On 9 July 2004, US Customs and Border Protection （hereafter “US Customs”） amended its existing bond requirements to include new guidelines specific for “covered cases” within “special categories” of merchandise. The EBR has been imposed pursuant to the Customs Bond Directive 99-3510-004 on Monetary Guidelines for Setting Bond Amounts issued on 23 July 1991 （the “1991 Customs Bond Directive”）, as amended by the Amendment to Bond Directive 99-3510-004 for Certain Merchandise Subject to Antidumping/Countervailing Cases （hereafter the “July 2004 Amendment”）, the document entitled “Clarification to July 9 2004 Amended Monetary Guidelines for Setting Bond Amounts for Special Categories of Merchandise Subject to Antidumping and/or Countervailing Duty Cases” （hereafter the “August 2005 Clarification”）, the document entitled“Current Bond Formulas” posted by US Customs on its website on 24 January 2005 （hereafter“Current Bond Formulas”）, and the Notice published in the United States Federal Register entitled Monetary Guidelines for Setting Bond Amounts for Importations Subject to Enhanced Bonding Requirements （hereafter the “October 2006 Notice”）. The July 2004 Amendment, the August 2005 Clarification, the document Current Bond Formulas and the October 2006 Notice is referred to collectively as the “Amended CBD”. US Customs has identified as a primary objective of the directive, “continued vigilance … to ensure collection of all appropriate anti-dumping and countervailing duties.” On 1 February 2005, US Customs implemented the EBR with respect to all imports of certain frozen warmwater shrimp subject to anti-dumping duties （hereafter “subject shrimp”）. Prior to 1 February 2005, the United States had also sent notices to 33 importers beginning on 6 August 2004, of which 12 importers furnished enhanced bonds. To date, “agriculture/aquaculture merchandise” is the only merchandise designated as a “special category” and “shrimp covered by anti-dumping or countervailing duty cases” is currently the only “covered case” designated within the agriculture/aquaculture category.