April 13, 2021
April 2021
Made In USA Tracker
January 1997 To Present
 
 
DATE
 
COMPANY
 
AUTHOR
 
ADDRESSEE/
COPYEE
 
NATURE OF INQUIRY
 
CLOSING REASON
2/8/2021 West Coast Corporation, also d/b/a Key-Bak
 
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Wendy Y. Wang, Esq.
Best Best & Krieger LLP
Concerns that marketing materials may have overstated the extent to which products advertised, including certain
retractable badge and key holders, are made in the United States. Specifically, although WCC operates a plant, designs products, and performs certain manufacturing functions in the USA, many products it offers are wholly imported or contain significant imported components.
 
 
To avoid deceiving consumers, WCC implemented a remedial action plan to update and qualify its representations. This plan included: (1) revising websites and social media accounts; (2) updating listings on third-party platforms, such as Amazon.com; (3) updating print materials and packaging, including by stickering over unqualified claims until new materials could be printed; (4) updating tradeshow materials; (5) updating product molds; (6) contacting and training trade customers on appropriate claims; (7) designating employees to supervise and ensure compliance; and (8) adding country-of-origin training to the Company’s semi-annual sales training for sales, marketing, and customer service staff.
1/11/2020 GDMC USA LLC d/b/a VOmax
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Mr. Bruce Tretter
Chief Operations Officer
Two sets of concerns. First, certain marketing materials may have overstated the extent to which VOmax products are made in the United States. For example, VOmax made “#madeinUSA” and other unqualified U.S.-origin
claims in social media posts and other online materials, even though some VOmax cycling apparel is imported or made from imported fabrics. Second, certain VOmax marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, for some apparel products, materials omitted required country-of-origin information, or failed to disclose that products were made from imported fabrics.
To come into compliance with Section 5 of the FTC Act, 15 U.S.C. § 45(a) (“Section 5”),
and the Textile Act and Textile Rules, VOmax implemented a remedial action plan to update its
labels and marketing materials. This plan included: (1) removing broad, unqualified U.S.-origin
claims from advertisements, including social media posts; (2) updating product labels, where
appropriate; and (3) ensuring all “mail order advertising” contains required origin information.
As discussed, it is appropriate for VOmax to promote the fact that it employs workers in
the United States and offers a line of U.S.-origin apparel. However, marketing materials that
cover imported products or products made from imported fabrics must (1) not overstate the
extent to which company products are made in the United States, and (2) make clear origin
disclosures in compliance with the Textile Act and Textile Rules. FTC staff is available to work
with companies to craft appropriate claims that comply with the Textile Act and Textile Rules,
convey non-deceptive information to consumers, and highlight work done in the United States.
1/11/2020 GDMC USA LLC d/b/a VOmax
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Mr. Bruce Tretter
Chief Operations Officer
Two sets of concerns. First, certain marketing materials may have overstated the extent to which VOmax products are made in the United States. For example, VOmax made “#madeinUSA” and other unqualified U.S.-origin
claims in social media posts and other online materials, even though some VOmax cycling apparel is imported or made from imported fabrics. Second, certain VOmax marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, for some apparel products, materials omitted required country-of-origin information, or failed to disclose that products were made from imported fabrics.
To come into compliance with Section 5 of the FTC Act, 15 U.S.C. § 45(a) (“Section 5”),
and the Textile Act and Textile Rules, VOmax implemented a remedial action plan to update its
labels and marketing materials. This plan included: (1) removing broad, unqualified U.S.-origin
claims from advertisements, including social media posts; (2) updating product labels, where
appropriate; and (3) ensuring all “mail order advertising” contains required origin information.
As discussed, it is appropriate for VOmax to promote the fact that it employs workers in
the United States and offers a line of U.S.-origin apparel. However, marketing materials that
cover imported products or products made from imported fabrics must (1) not overstate the
extent to which company products are made in the United States, and (2) make clear origin
disclosures in compliance with the Textile Act and Textile Rules. FTC staff is available to work
with companies to craft appropriate claims that comply with the Textile Act and Textile Rules,
convey non-deceptive information to consumers, and highlight work done in the United States.
11/12/2020 Dal-Tile Corporation, a subsidiary of Mohawk Industries, Inc.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Kathleen Benway, Esq.
Alston & Bird LLP
Concerns that marketing materials may have overstated the extent to which Dal-Tile’s quartz slab products are made in the United States. Specifically, although the Company substantially transforms American Reserve products into finished goods in the United States, because quartz material has limited availability in the U.S., the Company imports essential raw materials it incorporates into these products. Dal-Tile implemented a remedial action plan to update its representations. This plan included: (1) correcting webpages and social media posts;
(2) redistributing labels, as well as instructions and guidelines, to stone centers, third-party fabricators, and distributors that purchased sample tower displays; and (3) undertaking a comprehensive review of and substantiation check for U.S.-origin claims by other Mohawk Industries, Inc. subsidiaries.
11/12/2020 Dude Products, Inc.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Christine Skoczylas, Esq.
Barnes & Thornburg LLP
Concerns that marketing materials may have overstated the extent to which certain hygienic products including, but not limited to, Dude Wipes, are made in the United States. Specifically, although the Company’s wipes undergo significant manufacturing or processing in the United States, in some instances they incorporate significant imported components. Dude Products implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) updating affected packaging and marketing materials to qualify claims; (2) updating potentially confusing or conflicting marketing copy on Company websites; and (3) submitting updated photographs and marketing copy to third-party platforms, including Amazon and Walmart. As part of this inquiry, Dude Products also reviewed its country-of-origin claims for textile products to ensure compliance with the Textile Fiber Products Identification Act, 15 U.S.C. §§ 70-70k, and implementing rules, particularly 16 C.F.R. §§ 303.15(b); 303.16; 303.33; and 303.34.
10/21/2020 Keen Pump Company, Inc.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Jonathan G. Polak, Esq.
Taft Stettinius & Hollister LLP
Marketing materials may have overstated the extent to which certain specialty pumps are made or “built” in the United States. Specifically, although Keen assembles certain products in the United States, those products
incorporate significant imported parts.
Keen removed all references to U.S. origin from its
online and hardcopy marketing materials. Additionally, Keen provided notice of the changes
and updated marketing materials to all known third-party distributors.
10/1/2020 Zoeller Pump Company, LLC
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Jeffery P. Langer, Ph.D., J.D.
General Counsel
Marketing materials may have overstated the extent to which all of ZPC’s products are made in the United States. Specifically, although some ZPC products are “all or virtually all” made in the United States, many more
incorporate more than de minimis imported content, and some are wholly imported.
ZPC implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) introducing qualified claims to
ZPC marketing materials, where appropriate; (2) correcting outdated or incorrect claims, including by stickering over claims on product packaging until new packaging arrives; (3) reviewing and updating all social media accounts; (4) introduced enhanced training for ZPC and related-company staffs; and (5) implementing enhanced processes to ensure the accuracy of dealer/distributor claims, including by providing updated marketing materials and implementing a quarterly audit process.
10/1/2020 American Crafts, L.C.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Mr. Grant Madsen
Chief Marketing Officer
AC may have failed to update packaging for certain SKUs of a cardstock product sourced from overseas mills and cut, printed, and packaged in the United States. AC implemented a remedial
action plan to update and correct these representations. This plan included: (1) updating product packaging, specification sheets, and inventory systems; (2) updating social media; (3) contacting distributors with instructions to update materials; (4) blocking new sales to noncompliant
distributors; (5) updating third-party sales platforms, including Amazon.com; (6) training staff;
and (7) introducing a regular country-of-origin auditing program administered by the Chief
Marketing Officer.
10/1/2020 Sunex International, Inc.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
John Kavanagh, J.D.
Steptoe & Johnson LLP
Marketing materials may have overstated the extent to which certain hydraulic presses are made in the United States. Specifically, although the Companies’ hydraulic presses are substantially transformed in the United States, they incorporate significant imported components.. The companies implemented a remedial action plan to update and qualify their representations where needed. This plan included: (1) updating press
labels to state "Made in USA with Foreign Components;" (2) updating product manuals and
catalogues; (3) updating social media accounts; ( 4) updating profiles on third-party sales platforms, including amazon.com; and (5) implementing a plan to communicate changes and distribute materials to third-party distributors and downstream retailers, including sending multiple communications, performing internal checks on customer sites, and suspending noncompliant dealers.
7/2/2020 Electric Bike Company, LLC
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Shannon Lukei, Esq.
Lukei Consulting, Inc.
Concerns that marketing materials may have overstated the extent to which certain electric bicycles are made or “built” in the United States. Specifically, although EBC designs and performs complex custom assembly in the United States, its bicycles incorporate significant imported parts. EBC implemented a remedial action plan to qualify its representations. This plan included training staff, distributing letters and updated materials to
retail partners and independent distributors, and revising the following materials: (1) website; (2) social media; (3) print brochures; (4) retail rental fleet materials; (5) packaging; and (6) bike
branding.
6/24/2020 Bihler of America, Inc.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Maxine Nordmeyer, CEO Concerns that marketing materials may have overstated the extent to which all products advertised on Company websites are made in the United States. Specifically, although Bihlerflex sells some U.S.-origin bungee and pet products, it also sells other products, including the ShockStrap, that incorporate significant imported parts. Bihlerflex implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) revising websites and social media accounts to clarify that not all products advertised are “all or virtually all” made in the United States; (2) updating printed materials; (3) updating tradeshow materials; and (4) circulating a memo to Bihlerflex staff providing guidance on Company claims.
6/16/2020 Merrill Manufacturing Co.
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
 
Lashanda Freeman
Federal Trade Investigator
Mr. Stephen Anderson
President
Concerns that marketing materials may have
overstated the extent to which certain yard hydrants and water well accessories are made in the
United States. Specifically, although Merrill sells some U.S.-origin products, it also sells other
products that are wholly imported or contain significant imported content.
Merrill implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) revising online and hard-copy marketing materials, including product packaging; (2) correcting artwork on tradeshow booths; (3) updating social media platforms; and (4) providing updated materials to distributors and retail accounts.
5/21/2020 IRIS USA, Inc.
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
Richard H. Casper, Esq.
Foley & Lardner LLP
Marketing materials stating the company was “Born in Japan. Made in America” may have overstated the extent to which IRIS’s products are made in the United States. Specifically, although IRIS manufactures an extensive line of plastic storage products in its U.S. facilities, certain of those products incorporate significant imported components. Additionally, some IRIS products are wholly imported. IRIS implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) removing all broad, unqualified claims from marketing materials; (2) introducing product-specific claims, where appropriate; (3) updating product packaging; (4) instructing sales personnel not to distribute marketing materials with broad, unqualified claims; and (5) issuing an advisory message to all customers to clarify IRIS’s representations.
5/15/2020 Globetech Manufacturing Inc.
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
Mr. Tim Begley Concerns that marketing materials may have overstated the extent to which Globetech’s truck and trailer parts are made in the United States. Specifically, although Globetech makes certain mud flaps in the United States, the Company also sells an economy line of imported flaps, and offers other products that incorporate significant foreign content. Globetech implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) updating product labels; (2) updating online marketing materials, including social media accounts; (3) destroying outdated trade show and hard-copy advertising materials; and (4) sending a clarification email to sales representatives, customers, and potential customers.
4/9/2020 Sonnen, Inc.
 
 
(Made in USA)
Julia Solomon
Ensor Staff Attorney
Mr. Brent Stayer Chief Operating Officer Concerns that marketing materials with broad, unqualified claims that sonnen products are made in the United States may have failed to account for the fact that the Company’s battery products contain significant foreign content. Sonnen implemented a remedial action plan. This plan included: (1) updating printed and electronic marketing materials, including product labels;
(2) training sales staff; (3) sending a letter to all partners, dealers, and installers regarding country-of-origin marketing for sonnen products; and (4) scrubbing partner, dealer, and installer websites for unqualified claims.
3/26/2020 Therm-Omega-Tech, Inc., d/b/a The BBQ
Guru, Inc.
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Gregory Luib, Esq. Marketing materials with broad, unqualified claims that BBQ Guru products, including, but not limited to, grilling thermometers, are made in the United States may have failed to account for the fact that certain of these products contain significant foreign content. BBQ Guru implemented a remedial action plan. This plan included: (1) hiring a third-party marketing and technology vendor to conduct a
comprehensive review of all Company websites to identify and remove all “Made in USA” claims; (2) reviewing social media accounts to identify and remove claims; (3) identifying and removing unqualified claims on third-party sales platforms, including amazon.com and walmart.com; (4) removing claims from product packaging, including by stickering over unqualified claims until new packaging could be obtained; and (5) training customer service representatives on how to address country-of-origin questions from customers.
3/19/2020 J-B Weld Company, LLC
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Neil C. Jones, Esq. Marketing materials may have overstated the extent to which J-B Weld’s products are made in the United States. Specifically, although J-B Weld makes many U.S.-origin epoxy and silicone adhesive products in the United States, the Company also sells cyanoacrylate and other adhesive products that either incorporate significant imported content, or are wholly imported. J-B Weld implemented a remedial action plan to update and qualify its representations where needed. This plan included: (1) updating packaging for
three product lines; (2) removing unqualified U.S.-origin claims from general company marketing materials, including the J-B Weld website, LinkedIn page, Facebook page, and YouTube page; and (3) requiring updates to third-party online marketing materials for affected product lines.
3/17/2020 Aqua Marine Deck, Inc.
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Wesley A. Roberts, Esq. Marketing materials with broad, unqualified claims that Aqua Marine products are made in the United States may have failed to account for the fact that certain of the Company’s marine decking products contain significant foreign content. Aqua Marine implemented a remedial action plan. This plan included: (1) removing all “Made in USA” claims from Aqua Marine marketing materials; (2) updating social media platforms; (3) collecting and destroying outdated materials from
dealers and distributors; and (4) providing updated materials to dealers and distributors.
2/19/2020 Wagner Spray Tech Corporation, d/b/a Titan Tool, Inc.
 
(Made in USA)
Julia Solomon Ensor Staff Attorney David R. Merritt, Esq. Marketing materials may have overstated the extent to which Titan Tool products are made in the United States. Specifically, although Titan Tool sells a mix of USA-assembled products and imported products, marketing materials made broad claims that Company products were “Built in America with Globally Sourced Materials.” Additionally, for certain USA-assembled products, and particularly on social media platforms, Titan Tool used versions of a “Built in America with Globally Sourced Materials” emblem that failed to include the “with Globally Sourced Materials” qualifier in a typeface sufficiently large to be read or noticed by reasonable consumers. Titan Tool implemented a two-pronged remedial action plan to update and qualify its representations where needed, and to increase the clarity and prominence of existing qualifications. This plan included: (1) distributing new communication standards to all employees and partners responsible for making advertising claims; (2) limiting U.S.-origin claims to appropriate products; (3) setting specific standards for sizing of qualifications in print ads and social media posts; (4) updating all print, social, and digital advertising to conform to the updated requirements; (5) distributing updated materials; (6) training personnel; and (7) implementing new review and approval processes for U.S.-origin advertising.
2/5/2020 LumenFocus, LLC
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Russell C. Menyhart, Esq. Marketing materials may have overstated the extent to which LumenFocus products are made in the United States. Specifically, although LumenFocus performs manufacturing processes in the United States, certain LED lighting products incorporate significant imported content. To avoid deceiving consumers, LumenFocus implemented a remedial action plan to update and qualify its representations. This plan included: (1) updating marketing materials to clarify or correct U.S.-origin representations; (2) updating social media platforms; (3) training marketing staff; (4) communicating changes to third-party distributors and energy service companies; and (5) assigning direct responsibility for and oversight over U.S.-origin claims compliance to LumenFocus’s President/CEO.
1/28/2020 Urquid, Inc. d/b/a Urquid Linen
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Richard S. Hartunian, Esq Although Urquid Linen performs processes in the United States, including cut and sew of certain textile products, marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, for some products, materials omitted required country-of-origin information, or failed to disclose that those products were made from imported fabrics. To come into compliance with the Textile Act and Textile Rules, Urquid Linen implemented a remedial action plan to update its labels and marketing materials. This plan included: (1) removing broad, unqualified advertisements that stated Company products were made in the United States from Company marketing materials and third-party platforms; (2) updating product labels, packaging, and distribution literature; (3) sending a letter to consumers, retailers, and third parties regarding product origin, and posting the letter on the Urquid Linen website and social media pages; and (4) training Company personnel on the requirements of the Textile Act and Textile Rules.
1/3/2020 Ensurent.com LLC, d/b/a Bulkfilter
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney John Devlin, CEO Concerns that marketing materials may have overstated the extent to which the products Bulkfilter sells are made in the United States. Specifically, while Bulkfilter offers U.S.-origin carbon pre-filters, the Company also sells wholly imported HEPA filters. Additionally, in some instances, the Company offers bundles that include both the U.S.-origin and imported products. Bulkfilter implemented a remedial action plan to clarify its representations. The plan included: (1) removing U.S.-origin claims from packaging templates for imported products and bundled items; (2) updating product images on the Company website; (3) updating product images on the Bulkfilter’s eBay listings; and (4) collecting additional substantiation in support of the Company’s unqualified claims for carbon pre-filters.
12/19/2019 Solas Ray, LLC and Direct Tech Sales LLC
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Jeff Kingston, CEO Concerns that certain marketing materials may have overstated the extent to which certain LED lighting products are made in the United States. Specifically, although Solas Ray assembles products in the United States, those products incorporate significant imported content. Solas Ray implemented a remedial action plan to clarify its representations. The plan included: (1) removing unqualified claims from all marketing materials; (2) communicating with and distributing new materials to all sales contacts; and (3) training staff and dealers.
12/06/2019 Spaghetti Engineering Corp., d/b/a DIGI-TAILS
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Mr. Michael Muhlbaier, President Concerns that marketing materials may have overstated the extent to which DIGI-TAILS’ digital tail and front light products are made in the United States. Specifically, although certain DIGI-TAILS products are designed and assembled in the United States, they incorporate imported printed circuit boards and other significant imported electronic components. To avoid deceiving consumers, DIGI-TAILS implemented a remedial action plan to update its representations. This plan included: (1) removing unqualified U.S.-origin claims from marketing materials, including packaging, Company websites, flyers, social media accounts, and trade show materials; (2) removing unqualified claims from third-party sales platforms, including
ebay.com and amazon.com; (3) introducing qualified claims, where appropriate; (4) notifying all employees of changes; and (5) making diligent efforts to ensure the accuracy of distributor claims, including by suspending noncompliant or nonresponsive distributors.
12/06/2019 Sports Addix LLC, also d/b/a Addix and Addix Sportswear
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Mr. Steve Dean, Owner/President Concerns that certain Addix marketing materials may have failed to comply with provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, although Addix designs, prints, transfers, and cuts and sews sublimated custom team uniform apparel in the United States, that apparel is made from imported fabrics. For some products, labels and materials omitted required country-of-origin information, or failed to disclose the imported fabrics. To come into immediate compliance with the Textile Act and Textile Rules, Addix implemented a remedial action plan to update its labels and other marketing materials. This plan included: (1) updating sublimated country-of-origin claims on custom apparel; (2) removing broad, unqualified claims from social media, Company websites, and Company videos; (3) updating event signage and flyers; (4) updating paid Facebook and Google advertisements; and (5) training staff.
11/27/2019 Prismview LLC, a Samsung Electronics Company
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Laura Kim, Esq. We raised concerns that certain marketing materials may have overstated the extent to which Prismview products are made in the United States. Specifically, although Prismview designs and assembles LED display products in the United States, those products incorporate significant imported inputs, including LED components. To avoid deceiving consumers, Prismview implemented a remedial action plan to clarify its representations. The plan included: (1) removing unqualified claims from all marketing materials; (2) introducing qualified claims, where appropriate; and (3) developing new training materials for Prismview’s marketing and sales teams.
11/14/2019 Nevco, Inc.
 
