Full opinion text
OPINION POGUE, Judge. This matter arises from an affirmative antidumping duty determination by the Depaxtaient of Commerce (“Commerce”) in its investigation of wooden bedroom furniture from the People’s Republic of China (“PRC”). Plaintiffs challenge numerous aspects of that determination here. Before the court are USCIT R. 56.2 Motions for Judgment on the Agency Record filed by the parties, specifically by Dorbest Limited et al (“Dorbest” also known as “Respondents”), the American Furniture Manufacturers Committee for Legal Trade et al. (“AFMC” also the “Petitioners” in the investigation), and Commerce. For the reasons set forth below, the court grants in part each of these motions and denies in part each of these motions; the coui’t also reserves decision on several issues pending the results on remand. BACKGROUND A. On December 17, 2003, Commerce commenced an antidumping investigation of wooden bedroom furniture from the PRC in response to a petition filed by the domestic industry. See Wooden Bedroom, Furniture from, the People’s Republic of China, 68 Fed.Reg. 70,228 (Dep’t Commerce Dec. 17, 2003) (initiation of anti-dumping duty investigation). The investigation covered more than 211 Chinese exporters/producers of wooden bedroom furniture making this one of the largest investigations involving PRC companies. See Wooden Bedroom, Furniture from, the People’s Republic of China, 69 Fed.Reg. 35,312, 35,313 (Dep’t Commerce June 24, 2004) (notice of preliminary determination and postponement of final determination) (“Preliminary Determination ”). The period of investigation (“Period of Investigation” or “POI”) encompassed imports of the subject merchandise from April 1, 2003 through September 30, 2003. Commerce rendered an affirmative less than fair value determination for the subject merchandise and imposed the antidumping duty order and dumping margins that are at issue here. Wooden Bedroom Furniture from the People’s Republic of China, 69 Fed.Reg. 67,313, 67,317 (Dep’t Commerce Nov. 17, 2004)(notice of final determination of sales at less than fair value) (“Final Determination ”) amended by Wooden Bedroom Furniture from the People’s Republic of China, 70 Fed.Reg. 329, 330 (Dep’t Commerce Jan. 4, 2005) (notice of amended final determination of sales at less than fair market value and antidumping duty order) (“Amended Final Determination ”). More specifically, Commerce determined that the PRC is an NME country and that available information did not permit the foreign market value of the merchandise to be determined as it would in a market economy. See Preliminary Determination, 69 Fed.Reg. at 35,318. Consequently, Commerce derived the respondent’s normal value through aggregating the surrogate costs of the factors of production required to produce the product. See id. at 35,324. Because of the large number of companies under investigation, pursuant to 19 U.S.C. § 1677Í-1 (c)(2)(B), Commerce limited its investigation to the seven largest manufacturers of wooden bedroom furniture from the PRC. Among these seven was Respondent Dorbest. See Preliminary Determination, 69 Fed.Reg. at 35,-318. In the investigation, Commerce chose India as the surrogate country and chiefly relied on a data set referred to as the Monthly Statistics of Foreign Trade in India (“MSFTI”) to value the factors of production (numbering over 500). Id.; Id. at 35,324; Memorandum from James H. Joe-hum to Jeffrey A. May, Issues and Decision Memorandum for the Less-Thark-Fair-Value Investigation of Wooden Bedroom Furniture from the People’s Republic of China, at 41 (Cmt.2), Dep’t of Commerce (November 8, 2004), P.R. Doc.1933, available at http://ia.i ta.doc.gov/frn/sum-mary/prc/04-25507-l.pdf (“Issues & Decision Mem.”). Likewise, Commerce used arne. financial statements from Indian companies to calculate profit, overhead, and general expenses. Id. at 23. For its calculation of the wage rate, Commerce ran a regression to determine the relationship between nations’ per capita Gross National Product and their wage rates; Commerce then multiplied the resulting coefficient by the PRC’s per capita gross national product to derive China’s wage rate. See Wooden Bedroom Furniture from the People’s Republic of China: Final Results of Redetermination Pursuant to Court Remand Orders (Dep’t Commerce Aug. 1, 2005) (“Remand Determination”). B. The court must sustain a final determination in an antidumping duty investigation if that determination is supported by substantial evidence on the record and is otherwise in accordance with law. 19 U.S.C. § 1516a(b)(1)(B)(i) (2000); Ta Chen Stainless Steel Pipe, Inc. v. United States, 298 F.3d 1330, 1335 (Fed.Cir.2002). The parties here have collectively alleged more than a score of issues requiring review, some with multiple subparts. To issue a coherent opinion, the court has grouped the issues as follows: (1) Commerce’s selection of data sets, specifically, (a) Commerce’s use of Indian surrogate data to value the factors of production, (b)Commerce’s use of the MSFTI, (c) Commerce’s calculation of the wage rate, and (d) Commerce’s selection of surrogate companies for the calculation of profit, overhead, and selling, general and administrative expenses (collectively “financial ratios”); (2) Commerce’s valuation of certain specific factors of production; (3) other individual company-specific protests; and (4) the application (or lack thereof) of adverse inferences in Commerce’s selection of facts otherwise available. For ease of reference, the discussion is organized as follows: I. DATA SETS.............................................................1267 A. Selection of Surrogate Countries .......................................1270 (1) Evaluation of Indonesian Data......................................1272 (2) Commerce’s finding that India was a producer of the comparable merchandise....................................................1273 (3) Commerce’s finding that India was a significant producer of subject merchandise....................................................1274 (4) Weighing the choice between Indonesia and India.....................1274 B. Monthly Statistics of Foreign Trade in India.............................1276 (1) In general .......................................................1276 (2) MSFTI as a primary data set.......................................1276 (3) MSFTI as applied to individual factors...............................1278 (a) Mirrors......................................................1279 (i) Imported Mirrors As Inputs...............................1279 (ii) Glass Yug...............................................1280 (iii) Tarun Vadehra, Highland House and Goldfindo ..............1282 (iv) The MSFTI data is either non-inclusive or distortive of mirror inputs..........................................1283 (v) Infodrive India...........................................1284 (vi) Commerce’s evaluation....................................1286 (b) Paints........................................................1288 (e) Cardboard....................................................1290 C. Wage rate...........................................................1291 (1) Facial Challenge..................................................1292 (2) As Applied Invalidity..............................................1292 (a) Creation of the Regression Model ...............................1294 (i) Notice and Comment