Opinion
Plaintiff Branco Peres Citrus, S.A. (“Plaintiff”) moves pursuant to USCIT R. 56.2 for judgment upon the agency record in an action challenging the final results of the United States Department of Commerce’s (“Commerce”) eleventh administrative review of the anti-dumping order on frozen concentrated orange juice from Brazil. See Frozen Concentrated Orange Juice From Brazil; Final Results and Partial Rescission of Antidumping Duty Administrative Review, 64 Fed. Reg. 43,650 (Aug. 11, 1999) (“Final Results”). The court has jurisdiction, see 28 U.S.C. § 1581(c) (1994), and, for the reasons set forth below, denies Plaintiffs motion.
Background
Plaintiff is a Brazilian producer and exporter of frozen concentrated orange juice. In June 1998, at the request of Defendant-Intervenor Florida Citrus Mutual (“Defendant-Intervenor”) and other domestic producers of frozen concentrated orange juice, Commerce initiated the eleventh administrative review of the antidumping order on frozen concentrated orange juice from Brazil. See Initiation of Antidumping and Countervailing Duty Administrative Reviews and Request for Revocation in Part, 63 Fed. Reg. 35,188 (June 29, 1998).1 The review covered U.S. sales of frozen concentrated orange juice made by Plaintiff and five other foreign producers and exporters between May 1, 1997, and April 30, 1998. See Frozen Concentrated Orange Juice From Brazil; Preliminary Results and Partial Rescission of Antidumping Duty Administrative Review, 64 Fed. Reg. 5,767 (Feb. 5, 1999) (“Preliminary Results”).
At the outset of its investigation, Commerce sent an antidumping questionnaire to Plaintiff and each of the other foreign producers being reviewed. In its accompanying letter to Plaintiff, Commerce requested responses to sections A, B, and C of the questionnaire, which related to general information, sales in the home market or to third countries, and sales to the United States, respectively. (Letter from Maeder to Dunn of *11816/12/98, at 1, Pl.’s App., Tab 10.) At that time, Commerce did not request any data relating to Plaintiff's cost of production. (Id. at 1-2 (“You are not currently required to respond to section D (Cost of Production/ Constructed Value).”).) Commerce did, though, advise Plaintiff, “if the petitioner alleges that your sales in the home or third country market are at prices below the cost of production, we may request that you respond to section D at a later date.” (Id. at 1-2.) Approximately two weeks later, on July 1,1998, Plaintiff sold its frozen concentrated orange juice business.2 (Pl.’s Mem. Supp. Mot. J. Agency R. at 7; Pl.’s Reply Mem. Supp. Mot. J. Agency R. at 5.) According to Plaintiff, “[ijncluded in this sale were all of [its] cost of production records.” (Pl.’s Mem. Supp. Mot. J. Agency R. at 7.) Plaintiff did, however, “retain copies of its price documents because of the need to respond to [Commerce’s] antidumping questionnaire.” (Id.) Plaintiff timely responded to Commerce’s initial questionnaire, see Preliminary Results, 64 Fed. Reg. at 5,767, and to a supplemental questionnaire delivered shortly thereafter. See id.
In the interim, the domestic producers submitted to Commerce a letter alleging that Plaintiff, during the period of review, had made sales at prices below its cost of production. (See letter from McGrath & Chessler to Daley of 9/1/98, Pl.’s App., Tab 8.) Commerce initiated a cost of production investigation, see Preliminary Results, 64 Fed. Reg. at 5,767, and, on October 15,1998, requested from Plaintiff a response to section D of its initial questionnaire, which related to cost of production. (See letter from Maeder to Dunn of 10/15/98, PL’s App., Tab 12.) By letter dated November 12,1998, Plaintiff informed Commerce that it was “unable to respond to [Commerce’s] questionnaire on cost of production, owing to lack of information.” (Letter from Dunn to Daley of 11/12/98, at 1, PL’s App., Tab 2.) Plaintiff reported that it had sold its frozen concentrated orange juice operations and was “unable to locate any documents relating to the cost of producing [frozen concentrated orange juice] in Brazil. Under the circumstances,” Plaintiff stated, “it is simply not possible for us to respond to [Commerce’s] cost questionnaire.” (Id. at 2; see also PL’s Mem. Supp. Mot. J. Agency R. at 9 (asserting that its “factory, administrative offices and all records [had been transferred] as part of this sale”) (quoting letter from Dunn to Daley of 11/12/98, at 2, PL’s App., Tab 2).) Plaintiff did not return section D, and Commerce did not solicit any further explanation.
