No.14/17/2003-DGAD
GOVERNMENT OF INDIA
MINISTRY OF COMMERCE & INDUSTRY
(DEPARTMENT OF COMMERCE)
DIRECTORATE GENERAL OF ANTI DUMPING & ALLIED DUTIES

New Delhi, the 7th October 2004

Final Finding

Subject: Anti-dumping investigation concerning imports of Cyclohexanone originating in or exported from the European Union, Chinese Taipei and USA – Final finding

No. 14/17/2003-DGAD - Having regard to the Customs Tariff Act, 1975 as amended in 1995 and the Customs Tariff (Identification, Assessment and Collection of Anti Dumping Duty on Dumped Articles and for Determination of Injury) Rules, 1995, thereof;

A. PROCEDURE:

1.    The procedure described below has been followed:-

(i)  The Designated Authority (hereinafter referred to as Authority), under the above Rules, received a written    petition from M/s. Gujarat State Fertilisers and Chemicals Ltd (GSFC), Vadodra (hereinafter also referred to as petitioner), on behalf of the domestic industry, alleging dumping of Cyclohexanone originating in or exported from European Union, Chinese Taipei and USA (hereinafter referred to as subject countries). The preliminary scrutiny of the application filed by the petitioner reveals certain deficiencies which were subsequently rectified by the petitioner. The petitioner was, therefore, considered as properly documented.

(ii)  The Authority notified the Embassies/High Commissions of subject countries in India about the receipt of fully documented application made by the petitioner before proceeding to initiate the investigation in accordance with sub-rule (5) of Rule 5 supra;

(iii)  The Authority issued a Public Notice dated 8^th October 2003 published in the Gazette of India, Extraordinary, initiating anti dumping proceedings concerning imports of Cyclohexanone from subject countries.

(iv)  The Authority forwarded copy of the said public notice to the known exporters, importers, industry associations and to the complainant and gave them an opportunity to make their views known in writing within forty days from the date of the letter in accordance with Rule 6(2).

(v)  According to sub-rule (3) of Rule 6 supra, the Authority provided a copy of the petition to all the known exporters and Embassies/High Commissions of subject countries/territories in India. None of the producers and exporters from subject countries has responded to the application.

(vi)  The Authority sent questionnaires, to elicit relevant information, to the known exporters from subject countries in accordance with Rule 6(4). None of the exporters filed any response or information to the questionnaire and notification.

 

(vii) The Embassies of the subject countries in New Delhi were also informed about the initiation of investigation in accordance with Rule 6(2) and requested to advise the exporters/producers from their countries to respond to the questionnaire within the prescribed time. A copy of the letter, application filed by the domestic industry (Non-Confidential) and questionnaire sent to the known exporters was also sent to the embassies of subject countries/territory in accordance with Rule 6(3).

(viii) The questionnaire was sent to the large number of importers in accordance with Rule 6(4). None of the importers and users of the subject goods filed any response to the questionnaire and notification.

(ix) The Authority kept available non-confidential version of the evidence presented by various interested parties in the form of a public file maintained by the Authority and kept open for inspection by the interested parties in accordance with Rule 6(7);

(x) The Authority provided an opportunity to all interested parties to present their views orally on 25^th May, 2004. Parties presenting views orally were requested to file written submissions, of the views expressed orally. The parties were advised to collect copies of the views expressed by opposing parties and offer rebuttals, if any. None of the interested parties have filed any response other than M/s. BASF. M/s. BASF has stated that they have not exported any material in the period of investigation and they have further requested for New Shipper Review. Domestic verification as well as exporter’s verification of the data submitted by them were undertaken by the Authority. The Authority sought and verified all the information it deemed necessary for the purpose of Final Findings with regards to determination of dumping and resulting injury. The Authority conducted on the spot investigation of the domestic industry to the extent considered necessary. In accordance with Rule 16 of The Rule supra, the essential facts/ basis considered for these findings were disclosed to known interested parties on 10^th September 2004 and comments received on the same are duly considered in Final Findings.

(xi)    **** in this notification represents information furnished by the interested parties on confidential basis and so considered by the Authority under the Rules;

(xii)  The investigation of dumping and injury covered the period from 1^st April 2002 to 30^th June 2003 (Also called the period of investigation or POI). The examination of trends in the context of injury analysis covered the period from 1999-2000 to the end of POI. The import data has been examined from transaction wise data made available by the DGCIS for imports from the subject countries and countries other than subject countries.