Rulemaking..........................1295 (ii) Deadlines ...............................................1296 (b) Distortion of Regression Model..................................1296 (3) Proper Data Set..................................................1299 D. Financial Ratios......................................................1300 (1) IFP.............................................................1302 (2) Jayaraja.........................................................1303 (3) Evergreen.......................................................1304 (4) Swaran, Nizamuddin, Fusion Design, and DnD........................1305 (5) Indonesian Firms.................................................1307 II. VALUING SPECIFIC FACTORS OF PRODUCTION........................1308 (A) Hooks and Connectors................................................1309 (B) Hinges..............................................................1309 (C) Resin...............................................................1310 (D) Styrofoam...........................................................1311 (E) Cardboard...........................................................1312 (F) Iron Components.....................................................1313 III. DISCRETE COMPANY-SPECIFIC ISSUES ...............................1314 (A) Voluntary Remand Issues.............................................1314 (B) Zeroing.............................................................1315 IV. FACTS OTHERWISE AVAILABLE/ADVERSE INFERENCES..............1317 (A) Factor Inputs........................................................1319 (B) Wood Scraps.........................................................1321 V. CONCLUSION...........................................................1321 I. DATASETS As noted above, because pricing information in NMEs is largely unreliable, section 223 of the Tariff Act of 1930, 19 U.S.C. § 1677b(c)(1) authorizes Commerce to approximate the cost of production with pricing information from “surrogate” countries and companies. The court notes that the antidumping duty statute both authorizes and requires that “the valuation of the factors of production shall be based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate by the administering authority.” 19 U.S.C. § 1677b (c)(1) (emphasis added); see also Globe Metallurgical, Inc. v. United States, 28 CIT -, -, 350 F.Supp.2d 1148, 1156-57 (2004). The term “best available” is one of comparison, ie., the statute requires Commerce to select, from the information before it, the best data for calculating an accurate dumping margin. The term “best” means “excelling all others.” II Oxford English Dictionary 139(2d 1989); Webster’s II New Riverside University Dictionary 168 (1988) (“[exceeding all others in excellence, achievement, or quality”). This “best” choice is ascertained by examining and comparing the advantages and disadvantages of using certain data as opposed to other data. See Guangdong Chemicals Imp. & Exp. Corp. v. United States, 30 CIT ——, 460 F.Supp.2d 1365, 1370, 2006 WL 2679989, *5, Slip Op. 06-142, at 8 (Sept. 18, 2006). In calculating factors of production, Commerce typically employs data sets. Court review of whether Commerce’s data set selection is the “best available information” addresses whether the particular selection is supported by substantial evidence and whether it is in accordance with law. Whether a data set selection issue is factual or legal, ie., reviewed for substantial evidence or for its accordance with law, depends on the question presented. If the question is whether Commerce may use a particular piece of data, whether Commerce may use a factor in weighing the choice between two data sources, or what weight Commerce may attach to such a factor, the question is legal. Cf. Writing Instrument Mfrs. Ass’n v. U.S. Dep’t of Commerce, 21 CIT 1185, 1187-88, 984 F.Supp. 629, 634 (1997); Lasko Metal Prods., Inc. v. United States, 43 F.3d 1442, 1446 (Fed.Cir.1994); Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1377 (Fed.Cir.1999). If the question is whether Commerce should have used a particular piece of data, when viewed among alternative available data, or what weight Commerce should attach to a price or data, the question is factual. Cf. Shandong Haurong Machinery Co., v. United States, 29 CIT-,-, Slip Op 05-54 at 10 (2005); Yantai v. United States, 26 CIT 605, 607, 610-612 (2002). In reviewing legal issues presented here, the court applies the two-step inquiry of Chevron U.S.A. Inc. v. Natural Res. Def. Council, Inc., 467 U.S. 837, 842-843, 104 S.Ct. 2778, 81 L.Ed.2d 694 (1984). Accordingly, Commerce has considerable discretion in selecting a data source. See Nation Ford Chem. Co. v. United States, 166 F.3d at 1377. Commerce’s exercise of its discretion, however, must still have fidelity to its statutory mandate. Statutorily, Commerce has a duty to ensure that dumping margins are calculated as accurately as possible. See, e.g., Allied-Signal Aerospace Co. v. United States, 996 F.2d 1185, 1190 (Fed.Cir.1993); Rhone Poulenc, Inc. v. United States, 899 F.2d 1185, 1191 (Fed.Cir.1990). This rule applies with equal force to imports from an NME. S.Rep. No. 100-71 at 106 (1987) (Committee on Finance)(“[t]he Committee is particularly concerned that imports from certain nonmarket economy countries, such as the Peoples Republic of China, not be unfairly disadvantaged by use of the new methodology where price differences can be accounted for in whole or in part by quality differences in the imported merchandise.”). On factual issues, the court’s role “is not to evaluate whether the information Commerce used was the best available, but rather whether a reasonable mind could conclude that Commerce chose the best available information.” Goldlink Indus. Co. v. United States, 30 CIT-, -, 431 F.Supp.2d, 1323, 1327 (2006); see also CITIC Trading Co. v. United States, 27 CIT -, -, 2003 WL 1587093, *6 (2003) (“while the standard of review precludes the court from determining whether Department’s [sic] choice of surrogate values was the best available on an absolute scale, the court may determine the reasonableness of Commerce’s selection of surrogate prices.”); cf. Klein v. Peterson, 866 F.2d 412, 414 (Fed.Cir.1989) (reconciling an agency’s duty to find clear and convincing evidence of misconduct with the court’s substantial evidence standard of review as “a reasonable mind could have found the evidence of misconduct clear and convincing”). For the court to conclude that a reasonable mind would support Commerce’s selection of the best available information, Commerce needs to justify its selection of data with a reasoned explanation. Cf. Lasko Metal Prods. v. United States, 43 F.3d 1442, 1446 (Fed.Cir.1994); see Olympia Indus., Inc. v. United States, 22 CIT 387, 390, 7 F.Supp.2d 997, 1001 (1998) (“Commerce has an obligation to review all data and then determine what constitutes the best information available or, alternatively, to explain why a particular data set is not methodologically reliable”). In doing so, Commerce must “conduct a fair comparison of the data sets on the record” with regard to its announced method or criteria. Allied Pac. Food (Dalian) Co. v. United States, 30 CIT-,-, 435 F.Supp.2d 1295, 1313-14 (2006). The court must also recognize that Commerce has limited resources and is under time constraints and, therefore, a certain level of imprecision is not unreasonable. See Geum Poong Corp. v. United States, 26 CIT 991, 995 (2002). In addition, choosing the best data requires expertise and, on occasion, judgment. See Lasko Metal Prods., 43 F.3d at 1446; cf. Motor Vehicle Mfrs. Ass’n of U.S., Inc. v. State Farm Mut. Aut. Ins. Co., 463 U.S. 29, 52, 103 S.Ct. 2856, 77 L.Ed.2d 443 (1983) (“It is not infrequent that the available data do not settle a regulatory issue, and the agency must then exercise its judgment in moving from the facts and probabilities on the record to a policy conclusion.”). Accordingly, parties and courts may aspire to, but cannot demand, perfection. Moreover, “the court may not substitute its judgment for that of the [agency] when the choice ‘is between two fairly conflicting views, even though the court would justifiably have made a different choice had the matter been before it de novo.’ ” Goldlink Ind. Co. v. United States, 30 CIT at-, 431 F.Supp.2d at 1326 (quoting Am. Spring. Wire Corp. v. United States, 590 F.Supp. 1273, 8 CIT 20, 22 (1984)). Another related principle that may seem obvious, but is relevant here, is that Commerce’s findings or conclusions rendered in equations or numeric form are not beyond scrutiny. Id.; accord Geum Poong, 26 CIT at 995. Scrutiny of surrogate values is important because they are proxies — they are not actual costs but estimates based on the best available information. If the proxy values selected prove unrepresentative, reliance on them defeats their purpose, namely, to derive a dumping margin that is as accurate as possible. See, e.g., Goldlink Indus., 30 CIT at -, 431 F.Supp.2d at 1334. Hence, if Commerce selects a particular data set that is demonstrably unrepresentative or distortional, a reasonable mind may rightly, question how such a selection could be the “best.” It may in fact be the best available information, but affirming Commerce’s choice requires a reasoned explanation from Commerce that is supported by the administrative record. In considering Commerce’s announced criteria, an additional consideration is that merely enlarging the size of an unrepresentative data set does not necessarily mean that a reasonable mind can conclude that the data set is the best available on the administrative record. Data sets need not be large (proportional to all possible data points) if the means of selecting the data points is statistically sound, e.g., statistical sampling. Similarly, a large but biased data set is of limited (if any) probative value. Cf. Bazemore v. Friday, 478 U.S. 385, 400, 106 S.Ct. 3000, 92 L.Ed.2d 315 (1986). For example, a researcher attempting to assess the literacy rate in the United States who surveys every college graduate in the country would create a large data set that has absolutely no probative value; however, a researcher who randomly samples a few thousand people, chosen from the population at large, would create a valuable data set. With these considerations in mind, the court’s review of Commerce’s compilation of data sets will focus on the soundness of Commerce’s announced method or criteria in selecting data points, and its adherence thereto. Cf. Shanghai Foreign Trade Enters. Co. v. United States, 28 CIT-, 318 F.Supp.2d 1339, 1351-52 (2004). A. Selection of Surrogate Countries As noted above, “the valuation of the factors of production shall be based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate.” 19 U.S.C. § 1677b(c)(1) (emphases added). The statute further specifies that an “appropriate” market economy country is one “(A) at a level of economic development comparable to that of the nonmarket economy country, and (B) [a] significant producer[ ] of comparable merchandise.” 19 U.S.C. § 1677b(c)(4). Pursuant to this statutory direction, Commerce’s regulations specify that, other than for valuing labor costs, it “normally will use publicly available information to value factors” and that it “normally will value all factors in a single surrogate country.” 19 C.F.R. § 351.408(c)(1) & (2) (emphases added). As emphasized, Commerce “normally” will use pricing data from the surrogate country selected. The use of the word “normally” means that Commerce may select other data as warranted under the circumstances. Though Commerce, as is true of all agencies, is due deference for its reasonable interpretation of its own regulations, NSK Ltd. v. Koyo Seiko Co., 190 F.3d 1321, 1326 (Fed.Cir. 1999) (“we accord substantial deference to Commerce’s interpretations of its own regulations.”), the use of “normally” indicates that Commerce intends to give itself leeway in the selection of surrogate countries. However, Commerce cannot use this language to allow itself flexibility while simultaneously using the language to disallow consideration of data from other countries without regard for its own stated criteria. Cf. Shanghai Foreign Trade Enters. Co. v. United States, 28 CIT -, --, 318 F.Supp.2d 1339, 1351-52 (2004) (“Commerce’s decision to use Indian Import Statistics suffers from the same flaw that Commerce alleges as a basis for rejecting plaintiffs alternatives.”). For example, Commerce’s regulations acknowledge that “where a factor is purchased from a market economy supplier and paid for in a market economy currency, [Commerce] normally will use the price paid to the market economy supplier.” 19 C.F.R. § 351.408(c)(1). As such, the selection of a surrogate country does not require that the particular data that is used to value a specific factor of production also come from that surrogate country; rather, it appears that Commerce’s selection of a surrogate country creates, at most, a re-buttable presumption in favor of data from that surrogate country. In selecting the surrogate country, Commerce employs a four step process. First, Commerce compiles a list of countries that are at a level of economic development comparable to the country being investigated. Department of Commerce, Import Administration Policy Bulletin 04.1: Non-Market Economy Surrogate Country Selection Process at 2 (March 1, 2004), available at http://ia.ita.doc.gov/policy/bull 04-l.html. (“Policy Bulletin”). Commerce then ascertains which, if any, of those cited countries produce comparable merchandise. Id. Next, from the resulting list of countries, Commerce determines, which, if any, of the countries are significant producers of said comparable merchandise. Finally, Commerce evaluates the quality, e.g., the reliability and availability, of the data from those countries. Id. at 3. Upon review of these criteria, Commerce chooses the country most appropriate for use as a surrogate for the investigation. Here, Commerce listed five countries as economically comparable to the PRC: India, Indonesia, Sri Lanka, Pakistan and the Philippines. Memorandum from Jon Freed, Case Analyst, to File, through Edward C. Yang, Office Director & Robert Bolling, Program Manager, Re: Anti-dumping Investigation of Wooden Bedroom Furniture from the People’s Republic of China: Selection of a Surrogate Country, Dep’t of Commerce (March 8, 2004), P.R. Doc. 619. at 1 (“Surrogate Country Selection Mem.”). No party contests this finding. Id. at 5. Next, Commerce found that both India and Indonesia produced comparable merchandise. Commerce found that both countries are significant producers of comparable merchandise. Issues & Decision Mem., P.R. Doc. 1933 at 38, 40 (Cmt.2); but see id. at 41. Last, Commerce evaluated and compared the quality of Indian and Indonesian data. Although Respondents placed