In February 1999, Commerce issued its preliminary determination that Plaintiff had, during the period of review, made sales at prices below *1182normal value,3 see Preliminary Results, 64 Fed. Reg. at 5,767, and assigned to Plaintiff a 65.2 percent dumping margin based on adverse inferences drawn from facts otherwise available.4 Commerce stated that, “[b]ecause [Plaintiff has] failed to respond to certain questionnaires and [has] refused to participate fully in this administrative review * * * the use of total facts available is appropriate.” Id. at 5,768. In addition, Commerce stated, Plaintiff’s “failure * * * to participate in the review and to respond to [Commerce’s] questionnaires demonstrates that [it has] failed to act to the best of its ability in this review and, therefore, an adverse inference is warranted.” Id. Commerce also reported that, in calculating Plaintiffs dumping margin, it had declined to follow the “normal practice,” see id., of selecting as the adverse facts available margin the highest margin from the current or any prior segment of the proceeding, in this case, 2.52 percent, because use of such margin would allow Plaintiff to “benefit from [its] lack of cooperation.” Id. Consequently, Commerce stated, it had used data on the record of the proceeding for the purpose of calculating sales-specific dumping margins, namely, the publicly available industry-wide cost data provided by the domestic producers in the cost allegation, as well as the company-specific sales data provided by Plaintiff and one other foreign producer. See id. at 5,768. Commerce then selected the highest overall sales-specific margin calculated in this manner, 65.2 percent, as the facts available rate for Plaintiff and the other “non-cooperating respondents.” Id.
In its subsequent comments to Commerce, Plaintiff reiterated that it was “unable to respond to [Commerce’s] questionnaire on cost of production, owing to lack of information.” (Letter from Dunn to Daley of 3/30/99, at 4, PL’s App., Tab 1 (quoting letter from Dunn to Daley of 11/12/98, at 1, Pl.’s App., Tab 2).) Nonetheless, Commerce in its final results maintained that, with respect to Plaintiff, use of total facts available, as well as adverse inferences, was reasonable, supported by evidence on the record, and otherwise in accordance with law. See Final Results, 64 Fed. Reg. at 43,655. Commerce did, however, reconsider the methodology originally used to select an adverse facts available rate for Plaintiff, see id., and assigned Plaintiff a final margin based on Plaintiffs own sales data alone (and not, as had been the case in its preliminary determination, on the sales data provided by Plaintiff and one other foreign producer), and on the publicly available industry-wide *1183cost data provided by the domestic producers in the cost allegation. See id. at 43,657. Specifically, Commerce used this data to calculate transaction-specific dumping margins for Plaintiff, and then selected from among these margins, as Plaintiffs facts available rate, its highest transaction-specific dumping margin. The final rate thus assessed was 39.18 percent. See id. at 43,659.
Plaintiff subsequently commenced this action. Plaintiff s complaint challenges two aspects of Commerce’s final results: (1) Commerce’s determination that Plaintiff did not comply to the best of its ability with Commerce’s request for information, and its consequent resort to the use of adverse inferences;5 and (2) Commerce’s selection of the highest *1184transaction-specific dumping margin, calculated with the use of Plaintiff s own sales data and the cost data provided by the domestic producers in the cost allegation, as the facts available rate for Plaintiff. (See Compl. ¶ 7.)