(xiii) Domestic verification of the data submitted by them were undertaken by the Authority. The Authority sought and verified all the information it deemed necessary for the purpose of Final Findings with regards to determination of dumping and resulting injury. The Authority conducted on the spot investigation of the domestic industry to the extent considered necessary. In accordance with Rule 16 of The Rule supra, the essential facts/ basis considered for these findings are being disclosed to known interested parties and comments received on the same would be duly considered in Final Findings.

(xiv) The cost of the production of the domestic industry was also analysed to work out the optimum cost of the production and the cost to make and sell the subject goods in India on the basis of Generally Accepted Accounting Principles based on the information furnished by the petitioner so as to ascertain if anti Dumping duty lower than dumping margin would be sufficient to remove injury to the domestic Industry.

(xv) Copies of initiation notice were also sent to FICCI, CII, ASSOCHAM etc., for wider circulation

B. Product under consideration

2. The Product under consideration in the present petition is Cyclohexanone, having chemical formula C6H100 originating in or exported from Taiwan, EU and USA. Cyclohexanone is manufactured from Benzene. It acts as an intermediate in the production of adipic acid and in the manufacture of Nylon6. It is mainly sold in mild steel drums or made available in mild steel road tankers.

It is primarily used as an intermediate in the production of Caprolactum and in the manufacture of Nylon6. It is also used as a solvent and thinners for lacquers, especially those containing nitrocellulose or vinyl chloride polymer and copolymer resins including polyvinyl chloride and methacrylate ester polymers, as a sludge solvent in oil for piston type aircraft lubrication and as a solvent for DDT and organic phosphorus insecticides and pesticides. There are no arguments from any of the interested parties rebutting the contention of the domestic industry.

Cyclohexanone is classified under Chapter 29 of the Customs Tariff Act and at subheading No.29142200 in the International Trade Classification based on harmonized system.

C. Like Article

3. The petitioner has claimed that goods produced by it are like articles to the goods originating in or exported from subject countries/ territory. There is no significant difference in the subject goods produced by the petitioner and those exported from subject countries/ territory. Petitioner claims that the two are technically and commercially substitutable. Therefore, for the purpose of present investigation, the goods produced by the petitioner are being treated as Like Articles of the product imported from the subject countries/ territory within the meaning of the Rules, supra.

Petitioner have furnished copy of the invoices raised to various customers as sales evidence. Petitioner has also furnished import information as per secondary sources, which shows name of importer. It shows that material is being imported by same parties, who are buying material from domestic industry.

There is no arguments raised by any one of the opposing interested parties in this regard. On the basis of the detailed investigation, the Authority notes that Cyclohexanone produced by the domestic industry has characteristics, which are similar to those imported from subject countries and to those sold in the market of exporters’ countries. In view of the above, the Authority holds that Cyclohexanone produced by the domestic industry and those being imported from and sold in the subject countries are like articles within the meaning of the rules.

 

D. Domestic Industry

4. The petition has been filed by M/s Gujarat State Fertilziers & Chemicals Limited, Vadodra, Gujarat. The Authority has determined that the petitioner is a major producer of subject goods in India accounting for a major proportion of the production of the subject goods in India. The Authority notes that the petitioner constitutes a domestic Industry within the meaning of the rule 2(b) and the petitioner satisfies the criteria of standing to file the petition in terms of Rule 5(3)(a) of the Rules.

E. De-minimus.

5. As regards ascertaining that the imports from the subject countries during the period of investigation (POI) are above de-minimus levels, the Authority has referred to the transaction wise data from the subject countries as made available by DGCIS. After examining the data, The Authority holds that imports from all the subject countries are above de-minimus levels in terms of volume of imports.