domestic Indonesian pricing data on the record, Commerce rejected this data in favor of Indonesian import statistics. Focusing then on Indonesian import statistics, Commerce found that Indian import statistics were preferable to its Indonesian counterpart because: (1) Indonesian data had been unsatisfactory in other investigations; (2) Indonesian “information was either unreliable or the Indonesian import statistics were reported in units for which the Department was unable to obtain a comparable value ... and (3) there existed gaps in the Indonesian data which required the use of gap-filler data that Commerce “prefers not to use unless there are clear distortions in the surrogate price import statistics .... ” Issues & Decision Mem., P.R. Doc.1933 at 42 (Cmt.2). Therefore, Commerce selected India as its surrogate country for this investigation. Respondents challenge Commerce’s approach in several respects: (1) that Commerce erred in rejecting Indonesian data^ — both its domestic and import statistics; (2) that India is not a producer of products identical to the subject merchandise; (3) that Indian production of the subject merchandise is not significant; and (4) Commerce erred in weighing the evidence, in the aggregate, that India was preferable to Indonesia. Though the weighing of the data is considered to be the fourth step of Commerce’s process of selecting a surrogate country, the court will address the issues regarding Indian and Indonesian data first, as the data issues are intertwined with all aspects of selecting a surrogate country. (1) Evaluation of Indonesian Data Commerce has indicated that it does not have sufficient data from Indonesia, that the data it does have is suspect, and that it has had data problems with Indonesia in the past. Issues & Decision Mem., P.R. Doc.1933 at 42 (Cmt.2). These comments seem to be directed primarily towards the use of Indonesian import data, rather than Indonesian domestic data. However, a closer examination of the record indicates that Commerce also considered the domestic Indonesian data in its evaluation. Under established case-law, “[t]he decision on which price to use — domestic or import — is based on which value will result in a more accurate normal value.” Rhodia, Inc. v. United States, 25 CIT 1278, 1286, 185 F.Supp.2d 1343, 1352 (2001); Hebei Metals & Minerals Imp. & Exp. Corp. v. United States, 28 CIT - — -,-, 2004 WL 1615597, *8 (2004)(“Hebei I”). Commerce may prefer one to the other so long as a reasonable mind could find that the one preferred is more accurate than the other. See Goldlink Indus., 30 CIT at -, 431 F.Supp.2d at 1334; cf. Yantai Oriental Juice Co. v. United States, 26 CIT 605, 617 (2002). Here, Commerce found that respondent-selected domestic Indonesian data price lists are not more reliable than import statistics because “single prices from a narrow source are not necessarily representative of an entire industry during the entire period of investigation.” Def.’s Resp. Pls.’ Surrogate Value Related Rule 56.2 Mots. J. Agency R. 26 (“Def.’s Br.”); Issues & Decision Mem., P.R. Doc.1933 at 42 (Cmt.2); Polyethylene Retail Carrier Bags from the People’s Republic of China, 69 Fed.Reg. 34,125 (Dep’t Commerce June 18, 2004) (notice of final determination of sales at less than fair value) and accompanying Issues and Decision Memorandum at 47 (Cmt.9) available at http://ia.ita.doc. gov/frn/summary/prc/04-13815-l.pdf (“the experience of a single producer is less representative of the cost of an input in a surrogate country.”). In contrast, import statistics encompass a broader range of pricing data that are more representative of an entire industry during the entire period of investigation. Commerce was also “unable to find substantial information or directories for Indonesian furniture manufactures [sic].” Surrogate Country Selection Mem., P.R. Doc. 619 at 5. In addition to finding that Indonesian domestic data or price lists were wanting, Commerce found that Indonesian import data (1) had been unsatisfactory in other investigations; (2) that “information was either unreliable or the Indonesian import statistics were reported in units for which the Department was unable to obtain a comparable value ... and (3) “because of the inadequacies of the Indonesian import statistics [Respondents] submitted gap-filler data from various sources that the Department prefers not to use unless there are clear distortions in the surrogate price import statistics.... ” Issues & Decision Mem., P.R. Doc.1933 at 42 (Cmt.2). Admittedly, there is some circularity to Commerce’s explanation. Commerce rejected Indonesian domestic data due to its lack of completeness, and then rejected Indonesian import data due to the need to use “gap-filler” data which it will not use without finding distortion in import data. However, Commerce’s finding on the whole that Indonesian data is unreliable and insufficient is supported by substantial evidence. Respondents do admit that some of the Indonesian data is unreliable or unusable. Id. Though respondents do point to gap-filler data (such as “Indonesian domestic prices for woods and processed woods for the period of investigation published by the International Tropical Timber Organization (TTTO’))/’ Mem. P. & A. Support Pis.’ & Pl.-Intervenors’ Rule 56.2 Mot. J. Agency R. 10 (“Pis.’ Br.”), this represents but one set of various inputs required for valuing the factors of production. Assuming without deciding, that the ITTO data is reliable, accurate, and contemporaneous, it is still reasonable for Commerce to find, on the record here, that in toto the combination of domestic and import data from Indonesia was not of a sufficient quality or amount to allow for the valuation of all the necessary factors of production, and for the calculation of financial ratios. Therefore, Commerce’s determination that the Indonesian data was unreliable is supported by substantial evidence. (2) Commerce’s finding that India was a producer of the comparable merchandise Commerce’s determination that India is a producer of comparable merchandise is also supported by substantial evidence. Commerce found evidence on the record to indicate that India produces comparable furniture. Surrogate Country Selection Mem., P.R. Doc. 619 at 5; Issues & Decision Mem., P.R. Doc.1933 at 39 (Cmt.2) (“Respondents do not argue that India does not produce wooden bedroom furniture.”). In particular, Commerce found that International Furniture Producers, an Indian company, as well as other companies were significant producers of wooden bedroom furniture. Surrogate Country Selection Mem,., P.R. Doc. 619 at 5. Respondents, contend, however, that the finding that India produces comparable merchandise is irrelevant in the face of the fact that Indonesia produces identical merchandise. Pis.’ Br. 13-14, 16. As Respondents noted in their brief, Commerce automatically considers a producer of identical merchandise to be a producer of comparable merchandise. Pis.’ Br. 13. Respondents argue that because Indonesia produces identical merchandise, and they contend India does not, Indonesia should automatically be selected as the surrogate country. Commerce, however, does not always choose the producer of identical merchandise, if there is one. Commerce explains in its Policy Bulletin that “[if] considering a producer of identical merchandise leads to data difficulties, the operations team may consider countries that produce a broader category of reasonably comparable merchandise.” Policy Bulletin at n. 6. It appears to the court that this analysis is in accordance with the legislative history of the governing statute: Because the Commerce Department may have difficulties in getting detailed data from countries not subject to investigation, the bill gives the Commerce Department authority to use “comparable merchandise” as the basis for foreign market value. Comparable merchandise is a broader category than the “such or similar” merchandise comparison which is usually used in antidumping investigations. S.Rep. No. 100-71 at 106 (1987) (Committee on Finance). Given that Commerce chooses the surrogate country and identifies comparable merchandise on a case-by-case basis, it is reasonable for Commerce to decline to make the producer of identical merchandise the automatic choice. The process of constructing an export price is a necessarily laborious and data-intensive process, and it is reasonable, and necessary, for Commerce to feel assured that the data it is employing is sufficient and reliable. Therefore, assuming that Indonesia is a producer of identical merchandise, that identity does not upset Commerce’s determination that India produces comparable merchandise. The statute does not require Commerce to find a producer of identical merchandise, but rather a producer of comparable merchandise. Though Commerce has indicated a preference for identical goods, that preference must sometimes take second-seat if the use of identical goods leads to data selection problems. Given Commerce’s finding that Indonesian data was unreliable, Commerce’s decision to look to comparable producers of subject merchandise was supported by substantial evidence, as was its determination that India is a producer of comparable merchandise. (3) Commerce’s finding that India was a significant producer of subject merchandise In addition to determining that a country produces comparable merchandise, the statute requires that the surrogate country be a “significant producer” of the comparable subject merchandise. Here, Commerce found that both India and Indonesia were significant producers of comparable merchandise. Issues & Decision Mem., P.R. Doc.1933 at 39 (Cmt.2) (“it would be illogical to conclude, as argued by Respondents ..., that Indonesia is a significant producer of furniture while India is not.”). Respondents contest this finding asserting that India is not a significant producer of wooden bedroom furniture. Commerce identifies a significant producer based on a totality of the circumstances, and makes its decision concerning significance on a case-by-case basis. Policy Bulletin at 3. Commerce ascertained that “fixed standards such as ‘one of the top five producers’ ” are not helpful as the meaning can differ significantly from case to case. Id. Commerce further explained that the selection of a surrogate country is, of course, highly dependent on the available data. Here,. Commerce determined that India was a significant producer of comparable merchandise. In particular, Commerce determined that there was at least one major Indian manufacturer of wooden bedroom furniture, IFP, and that there were other producers of comparable merchandise. Surrogate Country Selection Mem., P.R. Doc. 619 at 5-6. Commerce has also indicated that it was able to find additional companies that produce comparable merchandise, in addition to further information and directories with regard to 416 Indian furniture manufacturers. Id. at Attachs. II & III, fr. 11, 14. Commerce found that there are upwards of 11,000 producers of furniture in India, and a furniture industry output of $1.7 billion (compared with Indonesia’s output of $1.9 billion). Issues & Decision Mem., P.R. Doc.1933 at 39 (Cmt.2). Commerce also indicated that it was able to find nine Indian surrogate financial statements. Id. at 67 (Cmt.3). Consequently, Commerce’s finding that India is a significant producer of comparable merchandise is supported by substantial record evidence. (4) Weighing the choice between Indonesia and India As the discussion above indicates, Commerce’s decision to opt for India as the surrogate country in this investigation, as opposed to Indonesia (or any of the other economically comparable countries) was driven in large part by data concerns and considerations. Commerce had access to and was apprised of numerous sources of information from India. Commerce was also able to locate Indian company directories, Surrogate Country Selection Mem., P.R. Doc. 619 at 5 & Attach. III fr. 14, and Commerce had experience utilizing the Indian import statistic data base, the Monthly Statistics of Foreign Trade in India (“MSFTI”). Respondents point to various criteria, including the fact that Indonesia is a net exporter of wooden bedroom furniture while India is not, Pis.’ Br. 17, and the size of the industry, to indicate that Commerce should have chosen Indonesia instead of India as the surrogate country. Id. at 14-15 (claiming that the portion of India’s furniture production that is wooden furniture is 60 percent and the proportion that is bedroom furniture is 20 percent); Id. at 17 (“the values of [India’s] exports were 38 million and 30 million rupees (about $875 thousand and $690 thousand)” in 2002 and 2003 respectively). However, just as previous case law has established that Commerce need not pick the “most comparable economy”, Tehnoimportexport v. United States, 15 CIT 250, 256, 766 F.Supp. 1169, 1175 (1991) (emphasis in original), Commerce need not pick the most significant producer. Despite the fact that the Indian data may or may not be a perfect fit for every surrogate value, this court has noted time and again that the estimation of a normal value using surrogate values is an inexact science. See, e.g., Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1377 (Fed. Cir.1999) (“the process of constructing foreign market value for a producer in a nonmarket economy country is difficult and necessarily imprecise”) (citing Sigma Corp. v. United States, 117 F.3d 1401, 1408 (Fed.Cir.1997)). While accuracy is a touchstone, Commerce often finds that it has to choose between two (or more) suboptimal data sources. In such a scenario, where Commerce is choosing between two less-than-ideal data sources, its decision must be upheld provided it is supported by substantial evidence. Here, Commerce has demonstrated, through substantial evidence, that it was able to locate data from India that it knew to be reliable having previously worked with the data. Surrogate Country Selection Mem., P.R. Doc. 619 at 3. Therefore, based on the preceding analysis, Commerce’s determination to use India as the surrogate country for this investigation was appropriate; as a factual matter that decision was also supported by substantial evidence. The legislative history of the governing statute does indicate that “if possible,” Commerce should utilize data based on production of “the same general class or kind of merchandise using similar levels of technology and at similar levels of volume as the producers subject to investigation.” Conf. Rep. at 591. Though the desire for comparability of technology is clear, and one could argue, optimal, this desire is qualified by the phrase “if possible.” Here, Commerce reasonably determined that the quality of Indonesian data would be a hindrance in calculating surrogate values; therefore it would not be possible to utilize Indonesian data, whether or not the Indonesian furniture industry proved to be a closer match in production process to the Chinese furniture industry. Issues & Decision Mem., P.R. Doc.1933 at 42. The statute requires Commerce to look to the comparability of merchandise, and Commerce acted in accordance with law in determining that comparability of merchandise does not necessarily require comparability of industry. 