* Trump implies firms would benefit by abstaining on

refunds

* US has begun taking electronic refund applications

* System will process up to $166 billion in refunds

By David Lawder

WASHINGTON, April 21 (Reuters) - President Donald Trump

said on Tuesday he will "remember" companies that do not seek

refunds for tariffs paid that were deemed illegal by the Supreme

Court, implying they would somehow benefit by abstaining from

the U.S. government's new refund portal.

On the second day that the U.S. Customs and Border

Protection agency began accepting electronic refund

applications, Trump told CNBC that he was pleased to hear about

media reports that Apple ( AAPL ), Amazon ( AMZN ) and some

other large companies have not yet sought refunds.

"It's brilliant if they don't do that," Trump said in a

phone conversation with CNBC anchors that was aired live.

"If they don't do that, I'll remember them. I will tell you

that, because I'm looking to make this country strong," the

Republican president said.

Trump, who has characterized the payment of tariffs by U.S.

importers as a patriotic act, on Tuesday appeared to

characterize American companies that are pursuing refunds as the

"enemy."

"In many cases, the enemy - the enemy - is getting this

money," Trump said, apparently referring to those companies.

"The people that have hated the United States, we're giving

them checks for billions of dollars. It's so sad to see," Trump

added, without naming any specific companies or countries of

origin for the imported products.

Trump said the Supreme Court "could have helped us" by

upholding the sweeping global tariffs he imposed last year under

a 1977 law meant for use in national emergencies. Trump

denounced the court after its February ruling that he had

exceeded his powers.

The ruling by the justices led to a decision by Judge Richard

Eaton of the New York-based U.S. Court of International Trade

that the CBP create a system to process up to $166 billion in

refunds. The system, called CAPE, was launched on Monday, mostly

without serious glitches.

Eaton on Tuesday issued a temporary stay, ordering CBP to submit

a progress report on the first phase of its refund processing

system by April 28.

It was not immediately clear what impact the stay would have

on the processing of refunds. Payments were not expected to be

issued until 60 to 90 days after CBP acceptance of refund

submissions.

Matthew Seligman, a founding partner of Grayhawk Law who is

advising companies on tariff litigation and refund strategies,

said he does not think the stay will change processing by CBP

and that it may be related to a change in the case's lead

plaintiff.

"It's an acknowledgment that CAPE launched yesterday,"

Seligman said.

CBP did not immediately respond to a request for comment on

the status of the refund processing.

Eaton also has given the Trump administration a June 7

deadline to appeal his ruling requiring refunds.

Damon Pike, a customs expert at the firm BDO USA, said that

if an appeal by the administration moves forward, companies may

be required to file individual lawsuits to claim their refunds,

which would slow the process down.

"The Justice Department wants to make this as hard as

possible," Pike said, adding that an appeal would likely stop

the processing of refunds.

LAWSUITS BY COMPANIES

Some big companies including Costco, FedEx ( FDX )

and Mondelez ( MDLZ ) have sued the U.S. government to preserve

their ability to secure tariffs refunds as quickly as possible.

Other companies including Walmart ( WMT ) and Amazon ( AMZN ) have not

filed lawsuits, a move some experts see as an attempt to avoid

the ire of Trump.

Trump told CNBC that the alternative tariffs that his

administration is working to impose, under Section 301 of the

Trade Act of 1974, may produce even more revenue than the

tariffs that were struck down, but would be more complicated.

The Section 301 unfair trade practices tariff process requires

investigations and public comments. Those tariffs are not

expected to be imposed until July.

"So we're doing it a different way. We're going to end up

with the same - actually, we'll end up with bigger numbers,

actually - but it's a little more unwieldy. But it's the way

it's been done," Trump said.