F. Dumping.

6. Under Section 9A(1) I of the Customs Tariff Act 1975, Normal value in relation to an article means:

1. The comparable price, in the ordinary course of trade, for the like article when meant for consumption in the exporting country or territory as determined in accordance with the rules made under sub-section (6); or
2. When there are no sales of the like article in the ordinary course of trade in the domestic market of the exporting country or territory, or when because of the particular market situation or low volume of the sales in the domestic market of the exporting country or territory, such sales do not permit a proper comparison, the normal value shall be either:-
1. Comparable representative price of the like article when exported from the exporting country or territory or an appropriate third country as determined in accordance with the rules made under sub-section (6); or
2. The cost of production of the said article in the country of origin along with reasonable addition for administrative, selling and general costs, and for profits, as determined in accordance with the rules made under sub-section (6)";

Provided that in the case of import of the article from a country other than the country of origin and where the article has been merely transhipped through the country of export or such article is not produced in the country of export or there is no comparable price in the country of export, the normal value shall be determined with reference to its price in the country of origin.

7. The Authority sent questionnaires to all the known exporters for the purpose of determination of normal value in accordance with Section 9A(1)(c). None of the exporters have responded to the questionnaire in the form and manner required as per letter to the exporters and exporters questionnaire. In fact there are no arguments from any of the exporters in this investigation.

 

F.1 USA, EU and Chinese Taipei.

(a) Cooperation

8. None of the exporters from the subject countries/territory have responded to the questionnaire in the form and manner required as per letter to the exporters and exporters questionnaire. In fact there are no arguments from any of the exporters in this investigation. M/s. BASF have stated that they have not exported any material in period of investigation and requested for new shipper investigation. WTO agreement on Anti Dumping states as in this regard. "As soon as possible after the initiation of the investigation, the investigating authorities should specify in detail the information required from any interested party, and the manner in which that information should be structured by the interested party in its response. The authorities should also ensure that the party is aware that if information is not supplied within a reasonable time, the authorities will be free to make determinations on the basis of the facts available, including those contained in the application for the initiation of the investigation by the domestic industry."

 

(b) Normal Value & Export Price:

9. The prices of the Cyclohexanone are being periodically reported in reputed journal "Polyamides and Intermediates" published by Tecnon. The petitioner has based its normal value in case of EU and Taiwan on the basis of the prices reported in this journal. The industry has stated that they made efforts to get evidence of prices of subject goods in the domestic market of subject countries. Efforts were also made to get an evidence of price from a published journal. However, it has been stated that they have not been able to get any evidence of price at which subject goods are being sold in the domestic market of subject countries, as the product does not appear to be widely traded (unlike products such as Benzene and Caprolactam). In view of the non cooperation from all exporters from each of the subject countries, Designated Authority has no option but to proceed on the basis of best information available. The Authority has determined normal value of the cyclohexanone on the basis of the prices of the subject goods reported in this journal for EU and Chinese Taipei where these prices are quoted in this journal for EU and Asia. For USA, normal value has been constructed on the basis of the prices of the cyclohexane reported in this journal for USA. It is noted that the claim made by the petitioner with regard to determination of normal value has also not been disputed by the exporter or other interested parties. Under the circumstances, normal value under the rules is determined on the basis of facts available as per rule 6(8) of the Anti-dumping Rules. Therefore, the information available on the published journal with reference to the prices of the subject goods in the country of origin has been taken as the basis for working out the normal value of the subject goods for the exporter. Export price at ex factory level has been determined with the available data from DGCIS and with adjustments as per the facts available.

(c) Comparison:

G.    Injury

Domestic consumption/demand

12. For the calculation of the Domestic consumption/demand of the product under consideration in a domestic market, the authority added the sales volume of the domestic industry to the total imports into the domestic market. On this basis, it is noted that the domestic demand or consumption of the subject goods in the domestic market declined from 21007 MTs in 1999-2000 to 15228 MTs representing a decline of 28%.

 

.

13. Cumulative Assessment of the effects of imports concerned

i) The Authority examined whether imports of subject goods originating in subject countries should be assessed cumulatively as per Article 3.3 of the Agreement on Anti-Dumping and Rule 11 of the Anti Dumping Rules Under the Customs Tariff Act.

ii) The margins of dumping established in relation to the imports from each of the subject countries) was above the de minimus threshold as defined in Article 5.8 of the Agreement on Anti-Dumping and Rule 14 of the Anti Dumping Rules and Volume of dumped imports from each of these countries was not negligible.

iii) The domestic product and product supplied by producers in subject countries are like articles; and the imported products and domestically produced subject goods can and are being interchangeably used. Transaction wise information on importers from various countries and sales invoices of the domestic industry show that there are a number of parties who have resorted to purchase from the domestic industry and imports from subject countries. It is further noted that subject goods supplied by various countries compete in the same market. Further, it is also noted that products supplied by various producers in subject countries are being marketed in India during the same periods through comparable sales channels and under similar commercial conditions. Price undercutting is positive in respect of each of the subject countries.

iv) In the light of the above, the authority has considered that the criteria set out in article 3.3 of the Agreement of Anti-Dumping and as per para iii of the Annexure II under Rule 11 were met with respect to imports from each of the subject countries and therefore Imports from these subject countries should be cumulated for the purpose of injury determination.

