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    Global Problem Solving from Covington: Deal with Complex Problems Anywhere in the World

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Shara L. Aranoff

Partner

Washington +1 202 662 5997

English
  • About
  • Representative Matters
  • Credentials
  • About

    Shara helps clients navigate trade remedies, tariffs, and customs regulations in support of their U.S. and global market strategies.

    Shara is the Chair of Covington’s International Trade Practice Group, and co-leads the Customs practice.

    Drawing on her 20 years of service in the U.S. government, she develops legal and public policy strategies to assist clients engaging with the U.S. International Trade Commission (ITC), U.S. Customs and Border Protection (CBP), Congress, and the courts. In high-stakes antidumping and countervailing duty investigations, Shara helps global manufacturers, distributors, and retailers protect their access to the U.S. market. She assists technology, life sciences and manufacturing companies enforce and defend their intellectual property rights in cross-border Section 337 investigations. Chambers praises her for bringing “behind-the-curtain knowledge to the private sector” in proceedings before the ITC by leveraging her experience as a decision maker.

    Shara also regularly advises clients in a wide range of industries on Customs compliance and tariff mitigation, including:

    • Providing legal opinions or seeking Customs rulings on classification, valuation, country of origin, and product marking/labelling.
    • Conducting internal compliance reviews, drafting compliance policies, and providing training.
    • Responding to CBP audits and inquiries and filing voluntary disclosures.
    • Developing strategies to reduce tariffs and take advantage of trusted trader programs.

    Prior to joining the firm, Shara was a Commissioner and Chairman of the ITC, where she was a decision-maker in hundreds of Section 337, antidumping, countervailing duty, and safeguard investigations.

    She previously served as Senior International Trade Counsel for Senator Max Baucus (D-MT) at the U.S. Senate Committee on Finance, where she was responsible for legislative and policy issues including Trade Promotion Authority; negotiations involving the World Trade Organization and free trade agreements; and trade remedy and customs laws. She was also an attorney-advisor in the Office of the General Counsel at the ITC, where she was lead counsel in litigation before the Court of Appeals for the Federal Circuit and the Court of International Trade.

    Areas of Expertise

  • Practices and Industries
  • Representative Matters

    Trade Remedy Investigations

    • Represented TTX Company in Freight Rail Coupler Systems and Components from China, Inv. Nos. 701-TA-670 & 731-TA-1570, resulting in unanimous negative determination by the ITC.
    • Represented OCP S.A. in a countervailing duty investigation of Phosphate Fertilizer from Morocco and Russia, USITC Inv. Nos. 701-TA-650-651.
    • Successfully assisted KT&G Corporation to defeat an antidumping duty petition, achieving a negative final injury determination at the ITC in Inv. No. 731-TA-1465, 4th Tier Cigarettes from Korea.
    • Represented GE Renewable Energy in Utility Scale Wind Towers from Canada, Indonesia, Korea, and Vietnam, Inv. Nos. 701-TA-627-629 and 731-TA-1458-1461.
    • Secured a unanimous negative determination from the ITC on behalf of Kruger Inc., the News Media Alliance, and Gannett, preserving open trade in newsprint, in Uncoated Groundwood Paper from Canada, Inv. Nos. 701-TA-584 and 731-TA-1382.
    • Defeated a countervailing duty petition lodged by Boeing against Bombardier, Inc.’s C-Series aircraft, obtaining a unanimous ITC negative injury determination in 100- to 150-Seat Large Civil Aircraft from Canada, Inv. Nos. 701-TA-578 and 731-TA-1368.
    • Represented Samsung Electronics before the ITC and USTR in the Large Residential Washers safeguard investigation, Inv. No. TA-201-76.
    • Represented South32 in antidumping investigation of Silicomanganese from Australia, Inv. No. 731-TA-1269, obtaining negative ITC final determination.
    • Represented an Asian paper manufacturer in Certain Uncoated Paper from Australia, Brazil, China, Indonesia, and Portugal, Inv. Nos. 701-TA-528-529 & 731-TA-1264-1268.
    • Represented Union Pacific Railroad in antidumping and countervailing duty investigations of 53-Foot Domestic Dry Containers from China, Inv. Nos. 701-TA-514 and 731-TA-1250, resulting in negative injury determination.