(Made in USA)
Julia Solomon Ensor Staff Attorney George Paul, Esq. Concerns that certain marketing materials may have overstated the extent to which Nevco products are made in the United States. Specifically, although Nevco designs, assembles, finishes, installs, and supports LED scoreboards and video displays in the United States, those products incorporate significant imported inputs, including LEDs and computer hardware. To avoid deceiving consumers, Nevco implemented a remedial action plan to clarify its representations. The plan included: (1) removing unqualified claims from all marketing materials; (2) introducing qualified claims, where appropriate; and (3) training relevant employees.
11/8/2019 ATD-American Co. d/b/a Thomaston Mills
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Robert Zaslow, President Concerns that, although Thomaston Mills performs processes in the United States, including cut and sew and finishing of certain textile products, and makes a particular line of products in the United States, marketing materials may have failed to comply with certain provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, for some products, materials omitted required country-of-origin information, or failed to disclose that those products were made from imported fabrics. To come into immediate compliance with the Textile Act and Textile Rules, Thomaston Mills implemented a remedial action plan to update its labels and marketing materials. This plan included: (1) removing broad, unqualified advertisements that stated Company products were made in the United States; (2) updating trade show signage; (3) ensuring that all Thomaston Mills products were labeled with an appropriate country of origin; (4) updating online marketing materials to include required country-of-origin information; (5) training Company personnel on the requirements of the Textile Act and Textile Rules; and (6) making diligent efforts to ensure the accuracy of third-party retailer claims, including contacting all Thomaston Mills dealers and distributors to confirm the accuracy of their marketing materials.
10/23/2019 Outlaw Audio, LLC
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Mr. Peter D. Tribeman Managing Partner Concerns that marketing materials may have overstated the extent to which Outlaw Audio products are made in the United States. Specifically, Outlaw Audio sells a mix of products that includes wholly imported products and multichannel amplifiers that are assembled in the United States of U.S. and imported parts. To avoid deceiving consumers, Outlaw Audio implemented a remedial action plan to update and qualify its representations. This plan included: (1) removing unqualified “Made in USA” claims from the Company website; (2) introducing qualified claims, where appropriate; (3) training staff; and (4) stickering over unqualified claims pending receipt of new product packaging. As discussed, it is appropriate for the Company to promote the fact that it employs workers and contracts with suppliers that perform certain processes in the United States, provided that marketing materials do not overstate the extent to which Outlaw Audio’s products are made in the United States.
10/15/2019 Coulter Ventures, LLC, d/b/a Rogue Fitness
 
(Made in USA)
 
Julia Solomon Ensor Staff Attorney Louis DiSanto, Esq.
Banner Witcoff
Concerns that marketing materials may have overstated the extent to which the products Rogue Fitness sells are made in the United States, as products featured in Company materials actually include a mix of made in
USA, assembled in USA, and imported products.
To avoid deceiving consumers, Rogue Fitness implemented a remedial action plan to
clarify its representations. The plan included: (1) removing broad U.S.-origin claims from the Company website and social media profiles; (2) verifying the origin of individual products;
(3) introducing qualified claims, where appropriate; (4) conducting training sessions; and
(5) implementing U.S.-origin verification procedures for product development and marketing
personnel.
10/1/2019 Ironcompany.com Inc., d/b/a Iron Company
 
(Made in USA)
Julia Solomon Ensor Staff Attorney J.P. Brice, CEO During our review, we discussed concerns that marketing materials may have overstated the extent to which the products Iron Company sells are made in the United States, when products featured in Company materials actually include a mix of made in USA, assembled in USA, and imported products. To avoid deceiving consumers, Iron Company implemented a remedial action plan to clarify its representations. The plan included:(1) removing broad U.S.-origin claims from the Company website and social media profiles; (2) clarifying that only certain products sold are made in the United States; and (3) verifying the origin of individual products.
10/1/2019 Komar Inc. d/b/a Bedhead Pajamas
 
(Made in USA)
Julia Solomon Ensor Staff Attorney David P. Callet, Esq. CalletLaw, LLC Although BedHead performs certain manufacturing processes in the United States, certain marketing materials may not have complied with certain provisions of the Textile Products Identification Act, 15 U.S.C. § 70 et seq. (“Textile Act”), and implementing rules, 16 C.F.R. Part 303 (“Textile Rules”). Specifically, Company materials omitted required country-of-origin information or failed to disclose that products were made from imported fabrics. To come into immediate compliance with the Textile Act and Textile Rules, BedHead implemented a remedial action plan to update its labels and marketing materials. This plan included: (1) removing broad, unqualified advertisements that stated BedHead products were made in the United States; (2) ensuring that all BedHead garments were labeled with an appropriate country of origin; (3) updating online marketing materials to include required country-of-origin information; (4) training BedHead personnel on the requirements of the Textile Act and Textile Rules; and (5) making diligent efforts to ensure the accuracy of third-party retailer claims, including contacting all BedHead retailers to confirm the accuracy of their marketing materials. Based on BedHead’s actions and other factors, the staff has decided not to pursue this investigation any further. This action should not be construed as a determination that there was no violation of Section 5 of the Federal Trade Commission Act, 15 U.S.C. § 45.
7/29/2019 Linmore LED Labs, Inc.
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Mr. John Gilmore
Vice President
Linmore LED Labs, Inc.
During our review, we raised concerns that certain marketing materials may have overstated the extent to which certain LED lighting products are made in the United States. Specifically, although Linmore LED assembles products in the United States, those products incorporate significant imported content. Linmore LED also sells wholly imported products. Substantial Compliance: to avoid deceiving consumers, Linmore LED implemented a remedial action plan to clarify its representations. The plan included: (1) removing unqualified claims from all marketing material; (2) sending notices to consumers that purchased mismarked product; (3) training personnel; and (4) introducing qualified claims, where appropriate.
7/23/2019 UNEX Corporation
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Justin B. Bender, Esq.
UNEX Corporation, d/b/a HYTORC
During our review, we discussed concerns that marketing materials may have overstated the extent to which HYTORC industrial bolting tools are made in the United States. Specifically, although HYTORC offers U.S.-origin hydraulic and pneumatic tools, the Company also offers electric tools that incorporate significant imported parts. Substantial Compliance: To avoid deceiving consumers, HYTORC removed U.S.-origin claims from marketing materials that relate to its electric tools, and revised marketing materials that apply to all Company products to remove or qualify claims as appropriate. HYTORC also sent a communication to all employees advising them of the updates.
7/23/2019 Kenall Manufacturing Co.
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Zack Hadzismajlovic, Esq. McCarter & English, LLP During our review, we discussed concerns that marketing materials may have overstated the extent to which Kenall products are made in the United States. Specifically, although most Kenall light fixtures are assembled in the United States and meet the domestic manufacturing requirements of the Buy American Act ("BAA"), they incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, Kenall implemented a remedial action plan to update and qualify its representations. This plan included: (1) conducting internal training on country-of-origin claims; (2) removing unqualified U.S.-origin claims from marketing materials, including the company website, social media accounts, and product labels; (3) removing Google Ads or other search engine optimization tags that incorporated unqualified claims; (4) communicating changes to agents and distributors; (5) adopting new processes to review marketing materials; and (6) introducing updated qualified claims where appropriate, including qualified claims relating to Kenall's BAA compliance.
7/22/2019 CURT Group
 
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Steven M. Wernikoff, Esq. Honigman LLP During our review, we discussed concerns that marketing materials may have overstated the extent to which CURT products are made in the United States. Specifically, although CURT makes custom hitches in the United States, and the Company performs certain manufacturing processes for other products in the United States, CURT also sells products that are imported or contain significant imported content. Substantial Compliance: it is appropriate for the Company to promote the fact that it employs workers and performs certain processes in the United States, provided that marketing materials do not overstate the extent to which CURT’s products are made in the United States. Additionally, FTC staff is available to work with companies to craft qualified claims that serve the dual purposes of conveying non-deceptive information to consumers and highlighting work done in the United States.
Based on CURT’s actions and other factors, the staff has decided not to pursue this investigation any further.
7/18/2019 Golden Brothers, Inc., d/b/a Golden Technologies Inc.
 
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Raymond P. Wendolowski, Esq. Fellerman & Ciarimboli During our review, we discussed concerns that marketing materials may have overstated the extent to which Golden Technologies products are made in the United States. Specifically, although the Company assembles many of its lift chairs in the United States, those chairs incorporate a mix of imported and domestic components. Additionally, Golden Technologies sells wholly imported products, including mobility scooters and its “Siesta” chair. Substantial Compliance: To avoid deceiving consumers, Golden Technologies implemented a remedial action plan to update its representations. This plan included: (1) removing unqualified U.S.-origin claims from marketing materials; (2) introducing qualified claims, where appropriate; (3) updating Google Ads; (4) training sales, customer service, technical service, and accounts payable teams; and (5) making diligent efforts to ensure the accuracy of retailer claims, including by sending several rounds of emails and letters, requiring signed declarations confirming retailers updated materials, independently monitoring compliance, and suspending noncompliant retailers.
7/18/2019 American LED Technology, Inc.
 
(Made in USA)
Julia Solomon Ensor Staff Attorney Mr. Steven Pursley Secretary/Treasurer American LED Technology, Inc. During our review, we raised concerns that certain marketing materials may have overstated the extent to which American LED displays are made in the United States. Specifically, although American LED assembles certain displays in Florida, those displays incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, American LED removed all U.S.-origin claims and logos from marketing materials. The Company also confirmed that future sales calls would no longer include U.S.-origin claims.
7/8/2019 Systematic Controls Corp., doing business as Valtorc International USA
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Katryna Lyn Spearman Concerns that marketing materials may have overstated the extent to which Valtorc products including, but not limited to, certain valves, are made in the United States Substantial Compliance: To avoid deceiving consumers, Valtorc removed U.S.-origin claims from all marketing materials and retrained staff. As we discussed, if in the future the Company offers a product or system that is "all or virtually all" made in the United States, it would be appropriate to update marketing materials accordingly. However, please note that marketing materials should clearly differentiate U.S.-origin products from imported products, and that Valtorc should take care not to make overly broad U.S.-origin claims on marketing materials that refer to multiple products.
6/10/2019 Bragel International, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Daren Peng Vice President Bragel International, Inc. Concerns that marketing materials may have overstated the extent to which Bragel products, including fabric cup adhesive bras and accessories, are made in the United States. Specifically, although certain Bragel adhesive bras are made in the United States, Bragel also sells products that contain significant imported content. Substantial Compliance: To avoid deceiving consumers, Bragel implemented a remedial action plan to update and qualify its representations. This plan included: (1) updating product packaging and labels; (2) updating online materials, including the Company website and social media pages; (3) stickering over outdated claims on hard copy marketing materials until new materials are printed; (4) updating trade show materials; (5) where appropriate, introducing new measures to enhance compliance with the Textile Fiber Products Identification Act, 15 U.S.C. § 70 et seq., and implementing rule, 16 C.F.R. Part 303; and (6) making diligent efforts to ensure the accuracy of third-party retailer claims, including by providing stickers to apply on packaging containing outdated claims, sending several communications relating to the updates, and declining to fulfill orders from noncompliant customers.
5/14/19 LG Hausys America, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Lizbeth Levinson, Esq.
Fox Rothschild LLP
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which LG Hausys's surface slabs for countertop fabrication are made in the United States. Specifically, in some instances, essential raw materials incorporated into the Company's quartz and solid surface slabs are imported. In other instances, slabs are imported as finished products. Substantial Compliance: To avoid deceiving consumers, LG Hausys implemented a remedial action plan to update its representations. This plan included: (1) removing U.S.-origin claims from or incorporating qualified claims into marketing materials; (2) sending out more than 5,000 update kits to customers; and (3) making diligent efforts to ensure the accuracy ofdealer claims, including by sending five rounds of email blasts, monitoring email open and read rates, conducting field visits, and terminating noncompliant dealers.
5/8/19 Norland International, Inc., d/b/a American Beer Equipment or A.B.E.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Erin Ebeler Rolf, Esq.
Woods & Aitken LLP
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which products and systems sold under the American Beer Equipment name are made in the United States. Substantial Compliance: To avoid deceiving consumers, Norland removed U.S.-origin claims from all marketing materials. As we discussed, if in the future the Company offers a product or system that is "all or virtually all" made in the United States, it would be appropriate to update marketing materials accordingly. However, please note that marketing materials should clearly differentiate U.S.- origin products from imported products, and that Norland should take care not to make overly broad U.S.-origin claims on marketing materials that refer to multiple products. As you know, FTC staff is available to work with companies to craft qualified claims that serve the dual purposes of conveying non-deceptive information to consumers and highlighting work done in the United States.
4/15/2019 Antigravity Batteries LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Scott Schafer, Owner
Antigravity Batteries LLC
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which Antigravity Batteries’ products are made in the United States. Specifically, certain materials were not timely updated to reflect shifts to overseas production. Substantial Compliance: To avoid deceiving consumers, Antigravity Batteries implemented a remedial action plan to update its representations. This plan included: (1) removing U.S.-origin claims from marketing materials; (2) stickering over outdated claims on retail boxes until new product packaging could be generated; and (3) making diligent efforts to ensure the accuracy of distributor claims, including notifying distributors that Antigravity Batteries would not fulfill any additional orders until distributors updated their marketing materials.
03/07/2019 Solve America’s Problems d/b/a TV Liquidator
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Reggie Judah, CEO
Solve America’s Problems
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstate the extent to which TV Liquidator sells LED signs that are made in the United States. Specifically, although TV Liquidator distributes USA-assembled signs, the signs contain significant imported parts. In this case, TV Liquidator appropriately qualified its claims in some places on its website. However, “[a] disclosure is more likely to be effective if consumers view the disclosure and the claim that raises the need for disclosure (often referred to as a “triggering claim”) together on the same screen.” Substantial Compliance: To avoid deceiving consumers, TV Liquidator updated its website, social media platforms, and Google Ads to ensure the Company’s U.S. origin claims included appropriate qualifications everywhere they appeared.
02/27/2019 Native Ken Eyewear, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Justin Tollis, Store and Production Manager Native Ken Eyewear, Inc. Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which Native Ken eyewear is made in the United States. Specifically, although Native Ken designs products in the United States, the Company sources its glasses frames overseas. Substantial Compliance: To avoid deceiving consumers, Native Ken removed all claims that its products are “made” or “built” in the United States or New York City from its advertising materials, including hashtagged claims on social media platforms.
02/27/2019 Cirrus Systems, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Stephen Rycyna, CEO Cirrus Systems, Inc. Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that certain marketing materials may have overstated the extent to which Cirrus LED displays are made in the United States. Specifically, although Cirrus assembles certain displays in Maine, they incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, Cirrus removed all “Made in Maine” claims and logos from online and hardcopy marketing materials. The Company also sent an email to dealers and distributors instructing them to destroy or update any materials with these claims.
02/22/2019 3D Solutech, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Gabe Verdugo
Keller Rohrback L.L.P.
Counsel for 3D Solutech, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which 3D Solutech’s three-dimensional printer filaments are made in the United States. Specifically, although certain filaments are made from United States-sourced raw materials, in many instances the U.S. materials undergo significant processing overseas to become finished filaments. Substantial Compliance: To avoid deceiving consumers, 3D Solutech implemented a remedial action plan. This plan included revisions and updates to product packaging, as well as the Company’s website and social media accounts. However, because most of 3D Solutech’s sales are effectuated through Amazon.com, the majority of the Company’s efforts appropriately focused n making changes to that platform. This required accessing 3D Solutech’s Amazon seller account to make both batch updates and listing-specific changes to product narratives, specifications, photographs, and listing titles.
02/05/2019 Whiteside Machine & Repair Company, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Richard B. Newman
Hinch Newman
Counsel for Whiteside Machine & Repair Company, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which Whiteside products, including router bits, are made in the United States. Specifically, although Whiteside performs some manufacturing functions in the United States, many of its products contain significant imported components. Substantial Compliance: To avoid deceiving consumers, Whiteside implemented a remedial action plan to update and qualify its representations. For Whiteside’s own materials, the Company: (1) stickered over outdated claims on product packaging; (2) updated online marketing materials; and (3) printed new catalogues, signs, banners and product packaging. Whiteside also sent a detailed communication to dealers requiring them to (1) sticker over claims on products in their possession; (2) remove potentially deceptive point-of-sale materials; and (3) update dealer-controlled online materials, including websites and social media accounts.
12/14/2018 Electrolux North America, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Megan Miller
Assistant General Counsel to Electrolux
Possible violations of Section 5 of the Federal Trade Commission Act related to potentially deceptive U.S.-origin claims made in conjunction with Electrolux’s “Built with American Pride” campaign for Frigidaire-branded products that incorporate significant imported parts. Substantial Compliance: To avoid deceiving consumers, Electrolux implemented a remedial action plan to qualify its representations. This plan included: (1) updating claims on frigidaire.com, including on the homepage and individual product pages; (2) using Google tools to accelerate the removal of Frigidaire pages from certain consumer searches; (3) removing certain YouTube videos; (4) updating the product information management system, which automatically results in updates to retailer pages; (5) removing affected in-store materials; and (6) sending field representatives to more than 2,000 retail locations to confirm updates were made.
12/13/2018 Emotiva Audio Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Robert Nieman
Director of Manufacturing and Technical Services Emotiva Audio Corporation
Possible violations of Section 5 of the Federal Trade Commission act related to concerns that marketing materials may have overstated the extent to which certain Emotiva audio products are made in the United States. Specifically, although certain Emotiva products are designed and assembled in Emotiva’s Franklin, Tennessee facility, these products contain significant imported parts, or parts of unknown origin. Substantial Compliance: Emotiva implemented a comprehensive remedial action plan to avoid deceiving consumers and update and qualify its representations. This plan included: (1) rewriting the Company website; (2) updating social media accounts; (3) destroying outdated packaging and other hardcopy marketing materials; (4) applying barcode stickers to cover claims on products; (5) purchasing back mismarked products from Amazon and updating Amazon listings; (6) instructing dealers and distributors to purge outdated materials and confirming compliance within a month; and (7) training marketing personnel on how to communication product origin.
12/11/2018 KONG Company, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Kevin J. Miller
Kellogg, Hansen, Todd, Figel & Frederick, P.L.L.C.
Counsel for KONG Company, LLC
Possible violations of Section 5 of the Federal Trade Commission act related to concerns that marketing materials may have overstated the extent to which KONG products, including rubber dog toys, are made in the United States. Specifically, although certain KONG treats are made in the United States, and the company performs certain manufacturing processes for other products in the United States, KONG also sells wholly imported products and products that contain significant imported content, including imported rubber latex. Substantial Compliance: KONG implemented a remedial action plan to update and qualify its representations. This plan included: (1) updating product packaging, product inserts, and trade show materials; (2) updating online material, including the Company website and social media pages; (3) working with direct-selling online retailers including Chewy, PetSmart, Petco, and Amazon to update claims; and (4) making diligent efforts to ensure the accuracy of third-party retailer claims, including by implementing a process to regularly check pages for origin claims and consistently notify the retailer of the issue until changes are made.
10/01/2018 Eversan, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Michael Evke
President and CEO of Eversan, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that marketing materials may have overstated the extent to which Eversan’s video screens and scoreboards are made in the United States. Specifically, Eversan products contain imported components that, in some instances account for a significant proportion of the products’ manufacturing costs and, in other instances, though less significant in terms of cost, are essential to the products’ functionality. Substantial Compliance:  Eversan implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) removing unqualified U.S.-origin claims from all online marketing materials; (2) removing unqualified claims from installation instructions; (3) introducing qualified claims such as “Assembled in USA” and “Made in USA with Some Imported Parts”; (4) communicating changes to business partners; (5) updating trade show materials; and (6) confirming that no additional products would leave the Eversan facility with unqualified claims.
10/01/2018 The Gillette Company, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Lydia B. Parnes
Wilson Sonsini Goodrich & Rosati, PC
Counsel for The Gillette Company, LLC
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns that certain marketing materials overstated the extent to which Gillette products, including certain three- and five-blade razors, are made in the United States. The relevant materials included among others, the following statements: “Boston Made Since 1901”; “Built in Boston Since 1901”; “Built in Boston, Delivered all over the globe.”; “Where do Gillette razors come from? The heart of South Boston…” Substantial Compliance: Gillette has implemented a remedial action plan to avoid deceiving consumers by re-focusing its campaign to highlight Boston-based employees and manufacturing functions without implying to consumers that Gillette razors or blades are “all or virtually all” made in the United States. Among other things, this plan includes discontinuing unqualified U.S.-origin claims across all shaving and shaving-related products in digital advertising, broadcast advertising, and on packages.
 