Imports originating in the subject countries.

Volume

14. The volume of dumped imports of the subject goods from subject countries into the domestic market increased by 9% over the injury period. Imports from subject countries were 4843 MT in 1999-2000, which declined to 3430 MT in 2000-2001. In 2001-2002, imports increased to 5093 MT, which increased to 5290 MT in period of investigation. The volume of dumped imports on annualised basis shows 9% increase over 1999-2000.

 

 

16. The Designated Authority has also examined share of dumped imports from subject countries in demand of subject goods in India. The Authority finds that share of subject countries, which was 23.03% in 1999-2000 in Merchant Demand increased to 34.74% during the POI.

17. It is found that dumped imports from subject countries increased in relation to production of the domestic industry. For the purpose, the Authority has considered production once by excluding captive consumption and thereafter by including captive consumption. There does not appear to be an uniform trend in this regards and though the dumped imports have increased in relation to the net production in India ,there is a marginal increase when the captive consumption is also included.

*Net excludes captive consumption and *gross includes captive consumption.

On the basis of above examination, the it is concluded that there has been a marginal rise in the market share of dumped imports of the subject countries during the POI as compared to previous years in proportion to the net as well as gross productions.

18. The Authority notes that there was no consistent pattern in the import prices. The import prices increased very significantly in 2000-01 as compared to previous year and thereafter declined in 2001-02. The prices increased thereafter.

The Authority notes that prices of the subject goods fluctuate in view of the fact that the input prices also keep fluctuating.

Price Underselling

20. The Authority has also examined the claim of the petitioner that the domestic industry is suffering on account of the losses from the sale of subject goods. The Authority notes that price underselling is an important indicator to make an assessment of the injury. The Authority has worked out the non-injurious price for the product under consideration and compared the same with the landed value to arrive at the extent of price underselling. The analysis shows a price underselling 6-10% from subject countries which is not considered significant by the Authority.

Price Depression

It is noted that the sales volume shows an erratic trend during the period under consideration. It is seen that the sales volumes increased between 1999-00 and 2001-02. However, sales volume have shown declining trend thereafter in the investigation period. As a result, the market share of the domestic industry also shows an erratic trend as a proportion to the total demand during the period under consideration though after increasing till 2000-01, it has declined consistently till the POI.

25. Since the domestic industry has significant captive consumption also, the Authority further examined the possible effect of dumping on captive consumption. Sales of the domestic industry, including captive consumption were as under:-

Even though the captive sales also show decline, the Authority does not consider that such decline is attributable to dumped imports. The Authority notes that the product under consideration is consumed captively for production of caprolactam, whereas the merchant sales of the domestic industry is to industry other than producers of caprolactam. It does not appear that performance of the domestic industry in respect of its captive consumption would be affected by dumping of the product in its merchant market.

Profits:

26.Profit/loss of the domestic industry per unit of production and for the quantities sold has been as under:

 

It appears from the above that profits of the domestic industry have been eroded.

 

27. Production, capacity and capacity utilization of the domestic industry have been tabled as under. The Authority notes that since the petitioner uses the same facility for its captive requirement as also merchant sales, it would be appropriate to assess trends in production and capacity utilization after including captive consumption also.

It is seen from the above that production of the domestic industry has declined. The decline in production of the domestic industry is in spite of sub-optimal prices at which the domestic industry sold the material to compete with the dumped imports. While it is noted that some decline in production could be due to decline in captive consumption also, the production has declined more than the decline in captive consumption.

It is seen that the share of the domestic industry in merchant demand increased significantly between 1999-2000 and POI.

29. Employment and wages of the domestic industry have been as follows:

The decline in wages may not be solely due to dumping, as it is found that the company has otherwise also reduced employment. Given above, the authority does not propose to conclusively determine injury to domestic industry on account of this parameter.