19 U.S.C. § 1677b(c)(4). Ultimately Commerce can, and does, mix and match the data that it chooses in its surrogate value selection, for instance through the use of gap-filling data. See Lasko Metal Prods. v. United States, 43 F.3d 1442, 1445-46 (Fed.Cir.1994); Nation Ford, 166 F.3d. at 1378. Because Commerce can mix and match data when it finds data from its primary source to be wanting, the surrogate country selection amounts to a nod or a presumption as to what will be Commerce’s “go-to” country. In this investigation, the choice of India had a direct bearing on the choice of the main data set employed by Commerce in its surrogate value selection, namely in Commerce’s selection of MSFTI as its main data set in valuing the factor inputs. B. Monthly Statistics of Foreign Trade in India (1) In general The valuation of factors of production in a nonmarket economy is governed by 19 U.S.C. § 1677b(e). As noted previously, this section of the statute instructs Commerce to value factors of production “based on the best available information regarding the values of such factors in a market economy country or countries considered to be appropriate by the [Secretary].” 19 U.S.C. § 1677b(c)(l). In addition, Commerce has promulgated regulations specifying that the information utilized is “normally” to be “publicly available” and that, except to value labor, the Department will normally value all factors using data from a single surrogate country. 19 C.F.R. § 351.408(c). While Commerce has not promulgated additional regulations to govern its selection of data for the valuation of factors of production, it has developed policy preferences relating to its data choices. Specifically, Commerce prefers data that is (1) a non-export average value; (2) most contemporaneous with the period of investigation (“POI”); (3) product-specific; and (4) tax-exclusive. Memorandum to File, From Michael Holton, Subject: Preliminary Determination Factors Valuation Memorandum: Wooden Bedroom Furniture from the People’s Republic of China, Dep’t of Commerce (June 17, 2004), P.R. Doc. 1329 at 2 (“Factors Valuation Mem.”). See, e.g., Polyethylene Retail Carrier Bag Comm. v. United States, 29 CIT -, 2005 WL 3555812, **14-15, **18-25 (Dec. 13, 2005). (2) MSFTI as a primary data set In this investigation, the application of the factors outlined above led Commerce to rely on the Monthly Statistics of Foreign Trade in India data for the valuation of raw materials. Factors Valuation Mem. at 4. MSFTI, published by the Government of India and available through the World Trade Atlas, provides the quantity and value of all Indian imports, reported by Harmonized Tariff Schedule of India (“HTS[I]”) headings and subheadings. Commerce argues that MSFTI data represents the best available information for the valuation of raw material inputs because MFSTI data were publicly available, contemporaneous and representative of all Indian imports, “representative of the inputs in question,” and tax-exclusive. Def.’s Resp. Br. Pls.’ Surrogate Value Related Mot. J. Agency Record 36 (“Def.’s Br.”); see also Issues & Decision Mem., P.R. Doc.1933 Cmts. 10, 17, 25 & 27. Commerce also notes that it has utilized MSFTI in previous investigations. Id. at 137 (Cmt.10) & 206 (Cmt.25) (Commerce has a long-standing preference for MSFTI unless it is unreliable or distorted). Respondents challenge Commerce’s use of MSFTI, arguing that MSFTI data is overbroad; that better import data is available from Infodrive India and IBIS; that MSFTI does not always capture the inputs that are used by the Indian wooden furniture industry; that MSFTI data is inaccurate and unreliable and that there are other sources of data that provide specific and accurate domestic data. Pis.’ Br. 32-46. As a threshold matter, Commerce has determined that when it selects import statistics as a means of valuing factors of production for a non-market economy, it would rather choose a broader range of statistics stating that “[a] broad, average price from import statistics is reliable is [sic] because the average includes a range of prices.” Def.’s Br. 52; see also Issues & Decision Mem., P.R. Doc.1933 at 137 & 206. Commerce further elaborated that, “[a]n average price representing a subset of imports is not more accurate than an average price of all imports into India.Def.’s Br. 52; see also Issues & Decision Mem. P.R. Doc.1933, at 206 (Cmt.25) & 214-217 (Cmt.26). Respondents propose Infodrive India and IBIS as alternative sources of import data, rather than MSFTI, arguing that Infodrive India and IBIS provide a detailed breakdown of Harmonized Tariff Schedule (“HTS”) subheadings. This line-by-line information, Respondents claim, would allow Commerce to make a more precise match between the input used by the Chinese manufacturers and the surrogate Indian import. Issues & Decision Mem., P.R. Doc.1933 at 131 (Cmt.10); Pls.’ Br. 36. All parties agree that Infodrive India and IBIS do not provide data on all imports into India. The court finds that, in general, Commerce’s preference for a broader data set is reasonable and supported by substantial evidence. In essence, Commerce is arguing that where it has a choice between underinclusive data (which does not capture all the inputs used by wooden furniture manufacturers) or overinclusive data (which includes some data which is not used as an input, but captures all the inputs because of its broad range), it will choose overinclusive data. As Commerce is faced with a choice between two imperfect options, it is within Commerce’s discretion to determine which choice represents the best available information. Commerce’s decision to rely on the MSFTI data, as a general database, to value raw material factors of production, instead of Infodrive India or IBIS data, is supported by substantial evidence in that the record supports Commerce’s conclusion that the MSFTI data is more inclusive than the Respondents’ alternatives. (3) MSFTI as applied to individual factors. However, while Commerce’s choice of MSFTI data, as a general database, rather than Respondents’ alternatives, is appropriate, Commerce’s individual determinations, on a factor input by factor input basis, must also be supported by substantial evidence. If Commerce’s specific data choices do not actually include or capture the factor or input it is estimating, or a reasonably comparable item, such a choice is not supported by the record; for example, if Commerce were estimating the cost of hard-cover law casebooks by relying on the average cost of paperback legal thrillers, while another data set provides the cost of hard-cover textbooks, its choice could not be sustained. Cf. Hebei Metals & Minerals Imp. & Exp. Corp. v. United States, 29 CIT-,-, 366 F.Supp.2d 1264, 1272-73 (2005) (“Hebei II”) (Commerce cannot assume that the “others” category includes the coal at issue, without establishing what category of coal was used by the respondents, and without establishing that the category did “cover the type of coal used in Hebei’s