Based on Gillette’s implementation of the plan described above, the staff has decided not to recommend enforcement action at this time. However, certain materials presented to us during the pendency of the investigation raise concerns that Gillette may make deceptive U.S.-origin claims in the future. Therefore, we will continue to monitor the Company’s advertising slowly.
09/10/2018 RentACoop, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Tyler Phillips
RentACoop, LLC
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns over marketing materials that may have overstated the extent to which RentACoop’s chicken feeding and watering products – which incorporate significant imported components – are made in the United States. Substantial Compliance: RentACoop implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) removing unqualified U.S.-origin claims from the Company website; (2) stickering over unqualified claims on RentACoop products; (3) updating listings on third-party platforms, including Amazon.com, Chewy.com, and MyPetChicken.com; (5) editing marketing videos that highlighted product labels with unqualified claims; and (6) introducing qualified claims.
08/22/2018 Prime-Line Products Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Jeffrey Margulies
Counsel for Prime-Line Products Company
Possible violations of Section 5 of the Federal Trade Commission Act related to concerns over Prime-Line corner shields in the marketplace with “Made in USA” labels affixed over visible “Made in China” labels. The affected corner shields, which were sold online, were not advertised as “Made in USA.” The conflicting labeling was not visible to consumers at point of purchase. Inadvertent Error: Based on Prime-Line’s actions and other factors, the staff decided not to pursue this investigation any further.
 
In response to the FTC’s inquiry, Prime-Line explained that it sells otherwise identical U.S.-and Chinese-made corner shields. This spring, Prime-Line depleted its inventory of U.S.-made shields and ordered its warehouse to substitute imported product. Prime-Line stated that it did not realize labels applied to the Chinese-made products by warehouse staff during this process contained “Made in USA” claims. Upon discovering the error, Prime-Line also inspected its inventory to ensure all other products were labeled properly.
07/02/2018 Jantec Sign Group, LLC d/b/a Jantec Neon Products
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Lauri Legere
Jantec Sign Group, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with marketing materials that may have overstated the extent to which Jantec’s neon signs – which incorporate significant imported components – are made in the United States. Substantial Compliance: Jantec implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) removing unqualified U.S.-origin claims form the Company website and printed materials; (2) revising claims on social media accounts; (3) updating listings on third-party platforms, including Etsy, eBay, and Amazon; (4) editing Google AdWords and Bing ads; and (5) introducing qualified claims that highlight the fact that Jantec hand-bends neon signs in the United States.
06/13/2018 Williams-Sonoma, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Danielle M. Hohos, Esq.
Deputy General Counsel for Williams-Sonoma, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with potentially deceptive U.S.-origin claims on the pbteen.com website for apparently imported mattress pads, as well as general concerns relating to Williams-Sonoma’s process for ensuring the accuracy of country-of-origin claims on the Company’s website. Inadvertent Error: Williams-Sonoma took several steps to prevent consumer deception, which included confirming that it had inadvertently labeled certain Chinese mattress pads as “Crafted in America” on the PBTeen website. After receiving notice of the FTC inquiry, Williams-Sonoma immediately corrected the error and updated the PBTeen website to reflect the fact that the affected mattress pads are imported. With respect to country-of-origin claims for products on its website, Williams-Sonoma confirmed the three-step process it uses to prevent consumer deception: (1) it receives and reviews country-of-origin information from vendors; (2) product information teams review country-of-origin statements to confirm that they comply with the FTC’s Enforcement Policy Statement on U.S.-Origin Claims; (3) product information teams correct errors immediately upon discovering inaccurate or incorrect claims. In response to the FTC inquiry, customer care and product information personnel were retrained on appropriate processes and policies.
06/05/2018 Daktronics, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Shawna Hanson
General Counsel to Daktronics, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with marketing materials that may have overstated the extent to which Daktronics’ LED signs – which incorporate significant imported materials – are made in the United States. Substantial Compliance: Daktronics implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) immediately withdrawing and replacing online ads identified by the staff; (2) reviewing all other online, hardcopy, tradeshow, and on-product marketing materials and removing or modifying overly broad or unsubstantiated U.S.-origin claims; (3) providing training on how to make non-deceptive U.S.-origin claims to marketing groups, sales groups, product managers, human resources, technical writers, content creation groups, and demos groups; and (4) reviewing reseller claims for Daktronics products and providing replacement marketing materials to resellers as needed.
05/30/2018 Semyx, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Jeffrey J. Dean
Morris & Dean
Counsel for Semyx, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with marketing materials that may have overstated the extent to which Semyx’s waterjet cutting machines – which contain significant imported components – are made in the United States. Substantial Compliance: Semyx implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) discontinuing use of unqualified U.S. –origin claims; (2) updating all marketing materials, including the Semyx website, social media, tradeshow materials, and other hardcopy materials; (3) removing “Made in USA” stickers from products in inventory; and (4) communicating changes and sending updated information to third-party distributors.
05/09/2018 Superwinch, LLC
 
(Made in USA)
Crystal D. Ostrum
Investigator
Scott Salmon
Vice President of Consumer Business
Superwinch, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with marketing materials that may have overstated the extent to which certain of Superwinch’s products are made in the United States. Substantial Compliance: Superwinch implemented a remedial action plan to avoid deceiving consumers. This plan included (1) updating Superwinch’s website and social media accounts to remove or appropriately qualify U.S.-origin claims; (2) correcting or discarding al print materials; (4) working with an extensive third-party distributor network to update all marketing materials; and (5) altering or replacing product packaging to remove or appropriately qualify U.S.-origin claims.
05/04/2018 Tradenet Enterprise, Inc. d/b/a Vantage LED
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Nathan Heyde
Varner & Brandt LLP
Counsel for Tradenet Enterprise, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with marketing materials that may have overstated the extent to which Vantage’s LED signs are made in the United States. Substantial Compliance: Vantage implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) updating Vantage’s website and social media accounts to remove or appropriately qualify U.S.-origin claims; (2) removing, discarding, or discontinuing use of all print materials that include potential deceptive U.S.-origin claims; (3) instructing all third-party distributors and dealers to discard or return outdated materials to Vantage; (4) providing updated materials to dealers and distributors; and (5) training all sales staff on how to make non-deceptive claims for Vantage’s products.
04/19/2018 Hallmark Cards, Incorporated
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Albert P. Mauro, Jr.
Assistant General Counsel to Hallmark Cards, Incorporated
Possible violations of Section 5 of the Federal Trade Commission Act in connection with potentially deceptive “Made in USA” claims on the hallmark.com website for apparently imported holiday puzzles, as well as general concerns relating to Hallmark’s process for ensuring the accuracy of country-of-origin claims on the Company’s website. Substantial Compliance: Hallmark took several steps to prevent consumer deception. (1) Hallmark confirmed and corrected the country-of-origin information for the identified puzzles (Hallmark noted the puzzles are no longer available for sale to consumers and for the 2018 season, it intends to sell puzzles that are “all or virtually” all made in the US); (2) Hallmark reviewed its website to confirm that all SKUs with product descriptions containing U.S.-origin claims make claims consistent with the FTC’s Enforcement Policy Statement on U.S.-Origin Claims; (3) updated its procedures to ensure that any time a product’s country of origin changes, any U.S.-origin claim will be removed from hallmark.com; (4) instituted new validation requirements for U.S.-origin claims on the site; and (5) introduced mandatory escalation of any consumer complaints relating to potentially inaccurate country-of-origin claims.
04/18/2018 Saylite, LLC d/b/a Mobern Lighting
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
John W. Van Lonkhuyzen
Verrill Dana LLP
Counsel to Saylite, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Mobern’s lighting fixtures are made in the United States. Substantial Compliance: Mobern implemented a remedial action plan to avoid deceiving consumers. The plan included: (1) reviewing and revising the company’s website and social media; (2) reviewing and revising the company’s product catalog, product cut sheets, and other print advertisements; and (3) revising training materials for staff.
04/17/2018 EBSCO Sign Group, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Paul D. Rubin
Debevoise & Plimpton LLP
Counsel to EBSCO Sign Group, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which ESG’s LED signs are made in the United States. Substantial Compliance: ESG implemented a remedial action plan to avoid deceiving consumers. The plan included: (1) discontinuing use of unqualified U.S.-origin claims; (2) updating all marketing materials accordingly; (3) communicating changes and distributing updated materials to third-party dealers; and (4) training staff on how to make non-deceptive claims for ESG products.
03/27/2018 Rainbow Play Systems, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Rick Biagi, Esq.
Neal & McDevitt, LLC
Counsel for Rainbow Play Systems, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which the Company’s products, including, but no limited to, certain playsets, are made in the United States. Specifically, although Rainbow operates a plant and employs workers in Brookings, South Dakota, certain Rainbow playsets incorporate significant imported parts and equipment. Substantial Compliance: Rainbow implemented a two-step remedial action plan to avoid deceiving consumers. First, Rainbow updated its own website, printed catalogue, and social media feeds. Second, because Rainbow playsets are sold through a distributor network, Rainbow undertook a comprehensive review and notification process to ensure thw accuracy of distributor claims. This review included: (1) instructing all distributors to remove unqualified claims from marketing materials within fourteen days; (2) conducting a granular review of distributor materials to ensure compliance; (3) providing direct technical assistance to distributors that encountered difficulties updating online materials; (4) distributing a detailed memo outlining acceptable distributor claims; and (5) introducing a new distributor agreement that includes several provisions governing the use of false advertising claims and claims not approved for use by Rainbow.
02/27/2018 Neutral Posture, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Rebecca Boenigk
CEO
Neutral Posture, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Neutral Posture products, including, but not limited to, certain ergonomic seating products and accessories, are made in the United States. Substantial Compliance: Neutral Posture implemented a remedial action plan to avoid deceiving consumers.  This plan included: (1) stickering over “Made in USA” claims on existing marketing materials; (2) reprinting marketing materials without “Made in USA” claims; (3) removing “Made in USA” claims from the Neutral Posture website and social media accounts; and (4) communicating changes to dealers and third-party retailers.
02/07/2018 Prodeco Technologies, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Robert Provost
CEO
Prodeco Technologies, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which the Company’s electric bicycles are made in the United States. Although the Company designs its products and performs sophisticated assembly operations in the United States, Prodecotech’s electric bicycles incorporate significant imported content. Substantial Compliance: Prodecotech implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) replacing unqualified “Built in USA” claims with “Built in the USA of Global Components” across all marketing materials and product packaging; (2) revising the ProdecoTech website, including by updating title tags and meta descriptions; (3) reviewing and revising social media accounts, including by removing #builtinUSA form posts; (4) terminating authorized dealers that failed to update marketing materials after three requests; and (5) updating contracts with authorized dealers to include language prohibiting them from making unqualified U.S.-origin claims for ProdecoTech products.
01/19/2018 IKEA Purchasing Services (US), Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Ms. Laurie Everill
International Trade/Customs Compliance
IKEA Purchasing Services (US), Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with inadvertent potentially deceptive “Made in USA” claims for certain pillows that were assembled in the United States with imported materials. Inadvertent Error: Upon recognizing the error, IKEA took several steps to prevent consumer deception. These steps included: (1) placing a stop sale on the product in question pending resolution of the issue; (2) generating an adhesive label with the correct country-of-origin marking to place over claims on all affected items in inventory; and (3) generating updated labels and polybags for new productions and shipments. Additionally, IKEA confirmed that affected inventory in the IKEA catalog was labeled in compliance with 16 C.F.R. 303.34 of the Textile Rules.
01/09/2018 The Solid Wood Cabinet Company, LLC d/b/a Solid Wood Cabinets
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Brian Siegel, Esq.
Secretary, Treasurer & General Counsel
The Solid Wood Company, LLC, d/b/a Solid Wood Cabinets
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Solid Wood Cabinets’ products are made in the United States. Specifically, although the company assembles cabinetry in its factory, much of the base material for its products comes from overseas. Additionally, Solid Wood Cabinets sells a line of wholly imported, ready-to-assemble products. Substantial Compliance: To avoid deceiving consumers, Solid Wood Cabinets updated its website, social media accounts, and other marketing materials to remove, or, where appropriate, qualify U.S.-origin claims.
12/21/2017 B/A Products Co.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Crystal D. Ostrum
Investigator
Terrie A. Gleason
Baker & McKenzie LLP
Counsel for B/A Products Co.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which the Company’s products, including, but not limited to, certain strap assemblies, are made in the United States. Although the Company performs some manufacturing functions in the United States, certain products incorporate significant imported content. Substantial Compliance: B/A Products implemented a comprehensive remedial action plan to avoid deceiving consumers. This plan included (1) removing unqualified U.S.-origin claims from marketing materials, including online, hardcopy, and tradeshow materials; (2) destroying outdated materials; (3) rendering unqualified claims on affected products in inventory invisible to consumers, either by removing tags containing the claims, or, in the case of the Company’s webbing, sewing the webbing into two-ply webbing with the claims sealed inside; (4); introducing qualified claims, where appropriate; (5); requesting a formal ruling from U.S. Customs and Border Protection regarding the country of last “substantial transformation” for certain products; (6) launching a new website; (7) scrubbing the Company’s social media platforms and updating promotional videos; (8) obtaining certification letters from suppliers regarding component origins; (9) training staff; and (10) instructing distributors and certain third-party sellers to make changes to marketing materials to reflect updated claims.
12/21/2017 High Technology, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Robert Mintz
Zlatko Hadzismajlovic
McCarter & English LLP
Counsel for High Technology, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which all HTI chemical analyzers and reagents are made in the United States. Substantial Compliance: HTI implemented a remedial action plan to avoid deceiving consumers. This plan included: (1) removing U.S.-origin claims, including “Made in USA,” “Manufactured in USA,” “Built in USA,” “Produced in USA,” and “Created in USA,” from digital, hardcopy, and tradeshow materials; (2) destroying packaging containing U.S.-origin claims; (3) training employees; (4) reviewing and updating social media; (5) removing all Google AdWords or other search engine optimization tags that included unqualified U.S.-origin claims; (6) providing notice to distributors of updates to marketing materials; and (7) implementing a policy to require upper management approval of all marketing materials.
12/18/2017 Maingear, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Wallace Santos
CEO
Maingear, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Maingear computers are made or “built” in the United States. Specifically, although Maingear designs, finishes, test, and supports its computers in New Jersey, the computers incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, Maingear implemented a corrective action plan to clarify its representations. The plan included: (1); removing all “Built in USA” claims from the website; (2); introducing claims that truthfully convey information about Maingear’s U.S. operations, including “Designed in the USA” and “Lifetime USA Support”; (3) suspending Google advertising and making corrective changes; (4) editing social media posts; and (5) conducting employee training.
12/13/2017 Watchfire Signs, LLC
 
