Instead, the cause of action pleaded on behalf of SEAI depends on “representational” standing, i.e., standing that relies solely on the status of SEAI as a representative of its members. See First Am. Compl. ¶ 1. An association invoking such representational standing “must allege that its members, or any one of them, are suffering immediate or threatened injury as a result of the challenged action of the sort that would make out a justiciable case had the members themselves brought suit.” Warth v. Seldin, 422 U.S. 490, 511, 95 S.Ct. 2197, 45 L.Ed.2d 343 (1975) (citing Sierra Club v. Morton, 405 U.S. 727, 734-41, 92 S.Ct. 1361, 31 L.Ed.2d 636 (1972)); see also Nat’l Customs Brokers & Forwarders Ass’n of Am., Inc. v. United States, 18 CIT 754, 758, 861 F.Supp. 121, 126-27 (1994) (<HOLDING>). The complaint alleges that “SEAI is an
holding mistake of fact exists where broker unintentionally and nonnegligently was unaware of the physical nature of the imported merchandise and customs relied on agent to enter good properly holding that an association of licensed customs brokers has standing to challenge an interim customs regulation allowing consignees to make informal entry of certain low value merchandise holding that the challenge to a university regulation was moot because the regulation had been substantially amended holding that the court lacked jurisdiction over customs allegedly erroneous duty assessments because the importer failed to timely protest liquidation which thereby made the customs decision final and conclusive upon the parties holding courts should interpret the contract using the references of the particular customs and usages of the trade of the parties to the contract