    ITC Section 337 Investigations

    • Represented SK Innovation in Certain Lithium Ion Batteries, Battery Cells, Battery Modules, Battery Packs, Components Thereof, and Processes Therefor, Inv. No. 337-TA-1159.
    • Represented Current Lighting Solutions, LLC, General Electric Company, and Consumer Lighting (U.S.), LLC in Certain LED Packages Containing PFS Phosphor and Products Containing Same, Inv. No. 337-TA-1156.
    • Represented Baosteel in Certain Carbon and Alloy Steel Products, Inv. No. 337-TA-1002, successfully defending against claims of antitrust violations, trade secret theft, and false designation of origin.

    • Represented Texas Instruments in Inv. No. 337-TA-984, Certain Computing or Graphics Systems, Components Thereof, and Vehicles Containing Same.
    • Represented Samsung in Inv. No. 337-TA- 925, Certain Communications or Computing Devices and Components Thereof.

    Customs Matters

    • Advised a global energy company on the reorganization of its customs compliance functions, including assessment of which compliance tasks needed to be localized in each country or affiliate entity and which could be centralized in a Global Trade Compliance unit.
    • Assisted a European parent company and its affiliated U.S. importer in the industrial sector to make a comprehensive prior disclosure, implement a new compliance manual and training program, and successfully settle a related Department of Justice (DOJ) False Claims Act investigation.
    • Represented a large automotive sector importer in a broad and complex internal review of import compliance, including multiple prior disclosures to CBP, a Focused Assessment, supply chain reassessments stemming from Section 301 tariffs and USMCA rules of origin, ruling requests, establishment of an FTZ, and development of improved internal controls.
    • Represented the U.S. subsidiary of a foreign pharmaceutical company with a global manufacturing and sales footprint on an internal compliance review, prior disclosure to CBP, redesign of product labels, valuation assessment for R&D materials and IP royalties, and development of upgraded import compliance procedures.
    • Assisted a biotechnology company with preparation of a prior disclosure addressing underpayment of Section 301 duties.
    • Represented an air cargo company responding to a CID issued by DOJ in connection with a False Claims Act investigation involving claims of import duty evasion and failure to adhere to CBP entry requirements for e-commerce shipments, successfully persuading DOJ to take no further action.
    • Conducted an internal review of potential country of origin misreporting for a manufacturer and importer of government and consumer IT products, advising on GSA, customs penalty, and False Claims Act risks and voluntary disclosure strategy.

    Areas of Expertise

  • Credentials
    Education
    • Harvard Law School, J.D.
    • Princeton University, Public and International Affairs, B.A.
    Bar Admissions
    • District of Columbia
    • Massachusetts
    • New York
    Government Experience
    • U.S. International Trade Commission
    • U.S. Senate
    Judicial Clerkship
    • Hon. Herbert P. Wilkins, Massachusetts Supreme Judicial Court
    Pro Bono
    • Assisted non-citizen soldier with military discharge upgrade, allowing her to overcome the final hurdle to U.S. citizenship.
    • Assisted disabled veteran to seek military discharge upgrade based on updated Department of Justice guidance on PTSD and mental illness.
    • Developing manual to assist veterans who receive discharge upgrades to claim newly-available benefits.
    • Developed guidance on transitional peace agreements under international law and global best practices, in support of peace negotiators in Sudan.
    Accolades
    • Chambers Global, International Trade: Trade Remedies & Trade Policy (2021-2024)
    • Chambers USA, International Trade: Trade Remedies & Trade Policy (2020-2024)
    • The National Law Journal, "Intellectual Property Trailblazers" (2019)
    • Law360, "International Trade MVP" (2018, 2016)
    • Legal 500 US, Patent Litigation - International Trade Commission (2016-2017)
    • Legal 500 US, Dispute Resolution - International Trade (2017)
    • Legal 500 US, Litigation - International Trade and Government Relations (2015)
    • Law360, "Influential Woman in IP Law" (2014)
    Previous Experience
    • U.S. International Trade Commission, Commissioner and Chairman
    • U.S. Senate Committee on Finance, Senior International Trade Counsel to Senator Max Baucus (D-MT)
    • U.S. International Trade Commission, Office of the General Counsel, Attorney Advisor

    Areas of Expertise

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