(Made in USA)
Crystal D. Ostrum
Investigator
Dan Gibb
Dentons US LLP
Counsel for Watchfire Signs, LLC
 
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Watchfire’s LED signs are made in the United States. Specifically, although Watchfire designs, assembles, and supports its products in the United States, the products contain significant foreign content. Further, imported LEDs constitute key parts that are essential to the product’s function. Substantial Compliance: To avoid deceiving consumers, Watchfire has: (1) updated its website and social media accounts to remove or qualify all U.S.-origin claims; (2); provided all third-party distributors and retailers with updated marketing material; and (3); trained sales and marketing staff on how to make non-deceptive claims for Watchfire products.
12/01/2017 Diggers Pool Services, Inc.
d/b/a LinerWorld
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Thomas W. Toolis
Frankfort Law Group
Counsel for Diggers Pool Services, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which products sold by Diggers are made in the United States. Although Diggers makes some of their swimming pool products in the United States, some are wholly imported. Substantial Compliance: To avoid deceiving consumers, Diggers has: (1) updated its LinerWorld website to remove “Made in USA” claims that appeared to apply to all products, as well as U.S.-origin claims for specific products that Diggers could not substantiate; (2); updated Google AdWords to remove “Made in USA” keywords; and (3) obtained additional substantiation from pool liner suppliers to support certain product-specific claims.
11/15/2017 Hyperform, Inc. d/b/a SeaDek and SwimDek
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Stephen C. Thomas, Esq.
Lowndes, Drosdick, Doster, Kantor & Reed P.A.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Hyperform products, including, but not limited to, certain EVA non-skid products targeted at the marine, pool, and spa markets, are made in the United States. Although Hyperform assembles and performs significant work on its products in the United States, key components, including the EVA foam, are imported. Substantial Compliance: To avoid deceiving consumers, Hyperform implemented a remedial action plan to clarify its representations. The plan included: (1) replacing unqualified “Made in USA: claims in Hyperform marketing materials with qualified claims such as “Made in the USA from Imported Materials”; (2) stickering over unqualified claims on product packaging until new packaging was available; (3) updating Hyperform’s trade show booth; (4) removing or qualifying claims on social media platforms; (5) sending notices to downstream retailers regarding changes to marketing materials; and (6) updating contracts with authorized dealers to include language prohibiting them from making unqualified U.S.-origin claims for Hyperform products.
10/11/2017 Georgia Exposition Manufacturing Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ian Van Sice, Vice President of Projects & Technology
Georgia Exposition Manufacturing Corporation
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Georgia Expo products are made in the United States. Specifically, although Georgia Expo sells a line of disposable waste containers that is made in the United States, certain Georgia Expo pipe and drape and other display products contain significant imported content. Substantial Compliance: To avoid deceiving consumers, Excel implemented a remedial action plan. The plan included: (1) updating product specification sheets, packing materials, and marketing inserts; (2) introducing qualified U.S.-origin claims where appropriate; (3) launching an updated website and releasing updated catalogues; (4) reviewing and updating social media postings on all platforms; (5) editing promotional videos that contain unqualified U.S.-origin claims; (6) training sales staff; and (7) sending notices to distributors regarding changes to marketing materials.
08/21/2017 Excel Industries, Inc.
d/b/a Hustler Turf Equipment and BigDog Mower Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jonathan N. Zerger, Esq. Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain lawnmowers are made in the United States. Specifically, although Excel assembles mowers and performs some manufacturing functions in the United States, certain mowers incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, Excel implemented a remedial action plan. The plan included: (1) completing phase-out of “Made in USA” decals for mowers; (2) updating marketing materials and photos; (3) sending notices to dealers regarding discontinuation of “Made in USA” decals and marketing claims; (4) deleting old social media posts; and (5) introducing qualified claims where appropriate, such as “Engineered, designed and assembled in USA of US and global parts,” “Designed and assembled in USA,” and “made in USA of US and Global Parts.”
08/16/2017 Harimatec, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Chris Pey, Esq.
FisherBroyles, LLP
Possible violations of Section 5 of the Federal Trade Commission Act in connection with Harimatec inadvertently making “Made in USA” claims on certain wholly imported product samples supplied to a potential customer. Inadvertent Error: Upon discovering the error, Harimatec notified its customer, and confirmed that subsequently shipped samples and products were marked properly.
08/11/2017 Thales e-Security, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
James K. Kearney, Esq.
Womble Carlyl Sandridge & Rice, LLP
Possible violations of Section 5 of the Federal Trade Commission Act in connection with Thales inadvertently making “Made in USA” claims on certain data security products that incorporate significant imported components. Inadvertent Error: To avoid deceiving consumers, Thales implemented a remedial action plan. The plan included: (1) changing labeling on all new products to “Assembled in the USA”; (2) relabeling products in inventory; (3) reviewing catalogues, signage, packaging, and social media content to ensure the accuracy of claims for affected products; (4) reviewing online descriptions for all products; (5) implementing a procedure to review regular reports for items whose production has shifted from U.S. to non-U.S. manufacturers; and (6) increasing legal review of the Company’s U.S.-origin claims.
08/07/2017 Hoshizaki America, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Daniel C. Schwartz, Esq.
Bryan Cave LLP
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which products, including certain ice machines, are made in the United States. Specifically, although most Hoshizaki products are assembled in the United States, many products incorporate significant imported content. Additionally, a small number of the Company’s products are wholly manufactured overseas. Substantial Compliance: To avoid deceiving consumers, Hoshizaki implemented a remedial action plan. The plan included: (1) removing general statements on marketing materials that suggest or imply that all Hoshizaki products are made in the U.S.; (2) sending a letter to distributors regarding updated claims; (3); providing stickers to distributors to place over claims in printed materials while updated versions were being generated; (4) updating YouTube videos; and (5) making all diligent efforts to identify and correct improper claims made by third-party marketers.
4/5/2017 Innovative Office Products, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Kate Fucci, Director of Marketing
Innovative Office Products, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Innovative products, including but not limited to, certain standing desks, are made in the United States. Specifically, although some Innovative products are designed and assembled in the United States, Innovative sells a line of products that is wholly imported. Substantial Compliance: To avoid deceiving consumers, Innovative implemented a remedial action plan. The plan included: (1) removing all unqualified U.S.-origin claims from Innovative’s websites and social media; (2) introduction product-specific qualified claims such as “Designed and Assembled in USA,” where appropriate; (3) updating, reprinting, and redistributing hard copy materials; (4) updating product listings on third-party platforms such as amazon.com; and (5) sending a notification letter to affected third-party resellers and distributors requesting updates be made to marketing materials within five business days.
4/5/2017 Cardinal Scale Manufacturing Company
d/b/a Detecto Scale
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Larry Hicks, Executive Vice President
Cardinal Scale Manufacturing Company
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which all Cardinal scales are made in the United States. Specifically, although many Cardinal scales are, at a minimum, assembled in the United States using a mix of U.S. and imported content, approximately 10-20% of the scales Cardinal sells are wholly imported. Substantial Compliance: To avoid deceiving consumers, Cardinal implemented a remedial action plan. The plan included: (1) removing general statements on marketing materials that suggest or imply that all Cardinal scales are made in the United States; (2) removing stickers with unqualified claims from affected products; (3) holding webinars and training sessions for sales teams; (4) sending a letter to dealers and distributors providing updated materials; and (5) making all diligent efforts to identify and correct improper claims made by third-party marketers.
3/31/2017 Versa Products, Inc.
 
(Made in USA)
Crystal D. Ostrum
Investigator
Dan Weber, Chief Strategy Officer
Versa Products, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Versa’s products are made in the United States. Although Versa’s adjustable standing desks include some U.S. components, key parts such as the electric motors used to raise and lower the desks are imported. Substantial Compliance: To avoid deceiving consumers, Versa implemented a remedial action plan to remove all unqualified U.S.-origin claims from all the company’s websites and social media, product packaging, and marketing material for all Versa brands. Where appropriate, Versa introduced qualified claims such as “Designed and Assembled in the USA” and/or “Designed and Assembled with Love in the USA.”
3/22/2017 APEC Water Systems
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Elaine Lo, CEO
APEC Water Systems
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which APEC’s water filtration systems are made in the United States.  Specifically, although APEC designs and assembles systems in the United States, those systems incorporate significant imported parts. Substantial Compliance: To avoid deceiving consumers, APEC implemented a remedial action plan to qualify its representations. The plan included: (1) removing all “Built in USA” or “Made in USA” claims for water filtration systems from marketing materials, including websites and social media; (2) updating claims on third-party sales platforms; and (3) making all diligent efforts to identify and correct improper claims made by third-party marketers.
3/22/2017 Suntactics, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Anthony Dean Sala, CEO
Suntactics, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Suntactics’ solar charger products – which include imported solar cells and other key components – are made in the United States. Although Suntactics acknowledged its products incorporated imported parts in some sections of its website, in many other places, Suntactics made broad, unqualified “Made in USA” or “Manufactured in the USA” claims for its chargers. Substantial Compliance: To avoid deceiving consumers, Suntactics implemented a remedial action plan to clarify its representations by clearly and prominently qualifying all of its U.S.-origin claims on marketing materials and product labels.
3/17/2017 Wilson Electronics, LLC,
d/b/a weBoost, zBoost, and WilsonPro
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Bruce Lancaster, President & CEO
Wilson Electronics, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Wilson Electronics products, including, but not limited to, certain cell phone signal boosters, are made in the United States. Specifically, although Wilson Electronics assembles certain products in the United States, these products incorporate significant imported content. Other Company products are wholly imported. Substantial Compliance: To avoid deceiving consumers, Wilson Electronics implemented a remedial action plan to clarify its representations. The plan included: (1) removing U.S.-origin claims from products that are not part of the WilsonPro line; (2) updating claims for WilsonPro products to “Assembled in the USA”; (3) sending a letter to over 6500 dealers providing updated claims and instructing dealers to correct marketing materials immediately; and (4) making all diligent efforts to identify and correct improper claims made by third-party marketers.
3/14/2017 Ratio, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mark Hellweg, Owner
Ratio, LLC
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Ratio coffeemakers are made in the United States. Specifically, although Ratio assembles coffeemakers in the United States using some domestic components, most of the parts used – including the parts that make the coffeemakers function – are imported. Substantial Compliance: To avoid deceiving consumers, Ratio, implemented a remedial action plan to clarify its representations. The plan included: (1) updating marketing claims for Ratio coffeemakers to add clear and conspicuous qualifications specifying that the products incorporate significant imported content; (2) updating social media accounts and posts; and (3) contacting wholesale customers to provide updated origin information and corrected marketing materials.
3/1/2017 Target Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jason K. Walbourn, Esq.
Senior Director, Assistant General Counsel – Regulatory, Operations and Investigations
Target Corporation
Possible violations of Section 5 of the Federal Trade Commission Act in connection with potentially deceptive “Made in USA” claims for Target owned-brand products. Specifically Room Essentials-branded pillows that were prominently marked “Made in USA” on exterior packaging, but consumers reporter that upon opening the packages post-purchase, they discovered the pillows were marked “Made in China.” Substantial Compliance: To prevent consumer deception, Target took several steps to correct the FTC’s concerns and reason for inquiry.  First, Target confirmed and corrected the country-of-origin information for the identified pillows, along with several other affected pillows. Second, Target immediately: (1) assembled a cross-functional group of internal experts from the Company’s packaging team, product safety and quality assurance team, merchant team, and law department to identify where it could make process improvements; (2) began implementing a new flag in the Company’s packaging system to identify when an unqualified “Made in USA” claim is proposed so Target can alert the vendor to ensure the claim meets with FTC guidance; (3); started developing new criteria for third-party testing and assessment labs to follow when an unqualified “Made in USA” claim appears on product packaging so that third-party testing and assessment labs can validate that any tag affixed to the item is consistent with claims made on the packaging; and (4) commenced a larger review of domestic vendors for owned-brand products to conduct additional spot checks of unqualified “Made in USA” claims made within Target’s product assortment.
2/3/2017 New Sensor Corporation
d/b/a Electro-Harmonix
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
William R. Vigdor, Esq.
Vinson & Elkins LLP
Possible violations of Section 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which EHX-branded products, specifically, but not limited to, certain guitar pedals, are made in the United States. Wihle the designs, tests, and finishing operations are all done within the United States, those products incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, NSC implemented a remedial action plan to clarify its representations. The plan included: (1) removing all unqualified claims from EHX products and advertising materials; (2) updating stock photos; (3); stickering over outdated claims on product packaging; (4) applying hangtags containing clear and conspicuous qualifications to EHX pedals in inventory with outdated claims; (5) modifying or applying appropriate qualifications to product videos and social media posts; (6) sending a letter to authorized dealers and distributors providing updated marketing materials, and instructing them to refrain from making unqualified claims; and (7) making all diligent efforts to identify and correct improper claims made by third-party marketers.
1/18/2017 Axis LED Group, LLC
 
