Freestyle World Takes Over as IEEPA Refund Lead Case

The lead IEEPA refund case at the Court of International Trade (CIT) is changing hands. On July 16, 2026, Euro-Notions Florida, Inc. filed a voluntary notice of dismissal in Euro-Notions Florida, Inc. v. United States, Court No. 25-00595 - the case Judge Richard K. Eaton has used to supervise CBP’s CAPE refund program since April. The shift was already planned: the court’s July 15 order disclosed Euro-Notions’ intention to dismiss and named Freestyle World, Inc. v. United States, Court No. 26-01088, as the successor lead case, where a motion for class certification is now pending.

The transition comes as CBP’s refund pipeline reaches its largest publicly reported size. The July 13 Lord Declaration reports that as of 3:00 p.m. EDT on July 10, approximately $121.75 billion in potential and certified refunds had been accepted for CAPE processing and approximately $86.3 billion had been completed, certified, and sent to the Treasury for disbursement - up from $104.29 billion accepted and $71.06 billion sent as of June 29.

Why Euro-Notions Is Dismissing

Euro-Notions filed its notice of dismissal under USCIT Rule 41(a)(1)(A)(i), which allows a plaintiff to dismiss without a court order before the defendant serves an answer. The dismissal was not a surprise. At a closed conference on July 14, 2026, the court and participants discussed Euro-Notions’ intention to voluntarily dismiss, and the July 15 order put that plan on the public record.

The dismissal does not end the broader IEEPA refund litigation. Judge Eaton said the court will lift the stay in Freestyle World, Inc. v. United States, Court No. 26-01088 - a separate IEEPA refund case in which a motion for class certification is currently pending. The court also discussed the Rule 23 hearing schedule in Freestyle World and in V.O.S. Selections, Inc. v. United States, No. 25-00066.

Why the Freestyle World Class Motion Matters

The most important development for importers is the pending class-certification motion in Freestyle World. To date, the government’s position has been that importers with finally liquidated IEEPA entries - entries where the 180-day protest window has closed and the entry is administratively final - must file their own individual CIT lawsuits to recover refunds. That has left millions of finally liquidated entries in legal limbo, with Phase 3 of CAPE still under development.

A certified plaintiff class would change that calculus. If the CIT certifies a class under Rule 23, importers who fit the class definition could potentially recover refunds as class members without filing individual complaints. That could open a path for non-litigant importers whose entries are otherwise locked out of CAPE Phase 1 and Phase 2.

Two important caveats:

1. Class certification is not guaranteed. The court has not yet ruled on the motion, and Rule 23 requires the plaintiffs to show numerosity, commonality, typicality, and adequacy of representation. The government is expected to oppose certification.
2. Phase 3 is still in development. The July 15 order says the court “will enter an order that directs Customs to reliquidate certain finally liquidated entries” under a procedure to be outlined in that order, and that the order “will be entered in each of the approximately 3,700 IEEPA cases assigned to the court.” That reliquidation procedure does not yet exist.

Importers with material finally liquidated exposure should continue treating individual counsel review as the reliable preservation step. Class membership, if it materializes, would be additive - not a substitute for protecting your own deadlines. See our finally liquidated CIT path guide for the decision framework.

Updated CAPE Pipeline Figures (July 13 Lord Declaration)

The July 13 declaration from CBP Executive Director Brandon Lord reports the following as of 3:00 p.m. EDT on July 10, 2026:

The most common file-validation failure reasons remain importer-of-record or filer mismatches, entry-number problems (wrong length or not found in ACE), and CSV files that do not match the published template. The most common entry-level failure reasons are entries past CBP’s 90-day reliquidation authority, entries without a Chapter 99 IEEPA HTS line, and entries already filed on a prior CAPE declaration. See our CAPE validation error guide and CSV resubmission guide for fixes.

The Three July 16-17 Filings

Three docket entries followed the July 15 order in Court No. 25-00595:

• ECF No. 47 (July 16): iGlobal Exports, LLC (doing business as Zonos) filed its response to Judge Eaton’s July 10 letter asking five questions about Zonos’s role in collecting IEEPA duties on postal-stream shipments. Zonos explained that it operates as a CBP-certified “Qualified Party” under Executive Order 14324, which created a separate duty-collection mechanism for the international postal stream outside the normal entry framework.
• ECF No. 48 (July 16): Euro-Notions’ notice of voluntary dismissal.
• ECF No. 49 (July 17): Judge Eaton denied a separate motion for leave to file an amicus curiae brief (ECF No. 36) brought by Hausfeld LLP, Nematzadeh PLLC, Barrett Law Group, P.A., Gordon Ball PLLC, Cuneo Gilbert Flannery & LaDuca, LLP, and McSweeney Cynkar & Kachouroff, PLLC.

The postal-stream question is a reminder that not every IEEPA duty was collected through the standard importer-of-record entry process. Importers that used de minimis postal shipments or Qualified Party mechanisms should confirm how their duties were paid before assuming CAPE covers them.

What Importers Should Do Now

1. Confirm ACH information is on file. 9,837 refunds are stuck at the disbursement step because ACH information is missing. Verify yours in ACE before filing. See our ACH enrollment guide.
2. File Phase 1 and Phase 2-eligible entries now. Phase 3 is not live. Clean unliquidated entries and reconciliation-flagged entries (Entry Types 01, 02, 06 without a Type 09 on file) remain the fastest path to refund. See the 7-step guide.
3. Protect protest deadlines. The 180-day protest window runs independently of CAPE. File protective protests on entries still inside the window. See the protest filing guide.
4. Get counsel review for finally liquidated entries. If you have material exposure on finally liquidated entries, do not wait for the Freestyle World class ruling or Phase 3. Ask trade counsel whether an individual 28 USC 1581(i) complaint is appropriate for your portfolio. Request a free assessment and we will connect you with vetted trade counsel.
5. Watch the August 4-5 checkpoints. CBP’s next progress report is due by 5:00 p.m. EDT on August 4, 2026, followed by a closed settlement conference on August 5. If Euro-Notions is dismissed before August 4, the government will file the report in Freestyle World.

What to Watch Next

The next material developments are likely to be: (1) the court’s ruling on the Freestyle World class-certification motion, (2) the future Phase 3 reliquidation order for the ~3,700 IEEPA cases, and (3) the August 4 progress report and August 5 settlement conference. Watch the CAPE Update Tracker on our home page for official updates.

Source Notes

Sources: CIT, Euro-Notions Florida, Inc. v. United States, Court No. 25-00595, July 15, 2026 order (ECF No. 46); Lord Declaration, July 13, 2026 (ECF No. 45); Zonos amicus response, July 16, 2026 (ECF No. 47); Notice of Dismissal, July 16, 2026 (ECF No. 48); Order denying amicus motion, July 17, 2026 (ECF No. 49); CIT, Freestyle World, Inc. v. United States, Court No. 26-01088; CIT, V.O.S. Selections, Inc. v. United States, No. 25-00066. CAPE Portal Guide is not a law firm, customs broker, or government agency.