As to its first argument, Plaintiff maintains that it was “not in possession of information concerning its cost of production because it had sold [its frozen concentrated orange juice] facility, including all office functions and records, between the time [Commerce] sent out its initial questionnaire (which did not include a request for cost of production information) and the time that a cost of production investigation was first requested by petitioners.” (Pl.’s Mem. Supp. Mot. J. Agency R. at 3.) Plaintiff further claims that it “had no reason to expect that a cost of production investigation would be requested or initiated.” (Id. at 4.)
In support of its second argument, that, even if the use of adverse inferences were “somehow justifiable” (id.), Commerce’s use of “the highest rate found on any single sale was not a proper application of facts available” (id.), Plaintiff asserts two grounds. First, Plaintiff claims there exists no rational connection between the rate assessed and the evidence of record. (Id. at 4.) Specifically, Plaintiff complains that the 39.18 percent margin assessed in the final results was the “highest less-than-normal-value margin found on any sale made by [Plaintiff] to the United States” (id. at 2) and, further, that it had made at least one other such sale at a price not less than normal value. (Id. at 2-3.) This “disregard of evidence clearly and properly on the record concerning [its] complete sales” (id. at 3), Plaintiff insists, “violated 19 U.S.C. § 1677m, which prohibits [Commerce] from disregarding information properly on the record.” (Id.) Second, Plaintiff asserts that Commerce failed to exercise the application of adverse inferences with “special circumspec*1185tion” (id. at 4) as, Plaintiff claims, is mandated by “Paragraph 7 of Annex II of the Agreement on Implementation of Article VI of the General Agreement on Tariffs and Trade (1994).” (See id.)
In response, the Government and Defendant-Intervenor claim that Commerce’s conclusion that Plaintiff failed to act to the best of its ability to comply with Commerce’s request for cost information, and its consequent resort to the use of adverse inferences drawn from facts otherwise available, are supported by substantial evidence on the record and are otherwise in accordance with law. (See Def.’s Mem. Opp’n to Mot. J. Agency R. at 12; Def.-Intervenor’s Mem. Opp’n to Mot. J. Agency R. at 13.) With respect to Commerce’s selection of Plaintiff’s facts available rate, the Government asserts that Commerce acted within its discretion, as it relied on data that was rationally related to the issue before it, and which also “provided an appropriate incentive to induce cooperation.” (Def.’s Mem. Opp’n to Mot. J. Agency R. at 13.)
Standard of Review
The court will hold unlawful “any determination, finding, or conclusion found * * * to be unsupported by substantial evidence on the record, or otherwise not in accordance with law.” 19 U.S.C. § 1516a(b)(1)(B)(i); see Consolo v. Fed. Mar. Comm’n, 383 U.S. 607, 620 (1966) (“[T]he possibility of drawing two inconsistent conclusions from the evidence does not prevent an administrative agency’s finding from being supported by substantial evidence.”); Inland Steel Indus., Inc. v. United States, 188 F.3d 1349, 1359 (Fed. Cir. 1999); Hoogovens Staal, BV v. United States, 24 CIT_,_, 86 F. Supp. 2d 1317, 1323 (2000) (“[I]n reviewing agency determinations the court declines to reweigh or reinterpret the evidence of record.”); see also Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938) (defining substantial evidence as “more than a mere scintilla,” or “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion”).
Discussion
Two questions are presented here. First, whether Plaintiff’s failure to provide information over which it had control at the outset of the administrative review, but which it subsequently transferred to a third party despite prior notice that such information might be requested by Commerce at a later date in the proceeding, constitutes a “failure] to cooperate by not acting to the best of [one’s] ability” within the meaning of 19 U.S.C. § 1677e(b), thereby warranting the application of adverse inferences. Second, whether Commerce’s selection of adverse inferences, namely, its selection of the highest transaction-specific dumping margin, calculated with the use of Plaintiffs own sales data as well as industry-wide cost data available on the record, as Plaintiffs facts available rate, is reasonable. The Court finds that Commerce’s application of adverse inferences is supported by substantial evidence on the record and is otherwise in accordance with law, and that Commerce’s selection of adverse inferences is in this case reasonable.
