rights under the due process and equal protection clauses of the United States Constitution. Compl. ¶ 14. Nowhere in WRIA’s summons, however, could defendant be expected to find such constitutional claims. (b) Argument for modification of existing law: Counsel for WRIA contended, in the alternative, that there exists a good faith argument for the modification of existing law, namely, the filing of a complaint is not a jurisdictional prerequisite under the current statutory scheme because 28 U.S.C. § 2636(c), not 19 U.S.C. § 1516a (a)(2), governs jurisdiction. WRIA’s Opp’n to Def.’s Motion to Dismiss, at 3. Counsel failed to mention, however, that this argument had already been rejected by the Federal Circuit. See Georgetown Steel, 4 Fed. Cir. (T) at 147-48, 801 F.2d at 1312-13 (<HOLDING>). Counsel subsequently advised the court that
holding that under 28 usc  1404a might have been brought requirement was not satisfied by defendants consent to jurisdiction holding that venue for litigation was proper based on 28 usc  1441 regardless of whether defendant was doing business in the district within the meaning of 28 usc  1391 holding that where jurisdiction was based on 28 usc  2201 venue was determined as per 28 usc  1391 holding sum certain requirement of 28 cfr 142a applies to 28 usc  2675 holding that 28 usc  2636c did not modify the filing requirement in 19 usc  1516aa2a