original Determination] on antifriction bearings other than TRBs considered and rejected arguments that wheel hub units should be carved out as a separate like product from the general category of [ball bearings]. Final Determination, USITC Pub. 3309, Vol. 1 at 8. Although the Court agrees with NTN that the Final Determination, USITC Pub. 3309, Vol. 1 at 8, does not contain language “in which the ITC makes the leap from acknowledging that a similar issue was raised in [the Original Determination] to deciding the issue summarily on the basis of its Rules of Practice and Procedure [,]” NTN’s Reply at 24, the Court finds that the Commission did provide a discernible reasoning for its determination not to treat wheel hub units as separate like products from ball bearings. See USEC Inc. v. United States, 27 CIT -, -, 259 F.Supp.2d 1310, 1317 (2003) (quoting Bowman Transp., 419 U.S. at 286, 95 S.Ct. 438 (“the Court may ‘uphold a decision of less than ideal clarity if the agency’s path may reasonably be discerned’ ”)). In particular, since NTN failed to provide record evidence warranting a basis for the Commission to revisit its Original Determination, the Commission in its Final Determination, resorted to its Original Determination and decided not to treat wheel hub units as separate like products from ball bearings. Moreover, the Court does not agree with NTN that the Commission failed to address the record evidence presented in this review, particularly since the evidence presented by NTN does not point to a change in the Original Determination. See USEC Inc. v. United States, 34 Fed.Appx. 725, 726, 2002 U.S.App. LEXIS 7845, *14 (Fed.Cir.2002) (citing Granges Metallverken, 13 CIT at 478-79, 716 F.Supp. at 24 (“The ITC is not required to explicitly address every piece of evidence presented by the parties, and absent a showing to the contrary, the ITC is presumed to have considered all of the evidence on the record”)). Accordingly, the Court sustains the Commission’s decision not to treat wheel hub units as separate like products from ball bearings. 3. Contentions of the Parties: ADP Bearings A. NSK-RHP’s Contentions NSK-RHP contends that the Commission’s determination that ADP ball bearings do not constitute a separate like product is not supported by substantial evidence and is contrary to law. See Mem. P. & A. Supp. NSK-RHP’s Mot. J. Agency R. (“NSK-RHP’s Mot.”) at 4-15, 29-43; Pis.’ Reply Mem. Supp. Mot. J. Agency R. (“NSK-RHP’s Reply”) at 2-19. In particular, NSK-RHP refers to the six factors (physical characteristics and uses, interchangeability, channels of distribution, common manufacturing facilities and personnel, customer and producer perceptions, and price) used by the Commission in defining the “like product” and challenges the Commission’s determination regarding each of the six factors. See id. First, with respect to the physical characteristics and uses factor, NSK-RHP contests the Commission’s finding that “the record shows that other highly specialized bearings use the same special materials as ADP bearings[,]” NSK-RHP’s Mot. at 29, by asserting that: (1) the Commission’s finding is unsupported by substantial evidence because in the Final Determination, USITC Pub. 3309, Vol. 1 at 12, the Commission cited to the Commission’s staff report which in turn cited to- Timken’s post-hearing brief that contains mere factual assertions which are not supported by substantial record evidence, see id.; (2) the Commission should have ignored the statements made by Mr. Gridley, Timken’s Executive Director for Marketing Services and Government Affairs, because he lacked relevant expertise, see id. at 31; and (3) the testimony of Ms. Demerling, president of a domestic firm that produces ADP ball bearings, was rebutted by two other experts and should have therefore been discounted by the Commission. See id. at 33 n. 113 (citing Appendices Mem. P. & A. Supp. NSK-RHP’s Mot. J. Agency R.) (“NSK-RHP’s App.”) 3 and 4 (confidential version). According to NSK-RHP, the Commission “gave too much weight to non-evidence, a non-expert, and a discredited expert.” NSK-RHP’s Mot. at 34. Second, regarding the interchangeability of the products factor, NSK-RHP contends that ADP bearings and non-ADP bearings are not interchangeable and the Commission abused its discretion when “the Commission acknowledged that ADP bearings were not interchangeable with non-ADP bearings, [citing Final Determination, USITC Pub. 3309, Vol. 2 at BB-II — 4] but then dismissed this finding by stating, ‘all ball bearings, and not ADP bearings in particular, are only interchangeable with other bearings on a parts number basis.’ ” Id. at 38 (quoting Final Determination, USITC Pub. 3309, Vol. 1 at 12). NSK-RHP also points to its Statement of Facts arguing that ADP bearings constitute a separate like product. See NSK-RHP’s Mot. at 39; see also id. at 9-11 (citing inter alia NSK-RHP’s App. 5, 9 (confidential version)). Third, with respect to the channels of distribution, NSK-RHP argues that the record evidence “demonstrates that ADP bearing OEM customers, unlike general non-ADP bearing OEM customers, supervise every aspect of ADP bearing production from cradle to grave.” NSK-RHP’s Mot. at 39; see also id. at 13. NSK-RHP further argues that the record evidence also “proves that the aftermarket otherwise common to non-ADP bearings simply does not exist with respect to ADP bearings, because OEM customers of ADP bearings tightly control the distribution of spare parts.” Id. at 39-40; see also id. at 13-14. Fourth, NSK-RHP argues that the Commission’s determination regarding the use of common manufacturing facilities and personnel factor “relies almost exclusively on assertions by counsel for which factual evidence does not exist on the record.” Id. at 34 (citing NSK-RHP’s App. 11 at 17 (answer to Commissioner Hill-man’s question)). NSK-RHP also argues that “[t]he Commission ... erred when it considered MPB’s [that is, a manufacturer of ADP bearings that opposed a separate like product treatment of ADP bearings] uncorroborated assertions and Ms. Demer-ling’s testimony as substantial evidence to support its erroneous conclusion about ADP bearing manufacturing facilities and processes” since “Mr. Ogden ... testified that MPB’s plant ... is dedicated almost exclusively to ADP bearings.” NSK-RHP’s Mot. at 35-36. Moreover, NSK-RHP contends that the website information regarding SKF’s subsidiary and NSK-RHP’s division that was submitted as evidence by the parties opposing that ADP bearings be treated as a separate like product does not support their contentions. See id. at 36. NSK-RHP alleges that its Statement of Facts “proves that substantial evidence on the record supports a finding that bearing companies, including MPB, use separate manufacturing facilities or flow lines to build ADP bearings.” Id. at 37; see also id. at 6-9. Fifth, NSK-RHP asserts that “[t]he Commission abused its discretion when it summarily dismissed the overwhelming factual evidence that customers perceive ADP bearings as a different like product than non-ADP bearings.” NSK-RHP’s Mot. at 40. NSK-RHP maintains that: (1) “there is no evidence on the record that customers perceive ADP bearings and non-ADP bearings as the same like product,]” id.; (2) the opponents of a separate like product treatment for ADP bearings “concede[] that customers perceive ADP bearings to be separate products[,]” id. (citing Final Determination, USITC Pub. 3309, Vol. 1 at 12); and (3) the Commission’s view that “customer perception is of limited use because purchasers buy all types of bearings by part number and are familiar only with the specifications of the particular products they purchase[,]” NSK-RHP’s Mot. at 41 (citing Final Determination, USITC Pub. 3309, Vol. 1 at 12), is not a credible statement pursuant to Torrington Co., 14 CIT at 654-55, 747 F.Supp. at 751, because unlike a casual observer, the Commission should have realized that “ADP bearing customers are critically aware of the differences between ADP bearings and non-ADP bearings, and their functional capabilities” and “to substitute a non-ADP bearing for an ADP bearing ‘would be tantamount to first degree murder.’ ” NSK-RHP’s Mot. at 41 (quoting NSK-RHP’s App. 5 at 331); see also NSK-RHP’s Mot. at 11-13. Finally, NSK-RHP argues that “[t]he factual record demonstrates that ADP bearings generally sell on average at prices much higher than the prices for an average non-ADP bearing.” Id. at 42; see also id. at 14-15. B. NTN’s Contentions NTN argues that the Commission’s statement in the Final Determination, that “the parties seeking to have ADP ball bearings treated as a separate like product from ball bearings set forth a clear dividing line between ADP ball bearings and ball bearings based on, ‘the use of special steels in fabricating ADP bearings[,]’ ” misstates the arguments raised by NTN. NTN’s Mot. at 77 (quoting Final Determination, USITC Pub. 3309, Vol. 1 at 9). NTN maintains that because of this misstatement, the Commission failed to consider that “several factors, when taken together, created a clear dividing line between ADP ball bearings and ball bearings.” NTN’s Mot. at 