production process.”); Guangdong Chems. Imp. & Exp. Corp. v. United States, 30 CIT-, -, 414 F.Supp.2d 1300, 1311 (2006) (“Even if the court were to conclude that Commerce produced substantial evidence demonstrating that azelaic and sebacic acid are priced similarly, that would not justify Commerce’s decision to abandon a more produet-specific data source.”). Additionally, if the data is heavily weighted by a disproportionate inclusion of higher priced or lower priced data, such that Commerce is systematically overvaluing or undervaluing the factors of production, the broad range of the statistics would not, in and of itself, render the data reliable. See Goldlink Indus., 30 CIT at -, 431 F.Supp.2d at 1334 (“Since the presumption is that NME data is distorted, Commerce must find a reasonable surrogate value. Logically then, Commerce cannot use a surrogate value if it is also distorted, otherwise defeating the purpose of using a surrogate value rather than the actual export value.”). In addition, although the court has, in specific instances, approved the use of import data, and the use of MSFTI data in particular, the court has always emphasized that in order for import data to be used, there must be reason to believe that the industry in question would use imported inputs. See Hebei I, 28 CIT at-, 2004 WL 1615597, *8 (“Commerce here did not explain why an Indian manufacturer would pay for imported coal”); Yantai Oriental Juice Co. v. United States, 26 CIT 605, 617 (2002) (“Here, Commerce has produced no evidence tending to lead to the conclusion that India’s domestic AJC producers would use imported as against domestic coal.”); Wuhan Bee Healthy Co. v. United States, 29 CIT-, -, 374 F.Supp.2d 1299, 1310 (2005) (Commerce gives “no reason[ ] as to why imported coal provides the best surrogate value.”). If it is unlikely that the domestic industry would use imported inputs, and there is domestic data available, then Commerce’s choice of import data to value factor inputs may not be reasonable. One example of when the domestic industry would choose to source its factor inputs domestically would be when the price of the imported good is markedly higher than the price of the domestic good. Hebei II, 29 CIT at -, 366 F.Supp.2d at 1274 (“[T]he preference for domestic data is most appropriate where the circumstances indicate that a producer in a hypothetical market would be unlikely to use an imported factor in its production process. The most obvious circumstance occurs where the import price is significantly greater than the domestic price.”). Another example would be when the import statistics themselves demonstrate that the specific input is not imported into the country. While Commerce may establish criteria in order to guide its data selection process, this does not relieve Commerce of the obligation to evaluate the relative accuracy of domestic and import data in valuing factors of production. See Yantai 26 CIT at 617 (“Commerce nowhere explains how the use of seemingly more expensive imported coal data is the best available information establishing the actual costs incurred by Indian AJC producers.”). Commerce itself, when noting potential price discrepancies in import data, has employed benchmarks in order to evaluate the reliability of MSFTI data. China First Pencil, 30 CIT -, 427 F.Supp.2d 1236 (on voluntary remand, Commerce examined MSFTI data for the price of pencil cores by comparing it with price quotes from the United States, since Commerce was unable to obtain price quotes from India). (a) Mirrors The court turns to Respondents’ challenge of the use of specific MSFTI data for the valuation of mirrors, paints, and cardboard. Respondents claim that the MSFTI data is demonstrably inaccurate for valuing these specific factors of production. Pis.’ Br. 27, & 40-46. Respondents attempt to demonstrate that MSFTI is inaccurate in valuing mirrors by alleging that (1) there is evidence that Indian furniture manufacturers do not use imported mirrors in their manufacturing process; (2) in this instance MSFTI is not inclusive of the mirrors utilized; and (3) the MSFTI data utilized was overly distorted by the inclusion of specialty mirrors. (i) Imported Mirrors As Inputs Respondents provide a range of data to demonstrate that the import prices for mirrors selected by Commerce are considerably higher than domestic prices, suggesting either that the import prices are distorted or that Indian producers would not use imported mirrors as an input for wooden bedroom furniture. See, e.g., Hebei II, 29 CIT at-, 366 F.Supp.2d at 1274 (companies are less likely to use imported inputs when the prices of imported inputs are higher than domestic inputs). Respondents argue that the actual price for 5mm mirrors used in wooden furniture production in India is within a range of between $9.35/m2 and $13.13 /m2 instead of the Final Determination value of $60.13 /m2 for mirror imports (a range of 4.6 to 6.4 times greater than the alternate prices). Pis.’ Br. 27. Repondents refer to: (a) record data from an Indian glass industry publication (“Glass Yug”); (b) actual average period of investigation prices paid for mirrors used by two Indian wooden furniture producers (Tarun Vadehra and Highland House); (c) and actual average prices paid for mirrors by a large Indonesian wooden bedroom furniture producer, Goldfmdo. Id. Additionally, there is evidence on the record that at least one furniture producer in India only sourced mirrors domestically during the period of investigation. See Ernst & Young Private Ltd., Report on the Agreed Upon Procedures on the Purchases Ledger of Highland House Private Ltd. (Apr. 1, 2004), Attach, to Letter from John D. Greenwald, Wilmer, Cutler, Pickering, Hale & Dorr, LLP., on behalf of Lacquer Craft Mfg. Inc. & Markor International Furniture (Tianjin) Manufacture Co., Ltd., to The Honorable Donald L. Evans, Secretary of Commerce, Re: Wooden Bedroom Furniture from the People’s Republic of China: Surrogate Country Submissions (Apr. 20, 2004), P.R. Doc. 770 at 56 (fr.13) (“As per the list provided by Lacquer Craft, Ernst & Young was required to compile prices of standard 5/6mm thickness type plain mirrors purchased by Highland House during the period. During the period, Highland House purchased plain mirrors from domestic suppliers only.”). Commerce did not address the assertion that imported mirrors were not used by Indian furniture manufacturers. Instead of addressing the Respondents’ concerns with the MSFTI data, Commerce chose ■ to attack the quality of the data proffered by Respondents,, claiming that the unreliability of the data negated its ability to serve even as a means of evaluating the MSFTI data. The court finds that Commerce’s determination that the MSFTI data was accurate with respect to mirrors is not supported by substantial evidence, because Commerce did not evaluate the inaccuracies of the MSFTI data set. See Shanghai Foreign Trade Enters. Co. v. United States, 28 CIT-,-, 318 F.Supp.2d 1339, 1352 (2004)(Commerce’s determination was not supported by substantial evidence when “Commerce summarily discarded the alternatives as flawed but did not evaluate the reliability of its own choice.”). Commerce argues that Yantai, Hebei II, and Shanghai Foreign Trade are inapplicable here as “Commerce did not summarily discard the alternatives as flawed without evaluating the reliability of its own choice.” Def.’s Br. 47. However, as