UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580

Mr. John Ducate, Jr.
President & CEO
The Ducane Company
800 Dutch Square Boulevard
Columbia, South Carolina 29210-7376

Re:	The Ducane Company File Number 982 3596

Dear Mr. Ducate, Jr.:

The Division of Enforcement staff has conducted an investigation of The Ducane Company ("Ducane") to determine whether Ducane has violated the Federal Trade Commission's "all or virtually all" standard for domestic country of origin claims and Section 5 of the Federal Trade Commission Act.

In its advertising, Ducane uses a logo in which the name "Ducane" appears across a circle containing the words "American made." Staff views this as a representation that Ducane's entire product line is of U.S. origin. Ducane has informed staff that, with the exception of one product in Ducane's advertising, all of Ducane's gas grills are manufactured in the United States, and provided information that shows that the percentage of foreign content in these gas grills is a de minimis amount of the grills' total material cost. Ducane also states that although one of the gas grills in its advertising is manufactured in Taiwan, Ducane has not distributed or sold this product since before January 1, 1998, and has sold its rights to this product to another company. Ducane also states that it has removed all references to this product from its Internet website and is revising all other promotional materials to delete references to it. If Ducane advertises this product in the future, it will clearly disclose that the product is "Made in Taiwan."

The staff has concluded that no further action is warranted by the Commission at this time. Accordingly, the investigation has been closed. This action is not to be construed as a determination that a violation may not have occurred, just as the pendency of an investigation should not be construed as a determination that a violation has occurred. The Commission reserves the right to take such further action as the public interest may require.

Sincerely,

Elaine D. Kolish
Associate Director