77. Next, NTN refers to the six factors used by the Commission in defining the “like product” (that is, physical characteristics and uses, interchangeability, channels of distribution, customer and producer perceptions, common manufacturing facilities and personnel, and price) and challenges the Commission’s determination regarding each of the six factors. See NTN’s Mot. at 79-90; see also NTN’s Reply at 27-34. First, with respect to the physical characteristics and uses factor, NTN argues that ADP bearings have different physical characteristics and end uses from ball bearings and that the Commission failed to consider certain record evidence relating to this factor. See NTN’s Mot. at 79-81. In particular, NTN maintains that contrary to the Commission’s findings that non-ADP and ADP bearings have some differences in physical characteristics and the special materials used to produce ADP bearings are also used to produce non-ADP specialized bearings, “there is no other general grouping of ball bearings [other than ADP bearings] in which all of the bearings are made from specialty steel.” Id. at 80 (citing NTN’s App. 9 at 5). NTN further maintains that ADP bearings are designed solely for certain specifically designed uses and “there is no evidence on the record indicating that ADP ball bearings have any alternate commercial use.” NTN’s Mot. at 80 (citing NTN’s Apps. 12 and 13 (confidential versions)). Second, with respect to interchangeability, NTN argues that: (1) the Commission’s “finding that all bearings are interchangeable on a part number basis is irrelevant to the question of whether ADP ball bearings and ball bearings are interchangeable” because the question asked by the ITC in a previous ball bearing investigation regarding interchangeability addressed the actual physical characteristics of ball bearings, NTN’s Mot. at 81-82 (citing Ball Bearings, Mounted or Unmounted, and Parts Thereof, From Argentina, Austria, Brazil, Canada, Hong Kong, Hungary, Mexico, the People’s Republic of China, Poland, the Republic of Korea, Spain, Taiwan, Turkey and Yugoslavia (Preliminary), Inv. Nos. 701-TA-S07, 731-TA-Jp98-511 (“1991 Determination”), USITC Pub. 2374 at 20 (April 1991)); (2) the Commission’s interchangeability finding essentially ignores the interchangeability prong, NTN’s Mot. at 82; and (3) “evidence on the record, which is not contested by any party, indicates that ADP bearings are not even interchangeable between different positions in the same model of aerospace engines[,]” Id. at 83 (citing NTN’s App. 11 (confidential version)); see also NTN’s Apps. 13 and 14 (confidential versions). Third, regarding channels of distribution, NTN contends that contrary to the Commission’s finding, “the channel of distribution for ADP ball bearings is not OEM, but rather, very limited and industry-specific OEM.” NTN’s Mot. at 84 (citing NTN’s App. 11 (confidential version)). Specifically, NTN alleges “there is not so much a ‘channel of distribution’ to aerospace OEMs, but rather, a channel of production contracting by aerospace OEMs.” NTN’s Mot. at 84. Fourth, with respect to the production facilities and personnel factor, NTN argues that this Court “should remand [the Commission’s determination] to the ITC to obtain further information in order to determine the extent to which ADP ball bearings and ball bearings are actually produced (rather than merely tested) at single facilities.” Id. at 85. Fifth, regarding the customer and producer perceptions, NTN contends that the Commission’s finding that “ ‘[c]ustomer perception is of limited use in distinguishing ADP bearings as a separate product category ... is illogical because “the record gives every indication that ADP ball bearing purchasers have very strong, well-documented perceptions regarding ADP versus non-ADP ball bearings.” NTN’s Mot. at 86-87 (quoting Final Determination, USITC Pub. 3309, Yol. 1 at 12); see also NTN’s Mot. at 87 (citing NTN’s App. 13 at 14, 16 (confidential version)). Additionally, NTN argues that “manufacturers of ADP ball bearings also have insightful perceptions concerning ADP ball bearings versus non-ADP ball bearings” but the Commission’s “determination did not address the perceptions of the manufacturers at all.” NTN’s Mot. at 88. Finally, with respect to the price factor, NTN asserts that “[wjhile there are undoubtedly specific bearing models that sell for prices as high or higher than ADP ball bearings, the [Commission] has misinterpreted the record evidence in using these specific bearing models as a comparison against ADP ball bearings in