*1186 I. Commerce’s Application of Adverse Inferences
Once it has determined that the use of facts available is warranted under 19 U.S.C. § 1677e(a), Commerce may draw adverse inferences from such facts. See 19 U.S.C. § 1677e(b); Kawasaki Steel Corp. v. United States, 24 CIT_,_, 110 F. Supp. 2d 1029, 1034 (2000). Before so doing, however, Commerce must make the “additional finding,” id. at _, 110 F. Supp. 2d at 1034, that a party has “failed to cooperate by not acting to the best of its ability to comply with a request for information.” 19 U.S.C. § 1677e(b); see Ferro Union, Inc. v. United States, 23 CIT_, _, 44 F. Supp. 2d 1310, 1329 (1999); Borden, Inc. v. United States, 22 CIT 233, 264, 4 F. Supp. 2d 1221, 1246 (1998), affd sub nom. F.lli De Cecco di Filippo Fara S. Martino S.p.A. v. United States, 216 F.3d 1027 (Fed. Cir. 2000), rev’d on other grounds by Micron Tech., Inc. v. United States, 243 F.3d 1301 (Fed. Cir. 2001). A “mere recitation of the relevant standard is not enough.” Ferro Union, 23 CIT at_, 44 F. Supp. 2d at 1330. Commerce must: (1) state its reasons for finding that the party failed to act to the best of its ability; and (2) explain why the absence of the requested information is important to the investigation. Nippon Steel Corp. v. United States, 24 CIT_,_, 118 F. Supp. 2d 1366, 1378 (2000) (“Nippon Steel I”).
Commerce may not, of course, resort to the use of adverse inferences where a party fails to produce information that never existed. Olympic Adhesives, Inc. v. United States, 899 F.2d 1565, 1572 (Fed. Cir. 1990). The statute “clearly requires noncompliance with an information request before resort to [adverse inferences] is justified, whether due to refusal or mere inability.” Id. at 1574; see also Nippon Steel I, 24 CIT at_, 118 F. Supp. 2d at 1378 (discussing “best ability to comply” standard). Thus, in cases where, as here, a party alleges that it is unable to comply with a request for information,
Commerce must find that [such party] could comply, or would have had the capability of complying if it knowingly did not place itself in a condition where it could not comply. Commerce must also find either a willful decision not to comply or behavior below the standard for a reasonable respondent.
Nippon Steel I, 24 CIT at_, 118 F. Supp. 2d at 1378-79 (internal citation omitted); accord Steel Auth. of India, Ltd. v. United States, 25 CIT _,_, 149 F. Supp. 2d 921, 930 (2001). In addition, Commerce may, in the context of an administrative review, consider a party’s past behavior. Gourmet Equip. (Taiwan) Corp. v. United States, 24 CIT_,_, Slip. Op. 00-78, at 16 (July 6, 2000) (“Past participation may be relevant to notice, knowledge and reliance issues.”); accord Heveafil Sdn. Bhd. v. United States, 25 CIT_,_, Slip Op. 01-22, at 11 (Feb. 27, 2001). Finally, “Commerce is to consider the extent to which a party may benefit from its own lack of cooperation.” Gourmet Equip., 24 CIT at_, Slip. Op. 00-78, at 14 (citing Statement of Administrative Action *1187(“SAA”) accompanying H.R. Rep. No. 103-826(1), at 870, reprinted in 1994 U.S.C.C.A.N. 4040, 4199).
