Olddog--I was wondering if you would mind considering doing some research that might be helpful. In reviewing an ALJ decision on an appeal, the ITC is different than any other administrative agency (I believe). Except for the ITC, other admistrative agencies are pretty much bound by the factual findings of the ALJ. They can only reverse factual findings (as opposed to legal rulings) in very rare instances where there is no substantial evidence on the record to support the ALJ's findings. The ITC, however, is free to review the entire record and make whatever factual findings it believes are appropriate, regardless of what the ALJ recommends and how much evidence there was to support the ALJ's factual findings. Also, it is my understanding that if the Commission decides to review the decision of an ALJ, it is subject to a detailed analysis by the ITC staff which has tremendous technical expertise and makes recommendations to the full commission. In those instances where the full commission has voted to reverse an ALJ, it would be interesting to see how many of those were unanimous or close to it. If they usually are pretty much unanimous, then I would think that the technical staff would play a very large role in influencing the members of the Commission. I don't know how readily available this information is, so it might not be possible or it could end up being an unreasonably huge undertaking. TIA
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