general.” Id. at 89. In particular, “ADP ball bearings are all at the upper end of the price range for bearings, while specific non-ADP models may also be in this price range.” Id. C. Commission’s Contentions The Commission responds that “the Commission’s determination that ADP ball bearings did not constitute a separate domestic like product was supported by substantial evidence and in accordance with law.” Def.’s Mem. at 14; see also id. at 14-36. First, with respect to the physical characteristics and end uses factor, the Commission maintains that “[n]o party disputed that ADP bearings are physically similar to non-ADP bearings, with both including races, cages, and ball rollers.” Id. at 18 (citing Def.’s Mem., App. Vol. 1, Doc. No. 167 at BB-I-29 (confidential version); Def.’s Mem., App. Vol. 1, Doc. No. 710 at 139). The Commission further maintains that the parties in support of a separate like product treatment for ADP bearings do not argue that ADP ball bearings and other ball bearings perform different functions. See Def.’s Mem. at 18. The Commission then responds to the parties’ contentions and argues that: (1) although NTN “may or may not be correct in its contention that there are no other ‘general groupings’ that all require a specific type of specialty steelf,]” the Commission does not need to find a general grouping that uses the same materials and “[t]he record supported the Commission’s conclusion that the use of specialty steels was not unique to the production of ADP bearings!,]” Def.’s Mem. at 19-20; (2) NSK’s arguments regarding the testimony of Ms. Demerling, statements made by Mr. Gridley and statements supplied in a post-hearing submission are without merit because “[t]he Commission, as trier of fact, is the proper party to determine the credibility of witnesses and to interpret reasonably the evidence collected in the course of its investigations.” Id. at 21 (citing Negev Phosphates, Ltd. v. U.S. Dep’t of Commerce, 12 CIT 1074, 1091-92, 699 F.Supp. 938, 953 (1988)). Additionally, the Commission cites to Kern-Liebers USA, Inc. v. United States, 19 CIT 87, 91-92 (1995), and points out that the Court has sustained “a Commission finding that a type of cold-rolled steel which required additional special processing, was produced only for one demanding end use, and was produced only to federally-mandated safety specifications, did not constitute a domestic like product separate from other types of cold-rolled steel.” Def.’s Mem. at 23. Second, responding to the arguments raised by NTN and NSK-RHP with respect to the interchangeability factor, the Commission maintains that: (1) “[i]nter-changeability is ... limited between ADP and non-ADP bearings, as non-ADP bearings are not designed for ADP environments and ADP bearings are not cost-efficient substitutes for non-ADP bearings[,][b]ut the interchangeability between ADP bearings and non-ADP bearings is no more limited than between other ball bearings within the domestic like product that are designed for different uses[,]” id. at 25 (citing Def.’s Mem., App. Vol. 1, Doc. No. 167 at BB-I-33) (confidential version); (2) “[t]he record ... indicated that interchangeability among similar bearings was high, but interchangeability between ball bearings manufactured for specific purposes or to specific tolerances was limited[,]” Def.’s Mem. at 26; and (3) “[t]he record ... indicated that a similarly limited degree of interchangeability existed both between and within ADP and non-ADP ball bearing categories.” Id. at 26-27. Third, responding to the arguments raised by NTN and NSK-RHP with respect to the channels of distribution factor, the Commission argues that: (1) “[t]he record ... reveals evidence that increased customization is the norm for all ball bearing production ... [and] OEM purchasers from every industry are involved in design and manufacture[,]” id. at 28 (citing Def.’s Mem., App. Vol. 1, Doc. No. 140) (Timken’s Post-Hearing Br. Resp. Commissioner Hillman) at 16 (confidential version); and (2) “[pjurchasers themselves believe that they are receiving customized products responsive to their specific end uses.” Def.’s Mem. at 28-29 (citing Def.’s Mem., App. Vol. 1, Doc. No. 167 at BB-I-33) (confidential version). Fourth, responding to the arguments raised by NTN and NSK-RHP with respect to the production facilities and personnel factor, the Commission contends that: (1) “[e]vidence on the record indicated that [a certain number of] domestic producers produced non-ADP bearings on the same equipment as ADP bearings[,]” Def.’s Mem. at 29 (citing Def.’s