New CIT Lead Case Named After Atmus Dismissal: Euro-Notions Florida — and 11.2 Million CAPE Filings in Week One

Two things happened in the IEEPA refund litigation since the Atmus order in early March that importers and counsel are still catching up on. The lead case changed. And the CAPE portal absorbed an opening-week filing volume that nobody had really planned around.

Here is where the docket stands as of April 29, 2026, and what it means for an importer deciding whether to keep waiting on litigation or move now.

The lead case is now Euro-Notions Florida

On April 6, 2026, Senior Judge Richard Eaton of the U.S. Court of International Trade granted the Notice of Dismissal filed by counsel for Atmus Filtration, Inc. The original lead case in the consolidated IEEPA refund litigation was over.

Eight days later, on April 14, Judge Eaton held a closed conference in the new lead case, Euro-Notions Florida, Inc. v. U.S. Customs and Border Protection, et al. Euro-Notions is now the case the rest of the IEEPA refund docket is staying behind.

A few things to keep in mind on what changed and what did not.

First, the underlying legal question did not change. The Supreme Court's February 20, 2026 ruling in Trump v. V.O.S. Selections, Inc. and Learning Resources, Inc. v. Trump (Nos. 24-1287 and 25-250) is still the controlling authority that IEEPA does not authorize the President to impose tariffs. Atmus did not lose. Atmus dismissed voluntarily. The legal merits move forward through Euro-Notions.

Second, the protective filing strategy did not change. The roughly 1,000+ companies who filed CIT actions to preserve refund rights are still preserved. Their cases are still stayed pending the lead case. Substituting Euro-Notions for Atmus does not unwind any of that.

Third, the calendar got more concrete. Judge Eaton ordered CBP to file a status update by noon Eastern on April 28, 2026, with a closed settlement conference at 2 p.m. the same day. CBP filed.

What the April 28 CBP filing said

The headline number from CBP's April 28 declaration: more than 11.2 million entries have been submitted through CAPE since the portal went live April 20.

Of that 11.2 million, approximately 1,740,000 have cleared all CBP validations and are now moving through the formal refund pipeline. The rest are still in some form of validation review, rejection, or correction loop.

A few observations on what those numbers actually mean.

The submission count is gross. It includes entries that were rejected, entries that need to be re-filed, and entries that came in with eligibility flags that need work. Submitting a CAPE Declaration is not the same as having a refund queued. The 1.74 million figure is the better benchmark for what is actually in the pipeline.

The validation gap is large. About 84% of submitted entries have not yet cleared. Some of that is normal first-week processing. Some of it is going to be entries that were filed without enough cleanup. CBP has been clear that compliance flags extend the 60-90 day processing window. For importers whose CAPE Declarations end up in extended review, the timing advantage of CAPE over a protest narrows.

The volume confirms what TRS has been telling clients since February. The CAPE pipeline is going to be congested. The importers who get refunds first are the ones whose Declarations are clean on the first submission.

What this changes for importers still deciding

If your IEEPA exposure is concentrated in unliquidated entries or entries within 80 days of liquidation, your primary pathway is still a CAPE Declaration. The April 28 numbers do not change that.

If your exposure includes entries past the 80-day Phase 1 window, your pathway is still a CBP protest inside the 180-day liquidation clock under 19 U.S.C. § 1514, or a CIT action under 28 U.S.C. § 1581(i) afterward. The Euro-Notions docket is the lead case those CIT filings stay behind.

The decision most importers face right now is not "CAPE or CIT." It is how to file across both at the same time so that no entries fall through the gap between them. That is what the deadline matrix at /ieepa-refund-deadlines lays out, and it is the work TRS does at intake.

What is next on the docket

CBP's next status update is on the calendar. Judge Eaton has been holding closed conferences on a roughly two-week cadence. The settlement conference posture suggests the court is pushing for resolution of administrable categories rather than waiting for a single dispositive ruling on every remaining issue.

For importers, that means the litigation is not standing still while CAPE rolls out. It is running in parallel.

This article is for informational purposes only and does not constitute legal advice. The Euro-Notions Florida docket is active and the facts above reflect publicly reported filings as of April 29, 2026. Consult a qualified trade attorney before relying on any of the foregoing for a specific entry or refund strategy.