Upon reference to the statute, the relevant case law, and the record, the Court finds that Commerce properly resorted to the application of adverse inferences drawn from facts otherwise available. First, it is undisputed that the necessary cost information does, or did, in fact exist. Compare Olympic Adhesives, 899 F.2d at 1573. Second, Commerce made the requisite “additional finding” under section 1677e(b) with respect to Plaintiffs failure to cooperate, stating:
We have determined that [Plaintiff] did not act to the best of [its] ability in this proceeding * * * because we find that the failure to provide the information requested was not beyond [its] control. * * *
[Plaintiff] possessed the information necessary to complete the review at the time that the review was initiated. At initiation, the information was within [its] control. Although [Plaintiff] subsequently maintained control of the sales data only, there is no evidence to indicate that it was outside [its] ability to maintain control over the data necessary to respond to the cost questionnaire. As with its sales data, [Plaintiff] could have made an adequate provision to retain this cost data. Not only was [Plaintiff] aware that the possibility of a cost investigation existed (in light of its participation in cost investigations in previous segments of this proceeding), but it should have been aware that such an investigation was likely, given that the information used in the cost allegation was public information based on Brazilian industry data.
Furthermore, although [Plaintiffs] factual circumstances changed during the course of the review, this does not relieve [Plaintiff] of the obligation to attempt to comply, to the best of its ability, with the request for information. In this case, [Plaintiff] provided no evidence that it attempted to obtain the cost information necessary to complete the review. Finally, we note that section 782(c) of the Act affords interested parties the opportunity to notify [Commerce] when they are unable to submit the information requested, and requires them to provide suggested alternatives for submitting the information. Although [Plaintiff] notified [Commerce] of its purported inability to submit the information, it provided no suggestions for submitting alternative information. Consequently, we find that [Plaintiff] did not act to the best of its ability in this proceeding.
Final Results, 64 Fed. Reg. at 43,655-56 (internal citations omitted). Commerce also explained why the missing cost data was “fundamental” to the investigation. See id. at 43,655.
Third, the record contains a reasonable showing in support of each of the grounds cited by Commerce as the basis for its conclusion that Plaintiffs failure to cooperate was not beyond its control. See Nippon Steel Corp. v. United States, 25 CIT_,_, 146 F. Supp. 2d 835, 841 (2001) (“In cases where a respondent claims an inability to comply with the agency’s requests for information, [Commerce] may permissibly draw *1188an adverse inference upon a reasonable showing that the respondent, in fact, could have complied.”) (“Nippon Steel II”). For instance, the record shows that Plaintiff possessed the requested cost data, as it did the requested sales data. (See, e.g., letter from Dunn to Daley of 11/12/98, at 2, Pl.’s App., Tab 2; Pl.’s Mem Supp. Mot. J. Agency R. at 24.) The record also contains representations by Plaintiff that further demonstrate that it “would have had the capability of complying if it knowingly did not place itself in a condition where it could not comply.” Nippon Steel I, 24 CIT at_, 118 F. Supp. 2d. at 1378-79. According to Plaintiff:
[o]n July 1, 1998, [it] sold its entire [frozen concentrated orange juice] operation, transferring the factory, administrative offices and all records as part of this sale. While [it] retained pricing information because of the administrative review that had been requested, [it] did not anticipate the initiation of a cost investigation and therefore did not retain any cost information. Thus, [it] did not have in its possession any of the cost information requested by [Commerce] and was unable to obtain it.
(Pl.’s Mem. Supp. Mot. J. Agency R. at 9 (quoting letter from Dunn to Daley of 11/12/98, at 1-2, Pl.’s App., Tab 2).) Notably, the record does not contain any representation that Plaintiffs failure to “retain” its cost data was beyond its control. Commerce’s conclusion, then, that Plaintiff could have retained its cost data, is reasonable in light of the statements on the record and Plaintiffs retention of its price data.
