This paper provides an empirical analysis of the factors explaining U.
S. countervail action. Factors that indicate changes in the political
economic environment are incorporated into a legit model to explain th
e propensity to initiate a countervail suit These factors, augmented b
y variables representing foreign subsidy specificity, are used in a le
git model to explain the propensity to levy a countervail duty, once a
suit is initiated. Evidence indicates that factors that would lead to
political lobbying are significant in the initiation of a countervail
suit. However, these variables are not significant in explaining the
propensity to actually levy a duty; rather, the analysis finds that su
bsidy specificity criteria are the significant variables.