Mem., App. Vol. 1, Doc. No. 140 at 17) (confidential version); (2) both NSK-RHP and NTN admit that the record contains evidence that a certain number of domestic producers manufactured both ADP and non-ADP bearings at the same location, see Def.’s Mem. at 29-30; (3) NSK-RHP and NTN “misstate the nature of their expert’s testimony and interpret this portion of the like product test too narrowly[,]” id. at 30; and (4) “[t]here is no evidence in the record that non-ADP bearings cannot be produced on ADP equipment, and there is evidence, some of it from plaintiffs own expert, that such production actually occurs.” Id. (citation omitted). Fifth, responding to the arguments raised by NTN and NSK-RHP with respect to the customer and producer perceptions, the Commission maintains that: (1) contrary to NTN’s assertion that the ADP purchasers’ lack of knowledge regarding other bearings indicates that the ADP market is a separate market from the non-ADP market, “[i]f the relative isolation of purchasers extended only to ADP buyers, plaintiffs argument might be valid. But most non-ADP ball bearing producers and purchasers showed little interest ... with products and markets outside their own niche[,]” Def.’s Mem. at 31; (2) contrary to NSK-RHP’s argument, there were two domestic producers of ADP bearings who “opposed a separate like product definition for ADP bearings[,]” id. at 32; (3) contrary to NSK-RHP’s argument that the Commission’s view regarding customer perception is not in accord with Torrington Co., 14 CIT at 654-55, 747 F.Supp. at 751, “in its evaluation of the evidence regarding customer perceptions, in these instant reviews, the Commission recognized that purchasers did have detailed perceptions regarding the bearings that suited their particular purposes ... [but were rarely] knowledgeable about other sections of the market[,]” id. at 33 (citations omitted); and (4) contrary to plaintiffs’ argument that the Commission did not adequately weigh customer and producer perceptions, “[t]he Commission reasonably determined that the evidence regarding product perception was limited because of the breadth of the product and buyers’ limited knowledge, and weighed the evidence accordingly.” Def.’s Mem. at 34. Finally, responding to NSK-RHP’s and NTN’s arguments regarding the price factor, the Commission asserts: The data ... indicates that overall ADP bearing prices are somewhat-higher than prices for non-ADP bearings. But the data on the record for both ADP and non-ADP bearings shows tremendous variation in price, depending in part on the size, order volume, and material used in fabricating the bearing. The Commission thus reasonably determined that this evidence of variation in price, across both ADP and non-ADP bearings, did not warrant treating ADP bearings as a separate like product. Id. at 36. Moreover, the Commission maintains: The domestic like product of ball bearings covered a wide variety of products. In reaching its determination regarding like product, the Commission considered its original like product determination and its practice in other cases involving similar ‘continuum’ products. While acknowledging record evidence favoring a separate like product for ADP bearings, the Commission weighed all of the available like product evidence and concluded that a bright diving line did not exist. Id. D. Timken’s Contentions Timken generally agrees with the Commission and maintains that the Commission’s determination that ADP bearings did not constitute a separate like product is supported by substantial evidence. See Timken’s Resp. at 74-95. Timken additionally argues inter alia that: (1) “NSK-RHP’s attacks on witness credibility and citations used in [Timken’s] post-hearing brief to the Commission are inappropriate[,]” id. at 80, see also id. at 80-85; (2) “contrary to NTN’s assertion, the Commission reasonably determined there was no clear dividing line between ADP and non-ADP bearings[,]” id. at 85; see also id. at 85-87; and (3) contrary to NTN’s argument that the Commission departed from a previous ball bearing investigation when addressing the interchangeability factor, the Commission in the 1991 Determination, USITC Pub. 2374, “as in the present sunset determination ... found that the interchangeability prong of its like product test unhelpful in making its like product determination.” Id. at 90. 