The record also demonstrates that Plaintiff was both: (1) actually alerted to the prospect that it might be required to submit cost data; and (2) sufficiently experienced with Commerce’s procedures, such that, even without actual notice, it should have known that cost data might be required. In other words, Plaintiffs “behavior [fell] below the standard for a reasonable respondent.” Nippon Steel I, 24 CIT at_, 118 F. Supp. 2d at 1379. At the outset of the administrative review, Plaintiff was unambiguously and explicitly advised by Commerce that cost of production data might be required at a later date. In addition, Plaintiff participated in two previous reviews where such information was, in fact, requested. Indeed, Plaintiff took part in six administrative reviews prior to the review contested herein. (See Pl.’s Mem. Supp. Mot. J. Agency R. at 5.) Plaintiff was not, then, unfamiliar with these proceedings, and was well aware of the kinds of information it might be required to submit. Hence, Plaintiff cannot be said to have had no “real indication that [Commerce] would conduct such an investigation.” (Id. at 7.) Here, a reasonable respondent would have retained its cost data. Cf. Heveafil 25 CIT at_, Slip Op. 01-22, at 11-12 (finding that evidence supported Commerce’s conclusion that plaintiff, in context of verification, had failed to cooperate, where plaintiff destroyed certain “source documents” despite having previously been informed that Commerce wished to review such documents and, in light of such notice and its past participation in verifications, knew or should have known to maintain *1189such documents); Ta Chen Stainless Steel Pipe, Inc. v. United States, 24 CIT_,_, Slip Op. 00-107, at 8 (Aug. 25, 2000) (“Ta Chen IF). Finally, Plaintiff fails to point to any evidence of any attempt on its part to provide Commerce with its cost information, much less that it acted to the best of its ability to do so. Nor does Plaintiff allege that it made any effort to obtain the requested data. In sum, the record does not show that Plaintiff was unable to obtain the requested cost information but, perhaps, only that it did not at the time of Commerce’s request readily possess such information. Similarly, Plaintiff made no attempt during the administrative proceedings to provide Commerce with alternative information that it now, belatedly, claims might have been “usable” (Pl.’s Mem. Supp. Mot. J. Agency R. at 32), if only it had been “give[n] * * * an opportunity to suggest it.” (Id.) Such behavior, again, falls “below the standard for a reasonable respondent.” Nippon Steel I, 24 CIT at_, 118 F. Supp. 2d at 1379; see, e.g., Kawasaki Steel, 24 CIT at_, 110 F. Supp. 2d at 1036 (noting that plaintiff, “a sophisticated and continuing player in the market, never suggested alternatives, never requested help from Commerce, and provided an unconvincing account of why it could not comply fully”); see also 19 U.S.C. § 1677m(c)(l).
Thus, the Court finds the grounds cited by Commerce in support of its determination that Plaintiff had failed to act to the best of its ability to comply with Commerce’s request for information, and, hence, its decision to apply adverse inferences, supported by substantial evidence on the record and otherwise in accordance with law.
II. Commerce’s Selection of Adverse Inferences
Commerce is authorized to draw adverse inferences, where permitted, on the basis of secondary information6 or on any other information placed on the record. See 19 U.S.C. § 1677e(b)(l)-(4); 19 C.F.R. § 351.308(c) (1998). “In the case of uncooperative respondents, the discretion granted by the statute appears to be particularly great.” F.lli De CecCo, 216 F.3d at 1032; see also Heveafil, 25 CIT at_, Slip Op. 01-22, at 13 (“Once it determines that it is appropriate to assign adverse facts *1190available, Commerce has discretion in choosing a specific dumping margin.”). However, a rational relationship must exist between the facts chosen and the matter to which they are applied. Ta Chen II, 24 CIT at _n.6, Slip Op. 00-107, at 20 n.6.
As previously noted, Commerce relied on the following record data: (1) cost of production information supplied by the domestic manufacturers in the cost allegation; and (2) sales data provided by Plaintiff. Final Results, 64 Fed. Reg. at 43,657. Thus, Commerce used data on which it was, by statute, permitted to rely when drawing an adverse inference. See 19 U.S.C. § 1677e(b)(4); see also NSK, Ltd. v. United States, 25 CIT _,_, Slip Op. 01-69, at 76 (June 6, 2001) (finding that, because Commerce drew adverse inference from information on which it was permitted to rely, selection of respondent’s rate was reasonable and in accordance with law).
