International trade · 01/12/2000

Sanction for Breaches of Commission Protective Order

Notice is hereby given of the sanction imposed by the Commission for breaches of the administrative protective order ("APO") issued in Crawfish Tail Meat From China, Inv. No. 731-TA-752 (Final). The Commission found that Steven B. Lehat, Esq., and Surjit P. Soni, Esq., breached the APO by (1) delegating primary responsibility for APO compliance to a junior attorney and then failing to provide appropriate supervision of that attorney, which resulted in two APO breaches, (2) repeatedly failing to remedy obvious flaws in their firm's procedures for protecting business proprietary information ("BPI") released to the firm under APO, and (3) failing to certify to the return or destruction of the BPI obtained under the APO. As a sanction, the Commission is issuing this public reprimand and barring them from access to BPI for a period of six months from the date of publication of this notice.