7.22 On the basis of this evidence, and in the light of the fact that the United States does not
contest that the USDOC used the "zeroing" methodology in the manner described by Korea, in the
Panel's view Korea has established that the USDOC "zeroed" in the measures at issue.
(d) Has Korea established that the methodology used by the USDOC is the same in all legally
relevant respects as the methodology reviewed by the Appellate Body in US – Softwood
Lumber V?
7.23 Korea contends that the "zeroing" methodology at issue in this dispute is "virtually identical"
to the methodology that was held to be inconsistent with Article 2.4.2 of the Anti-Dumping
Agreement in US – Softwood Lumber V. It is necessary for us to consider whether this is indeed the
case and if so, to consider the implications of the identity between the methodologies.
7.24 In US – Softwood Lumber V, Canada's challenge was limited to an "as applied" challenge to
the consistency of "zeroing" when used in calculating margins of dumping on the basis of a
comparison of a weighted average normal value with a weighted average of prices of all comparable
export transactions (the "weighted average-to-weighted average" methodology) in the context of an
original investigation under Article 2.4.2 of the Anti-Dumping Agreement.
7.25 The Appellate Body in US – Softwood Lumber V, described "zeroing" as applied by the
USDOC in that investigation as follows:
"First, USDOC divided the product under investigation (that is, softwood lumber
from Canada) into sub-groups of identical, or broadly similar, product types. Within
each sub-group, USDOC made certain adjustments to ensure price comparability of
the transactions and, thereafter, calculated a weighted average normal value and a
weighted average export price per unit of the product type. When the weighted.