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In reply, counsel for the appellant reiterated his previous point that the respondent's position represents treating the purchase orders as if they were unilateral contracts, which is inconsistent with the evidence of the appellant's witness. He submitted that this evidence is uncontradicted by the respondent's evidence. With respect to the respondent's discussion of the Ansaldo case, counsel suggested that there would only be injury to Canadian production at the time that the offer is made, if it were actually a unilateral contract. Counsel also suggested that the Federal Court of Appeal, in the Ansaldo case, dealt with a broader issue than this case, namely, what should be covered in terms of the overall objectives of SIMA and how to interpret the phrase "sale price" in that context. In regard to the Dico case, counsel stated that this case should be seen as a special case, without precedential value, because it was decided by an order drafted by the parties pursuant to a settlement that they reached and because the appellant's position was that, at all relevant times, it had furnished sufficient information.
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