d/b/a Patriot Tube
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Adam Harmon, President
Axis LED Group, LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Axis products, including LED tubes, are made in the United States. Although certain parts of Axis’s tubes are assembled in the United States, those products incorporate significant imported content. Substantial Compliance: To avoid deceiving consumers, Axis implemented a remedial action plan to clarify its representations. The plan included: (1) replacing all affected “Made in USA” claims on Axis marketing materials with “Assembled in the USA” claims; and (2); qualifying “Buy American Act Compliant” claims on marketing materials not specifically targeted at government consumers with “Assembled in the USA” claims.
1/6/2017 RGF Environmental Group, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Martin M. Zoltick, Esq.
Rothwell, Figg, Ernst & Manbeck, P.C.
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which RGF products are made in the United States, including, but not limited to, certain air purifiers that incorporate imported parts. Substantial Compliance: To avoid deceiving consumers, RGF implemented a corrective action plan. This plan included: (1) removing unqualified "Made in USA" claims from online and printed marketing materials; (2) introducing qualified claims for eight specific products that, although assembled in the United States, contain imported parts or components; (3) covering unqualified claims on products in inventory with stickers incorporating appropriately qualified claims; ( 4) introducing new product packaging with qualified claims; (5) removing unqualified claims from trade show materials; and (6) sending a communication to
distributors and direct customers to provide updated claims.
12/21/2016 Advanced Air Systems, Inc.
d/b/a Powertank
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Steve Sasaki, President
Advanced Air Systems, Inc., also d/b/a Powertank
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Powertank's products, including, but not limited to, certain CO2 tank systems, are made in the United States. Although
Powertank completes final assembly of certain products in the United States, those products incorporate significant imported content.
Substantial Compliance: To avoid deceiving consumers, Powertank implemented a remedial action plan to clarify its representations. The plan included: (1) removing all "Made in USA" messaging from the website; (2) removing "Made in USA" decals from Powertank products; (3) introducing claims that truthfully convey information about Powertank's U.S. operations without conveying that its products are of U.S. origin, such as "Designed in USA"; and (4) sending a letter to distributors and other representatives clarifying that Powertank designs products in the United States, and instructing representatives to remove unqualified "Made in USA" claims from marketing materials.
12/21/2016 American Scientific Lighting Corp.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Steven A. Horowitz, Esq.
Horowitz and Rubenstein, LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which ASL's LED fixtures are made in the United States. ASL assembles some LED fixtures in the United States using significant imported parts, and also sells some wholly imported products. Substantial Compliance: To avoid deceiving consumers, the Company implemented a remedial action plan to clarify its representations. This plan included: (1) removing unqualified "Made in USA" or "Manufactured in USA" claims from all Company marketing materials and replacing them with "Assembled in the USA" claims, where appropriate; (2) updating product specification sheets; (3) sending a letter to distributors and other representatives clarifying that ASL sells a mix of products assembled in the United States and imported products, and instructing representatives to update marketing materials accordingly; and ( 4) making all diligent efforts to identify and correct improper claims made by third-party marketers.
12/13/2016 Commando Lock Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Patrick Smith
President
Commando Lock Company
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Commando's locks are made in the United States. Although Commando uses proprietary methods to assemble locks in the United States with some U.S. parts, it sources the cylinders and keys for those products overseas. Although Commando performs significant work on its products in the United States, the imported cylinders and keys are essential to the locks' function. Substantial Compliance: To avoid deceiving consumers, Commando implemented a remedial action plan to clarify its representations by clearly and prominently qualifying all of its U.S.-origin claims. This plan included: (1) updating all U.S.-origin claims on Commando websites and social media to state "Made in USA with US and global components"; (2) updating product packaging to ensure consistent claim qualification in an increased font size; (3) reviewing sales and training materials; and (4) making all diligent efforts to identify and correct unqualified claims made by third-party marketers.
12/13/2016 Window Design Group
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ms. Cindy Patai
Mr. Mychael Margott
Window Design Group
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that overstated the extent to which WDG's
window and shutter products are made in the United States. Although WDG offers some products that are assembled in the United States, WDG primarily sells imported products.
Substantial Compliance: To avoid deceiving consumers, WDG has now removed all "Made in USA" claims from its marketing materials, including web and hard copy materials. To the extent WDG customers express interest in U.S.-origin products, WDG has also revised sales scripts to clarify that it
offers a limited number of products that are assembled in the United States.
12/2/2016 JL Audio Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Emma E. Collum, Esq.
In House Counsel
JL Audio Inc.
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which JL Audio's audio equipment products, including car and marine audio systems, are made in the United States. Although JL Audio assembles products in the United States, many of those products incorporate significant imported parts. Substantial Compliance: To avoid deceiving consumers, to avoid deceiving consumers, JL
Audio implemented a remedial action plan to qualify its representations. This plan included:
(1) removing all unqualified "Built in USA" statements from marketing materials, including packaging and inserts, and replacing such claims with qualified claims like "Built in USA with Global Components"; (2) updating packaging, stickers, and inserts to increase the font size of
qualifications to U.S.-origin claims; (3) updating product markings and instruction manuals; (4) updating social media and discontinuing use of hashtags making unqualified U.S.-origin claims, such as #builtinUSA and #madeinUSA; (5) updating tradeshow materials; (6) providing notice to authorized dealers and distributors that they must review and update marketing materials; and (7) making all diligent efforts to identify and correct improper claims made by third-party marketers.
12/2/2016 TecNiq, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Charles F. Gray, Esq.
Varnum LLP
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which TecNiq's LED products and equipment are made in the United States.  TecNiq designs and assembles LED products and equipment in the United States using significant imported parts. Substantial Compliance: To avoid deceiving consumers, TecNiq implemented a remedial action plan to clarify its representations. This plan includes: (1) removing unqualified "Made in USA" claims, including those implied through symbols, from all Company marketing materials and replacing them with "Assembled in the USA" claims; (2) discarding outdated printed materials; (3) initiating retooling of affected steel mold tooling; (4) sending a letter to master distributors and other contractually-related sellers instructing them to discard old marketing materials and to revise their claims; and (5) making all diligent efforts to identify and correct improper claims made by third-party marketers.
11/14/2016 Down-Lite International, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Bradley G. Haas, Esq.
Katz Teller Brant & Hild
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing
materials that may have overstated the extent to which certain Down-Lite comforters, pillows, and mattress pads are made in the United States. Although Down-Lite assembles and fills many products in the United States, most product shells - and certain product fills – are imported.
Substantial Compliance: To avoid deceiving consumers, Down-Lite implemented a corrective action plan to clarify its representations and provide updates to its retail customers. The plan includes: (1) updating law labels for comforters to state "Shell made in China; Filled and finished in the USA of imported materials;" (2) updating law labels for mattress pads to state "Fabric made in China; Filled and finished in the USA of imported materials;" (3) updating packaging materials and artwork inserts to match the law labels; (4) revising the Down-Lite website and social media as appropriate; and (5) providing written notification to retail customers regarding the updated law tags and marketing materials.
11/14/2016 Blount International
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Chad E. Paulson, Vice President, General Counsel & Secretary
Blount International
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which
Blount products, including certain attachments to tractors, excavators, loaders, and mowers sold under the "Woods" name, are made in the United States. Although Blount assembles finished goods in the United States, several of these products incorporate significant imported parts.
Substantial Compliance: To avoid deceiving consumers, Blount implemented a corrective action plan. This plan includes: (1) removing unqualified "Made in USA" claims from online and printed marketing materials; (2) removing or covering affected product decals; (3) emailing Blount employees to explain new marketing claims; (4) emailing all dealers to provide updated materials; (5) meeting with external sales personnel to follow up; and (6) conducting a field inventory to verify claims on all products and marketing materials.
11/1/2016 Laser Products Industries, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Brian Stoiber, Director of Marketing & Support, Laser Products Industries, Inc. Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain Laser Products Industries products are made in the United States. Although the Company assembles its products in the United States using many U.S. parts, certain key parts, including the lasers in the Company’s 3D laser measuring systems, are imported. Although the cost of the imported content may be small relative to overall manufacturing costs, the imported lasers are essential to the function of the Company’s products. Substantial Compliance: To avoid deceiving consumers, Laser Products Industries implemented a remedial action plan to clarify its representations. This plan included: (1) removing unqualified claims from the Company website and product labels; (2) revising the website and product labels to clarify that the Company’s products are “Made in USA with US and Imported Parts;” and (3) sending a letter to all sales personnel and distributors instructing them to discard old marketing materials and to revise their claims.
10/25/2016 American Furniture Manufacturing, Inc. (AFM)
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
A. Brian Albritton, Esq.
Phelps Dunbar LLP
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which AFM furniture products are “made” or “manufactured” in the United States. Although AFM assembles many products in the United States, some products incorporate imported content that is significant in terms of both cost and function, including covers used to upholster furniture, “show wood” used on some upholstered furniture pieces, and motors in motorized recliners. Additionally, AFM sells a line of tables that are wholly imported. Substantial Compliance: To avoid deceiving consumers, AFM implemented a corrective action plan to clarify its representations and provide updates to its customers. This included: (1) modifying the Company logo and incorporating a prominent disclosure on marketing materials; (2) eliminating unqualified U.S.-origin claims from, and making other revisions to, the AFM website; (3) updating trade publications; (4) stickering over unqualified claims in undistributed 2016 catalogues; (6) updating the 2017 catalogue to include prominent qualifications; (7) revising furniture labels; (8) applying stickers to product packaging; and (9) sending a letter to retail customers clarifying AFM’s origin claims and providing instructions on how to update marketing materials.
10/3/2016 Ballistic Fabrication LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jeffrey A. Bullock, President
Ballistic Fabrication LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with Ballistic’s marketing materials may have overstated the extent to which certain products are made in the United States, including joints and bushings that incorporate imported metal housings. We received your submissions on behalf of Ballistic Fabrication LLC (“Ballistic”). Substantial Compliance: To avoid deceiving consumers, Ballistic implemented a remedial action plan to clarify its representations. This plan includes: (1) removing outdated catalogues and other materials from the Ballistic website; (2) removing unqualified “Proudly Made in the USA” claims from the homepage; and (3) introducing qualified claims for affected products that clearly disclose that those products contain a mix of domestic and imported materials.
8/10/2016 Mega Sign, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. David J. Park
Mega Sign, Inc.
d/b/a Mega LED Technology
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Mega Sign light-emitting diode (“LED”) signs are made in the United State using some U.S. components, key sign parts, including LEDs and power supplies, are imported. Substantial Compliance: To avoid deceiving consumers, Mega Sign removed unqualified “Made in USA” claims from affected advertising materials, and replaced them with qualified claims such as “Manufactured in the USA with Domestic and Imported Components.” Additionally, Mega Sign provided updated information to its third-party retailers.
7/28/2016 Tacony Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Amy R. Mudge, Esq.
Venable LLP
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain vacuum cleaners, including vacuums sold under the Riccar, Simplicity, and Maytag brand names, are made in the United States. Specifically, although Tacony designs, engineers, assembles, quality tests, and paints residential upright vacuums in Missouri, it sources the motors for those products overseas. Substantial Compliance: Tacony implemented a remedial action plan that incorporates qualified claims designed to highlight Tacony’s U.S. operations without deceiving consumers. As part of this plan, Tacony: (1) qualified claims on its website and social media pages; (2) updated packaging stickers and in-store displays to increase the size of its qualifying disclosures; and (3) sent a letter to authorized dealers requesting that they review and update marketing materials as appropriate.
7/15/2016 Wright Tool Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Alicia J. Batts, Esq.
Squire Patton Boggs LLP
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which products sold by Wright Tool are made in the United States Wright Tool sells two lines of tools, Wright Tool-branded tools and tools sold as part of the “Cougar Pro” line. Although Wright Tool-branded tools are made in the United States, Cougar Pro tools are designed in the United States and manufactured in Taiwan. Substantial Compliance: To avoid deceiving consumers, Wright Tool: (1) made several changes to its website and social media accounts to clarify that Cougar Pro tools are made in Taiwan; and (2) sent a letter to distributors explaining the difference between Wright Tool-branded tools and Cougar Pro tools, and instructing distributors to update their marketing materials as appropriate. As part of the review, Wright Tool also confirmed the accuracy of country-of-origin claims on all Cougar Pro and Wright Tool products and packaging.
7/5/2016 Lotus Computer USA
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Karel Felipe, Owner
Lotus Computer USA
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Lotus computers are made or “built” in the United States. Lotus completed final assembly of computers in the United States using nearly all imported parts. Substantial Compliance: To avoid deceiving consumers, Lotus removed all unqualified U.S.-origin claims from its marketing materials, and replaced them with claims such as, “A US-Based Computer Company” and “100% USA-Based Support.”
6/24/2016 MistCooling, Inc. and Hydrobreeze, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Bashil Patel
MistCooling, Inc.
Hydrobreeze, LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain MistCooling outdoor mist systems are made in the United States. Specifically, certain MistCooling systems incorporate imported fans and tents, which are significant in cost and to the function and design of those systems. Substantial Compliance: To avoid deceiving consumers, MistCooling immediately removed all U.S.-origin claims from its marketing materials pending a thorough supply chain review. Upon completion of that review, MistCooling intends to reintroduce unqualified claims for particular products it can substantiate are “all or virtually all” made in the United States, and qualified claims such as “Assembled in the USA with USA & Imported Parts” for other products that incorporate imported fans and tents.
6/16/2016 Bedrock Manufacturing LLC
d/b/a Shinola/Detroit LLC, and Filson Holdings, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
 
Colin D. A. MacDonald
Staff Attorney
Lisa Gold, Esq.
General Counsel
Bedrock Manufacturing Company, LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain Shinola and Filson-branded products, including, but not limited to, watches and certain leather goods and bicycles, are “made” or “built” in the United States. Specifically, the Company sources significant inputs to many of its products overseas. Substantial Compliance: To avoid deceiving consumers, Bedrock implemented a remedial action plan to account for this significant imported content by qualifying its representations. Among other things, this plan includes: (1) applying corrective hangtags and information cards to watch, bicycles, and other affected products to alert consumers to the fact that those products include significant imported content; (2) redesigning watch casebacks; (3) updating embossed claims in affected leather goods; (4) updating Internet and hardcopy advertising materials to qualify claims; (5) updating employee training materials; (6) updating advertising materials distributed to third-party retailers; (7) transitioning away from the Company’s “Where American is Made” slogan; and (8) developing enhanced policies and procedures, including additional legal review, to avoid future deception or mislabeling.
6/3/2016 Frameware Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Dean DeLuccia
President
Frameware, Inc.
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Frameware’s products are made in the United States. Specifically, although the Company sells certain hardware and other products that are made in the United States, it also sells other hardware products that include significant imported content. Substantial Compliance: To avoid deceiving consumers, Frameware implemented a remedial action plan to clarify its representations. This plan included: (1) removing unqualified “Made in America” claims from the Frameware homepage; (2) removing misplaced claims from the Company’s digital catalogue; (3) placing stickers that read “Made in USA of U.S. and foreign parts” over claims for affected products in the printed Frameware catalogue until the Company develops and prints new catalogues; (4) providing updated information to distributors; and (5) revising tradeshow materials to specify that a “majority” of the Company’s products are made in the United States.
6/1/2016 Justin Brands, Inc.
 
