Federal Trade Commission
Received Documents
Jan 17 1996
B18354900058
Secretary

                          LAW OFFICES
                                
             WUNDER, DIEFENDERFER, CANNON & THELEN
                                
                 1615 L STREET, N.W., SUITE 65O
                    WASHINGTON, D. C. 20036
                                
                         (202) 659-3005
                   FACSIMILE: (202) 659-3010

January 16, 1996

Mr. Mike Welther
Division of Enforcement
Federal Trade Commission
Sixth Street and Pennsylvania Ave. NW
Washington, DC 20580

Dear Mr. Welther,

         On behalf of our clients, Jewelers of America, Inc., I would like to take this opportunity to
respond to the FTC Announcement of Dates for Public Workshop Regarding "Made in USA"
Claims in Product Advertising and Labeling, and as a follow up to your previous conversations
with my partner Deborah Outlaw on this issue.

         Jewelers of America, Inc. (JA) represents more than 15,000 retail jewelry outlets in the
United States.  Its primary mission is to promote, update and upgrade the retail jewelry industry
and to reinforce consumer confidence in jewelry products and retail jewelers.  This is
accomplished through a variety of written materials and programs directed at both retailers and
consumers, as well as through active participation and involvement in federal legislative proposals
of interest to the industry.

         Of particular interest in conjunction with the upcoming FTC public workshop on "Made in
USA" claims is a nationwide survey currently being conducted by JA to assist the industry in
developing a benchmark to gain a thorough understanding of the American fine jewelry consumer. 
Objectives of the survey are to portray the American fine jewelry consumer (both male and
female) in terms of such issues as purchase patterns and habits and attitudes toward different
sources of fine jewelry (emphasis added).  The survey will cover a variety of issues from shopping
and wearing habits, to attitudes towards the jewelry industry on issues such as pricing and value
for dollars spent.  When completed, a detailed report and analysis will be provided, which is
hoped will provide a complete and integrated view of both the jewelry consumer and the retail
industry.

         Since the survey is still in process, JA does not have specific comments at the present with
regard to the FTC public workshop insofar as possible consumer perceptions surrounding the
"Made in USA" claims.  Nonetheless, because of the relevance of this survey to FTC deliberations
on this issue, JA would like to take this opportunity to be on record as a potential participant/
observer in the upcoming meeting and to have the opportunity to present the survey results to the
FTC at the appropriate time.

         Thank you for your consideration.  If you have any questions, please do not hesitate to
call me or Deborah Outlaw at 202/293-8464.

                                  Sincerely,



                                  Timothy M. Haake