The panel report addresses two main issues: (i) the use of “zeroing” by the USDOC in the First and Second Administrative Reviews; and (ii) the notion of “continued zeroing”. With respect to the latter issue, the Panel examined whether the “continued use” of “zeroing” as “ongoing conduct” is a “measure” susceptible to WTO dispute settlement. The Panel noted that, conceptually, the alleged “measure” challenged by Brazil appeared to be very similar, if not identical, to the “ongoing conduct” measure that was the subject of the European Communities' complaint in US — Continued Zeroing. The Panel described this measure as conduct that is currently taking place and is likely to continue in the future, recalling that the Appellate Body in US — Continued Zeroing had found that such a measure was susceptible to WTO dispute settlement.