(Made in USA)
Crystal Ostrum
Investigator
Cheryl Leb
Partner, Kelly Hart & Hallman LLP
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with concerns relating to potentially deceptive or overly broad domestic-origin marketing claims for the Company’s Chippewa, Justin Boots, Justin Original Work Boots, Tony Lama Boots, and Nocona Boots brands. Substantial Compliance: The Company implemented a comprehensive corrective action plan to avoid deceiving consumers. Among other things, Justin Brands (1) performed a company-wide analysis of all domestic-origin marketing claims on the Company’s websites, marketing materials, social media campaigns, and point of sale items; (2) made substantial changes to its websites to distinguish the Company’s “Handcrafted in the USA” product lines from its other product offerings; and (3) removed or qualified all domestic-origin marketing claims where appropriate.
5/26/2016 J.W. Manufacturing Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Jason Harrison
Vice President, Production and Sales
J.W. Manufacturing Conpamy
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which J.W. Manufacturing’s mops are made in the United States. Specifically, although the company makes many of its mops in the United States using United States materials, certain mop heads incorporate significant imported fibers. Substantial Compliance: To avoid deceiving consumers, J.W. Manufacturing is in the process of implementing a remedial action plan to clarify its representations. This plan includes: (1) updating the company’s website to clarify that some mops incorporate imported fibers; (2) placing stickers that read “Made in USA and US and Foreign Materials” over unqualified claims on affected packaging; (3) ordering new packaging with qualified claims; and (4) contacting third-party distributors to provide updated claims and product descriptions.
5/18/2016 Hexacon Electric Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ms. Kathi Johnson
President
Hexacon Electric Company
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which certain Hexacon products, including soldering iron temperature controllers, are mide in the United States. Although Hexacon makes some products in the United States, other products, including certain soldering iron temperature controllers, are assembled in the United States using domestic parts and imported parts that are significant both in terms of cost and overall product function. Substantial Compliance: To avoid deceiving consumers, Hexacon: (1) updated its website and other online promotional materials to eliminate overly broad or inaccurate claims; (2) corrected product labels and product materials and product-specific marketing materials; (3) contacted distributors to provide updated claims; and (4) implemented new procedures to avoid future mislabeling.
5/9/2016 Wayfair LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Enrique Colbert, Esq.
General Counsel
Wayfair LLC
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with potentially deceptive “Made in USA” claims for a particular chair we identified as containing significant imported content, as well as general concerns related to Wayfair’s process for ensuring the accuracy of country-of-origin claims across the Company’s website. Substantial Compliance: Wayfair took several steps to prevent consumer deception, both with regard to the particular product and the wayfair.com website. First, Wayfair confirmed and corrected the country-of-origin information for the identified product. Second, the Company implemented several longer-term process enhancements designed to significantly decrease the number of inaccurate country-of-origin claims appearing on its site. Specifically, Wayfair: (1) introduced and enhanced procedure to conduct supplier verification of each product’s country of origin at the time the product is listed on the wayfair.com website; (2) implemented an annual verification process in which suppliers re-certify the country of origin of all of their products; and (3) instituted annual audits regarding country of origin wherein Wayfair will use automation to identify listing with the highest risk of error, target suppliers of those listing to audit, and request documentation to support a supplier’s claim that a product is made in the United States.
4/15/2016 Rico Industries, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Steven Bright
VP of Strategic Development and General Counsel
Rico Industries, Inc.
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with Rico inadvertently making misleading “Made in the USA” claims for certain nylon National Football League-branded wallets. Specifically, although affected wallets were made overseas, the Company mistakenly printed “Made in the USA” claims on product packaging in 2014. The Company discovered the error shortly after printing and took immediate corrective actions. However, the Company missed certain inventory during this initial review, which resulted in dissemination of inaccurate claims for a small quantity of wallets thereafter. Inadvertent Error: In its submissions, Rico outlined several steps that it has taken to ensure that its corrective actions extended to all affected wallets in inventory. Specifically, Rico identified and destroyed all remaining affected packaging inventory and verified that all current artwork and packaging inventory contain proper claims. Additionally, the Company conducted a company-wide claims review; and implemented new training and review procedures to ensure continuing compliance with the FTC’s Enforcement Policy Statement on U.S. Origin Claims.
3/8/2016 Winholt Equipment Group
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Dominick Scarfogliero, President & COO
Winholt Equipment Group
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with Winholt advertently making misleading or confusing “Made in the USA” claims for certain food service sinks. Specifically, affected sinks contained conflicting “Made in the USA” and “Made in China” labels. Inadvertent Error: The company explained that this problem arose because Winholt employees applied outdated, pre-printed barcode labels to affected products upon final inspection and cleaning. Winholt took the following steps to correct its representations and avoid future mislabeling: (1) discarded all outdated barcode labels; (2) ensured that current barcode labels were correctly marked “Designed in USA, Made in China”; (3) retrained floor associates on proper labeling procedures; and (4) sent an email to customers explaining the problem and the steps Winholt took to correct it.
2/25/2016 Leggett & Platt, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jennifer Coleman, Esq., Deputy General Counsel and Chief Litigation Counsel
Leggett & Platt, Inc.
Possible violations of Sections 5 of the Federal Trade Commission Act in connection with certain marketing materials that were provided to third-party retailers for use in the sale or marketing of Gordon Manufacturing-branded adjustable standing desks may have overstated the extent to which those desks are made in the United States. Specifically, although the desks include U.S. components, the motor and electronics used to raise and lower the desk are imported. Substantial Compliance: Leggett & Platt does not market the relevant desks directly to end-use consumers, it distributes promotional materials to third-party retailers for the use in marketing and sale of its products, which retailers rely upon to market the desks. To avoid deceiving consumers, Leggett & Platt amended affected advertising materials and sent a letter to its customers notifying them of the change and updated materials.
2/10/2016 Peripheral Logix LLC
d/b/a Ergoprise
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Peter Gilbert, President
Peripheral Logix
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which certain Ergoprise-branded adjustable standing desks are made in the United States. Specifically, although the desks include U.S. components, the motor and electronics used to raise and lower the desk are imported. Substantial Compliance: To avoid deceiving customers, Peripheral Logix removed broad, unqualified “Made in USA” claims from affected advertising materials.
2/9/2016 Origin PC Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Hector Penton, COO
Origin PC Corporation
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Origin computers are made or “built” in the United States. Origin completes final assembly of computers in the United States using significant imported parts. Substantial Compliance: To avoid deceiving customers, Origin removed all “Built in the USA” claims from its marketing materials, and replaced them with the claim, “24/7 US Based Support” since Origin completes final assembly of computers in the United States using significant imported parts.
1/29/2016 P&L Industries, Inc.
d/b/a LaserLyte
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Kelly Wilkins, Esq.
Snell & Wilmer LLP
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which P&L’s LaserLyte-branded laser sights, trainer targets, and other products are made in the United States. Specifically, even though P&L designs and assembles products in the United States, certain products contain foreign content significant in cost or to the overall function of those products. Substantial Compliance: P&L implemented a remedial actions plan to clarify its representations. This plan includes: (1) auditing and updating P&L websites, social media outlets, online catalogues, specification sheets, media statements, and other online materials provided to distributors and internet fulfillment sites; (2) removing U.S. origin claims from packaging and marketing materiasl; and (3) educating marketing employees on the FTC’s Enforcement Policy Statement on U.S. Origin Claims.
1/4/2016 Veilux, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
William C. Lavery, Esq.
Baker Botts LLP
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Veliux’s cameras and security systems are made in the United States. Specifically, although Veilux assembles cameras in the United States, the products incorporate significant imported content. Substantial Compliance: Veilux implemented a corrective action plan to clarify its representations. Specifically, Veilux ceased applying stickers to cameras that stated “Made in USA” and removed “Made in USA” claims from product packaging. Additionally, Veilux intends to mark cameras as “Assembled in USA.”
12/16/2015 Crimson Trace Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Lane Tobiassen
Chief Executive Officeer and President
Crimson Trace Corporation
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Crimson Trace’s laser sighting and other products are made in the United States. Specifically, although Crimson Trace designs, assembles, markets, and supports products in the United States, certain products incorporate significant imported content. Substantial Compliance: Crimson Trace implemented a comprehensive remedial action plan to clarify its representations. This plan includes: (1) removing unqualified claims from the Crimson Trace website and other electronic marketing venues; (2) updating packaging, labels, and instruction manuals, including by placing stickers over unqualified claims until materials could be reprinted; (3) scrapping certain molded parts and outdated marketing materials; (4) providing updates materials to third-party marketers; and (5) conducting a sweep to identify and request removal of claims from third-party websites.
12/11/2015 Pro Performance LLC
d/b/a HarpArm
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Timothy R. McGreal, P.E.
Pro Performance LLC, d/b/a HarpArm
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which the version of the HarpArm magnetic harmonica holder currently available to consumers is made in the United States. Specifically, although you explained that you are developing a HarpArm product that contains significant U.S. content, the version available in stores today is wholly imported. Substantial Compliance: To avoid deceiving consumers, HarpArm updated their marketing materials to state, “Designed by an American Professional Engineer / forensic investigator / former rocket scientist!”
12/7/2015 Weiss Watch Company, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Cameron Weiss, CEO
Weiss Watch Company, Inc.
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Weiss’s watches are made in the United States. Specifically, although Weiss sources many parts in the United States, the key parts used to make the watches’ movements are imported from Switzerland. Substantial Compliance: Weiss implemented a remedial action plan to qualify its representations. This plan included: (1) updating the Weiss company logo to remove the phrase “US MADE;” (2) adding qualifying statements to marketing materials to explain that watches contain a combination of U.S. and Swiss parts; and (3) updating websites and social media.
12/3/2015 Velocity Holdings, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Randy Copeland
President and CEO
Velocity Holdings, LLC
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Velocity Micro computers are made in the United States. Specifically, although Velocity Micro completes final assembly of its computers in its Richmond, VA facility, the computers incorporate significant imported content. Substantial Compliance: Velocity Micro implemented a remedial action plan to clarify its representations. This plan included: (1) removing all “Made in the USA” messaging from the website; (2) introducing claims that truthfully convey information about Velocity Micro’s U.S. operations without conveying that its products are of U.S. origin, including: “Owned and operated in the USA,” “Each and every Velocity Micro PC ships from and is supported by our Richmond, VA headquarters,” “Immaculate custom hand wiring by Senior Technicians, right here in Richmond, Virginia, USA,” and “100% US-based;” (3) suspending Google advertising or editing it to state “Based and Supported in the USA;” (4) reviewing product packaging to confirm the accuracy of claims; and (5) making all diligent efforts to identify and correct improper claims made by third-party marketers.
12/2/2015 Associated Equipment Corp.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mary Ann L. Wymore, Esq.
Greensfelder, Hemker & Gale, P.C.
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which AEC’s battery chargers and other products are made in the United States. Specifically, although AEC performs some manufacturing functions in the United States, some of AEC’s products incorporate significant imported content. Substantial Compliance: AEC implemented a remedial action plan to clarify its representations. This plan included: (1) identifying claims that should be qualified or limited; (2) removing general “Made in the USA” language from marketing materials; (3) qualifying claims as appropriate to state products are “assembled in the United States with domestic and foreign parts,” “made in the USA of imported parts,” or “manufactured in the United States of domestic parts that may contain foreign components”; (4) revising previously-distributed marketing materials; (5) removing the current product catalogue from the website; (6) issuing takedown demands to third parties posting out-of-date marketing materials; and (7) implementing an ongoing review process.
12/1/2015 SnugZ USA
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Richard Massey
Regulatory Affairs
SnugZ USA
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which SnugZ’s products are made in the United States. Specifically, although the Company sells certain promotional products that are made in the United States, it also sells a line of lanyards that includes significant imported content. Substantial Compliance: SnugZ implemented a remedial action plan to clarify its representations. This plan included: (1) performing a company-wide analysis of all labeling, catalogue, website, and social media claims; (2) updating claims as necessary by removing “Made in the USA” and replacing it with “Assembled and Printed in the USA”; and (3) sending an email to the Company’s sales teams, marketing team, industry bloggers, and re-sellers with updated marketing materials.
11/20/2015 Niall Luxury Goods, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Braden Perry, Esq.
Kennyhertz Perry LLC
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Niall’s watches are made in the United States. Specifically, although Niall sources many parts in the United States, the watches’ movements are made in Switzerland. Substantial Compliance: Niall implemented a remedial action plan to qualify its representations. This plan included: (1) updating claims on watch dials and bezels to clarify that the watches contain Swiss parts; (2) updating websites and social media; and (3) adopting new compliance measures, including legal review of future marketing materials and a coordinated media plan.
11/13/2015 Tramontina USA, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Chuck Silverman, Esq.
General Counsel
Tramontina USA, Inc.
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which Tramontina’s cookware and other products are made in the United States. Specifically, although the Company performs some manufacturing functions in the United States, certain products incorporate significant imported content, and others are sourced entirely overseas. Substantial Compliance: Tramontina implemented a remedial action plan to clarify its representations. This plan included: (1) updating claims to state that affected products contain imported components; (2) removing a banner that appeared on all product webpages containing the word “USA” superimposed over and image of the flag; (3) revising the website to clarify Tramontina’s manufacturing process; and (4) contacting third-party retailers to provide updated claims and product descriptions.
10/20/2015 Wal-Mart Stores, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Annemarie C. O’Shea, Esq.
Associate General Counsel
Walmart Global eCommerce
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with discrepancies or outdated information regarding country-of-origin claims on the walmart.com website and concerns regarding the clarity and conspicuousness of disclosures on “Made in USA” logos used in conjunction with Walmart’s Investing in American Jobs Program. Substantial Compliance: Walmart took the following steps to prevent consumer deception. With regard to its website Walmart: (1) removed “Made in USA” logos from all product listings; (2) removed country-of-origin information from all product specifications, except where required by law; (3) removed U.S.-origin claims that appeared in product descriptions or titles; and (4) implemented a procedure to flag and remove new U.S.-origin claims made in ad copy submitted by suppliers. Additionally, Walmart rolled out redesigned “Made in USA” logos for private brand products promoted in conjunction with the Investing in American Jobs Program. The redesigned logos, which appear on product packaging, include larger disclosures regarding the percentage of U.S. content contained in the product, as well as a disclosure intended to convey that the U.S.-origin claim is self-certified by the supplying factory.
10/09/2015 OMG, Inc.
(formerly Olympic Manufacturing Group, Inc.)
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Anthony Aaron, Esq.
Ice Miller LLP
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with overly broad or outdated U.S.-origin claims for certain OMG products, including, but not limited to, certain Cortex deck screws and kits sold under the FastenMaster brand name. Substantial Compliance: OMG has implemented a remedial action plan to correct its representations and avoid future mislabeling that includes: (1) removing U.S.-origin claims and updating packaging for products now sourced outside the United States; (2) re-labeling products containing imported raw materials as “Manufactured in the USA from globally sourced materials,” where appropriate; (3) removing overly broad U.S.-origin claims from marketing materials; and (4) adopting compliance measures to ensure all future U.S.-origin claims comply with the FTC’s Enforcement Policy Statement on U.S. Origin Claims.
10/01/2015 Spray Pal
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. Andrew C. Aitken, Esq.
IP Law Leaders PLLC
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials that may have overstated the extent to which the Spray Pal cloth diaper cleaning device is made in the United States. Specifically, though some parts or the product are made in the United States, the clip, which is essential to the function of the product and is used to fasten diapers to the device, is imported. Substantial Compliance: Spray Pal has implemented a corrective action plan that includes:(1) performing a company-wide analysis of labeling claims; (2) re-labeling existing Spray Pal inventory with the claim “Made in USA from US and Imported Parts”; (3) reviewing and correcting claims on the Spray Pal website and on the social media; and (4) sending an email to website hosts of re-sellers and bloggers that have reviewed the Spray Pal product with updated marketing materials.
09/18/2015 Henkel Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jean-Cyril Walker, Esq.
Keller and Heckman LLP
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain labels or marketing materials may have overstated the extent to which certain Henkel-Loctite cyanoacrylate glue products are made in the United States or contain U.S.-sourced ingredients. Specifically, although Henkel substantially transforms raw materials into cyanoacrylate glues in the United States, a significant proportion of the cost of the chemical inputs to these products is attributable to imported chemicals. Substantial Compliance: Although the cyanoacrylate glue products in question were last substantially transformed in the United States, they include imported raw materials that are significant in cost and to the function of the adhesives. Accordingly, to avoid deceiving consumers, Henkel Corporation is updating labels for affected glues to state “U.S. Made: US/Foreign Materials.” Because Henkel makes no U.S.-origin claims for these products other than on labels, no further corrective action is needed.
08/31/2015 Nordic Ware/Northland Aluminium Products, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ms. Jennifer Dalquist
Director of Sales and Marketing
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with certain marketing materials may have overstated the extent to which Nordic Ware's products are made in the United States. Specifically, though many of Nordic Ware's products are "all or virtually all" made in the United States, the Company also sells products that are made overseas. Substantial Compliance: Nordic Ware removed broad, unqualified "Made in USA" claims from the nordicware.com site and confirmed no similar language exists in other marketing materials; amended Company descriptions on social media accounts; and (3) reviewed country-of-origin documentation for products to confirm the accuracy of product labels and product-specific advertisements.
08/19/2015 Ariens Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
I. Gregg Curry IV, Esq.
McCarty Law LLP
Possible violations of Sections 5(a) and 12 of the Federal Trade Commission Act in connection with “American Craftsmanship" claims for outdoor power equipment, including snow blowers, that may have overstated the extent to which such products are made in the United States. Substantial Compliance: Ariens implemented a remedial action plan, including (1) removing the
Company's "American Craftsmanship" logo from all products, brochures, manuals, websites, social media, and advertising; (2) introducing a new logo that states products are "Designed & Assembled in the U.S.A."; and (3) sending a letter to all Company dealers communicating changes to marketing materials.
06/29/2015 The Coleman Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mark A. Rosebrock, Esq.,
SVP-Global Legal Affairs & General Counsel, The Coleman Company, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act due to Coleman inadvertently making deceptive "Made in USA" claims for certain disposable butane lighters. Specifically, a vendor mistakenly printed
packages with unqualified "Made in USA" claims, and retailers sold them to consumers.
Inadvertent Error:  Coleman took several steps to prevent consumer deception. These steps included: (1) destroying remaining mislabeled product in inventory; (2) confirming that new labels for the product contained correct country-of-origin information; (3) spot-checking claims on a random sample of Coleman products; and (4) submitting examples of Coleman's "Made in USA" labels and labeling policies to FTC staff for review and informal staff feedback.
06/29/2015 NHS, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Nathan Benjamin, Esq.,
The Law Office of
Benjamin Leibrock
Possible violations of Section 5 of the Federal Trade Commission Act because NHS inadvertently made
misleading "Made in USA" claims for certain skateboard trucks. Specifically, though the Company assembles, finishes, and packages skateboard trucks in the United States, some trucks contain significant imported content.
Inadvertent Error:  NHS has implemented a remedial action plan to correct its representations and avoid future mislabeling. This plan includes: (1) performing a company-wide analysis of labeling claims for both hard and soft goods; (2) re-labeling affected skateboard trucks with the claim "MFG IN USA FROM US AND IMPORTED PARTS";
(3) removing a "USA" stamp from foundry molds for affected trucks; (4) re-labeling affected
apparel items with the claim "Made in USA of Imported Fabric"; and (5) reviewing catalogue,
video, and web marketing materials to confirm the accuracy of all country-of-origin claims.
06/18/2015 San Antonio Shoe, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Janice Thomson, Esq.
In-House Counsel
Possible violations of Section 5 of the Federal Trade Commission Act regarding certain SAS marketing materials may have overstated the extent to which the Company sells shoes that are made in the United States. Specifically, Company materials made broad "Made in USA" claims that appeared to apply to all SAS shoes. Substantial Compliance:  SAS is implementing a corrective action plan to limit SAS's "Made in USA" claims to products that are "all or virtually all" made in the United States. This plan includes: (1) updating claims on the Company website and other marketing materials; (2) applying updated shoebox labels; and (3) instituting a legal review process for U.S.-origin marketing claims.
06/05/2015 Gorilla Glue Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Alison J. Stimac, Esq., outside counsel to Gorilla Glue Company Possible violations of Section 5 of the Federal Trade Commission Act regarding certain labels and
marketing materials may have overstated the extent to which Gorilla Glue adhesive products are made in the United States or contain U.S.-sourced ingredients. Specifically, there were  concerns that an unqualified "Made in USA" claim for a glue or tape product may deceive consumers where, although the product was last substantially transformed in the United States, either: (1) a significant percentage of the raw materials contained in the product is sourced overseas, or (2) a key raw material in the product that gives it its adhesive quality is sourced
overseas.
Substantial Compliance:  Although the adhesive products in question were last substantially transformed in the United States, they include imported raw materials that are significant, either in quantity or to the function of the relevant product. Accordingly, Gorilla Glue is in the process of implementing a comprehensive corrective action plan. This plan includes: (1) updating "Made in USA" claims for impacted products to state "Made in USA with Domestic and Imported Materials" or "Made in Germany. Bottled in the USA," as appropriate; (2) revising product packaging to make qualifications more clear and prominent; (3) updating product descriptions and photos on the Company website and social media; and (4) contacting third-party retailers to provide updated product claims, descriptions, and images.
06/02/2015 Quickie Manufacturing Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Lorelei Joy Borland, Esq., Vice President- Environmental & Regulatory Affairs
Jarden Corporation
Possible violations of Section 5 of the Federal Trade Commission Act in connection with third-party websites
marketing Quickie cleaning products making deceptive unqualified "Made in USA" claims for certain products not all or virtually all made in the USA.
Inadvertent Error:  Quickie quickly implemented a remedial action plan, including confirming that all Quickie product labels display accurate country-of-origin claims; hiring a temporary employee to ensure that country-of-origin claims made by third-party retailers match the claims on product packaging; and taking steps to correct inaccurate claims on third-party websites, including sending cease-and-desist letters and taking further action as appropriate.
05/27/2015 Military Pet, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. West Moore
Military Pet, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act in connection with Military Pet's marketing materials may have overstated the extent to which some pet products containing domestic and
imported content were made in the United States.
Substantial Compliance:  Military Pet worked with its suppliers to confirm the origin of its products, and made several changes to its marketing materials to correct and clarify its representations. These changes included removing overly broad "Made in USA" claims from Military Pet's website, and changing unqualified "Made in USA" claims to qualified claims such as "Made in USA of U.S. and Imported Parts," where appropriate.
05/07/2015 Element Electronics, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Timothy J. Fitzgibbon, Esq., Outside Counsel to Element Electronics Possible violations of Section 5 of the Federal Trade Commission Act regarding marketing materials may have
suggested that all Element televisions are assembled in the United States.
Substantial Compliance: Element confirmed that the U.S. Customs Service would consider certain of Element's televisions to be "substantially transformed" in the United States. Thus, an "Assembled in USA" claim likely would not be deceptive for those televisions. However, Element continues to market other televisions that are not "substantially transformed" in the United States. Accordingly, to avoid deceiving consumers, the Company made changes to its website to clarify that some - not all - of Element's televisions are
assembled in the United States, and to make it easier for consumers to view televisions assembled in the United States separately from other Company products.
04/28/2015 Platinum Pets, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mark Kier, Director of Business Development
Platinum Pets, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act regarding marketing materials that may have overstated the extent to which certain Platinum Pets products are made in the United States. Substantial Compliance: Platinum Pets conducted an extensive review of its marketing materials, including claims made through third-party websites and social media, and  updated marketing materials to remove overly broad claims and, where applicable, to identify specific manufacturing processes that the Company performs in the United States.
04/13/2015 Toagosei America Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Leslie Alan Glick, Esq.
Counsel to Toagosei America Inc.
Possible violations of Section 5 of the Federal Trade Commission Act regarding certain labels and marketing materials that may have overstated the extent to which certain Toagosei adhesive products are made in the United States or contain U.S.-sourced ingredients. Specifically, although certain Toagosei products contain raw materials that are substantially transformed into glues in the United States, in some instances, a significant percentage of those raw materials are sourced overseas. Substantial Compliance: Toagosei implemented a corrective action plan, including updating relevant "Made in USA" claims for impacted glues to state "Made in USA with Foreign Materials"; (2) stickering over unqualified "Made in USA" claims on certain packages; (3) scrapping packaging with unqualified claims; and (4) repackaging certain products so that claims on tubes are not visible to consumers at the point of purchase.
04/13/2015 Office Depot
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Joseph G. White, Senior Director, Associate General Counsel- Transactions
Office Depot, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act regarding Office Depot’s inadvertent misleading "Made in USA" claims for certain private brand desks. Specifically, though the Company moved production of these desk overseas, the Company did not remove U.S.-origin claims for these products from its website. Inadvertent Error: Office Depot has implemented a remedial action plan to correct its representations and avoid future mislabeling. This plan includes: (1) removing inaccurate claims from the website; (2) reviewing catalogues, signage, packaging, and social media content to ensure the accuracy of claims for the affected products;
(3) reviewing online descriptions for all products; (4) implementing a procedure wherein legal
personnel review weekly reports regarding any items where production has shifted from U.S. to
non-U.S. manufacturers; and (5) increasing legal review of the Company's U.S.-origin claims.
03/30/2015 Global Syn-Turf, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Andrew Gao, CEO
Global Syn-Turf, Inc.
Possible violations of Section 5 of the Federal Trade Commission Act regarding certain marketing materials that may have overstated the extent to which GST sells products that are made in the United States. Substantial Compliance: GST made several changes to its website and other materials to clarify that the company's "Made in USA" claims apply only to the Patriot Series. These changes included updating claims on marketing materials to specify "Patriot Series Made in the USA," and updating GST's website to make it easier for consumers to locate Patriot Series products.
03/26/2015 84 Lumber Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ronald Y. Rothstein, Outside Counsel for 84 Lumber Company Possible violations of Section 5 of the Federal Trade Commission Act regarding www.webuildamerican.com, a website maintained by 84 Lumber, might mislead
consumers by failing to disclose that some featured manufacturers sell a mix of U.S.- and foreign-origin products, or by overstating the extent to which featured manufacturers make their products in the USA.
Substantial Compliance: 84 Lumber agreed to clarify the Website by adding prominent disclosures to the Home and Building Products pages explaining that some featured manufacturers offer products not made in the USA. Additionally, the Website contains a disclosure stating that 84 Lumber does not verify U.S.-origin claims made by featured manufacturers.
02/18/2015 Florida Tile, Inc.
 