explained below, here Commerce’s reasons for rejecting other data were either applied on an inconsistent basis, or did not actually provide a rational reason for rejecting the data. (ii) Glass Yug Commerce provided three reasons for dismissing the Glass Yug data: (1) the data do not cover the entire POI; (2) the Glass Yug data are very specific and Commerce does not know whether or not Respondents use the same type of mirrors; and (3) the Glass Yug data are not specific enough because it does not contain information on the sizes of the mirrors and whether or not the mirrors are beveled. Issues & Decision Mem., P.R. Doc.1933 at 204-206 (Cmt.25). First, regarding the POI, Commerce may not always elevate contemporaneity, or its desire to have data covering an entire POI, over the need for accuracy. See Hebei II, 29 CIT at-, 366 F.Supp.2d at 1275 (finding that contemporaneity is but one factor to be considered in looking at data and noting that “the Court has previously found contemporaneity to be insufficient to explain why an import price is the best available information for establishing the actual costs incurred by a producer.” (citing Yantai, 2002 WL 1347018, *9)). If the domestic data proves to be otherwise accurate, then it may well be preferable to use accurate data, compiled over a shorter period of time, then inaccurate or unreliable data that covers the entire POI. Commerce’s second and third contentions rely on Commerce’s desire not to have underinclusive data. Essentially, Commerce is arguing that since it cannot match Glass Yug data with Respondent data, either because the Glass Yug data are not specific enough or because the data are too specific, use of the Glass Yug data would lead to an underinclusive data set. Respondents have asserted that they have placed evidence on the record that shows the width of their mirrors. Respondents note that Shing Mark has reported its mirrors to be 3mm, 5mm, and 6mm in depth, Steptoe & Johnson, LLP, Case Brief on Behalf of Shing Mark Co., Ltd., (Oct. 6, 2004) Attach, to Letter from Jack R. Hayes, Steptoe & Johnson, LLP, on behalf of Shing Mark Co., Ltd. to the Honorable Donald L. Evans, Secretary of Commerce, Re: Antidumping Duty Investigation on Wooden Bedroom Furniture from the People’s Republic of China: Submission of Case Brief on Behalf of Shing Mark Enterprise Co., Ltd., (Oct. 7, 2004), P.R. Doc. 1854, fr. 58 (“Shing Mark Case Brief’), while there is evidence on the record indicating that Dorbest’s mirrors are 5mm in thickness, Dorbest Ltd., Second Supplemental Sections C & D Response (June 15, 2004), Attach, to Letter from Jeffrey S. Grimson, Kaye Sholer, LLP, on behalf of Dorbest Ltd., to the Honorable Donald L. Evans, Secretary of Commerce, Re: Response to DOC’s June 8, 2001, Second Supplemental Sections C-D Questionnaire in Wooden Bedroom Furniture from China, (Inv. No. A-570-890), (June 15, 2004), Prop. Doc. 599, fr. 314 & 318 (“Dorbest June 15 Submission”); See Pis.’ Br. 42. Respondents maintain that this is sufficient information for Commerce to match Glass Yug data with Respondents’ inputs, because Glass Yug data provided prices for mirrors with thickness of 2.5, 3.5, 4.0, 5.0 and 6.0 millimeters. Pis.’ Br. 42; Shing Mark Apr. 16 Submission, P.R. Doc. 761, fr. 446. Additionally, it appears inconsistent for Commerce to require specificity for one data set, while allowing for a broader data set that has no indication either as to whether it includes mirrors with “beveling” or etching, as is the case with MSFTI. See Hebei II, 366 F.Supp.2d at 1273 (“A broad and unsupported coal value falls short of a substantial evidentiary basis just as a narrow and unsupported coal value does.”); Shanghai, 318 F.Supp.2d at 1352 (Commerce must apply its standards as consistently to its selected data set as to other data sets). At the very least, none of Commerce’s arguments with respect to Glass Yug address why this data should not be viewed as probative towards a view that Commerce’s chosen valuation is too high and/or inaccurate. (iii) Tarun Vadehra, Highland House and Goldfindo Commerce rejected the Tarun Vadehra and Highland House information because it found that the information was not “publicly available” insofar as it was not information that could “be duplicated by the Department, the Petitioners, or anyone else that lack[ ] access to the confidential records from which they were derived.” Issues & Decision Mem., P.R. Doc.1933 at 162-63. (Cmt.17). Respondents argue that this is not how Commerce has generally defined publicly available. Pis.’ Br. 34. The court does not have to reach this issue with regard to the Tarun Vadehra and Highland House data, because Commerce also explained that it found that this data was not representative of all Indian prices. Though Commerce considers several issues in evaluating the merits of various data, see supra, p. 30, Commerce’s determination is supported by substantial evidence in that the data from two Indian producers is not representative of the country as a whole. See Retail Carrier Bags, 29 CIT at-, 2005 WL 3555812, *17 (finding that the selection of import statistics in valuing black inks on the basis of the import data being “country-wide” data was supported by substantial evidence, as evidence submitted to demonstrate that Indian import statistics counted as an even smaller percentage of sales of the relevant inks was not provided during the administrative review.). Commerce also implicitly rejected the data provided by Respondents from the Indonesian company, Goldfindo stating that “the Department has not considered the factor values derived form [sic] Goldfindo because Gold-findo is an Indonesian company and the Department has determined to use India as the surrogate country in this investigation.” Issues & Decision Mem., P.R. Doc. 1933 at 163 (Cmt.17). The court notes that though Commerce is not obligated to value its factors of production from just one surrogate country, see, e.g., 19 U.S.C. § 1677b(e)(1); Nation Ford Chem. Co. v. United States, 166 F.3d 1373, 1378 n. 5 (Fed.Cir.1999) (the antidumping duty statute “does not preclude consideration of pricing or costs beyond the surrogate country if necessary”), Commerce has also noted that the same argument against using Tarun Vadehra and Highland House data — namely that the data do not cover country-wide prices and are too narrow to be considered for surrogate valuation— applies as well to Goldfindo data. Issues & Decision Mem., P.R. Doc.1933 at 163 (Cmt.17) (“the Department’s practice is to not use price quotes to value factors when other usable, reliable information is available.”). (iv) The MSFTI data is either noninclusive or distortive of mirror inputs Respondents also argue that the Info-drive India and IBIS data indicate that the mirrors reported as being imported under subheading 7009.91.00 of the Harmonized Tariff Schedule of India (“HTS[I]”) included Taiwanese exports of rearview mirrors for automobiles to an Indian company by the name of “Enginetech” or mirrors from Germany including a “chiara” bathroom mirror and a telescopic mirror. Issues & Decision Mem., P.R. Doc.1933 at 194 (Cmt.25) & 183 (Cmt.2.4); see also Pis.’ Br. 26. According to Respondents, these are higher-priced specialty mirrors, the inclusion of which has a distortive effect on the valuation of the mirror inputs used in furniture production. Respondents also claim that, in addition to examining the line-by-line data