1. Did the Court of International Trade erroneously conclude that Algonquin controls the outcome of this action by failing to distinguish this facial delegation challenge to section 232 from this Court's limited ruling in Algonquin, which considered only whether construing section 232 to permit the President to impose monetary exactions would result in an unconstitutionally broad delegation?

2. Is section 232 facially unconstitutional on the ground that it lacks any intelligible principle and therefore constitutes an improper delegation of legislative authority and violates the principles of separation of powers and checks and balances established by the Constitution?

Whether section 232 of the Trade Expansion Act of 1962 unconstitutionally delegates legislative power to the President, violating separation of powers