 (Made in USA)
Julia Solomon Ensor
Staff Attorney
Lloyd C. Chatfield II, Esq., counsel for Florida Tile, Inc. Possible violations of Section 5 of the Federal Trade Commission Act regarding Florida Tile's marketing materials that may have overstated the extent to which some product lines, consisting of floor and wall tile containing domestic and imported content, were made in the United States. Substantial Compliance:  Florida Tile implemented a remedial action plan to correct its representations and avoid future mislabeling, including: (1) updating the "Made in USA" page on Florida Tile's website; (2) updating website product descriptions; (3) updating printed product literature; and (4) adding a clarifying label to architectural binders, sample boards, contractor boards, and cradles.
02/13/2015 Aeromotive, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Arthur A. Chaykin, Esq., counsel for Aeromotive, Inc. Possible violations of Section 5 of the Federal Trade Commission Act regarding Aeromotive's marketing materials that may have overstated the extent to which certain auto parts containing imported content were made in the United States. Substantial Compliance:  Aeromotive implemented a remedial action plan to correct its representations and avoid future mislabeling. This plan included removing U.S.-origin claims from all marketing materials and product packaging.
10/7/2014 Attwood Corporation
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Kathyleen O' Brien, Esq.
Counsel for Attwood Corporation
Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with inadvertent misleading "Made in USA" claims for certain MotorGuide Trolling Motors that contain significant imported content, but are designated as originating in the United States for export tariff purposes. Inadvertent Error:  Attwood implemented a remedial action plan to correct its representations and avoid future mislabeling: (1) removing export designations from the standard pack labels of shipping cartons for MotorGuide Trolling Motors sold in the United States; and (2) training involved employees on the FTC's Enforcement Policy Statement on U.S.-Origin Claims.
10/6/2014 Croakies, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mr. John M. Scott
Executive VicePresident
Croakies, Inc.
Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Croakies' marketing materials may have overstated the extent to which certain eyeglass
retainers containing imported content were made in the United States.
Substantial Compliance:  Croakies implemented a remedial action, which included (1) updating the website to remove overly broad claims; (2) reviewing product packaging; (3) revising business cards to remove unqualified U.S.-origin claims; and (4) providing guidance and background on making U.S. origin claims to marketing, art, production, and sales personnel.
10/1/2014 D’Addario & Company, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
John J. Burke, Jr., Esq.
General Counsel
D' Addario & Company, Inc.
Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with mistakenly making potentially misleading or overly broad "Made in USA" claims for several D' Addario and affiliate company lines, including the American Stage Cable line; several ukulele, guitar, and bass string lines; and certain woodwind reed lines. Inadvertent Error:  D' Addario conducted a significant audit of its country-of-origin marketing claims, and implemented a comprehensive remedial action plan to correct its representations. This plan included: (1) reviewing claims for all products, including those sold by D' Addario affiliates; (2) updating online marketing materials for affected products; (3) reviewing and updating marketing claims on D' Addario's social media platforms; and (4) providing detailed schedules for rolling out updated packaging for affected products.
9/9/2014 Jewelers Vigilance Committee
 
 
Donald S. Clark
Secretary
Cecilia L. Gardner
President, CEO, and General Counsel
Jewelers Vigilance Committee
JVC requested a staff advisory opinion stating that “Made in the USA” claims for jewelry made from minerals and metals recycled in the United States (the “Request”) do not deceive consumers. JVC states that because “significant time and resources . . . go into collecting recyclable material, delivering it to refiners in the United States, and then processing to a purity level of almost 100% [i]t makes sense to equate the recycling process to a ‘new life cycle’ and to assign a new origin to recycled material.”
 
Other: Jewelry returned for recycling is often of unknown origin. Accordingly, because gold and precious minerals may be – and often are – mined internationally, it is highly likely that any piece of recycled jewelry might contain components or natural resources that originated outside the United States. The Commission staff cannot provide an opinion stating that “Made in the USA” claims for recycled jewelry do not deceive consumers.
8/21/2014 Circle Y Saddles, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Amy Orsak
Marketing and Design Manager
Circle Y Saddles, Inc.
Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Circle Y's marketing materials may have overstated the extent to which certain saddles, saddlebags, and tack items containing imported content were made in the United States. Substantial Compliance: Circle Y implemented a remedial action plan to correct its representations. This plan included: (1) updating the website to
remove overly broad claims; (2) adding product origin disclaimers to imported products; (3) updating the Company's catalogues; and (4) removing "Made in the USA" claims from warranty cards for imported saddles.
7/28/2014 Karen Kane, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Kathleen A. Juniper, Esq., outside counsel to Karen Kane, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Karen Kane mistakenly making overly broad "Made in USA" claims for certain clothing items made from imported fabrics, including in connection with the Company's use of the Made in the USA Brand, LLC Certification Mark. Inadvertent Error: Karen Kane implemented a remedial action plan to correct its representations. This plan included: (1) removing the Made in the USA Brand, LLC Certification Mark from the Company's website; (2) applying updated hang-tags to clothing disclosing imported content; and (3) developing written policies and procedures regarding U.S.-origin marketing claims.
7/28/2014 Windward Design Group, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Marc Morales, VP, Business Development for Windward Design Group, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Windward’s marketing materials, including materials featuring the Made in the USA Brand, LLC Certification Mark, may have overstated the extent to which certain outdoor furniture and accessory products containing imported content were made in the United States. Substantial Compliance: Windward implemented a remedial action plan to correct its representations. This plan included: (1) removing the Made in
the USA Brand, LLC Certification Mark from the Windward website and catalogues; (2) updating marketing materials to clarify that some products contain imported content; and (3) closely monitoring U.S.-origin claims going forward.
7/28/2014 Burley Clay Products Co., Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ms. Bobbi Bennett, VP of Marketing and Customer Service Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Burley's marketing materials, including materials featuring the Made in the USA Brand, LLC Certification Mark, may have overstated the extent to which some pottery products containing imported content were made in the United States. Substantial Compliance: Burley implemented a remedial action plan. This plan included: (1) removing the Made in the USA Brand, LLC Certification Mark from the Burley website; (2) qualifying U.S.-origin claims to reflect that some of Burley's products contain imported content; and (3) only making unqualified U.S.-origin claims for products made in Burley's Ohio factory that
contain no imported content.
7/18/2014 Fresh Produce Holdings, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Joel M. Alam, Outside Counsel to Fresh Produce Holdings, LLC Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Fresh Produce's marketing materials may have overstated the extent to which certain clothing and accessory products containing imported content were made in the United States. Substantial Compliance: Fresh Produce Holdings implemented a remedial action plan to correct its representations. This plan included: (1) updating the website to clarify that 20% of the Company's products contain imported content; (2) undertaking a comprehensive review of country-of-origin claims; (3) revising website product descriptions to make disclosures consistent with product labels; (4) educating staff; and (5) enhancing compliance and quality controls.
04/10/2014 Shinn Fu Company of America, Inc.
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Michael J. Abrams, Counsel for Shinn Fu Co. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Shinn Fu mistakenly making misleading "Made in USA" claims for two service jacks and two jack stands that contain significant imported content. Inadvertent Error:  Shinn Fu implemented a remedial action plan to correct its representations, altering the claim to read “assembled in the US with US and Global Components.” Other promotional material underwent revisions as well.
03/04/2014 Spacelabs Healthcare
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Cheryl A. Falvey, Counsel for Spacelabs Healthcare Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with inadvertent misleading "Made in USA" claims made for approximately 14 medical device product families that contain imported content. Inadvertent Error:  Remedial action plan implemented, which included: (1) implementing regular training for employees on "Made in the
USA" claims; (2) removing "Made in the USA" labels from affected products and accessories; and (3) enhancing compliance and quality controls to ensure all labels continue to meet applicable regulatory requirements.
02/28/2014 Niagara Industries, Inc.
 (Made in USA)
Julia Solomon Ensor
Staff Attorney
Henry E. Marinello, Esq., Counsel for Niagara Industries, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Niagara’s marketing materials overstating the extent that their tankless water heaters are made in the United States. Substantial Compliance:  Niagara has removed all unqualified U.S.-origin claims from its marketing materials and rolled out new product packaging.
02/11/2014 Graco Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Frank J. Brixius Jr., Esq., GC for Graco Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Graco inadvertently applying “Made in USA” labels to a part that is sourced overseas. Inadvertent Error:  Graco implemented a remedial action plan to correct its representations and avoid future mislabeling. This plan included: (1) updating the product database; (2) correcting labels on affected products still in inventory; and (3) training staff to update the product database and review labels more frequently.
01/31/2014 AS America, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Sean T. Murray, Esq., Counsel for AS America, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with inadvertent misleading "Made in USA" claims for certain American Standard-branded toilets. The distribution center applied incorrect bar codes to product packaging, causing a misapplication of “Made in USA.” Inadvertent Error:  AS American implemented a remedial action plan, including: (1) correcting labels on affected products still in inventory; (2) retraining employees responsible for generating bar code labels; (3) adding country-of-origin verification procedures to packaging processes and internal audit processes; and (4) comprehensively reviewing country-of-origin claims on AS America marketing materials.
01/27/2014 Rapiscan Systems
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Cheryl A. Falvey, Esq., Counsel for Rapiscan Systems Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Rapiscan inadvertently claiming “Made in USA” on approximately 791 units that contained parts not made in the US. Rapiscan makes security systems designed for checkpoints/inspection. Inadvertent Error: Rapiscan implemented a remedial action plan, including: providing comprehensive training to employees; notifying affected customers; implementing a process to permanently remove any potentially deceptive
U.S.-origin claims; incorporating new labels without U.S.-origin claims into the assembly line; and introducing a product label review process.
01/02/2014 Kocheck Co., Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Michael K. Kinney, Esq. Counsel for Kochek Co., Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with broad statements in Kochek’s marketing materials that could mislead consumers to thinking all products were made in the United States. Substantial Compliance: Kochek implemented a remedial action plan to correct any misrepresentations of “Made in USA” claims made on marketing materials, added qualifications on products, and introduced new protocol for substantiating U.S.-origin claims.
12/18/2013 Lava Cable, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Mark L. Stoddard, CEO, Lava Cable, LLC Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Lava Cable mistakenly misleading “Made in USA” claims for the TightRope patch cable kit, whose most valuable components were imported. Inadvertent Error: Lava Cable implemented a remedial action plan to correct its misrepresentations, which revised current packaging to clarify country of origin, removed “Made in the USA” from new packaging, and implemented a procedure to ensure substantiation of future U.S. origin claims.
12/17/2013 Action Coupling & Equipment, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Scott Eliot, President, Action Coupling & Equipment, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with marketing materials that could inadvertently mislead consumers about the extent to which the Company’s products are made in the USA. Some products are imported and could be misidentified as made in the USA. Substantial Compliance: Company will implement remedial action plan to correct any misrepresentations of “Made in USA” claims made on marketing materials and introduce new protocol for substantiating U.S.-origin claims.
12/17/2013 U.S. Coupling & Accessories, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Cathy Gourlay, President, U.S. Coupling & Accessories, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with marketing materials that could inadvertently mislead consumers about the extent to which the Company’s products are made in the USA. Substantial Compliance: Company will implement remedial action plan to correct any misrepresentations of “Made in USA” claims made on products, the website, or marketing materiel.
11/26/2013 MadeInTheUSA.com, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Don Buckner, President, MadeInTheUSA.com, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with MadeInTheUSA.com promotion of certain products sold on Amazon.com as made in the USA. Specifically, MadeinTheUSA.com uses Amazon.com technology to identify products marketed as made in the USA, and earns advertising fees by linking consumers directly to Amazon.com to purchase those products. The Company does not independently verify that products listed on Amazon.com are, in fact, made in the USA. Substantial Compliance: MadeInTheUSA.com agreed to clarify their representations by adding a prominent disclosure to the website's product search toolbar. This disclosure, which appears on every portion of the website, explains that MadeinTheUSA.com does not verify U.S.-origin claims, provides a mechanism for consumers to report potentially deceptive claims, and states that search results are provided by Amazon.com.
11/19/2013 J.K. Adams Company
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Jon Blatchford, Chief Executive Officer, J.K. Adams Company Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with J.K. Adams mistakenly promoting products as “Made in the United States” even though those products contained foreign components. Inadvertent Error: J.K. Adams is (1) removing "USA Made" brands from products containing imported hardware or Canadian content; (2) updating J.K. Adams's marketing materials and website; (3) correcting product packaging; (4) contacting independent sales representatives to clarify that some products contain imported content; and (5) planning an updated website and associated marketing materials for rollout mid-2014.
10/29/2013 Dental USA, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Nicholas S. Lee, Counsel for Dental USA, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with marketing materials that could mislead consumers about the extent to which Dental USA’s products are made in the United States. Substantial Compliance: Dental USA implemented a remedial action plan to correct its representations. This plan included conducting a comprehensive review of all Dental USA’s marketing materials, deleting potentially misleading statements from Dental USA’s website and catalogues; and clarifying Dental USA’s policy for marking products as Made in the USA.
9/11/2013 Midwest Motion Products, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Randy Cordes, President, Midwest Motion Products, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Midwest Motion Products, Inc. mistakenly making misleading "Made in USA" claims for certain motors. Specifically, although the Company assembled motors in the United States, many of the parts used were imported. Inadvertent Error: Midwest Motion
implemented a remedial action plan to correct its representations. This plan included: (1) removing all "Made in USA" labels from the Company's production area; (2) instructing manufacturing personnel to discontinue use and application of "Made in USA" labels for affected products; and (3) updating and correcting the Company's website.
8/1/2013 All-Clad Metalcrafters, LLC
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Wendelynne J. Newton, Counsel for All-Clad Metalcrafters, LLC Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with All-Clad's website stating that the Company makes some, but not all, of its products in the USA. The FTC was concerned that some consumers could be misled into thinking that all of All-Clad's products are made in the USA. Substantial Compliance: All-Clad agreed to a plan which included: (1) adding more specific country-of-origin statements to All-Clad's website; (2) communicating with customers and retailers about All-Clad's domestic and foreign manufacturing activity; (3) revising brochures to clarify USA -origin claims; and (4) scheduling periodic reviews of retailer websites to monitor the accuracy of any USA-origin claim for All-Clad products.
7/8/2013 Regency Wraps, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Doug Cohen, President, Regency Wraps, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45, in connection with the marketed claim of “Made in the USA” for the Company's EvenBake Cake Strips which were sourced from a factory in Pakistan. Substantial Compliance: Regency Wraps implemented a remedial action plan to clarify and update its representations, which included: (1) informing distributors and customers that all further orders of EvenBake Cake Strips would be made in Pakistan; and (2) updating product packaging to reflect that the Cake Strips are now "Made in Pakistan[;] Packaged and Inspected in the USA."
6/3/2013 Little Giant Ladders, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Linda A. Goldstein, Counsel for Little Giant Ladders, Inc Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45, in connection with two instances where Little Giant
inadvertently made misleading "Made in the USA" claims for certain Little Giant ladders.
Inadvertent Error: Little Giant Ladders implemented a remedial action plan to correct its representations. This plan included: (1) ensuring that all third-party dealers corrected erroneous "Made in USA" representations; (2) re-editing the infomercial that contained misleading claims;
(3) adding country-of-origin information to every product SKU on the Little Giant website; (4) checking the Internet for unauthorized postings of outdated infomercials; and (5) updating call center training protocols and scripts.
5/8/2013 PetSmart, Inc.
 
