Application of the comparable PSM requires the identification of unrelated companies that have functions, risks, and transactions comparable to those involved in the transactions between DC and DSST/DSTT. However, it is extremely unlikely to find companies whose functions, risks, and transactions are sufficiently comparable to those involved in the intercompany transactions between DC and DSST/DSTT. Even if such companies were found, it would be extremely unlikely that data would be available to measure the profit on the comparable uncontrolled transactions.