Furthermore, there exists a rational relationship between the facts • chosen — data on the record relating to the costs associated with the production of frozen concentrated orange juice in Brazil, together with Plaintiff s own sales data — and the matter to which they were applied— the calculation of Plaintiffs sales-specific dumping margins. Cf. Mannesmannrohren-Werke, 23 CIT at_, 77 F. Supp. 2d at 1319 (finding that a “close nexus” and, hence, rational relationship, existed “between the data chosen and the matter to which it applie[d] since, essentially, Commerce did no more than use available record evidence of a market price to help it approximate other market prices”).
Moreover, use of the highest calculated transaction-specific dumping margin as Plaintiffs facts available rate furthers the underlying purpose of using an adverse inference, i.e., to “ensure that [a] party does not obtain a more favorable result by failing to cooperate than if it had cooperated fully.” SAA at 870, 1994 U.S.C.C.A.N. at 4199; Mannesmannrohren-Werke, 23 CIT at_n.7, 77 F. Supp. 2d at 1319 n.7; cf. NSK Ltd., 25 CIT at_, Slip Op. 01-69, at 76 (upholding as reasonable Commerce’s selection of highest calculated margin as adverse facts available rate so that plaintiff “would not benefit from its lack of cooperation and so that [plaintiff] would have an incentive to cooperate in future reviews”). Indeed, Commerce noted that it had declined to follow its normal practice of using the highest margin from the current or any prior segment of the proceeding, as this would have led to the application of a dumping mar*1191gin that was, according to Commerce, “much lower than [the] margin[] actually calculated based on information submitted by [Plaintiff] in this segment of the proceeding,” Final Results, 64 Fed. Reg. at 43,651, and which would, therefore, have allowed Plaintiff to benefit from its lack of cooperation. See id.
As to Commerce’s alleged disregard of Plaintiffs other sales data, which, Plaintiff argues, Commerce should have used to calculate a weighted-average dumping margin rather than relying on the single highest transaction-specific dumping margin selected, the Court is not convinced that Commerce’s decision was unreasonable. Plaintiff cites no authority indicating that Commerce is mandated to use such an approach.7 Indeed, the selection of particular adverse facts is a matter largely within Commerce’s discretion. See F.lli De Cecco, 216 F.3d at 1032 (“Commerce is in the best position, based on its expert knowledge of the market and the individual respondent, to select adverse facts that will create the proper deterrent to noncooperation with its investigations and assure a reasonable margin.”). While the selection of a party’s highest transaction-specific dumping margin as its facts available rate may not in every case be reasonable, see, e.g., NTN Bearing Corp. v. United States, 74 F.3d 1204, 1208 (Fed. Cir. 1995) (underscoring Commerce’s duty to calculate dumping margins “as accurately as possible”) (“NTN IF’), here, Commerce explained that the application of a weighted-average dumping margin “potentially would allow [Plaintiff] to benefit,” Final Results, 64 Fed. Reg. at 43,657, as the reported costs otherwise available “are based on average data from the Brazilian [frozen concentrated orange juice] industry, which is comprised of both high- and low-cost producers,” id., and are, thus, “likely * * * understated.” Id. Finally, although Commerce’s selection of the highest transaction-specific dumping margin may have resulted in a higher rate than that which would have been assessed had Commerce used a weighted-average dumping margin incorporating all of Plaintiffs sales data, this *1192does not render Commerce’s methodology “lacking in rationality.” Mannesmannrohren-Werke, 23 CIT at_, 77 F. Supp. 2d at 1319.
Thus, the Court concludes that Commerce’s selection of adverse inferences, namely, its selection of Plaintiffs highest transaction-specific dumping margin as Plaintiffs facts available rate, is reasonable.
Conclusion
For the reasons set forth above, the Court concludes that Commerce’s application of adverse inferences drawn from the facts otherwise available is supported by substantial evidence on the record and is otherwise in accordance with law, and that Commerce’s selection of adverse inferences is in this particular case reasonable. Thus, the Court upholds Commerce’s final determination. Judgment is entered accordingly.