(Made in USA)
Julia Solomon Ensor
Staff Attorney
SUSAn E. Foster, Esq., Counsel for PetSmart, Inc PetSmart inadvertently made misleading "Made in the USA" claims for some of its Grreat Choice™ pet products on the Company's website. Inadvertent Error: PetSmart implemented a remedial action plan to correct its representations. This plan included: (1) removing all deceptive "Made in the USA" claims from PetSmart's website; (2) implementing a new product information management system for products marketed online; and (3) subjecting website copy to the same level of legal review previously given to product packaging.
11/14/2012 Hawk Enterprises, Inc.
(Made in USA)
Julia Solomon Ensor
Staff Attorney
Ms. Linda M. Weinberg
Barnes and Thornberg LLP
Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Hawk Enterprises’ floor cleaner and polisher packaging with “Made in the USA” labels. Substantial Compliance:  Hawk implemented a remedial action plan to correct its representations. The plan included: (1) removing “Made in USA” markings from the relevant products; (2) correcting “Made in USA” representations in the Hawk catalogue and on the Hawk website; (3) discontinuing “Made in USA” stenciling on shipping cartons; and (4) providing updated information to sales representatives and distributors with respect to relevant products.
9/6/2012 Gilmour Manufacturing Company, Inc.
 
(Made in USA)
Laura Koss
Staff Attorney
Mr. Michael A. Lindsay, Esq., Counsel for Gilmour Manufacturing Company, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with Gilmour brand nozzles may have
been inadvertently advertised as "Made in USA" despite being made in China.
Inadvertent Error: Although product packaging correctly reflected this fact, the company's website contained outdated photography incorrectly stating that some products were U.S.-made. After receiving Commission staff's letter, Gilmour has taken down its website while it corrects its representations and Gilmour is auditing its retailers' web pages to ensure they are using updated images.
9/6/2012 G & A Investments, Inc.
 
(Made in USA)
Laura Koss
Staff Attorney
Mr. Gerardo Anaya, President, G & A Investments, Inc. Possible violations of Section 5 of the FTC Act, 15 U.S.C. § 45 in connection with G&A's gun cleaning patches being made with imported material and therefore have more than de minimis foreign content, but made "Made in USA" claims for these products upon the fact that G&A converts these materials into gun patches in its U.S. manufacturing plant. Substantial Compliance: G&A no longer makes unqualified "Made in USA" claims for products that are not all or virtually all made in the United States.
5/29/2012 Beams Industries, Inc.
 
(Made in USA)
Laura Koss
Staff Attorney
Mike Bosley
President
Beams Industries, Inc.
Possible violations of Section 5 of the FTC Act in connection with Beams’ products having more than de minimis foreign content and unqualified “Made in USA” claims. Substantial Compliance: In light of guidance provided by Commission staff, Beams no longer makes unqualified “Made in USA” claims for products that are not all or virtually all made in the United States.
5/29/2012 SeatBeltsPlus.com
 
(Made in USA)
Laura Koss
Staff Attorney
Gary Vogl
President
SeatBeltsPlus.com
Possible violations of Section 5 of the FTC Act in connection with Beams’ products having more than de minimis foreign content and unqualified “Made in USA” claims. Substantial Compliance: In light of guidance provided by Commission staff, SeatBeltsPlus.com no longer makes unqualified “Made in USA” claims for products that are not all or virtually all made in the United States.
5/29/2012 Seatbelt Solutions
 
(Made in USA)
Laura Koss
Staff Attorney
Jeffery L. Biegun
President/CEO
Seatbelt Solutions
Possible violations of Section 5 of the FTC Act in connection with Beams’ products having more than de minimis foreign content and unqualified “Made in USA” claims. Substantial Compliance: In light of guidance provided by Commission staff, Seatbelt Solutions no longer makes unqualified “Made in USA” claims for products that are not all or virtually all made in the United States.
5/8/2012 Summer Infant, Inc.
 
(Made in USA)
Laura Koss
Staff Attorney
Anthony A. Paolo
VP Corporate Quality
Summer Infant, Inc.
Possible violations of Section 5 of the FTC Act in connection with Summer Infant’s retailers’ websites advertising Summer Infant bibs as “Made in the United States,” when, in fact, some of the bibs were imported from China. Substantial Compliance: Summer Infant contacted its retail partners to notify them of the error and has assisted them with making necessary changes to their websites. Further, Summer Infant reviewed its website to ensure all “Made in USA” claims are accurate. Finally, Summer Infant is developing an “Internal Work Instruction/Procedure” to periodically audit retailer websites to ensure compliance with the FTC law.
1/20/2012 Lucky Brand Dungarees, Inc.
(Made in USA)
Matthew J. Wilshire
Staff Attorney
Andrew C. Finch
Paul, Weiss, Rifkind, Wharton & Garrison LLP
Possible violations of the Section 5 of the FTC Act in connection with Luck Brand advertising describing their clothing as “hand-crafted in America”, made in the United States, and/or “born in America.” Substantial Compliance: After being notified by the FTC, Lucky Brand removed “hand-crafted in America” and “Born in America” from its website and all other advertising on all its products.
10/03/2011 EBI, LLC
 
(Made in USA)
Laura Koss
Staff Attorney
George W. Thompson
Neville Peterson LLP
Possible violations of Section 5 of the FTC Act regarding “Made in United States” claims that EBI had inadvertently labeled certain mattresses and sofas, even though the products were imported. Inadvertent Error: Upon discovering the issue, EBI immediately ceased the practice and advised its customer of the mislabeling to prevent further sales of the mislabeled sofas and mattresses. In addition, EBI has established a program to have all mislabeled products returned to have replacement labels added. EBI is also taking steps to avoid a recurrence by issuing guidelines on appropriate country-of-origin marking and commencing an internal investigation. Based on EBI’s immediate and continuing corrective action and self-reporting, the staff did not recommend enforcement action.
09/26/2011 IKEA
 
(Made in USA)
Laura Koss
Staff Attorney
James P. Connors, Esq.
Jones Hirsch Connors & Bull P.C.
Possible violations of Section 5 of the FTC Act regarding “Made in United States” claims that IKEA’s supplier had inadvertently labeled certain mattresses and sofas, even though the products were imported. Inadvertent Error: IKEA stated that the supplier inadvertently used the same labels for the imported products that it used for those it produced in the United States. After IKEA discovered the issued, it required the supplier to immediately cease the practice. IKEA is not permitting the shipment of improperly marked goods from the supplier’s warehouse until the supplier takes corrective action. Additionally, IKEA and the supplier are establishing a program to have all mislabeled sofas and mattresses returned for removal of the claim. Based on IKEA’s immediate and continuing corrective action and self-reporting, the staff did not recommend enforcement action. 
6/24/2011 Munchkin, Inc.
 
(Made in USA)
Laura Koss
Staff Attorney
Petty Rader, Esq.
Corporate Counsel
Munchkin, Inc.
Possible violations of Section 5 of the FTC Act in connection with unqualified “Made in USA” claims on retailer websites, law labels, and retail packaging for mattresses that are not all or virtually all made in the USA. Substantial Compliance: Munchkin will no longer make unqualified “Made in USA” claims and will only make appropriate qualified claims for these mattresses. Unqualified “made in USA” claims have been removed from retailer websites, and Munchkin is working to implement changes to labesl and packaging as expeditiously as possible.
8/23/2010 Ritter Chemical LLC
 
(Made in USA)
Laura Koss
Staff Attorney
Daniel T. Rockey
Bullivant Houser Bailey
Possible violations of Section 5 of the FTC Act in connection with advertising its Alecto herbicide product as “Made in USA” on its website and on stickers for approximately 5,000 Alecto product contianers. Substantial Compliance: Upon being contacted by FTC staff in July 2010, Ritter removed the “Made in USA” statement from its website and halted the placement of “Made in USA” stickers on products. Ritter has also cautioned each of its distributors against making misrepresentations concerning the manufacturing process or origin of Alecto products.
3/6/2000  
Moen Incorporated
 
Elaine D. Kolish
Associate Director
Enforcement
 
Bruce A. Carbonari
Chairman and Chief Executive Officer
Moen Incorporated
 
Stephen P. Durchslag, Esq.
Winston & Strawn
 
Investigation involving an allegation that Moen Incorp. violated the FTCs All or virtually all standard for domestic country of origin claims and Section 5 of the FTC Act.  A complaint received alleged that the packaging for the Moen faucet included a Made in USA claim, but the machined brass valve body of the faucet was marked China.
 
 
 
5/26/1999  
Crown Crafts, Inc.
 
Carol J. Jennings
Enforcement
 
Robert A. Enholm
General Counsel
Crown Crafts, Inc.
 
Inquiry concerning allegations that the company may have distributed certain twin sheets sets labeled as AMade in the USA@ on the outer package, even though the sheets themselves allegedly were labeled AMade in China.@
 
 
12/22/1998  
Goodyear Tire & Rubber Company
 
Elaine D. Kolish
Associate Director
Enforcement
 
Samir F. Gibara
President
Goodyear Tire & Rubber Co.
 
Michael R. Rickman, Esq.
 
Tire manufacturer distributed tires marked "Made in USA" that were manufactured in Chile.  Company claimed inadvertent error in that production had recently shifted from the United States to Chile and that certain tires were sent to the United States before the "Made in USA" mold had been modified.  Upon discovery, the manufacturer buffed off the "Made in USA" mark and took steps to prevent distribution in U.S. commerce. 
 
 
12/22/1998  
All Laser Service
 
Elaine D. Kolish
Associate Director
Enforcement
 
Jeff Wilkinson
President
All Laser Service
 
Company advertised its laser printer memory upgrades as "Made in USA."  All labor in manufacturing laser printer memory upgrades performed in the U.S.  The percentage of foreign content was de minimis.
 
 
12/22/1998  
Eaton Corporation
 
Elaine D. Kolish
Associate Director
Enforcement
 
Alexander M. Cutler
President
Eaton Corp.
 
Steven A. Newborn
Rogers & Wells LLP
 
Golf club grips molded in the U.S. and finished outside the U.S.  Grips designed, engineered, poured, and molded into their final shape in the U.S. and are stamped "USA."  The finishing operations performed outside the U.S. (i.e., buffing of excess residue and painting certain portions) are minor and do not constitute a substantial transformation as that term is used by the U.S. Customs Service. 
 
 
12/22/1998  
Edcor Electronics
 
Elaine D. Kolish
Associate Director
Enforcement
 
Phyllis Weston
Edcor Electronics
 
Website stated "All of Edcor's products are proudly designed and manufactured in the United States."  Company manufactures two types of products in the U.S., transformers and audio amplifiers/mixers.  All of the parts and labor used in manufacturing the transformers are domestic.  All the labor in manufacturing  audio amplifiers/mixers is performed in the U.S. and the percentage of foreign content in audio amplifiers/mixers is de minimis relevant to the total manufacturing cost.
 
 
10/27/1998  
Mitek Corporation
 
Elaine D. Kolish
Associate Director
Enforcement
 
Loyd Ivey
CEO
Mitek Corp.
 
Company advertised its "MTX Blue Thunder" amplifier line as "Made in USA."  All the labor in manufacturing these amplifiers performed in the U.S.  Company provided information that shows that the percentage of foreign content in those amplifiers is de minimis relevant to the amplifiers' total manufacturing cost.
 
 
9/1/1998  
In The Swim
 
Elaine D. Kolish
Associate Director
Enforcement
 
James Coxworth
President
In The Swim
 
Advertisements for pool cover included claims "American" and "American-Made."  Pool covers actually manufactured in Canada.  Company stated that it intended the claim to mean "North America" and agreed to revise advertising to state either "Made in Canada" or "Made in North America." 
 
9/1/1998  
Sears, Roebuck and Company
 
Elaine D. Kolish
Associate Director
Enforcement
 
Arthur C. Martinez
President
Sears Roebuck and Co.
 
Charaluta Pagar, Esq.
Senior Counsel
Sears Roebuck and Co.
 
Retail distributor of work light claimed the product was "Made in USA" when it was actually made in China.  Distributor also claimed stud finder was "Made in USA" when it was actually assembled in Mexico of U.S. and imported parts.  Distributor explained that the products were produced by independent vendors who were required to inform the distributor whenever foreign-made parts or foreign assembly operations were used.  Distributor also provided staff information about its efforts to ensure vendor compliance in terms of "Made in USA" claims. 
 
 
8/27/1998  
American Whistle Corporation
 
Elaine D. Kolish
Associate Director
Enforcement
 
Ray Giesse
CEO
American Whistle Corp.
 
Packaging for American Patriot Whistle, which included the words "Crafted with Pride In the USA," discontinued for two years. Current packaging makes no representation about U.S. origin.
 
8/24/1998  
Selectrode Industries, Inc.
 
Elaine D. Kolish
Associate Director
Enforcement
 
Joseph Paternoster
President
Selectrode Industries
 
Electrodes packaged in cartons marked "Made in USA" possibly taken from inventory of electrodes manufactured in Europe.  Staff assured that appropriate steps would be taken to prevent future mistakes.
 
 
 
8/24/1998  
L.S. Starrett
 
Elaine D. Kolish
Associate Director
Enforcement
 
Douglas R. Starrett
Chairman & CEO
 
L.S. Starett
 
Package and cardboard hangers for fiberglass blade measuring tapes included "Made in USA" claim despite the fact that tapes were actually manufactured in Taiwan.  Company agreed to eliminate the words "American made" from labels and hangers and dispose of packaging inventory.
 
 
8/24/1998  
Lincoln Automotive
 
Elaine D. Kolish
Associate Director
Enforcement
 
Kenneth J. Fehlig
Lincoln Automotive
 
Package for aluminum electrodes manufactured in Europe included an "All American Made in USA" logo.  Company informed staff that packages were filled with incorrect inventory and provided assurances that the mistake would not be repeated.
 
 
3/9/1998  
Starcrest Products of California, Inc.
 
Gregory W. Staples
Acting Regional Director
Los Angeles Regional Office
 
Timothy M. Calandra
President, Starcrest Products
Daniel G. Murphy, Esq.
(Loeb & Loeb LLP)
 
Investigation of possible violations of (1) the Wool Products Labeling Act in the mail-order sale of moccasins advertised as "sheepskin"-lined and (2) the Textile Fiber Products Identification Act in the mail-order sale of undergarments advertised as "Made in the USA"