4. Analysis: ADP Bearings As a preliminary matter, the Court finds that NSK-RHP’s arguments regarding the testimony of a witness, statements made by a witness and statements supplied in a post-hearing submission are without merit. See Floral Trade Council v. United States, 20 CIT 595, 600 (1996) (quoting Negev Phosphates, 12 CIT at 1092, 699 F.Supp. at 953) (“ ‘assessments of the credibility of witnesses are within the province of the trier of fact. This Court lacks authority to interfere with the Commission’s discretion as trier of fact to interpret reasonably evidence collected in the investigation’ ”). Next, the Court finds that the Commission’s determination that ADP bearings do not constitute a separate like product is supported by substantial evidence and is in accordance with law. The Commission’s like product determination is a factual determination that is conducted on a case-by-case basis. See Chefline Corp., 25 CIT at --, 170 F.Supp.2d at 1327 (citing Torrington Co., 14 CIT at 652 n. 3, 747 F.Supp. at 749 n. 3). As stated above, the Commission considers the following six factors in defining the like product: (1) physical characteristics and uses; (2) interchangeability of the products; (3) channels of distribution; (4) customer and producer perceptions of the products; (5) the use of common manufacturing facilities and personnel; and (6) price. See Timken, 20 CIT at 80, 913 F.Supp. at 584 (citation omitted). The Court “review[s] the Commission’s determination for substantial evidence, bearing in mind that ‘it is not the province of the courts to change the priority of the relevant like product factors or to reweigh or judge the credibility of conflicting evidence.’ ” Chefline Corp., 25 CIT at -, 170 F.Supp.2d at 1327-28 (quoting Chung Ling Co. v. United States, 16 CIT 636, 648, 805 F.Supp. 45, 55 (1992)). Additionally, “ ‘minor differences’ ... do not merit a separate like product determination.” Kern-Liebers, 19 CIT at 92 (citing Cambridge Lee Indus., Inc. v. United States, 13 CIT 1052, 1055, 728 F.Supp. 748, 750-51 (1989)) (quoting in turn S.Rep. No. 249, 96th Cong., 1st Sess. 90-91 (1979), reprinted in 1979 U.S.C.C.A.N. 381, 476-77 (the like product determination “should not be narrowly interpreted ‘as to permit minor differences in physical characteristics or uses to lead to the conclusion that the [domestic] product and [the imported] article are not “like” each other’ ”)). In the case at bar, the Commission determined that: ADP bearings [do not] comprise a separate domestic like product. While the record indicates some differences in physical characteristics, end uses, interchangeability, price, and facilities between ADP bearings and other [ball bearings] ..., [the Commission] find[s] that the similarities outweigh these differences. The record shows that the special materials and special machinery and facilities used to produce ADP bearings are also used in the production of other highly specialized bearings and that other types of precision and non-precision bearings may command prices as high as those for ADP bearings. With respect to interchangeability, all bearings, and not ADP bearings in particular, are only interchangeable with other bearings on a parts number basis. Customer perception is of limited use in distinguishing ADP bearings as a separate product category, given that purchasers typically buy all types of bearings by part number and are familiar only with the specifications of the particular products they purchase. In addition, while ADP bearings are sold only to OEMs, so is the majority of [United States] producers’ sales of non-ADP ball ... bearings, with [United States] producers shipping 79.1 percent of their [United States] [ball bearing] shipments ... to OEMs. In cases such as the present one, where the domestically manufactured merchandise is made up of a continuum of similar products, [the Commission] normally do[es] not consider each item of merchandise to be a separate domestic like product that is only “like” its counterpart in the scope, but considers] the continuum itself to constitute the domestic like product. Given the “continuum” nature of bearings, then, [the Commission] conclude[s] that there is no clear dividing line between ADP bearings and all other types of bearings. Final Determination, USITC Pub. 3309, Vol. 1 at 12-13 (citations omitted). In turn, the evidence presented by NSK-RHP and NTN does not prove that the Commission’s finding is not supported by substantial evidence, but rather, calls for the Court to reach a different conclusion. This, the Court is not willing to do. See Consolo, 383 U.S. at 620, 86 S.Ct. 1018 (“the possibility of drawing two inconsistent conclusions from the [same] evidence does not” preclude the Court from holding that the agency finding is supporte