Productivity:

30. While production per day declined, production per employee increased. The increase in production per employee is in spite of reduction in production. It is noted that productivity per employee has increased during injury determination period.

 

31. The imports from subject countries are resulting in price undercutting and price underselling in the Indian market. The landed price of imports is below the non injurious price of the domestic industry. Selling prices of the domestic industry have declined from 2000-01 to the POI though it increased significantly from base period to 2000-01. It is also noted that the cost of production has gone up much more than increase in NSR. Further, from 2000-01 to the POI, while the cost of production has gone up, the NSR of the domestic industry has gone down.

 

32. Return on investments (profit before interest) shows the same trend as that of profits. The domestic industry was earlier having positive return on investments, which became negative in period of investigation.

It is evident from the above that cash profit situation of the domestic industry, which was increasing till 2001-02 declined in period of investigation. However, being the multiproduct company, the Authority could not conclusively determine injury on account of this parameter.

34. Inventories with the domestic industry has been as under:

It is seen form the above that inventories of the domestic industry reduced till 2001-02. However, inventories increased thereafter. The Authority could not therefore conclusively determine any injury on account of this parameter.

Ability to raise capital investments:

35. Being a multi product company where this product constitutes a small proportion of the total turnover of the company, the Authority does not propose to hold that ability to raise investments could be a conclusive parameter in the injury determination of the domestic industry.

36. The domestic industry has faced negative growth so far as operations of product under consideration is concerned as production, sales have declined and profits of the domestic industry have declined with respect to subject goods and have now been converted into losses. Following table shows that domestic industry has negative growth in many parameters. However, these declines in the growth parameters would have to be viewed in the larger context of steep decline in the demand of the subject goods.

 

 

 

 

 

 

 

 

 

 

 

 

 

It is seen from the above that domestic industry faced negative growth in respect of a number of parameters.

Dumping Margin37. The dumping margin from the subject countries ranges from 16% to 56% and is considered significant by the Authority.

Conclusion on Injury

38. The Authority notes that the volume of dumped imports of subject goods from subject countries has increased though marginally in the injury period. The share of dumped imports from subject countries in the total imports and in the merchant demand has also increased. The authority further notes that during the period of investigation, the subject goods from subject countries undercut the domestic industry prices when expressed as a percentage of the domestic selling prices of the domestic industry though the margin of price undercutting is not considered significant. It is further noted that there are varying and contradictory indications with regard to different injury parameters. As regards the effect of the dumped imports on the domestic industry, the Authority notes that though the volume of the dumped imports in the total demand has increased, the share of the domestic industry in the total demand has followed a rising trend during the injury pereiod. This is coupled with the fact that the overall demand has been falling during the injury period. However, the other parameters such as profitability and sales prices of the domestic industry show a positive injury to the domestic industry. Overall, the Authority concludes that the domestic industry has suffered material injury.

H Causal Link.

(c)    Effect of Other factors

(a) Performance of Other Domestic producers:

43. There was no other domestic producer during the period under consideration which had made any merchant sales. Another producer M/s FACT Ltd has consumed the entire production for its captive consumption only and therefore their production has not been taken into account in the sales volume of the domestic industry.

(b) Self Inflicted Injury, Economies of Scale & Cost Efficiency:

44. There has been no arguments from any of the interested parties with regards to the Self Inflicted Injury, Economies of Scale & Cost Efficiency. It is noted that the Authority has arrived at the cost of production of the subject goods and its Non injurious price by taking into account actual cost of production of subject goods by verifying the domestic industries data without loading any overheads pertaining to the other business of the company.

(c) Contraction of demand or Changes in the pattern of consumption

45. The Authority notes that there is contraction in the overall demand during the period under consideration, which could have been a factor for injury to the domestic industry. Further, there has been a decline in the captive sales of the domestic industry which denotes that the domestic industry is allegedly facing injury on their other products which could also be responsible for profitability to the domestic industry considering the fact that there has not been a dedicated capacity for the subject goods by the domestic industry and injury suffered on account of the sales of the subject goods by the domestic industry cannot be conclusively attributed to the dumped imports of the subject goods from the subject countries. The Authority could not come across any changes in the pattern of consumption of the subject goods. The Authority therefore, concludes that there is no apparent change in the pattern of consumption.

