OPINION

WALLACH, Judge:

This matter, see generally Roche Vitamins, Inc. v. United States, 750 F.Supp.2d 1367 (CIT 2010), comes before the court on the Motion to Deem Admitted Certain Paragraphs of Plaintiff's Statement of Material Facts Not in Dispute ("Plaintiff's Motion") filed by Plaintiff Roche Vitamins, Inc.1 Plaintiff asks the court to deem admitted paragraphs 202, 213, 224, 235, and 286 of Plaintiff's Statement of Material Facts Not in Dispute ("Plaintiff's Fact Statement") because "defendant's responses thereto are insufficient under USCIT R. 56(h) to controvert plaintiff's statement of material facts not in dispute." Plaintiff's Motion at 1.7 Plaintiff's argument is as follows:

Plaintiff's Motion at 2.

Although this court has applied the remedy prescribed by USCIT R. 56(h)(3) to violations of USCIT R. 56(h)(2), see United States v. Tip Top Pants, Inc., Slip Op. 10-5, 2010 WL 167952 at *5-6, 2010 Ct. Intl. Trade LEXIS 5 at *17-18 (January 13, 2010); Deckers Corp. v. United States, 29 CIT 1481, 1483, 414 F.Supp.2d 1252, 1253-54 (2005); United States v. T.J. Manalo, Inc., 26 CIT 1117, 1120, 240 F.Supp.2d 1255, 1258-59 (2002); Precision Specialty Metals v. United States, 24 CIT 1016, 1024 n. 10, 116 F.Supp.2d 1350, 1359 n. 10 (2000), Plaintiff does not identify any decision explicitly holding that this remedy also applies when an opposing party violates USCIT R. 56(h)(4), see Plaintiff's Motion at 1-5.8

Even if the remedy provided in USCIT R. 56(h)(3) could apply to a violation of USCIT R. 56(h)(4), it does not apply here. Because paragraphs 20 and 21 contain conclusions of law, Plaintiff's Motion is DENIED as to these two paragraphs. Because deeming paragraphs 22, 23, and 28 admitted could preclude the "correct result" that the Federal Circuit requires this court to reach in customs classification cases, Jarvis Clark Co. v. United States, 733 F.2d 873, 878 (Fed.Cir.1984), Plaintiff's Motion is also DENIED as to these three paragraphs.

With respect to paragraphs 20 and 21, Defendant correctly argues that the phrases "synthetic organic coloring matter," Plaintiff's Fact Statement ¶ 20, and "essential character," id. ¶ 21, imply legal conclusions that are not properly asserted as facts. See Defendant's Opposition to Plaintiff's Motion to Deem Admitted Paragraphs 20, 21, 22, 23, and 28 of Plaintiff's Statement of Material Facts of November 16, 2009 ("Defendant's Opposition") at 4-8. "The phrase `synthetic organic coloring matter' is part of the exact language of heading 3204." Id. at 4; see Harmonized Tariff Schedule of the United States ("HTSUS") Heading 3204. "A determination regarding essential character is a legal conclusion, applicable if merchandise is classifiable pursuant to General Rule of Interpretation . . . 3(b)." Defendant's Opposition at 7; see HTSUS General Rule of Interpretation ("GRI") 3(b). USCIT R. 56(h) requires a statement of certain material facts and a response thereto; it says nothing about conclusions of law. See USCIT R. 56(h). Indeed, "the Government cannot controvert a conclusion of law by providing `citation to evidence which would be admissible,' Rule 56(h)(4), since any evidence that would be admissible would be factual in nature, and not legal authority or support." Defendant's Opposition at 5 (citing Tropigas de Puerto Rico, Inc. v. Certain Underwriters At Lloyd's Of London, 637 F.3d 53, 56-57 (1st Cir.2011)).9

With respect to paragraphs 22, 23, and 28, although Defendant acknowledges its failure to provide specific citations in each particular statement, Defendant's Opposition at 8; see id. at 8, 9, 11, Federal Circuit precedent precludes the court from granting the remedy that Plaintiff seeks. In customs classification cases, the court must reach the "correct result." Jarvis Clark, 733 F.2d at 878; see also Universal Elecs. v. United States, 112 F.3d 488, 492 n. 3 (Fed.Cir.1997) (rejecting an approach under which "the meaning of tariff terms could depend on the quality of the importer's advocacy and could shift from case to case based on the showing made by the particular importer"); Simod America Corp. v. United States, 872 F.2d 1572, 1579 (Fed.Cir.1989) ("[T]he courts are too burdened with cases for the same or similar entries to be litigated and relitigated over and over again."). This obligation extends to both "findings of fact and conclusions of law." Peerless Clothing Int'l, Inc. v. United States, 602 F.Supp.2d 1309, 1315 (CIT 2009) (citing 28 U.S.C. § 2640(a); Jarvis Clark, 733 F.2d at 878). If the court were to deem paragraphs 22, 23, and 28 admitted on the basis of Defendant's failure to properly cite evidence, it would risk ultimately classifying the merchandise at issue according to facts that, while "true" in the courtroom, may be demonstrably false in the world in which Defendant, Plaintiff, and any other importer must operate. Because the Federal Circuit has rejected that course, see, e.g., Jarvis Clark, 733 F.2d at 878, so too must this court.

Accordingly, for the reasons stated above, Plaintiff's Motion is DENIED.