(d) Volume and Prices of imports not sold at the dumped prices

46. Analysis of non-subject imports reveals that such imports have remained at very low level. Moreover, the import prices from some of these sources were very high in the investigation period. Import prices from other sources were lower and comparable to subject countries imports. However, these countries individually commanded less than 3% of import volumes and collectively commanded less than 7% of import volumes. Further, the share of the Non dumped imports from all countries other than subject countries declined in the total demand and also in the share of the total imports. In view of the foregoing, it is noted that imports from non subject countries are considered not to have had any impact on the domestic industry.

(e) Trade Restrictive practices of and competition between foreign and domestic producers

47. The Authority notes that there is a single market for the subject goods where dumped imports from the subject countries compete directly with the subject goods produced by the domestic industry. On the basis of the examination of the transaction wise imports from the subject countries and from the data furnished by the cooperating exporter from subject countries, it appears that the price determines the choice of the supplier as dumped subject goods are like product to the indigenous producer. There is no allegation of trade restrictive practices. It is further noted that the imported product is sold to meet the similar commercial grades and specification as domestically produced subject goods. It is also noted that the imported subject goods and domestically produced goods are like articles and are used for similar applications/end uses.

(f) Developments in Technology, Export performance and productivity of the Domestic Industry

48. There has been no argument from any of the interested parties with regards to the fact that possible developments in technology could have been a possible cause of material injury being caused to the domestic industry.

49. Domestic industry is not having exports of the product. Therefore, deterioration in the export performance may not be a possible cause for injury to the domestic industry.

50. As regards improvement in productivity, the authority notes that during the period under consideration, the productivity measures as output per person employed per year increased significantly during the period under consideration. Thus, possible deterioration in productivity is not a cause for injury to the domestic industry..

(g) Conclusion on causation

51. The Authority notes that there is a contraction in the overall demand during the period under consideration, which could have been a factor for injury to the domestic industry. Further, there has been a decline in the captive sales of the domestic industry, which denotes that the domestic industry is allegedly facing injury on their other products, which could also be responsible for decline in profitability of the domestic industry considering the fact that there has not been a dedicated capacity for the subject goods by the domestic industry. With reference to the submissions of the domestic industry following the disclosure statements, the Authority notes that injury and causal link analysis is required to be done for the injury period as a whole for the trend analysis and no specific segmentation could be culled out for imputing or attributing injury to the domestic industry from the dumped imports of the subject goods from the subject countries. It is further noted that the Designated Authority has already recommended anti dumping duty on the downstream product i.e caprolactum which is expected to take care of the injury resulting from the fall in their captive consumption of the subject goods by the domestic industry. While drawing the conclusions on the causal link, the Authority also notes that the domestic industry does not have a dedicated capacity of the subject goods and what is leftover after the captive consumption for the production of caprolactum is diverted to the merchant sales of the subject goods. Therefore, no such causal link is apparent from the dumped imports of the subject goods, sales made by the domestic industry and consequent injury to the domestic industry.

52. The purpose of anti dumping duties in general is to eliminate dumping which is causing injury to the domestic industry and to re-establish a situation of open and fair competition in the Indian market, which is in the general interest of the country.

53. The Authority recognizes that the imposition of anti dumping duties might affect the price levels of the products manufactured using subject goods and consequently might have some influence on relative competitiveness of these products. However, fair competition on the Indian market will not be reduced by the anti dumping measures. On the contrary, imposition of anti dumping measures would remove the unfair advantages gained by dumping practices, would prevent the decline of the domestic industry and help maintain availability of wider choice to the consumers of subject goods. It is noted that the imposition of anti dumping measures would not restrict imports from subject countries in any way, and therefore, would not affect the availability of the product to the consumers. The consumers could still maintain two or even more sources of supply.

J. CONCLUSIONS:

54. The Authority has, after considering the foregoing, come to the conclusion that:

1. The subject goods have been exported to India from the subject countries below its normal value.
2. The Domestic Industry has suffered material injury;

C. However, the Authority has determined that there is an absence of causal link between the dumped imports of subject goods from subject countries and material injury to the domestic industry

Therefore, no anti dumping duty is recommended with respect to the subject goods from the subject countries in this subject investigation.

 

 

(ABHIJIT SENGUPTA)
DESIGNATED AUTHORITY

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