UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION

In the Matter of

THE STANLEY WORKS, a corporation.

DOCKET NO.

COMPLAINT

The Federal Trade Commission, having reason to believe that The Stanley Works ("respondent") has violated the provisions of the Federal Trade Commission Act, and it appearing to the Commission that this proceeding is in the public interest, alleges:

1. Respondent The Stanley Works is a Connecticut corporation with its principal office or place of business at 1000 Stanley Drive, New Britain, Connecticut 06053.
2. Respondent has manufactured, advertised, labeled, offered for sale, sold, and distributed products to the public, including mechanics tools.
3. The acts and practices of respondent alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.

Husky Mechanics Tools

4. Respondent has disseminated or has caused to be disseminated advertisements, catalogs, packaging, labeling, in-store displays, and other promotional materials for certain of its Husky combination wrenches and sockets, including but not necessarily limited to the attached Exhibits A through J. These advertisements, catalogs, packaging, labeling, in-store displays, and other promotional materials contain the following statements or depictions:

A. Television Advertisement, Exhibit A:

Shows mechanics at work using Husky combination wrenches and standard sockets. Voice-over states: "We told these mechanics that Husky tools were American made and guaranteed forever."

B. Print Advertisement, Exhibit B:

A photograph of a man holding a combination wrench while working on his car. The words "Made in U.S.A." appear on the combination wrench.

C. Catalog, Exhibit C:

"The Husky name was first registered back in 1924 for use on quality US made Mechanics Tools. . . . Husky tools are made to exact standards in state of the art manufacturing plants in Dallas, Texas"; and

A logo consisting of an American flag with the phrases "Made in U.S.A." and "Guaranteed Forever" ("U.S. flag logo").

D. Catalog, Exhibit D:

"American Made to Meet or Exceed ANSI Specifications"; and

"Made in the USA."

E. Catalog, Exhibit E:

"Made in the USA"; and

U.S. flag logo.

F. Catalog, Exhibit F:

U.S. flag logo.

G. Packaging and Labeling, Exhibit G:

"Made in U.S.A." in black and white; and

U.S. flag logo.

H. Packaging and Labeling, Exhibit H:

"Made in U.S.A." in red, white, and blue; and

"Made in U.S.A." in black and white.

I. In-store Display, Exhibit I:

"All Husky Tools Made in USA"; and

U.S. flag logo.

J. Product Registration Card, Exhibit J:

A depiction of a U.S. flag.

5. Respondent has distributed or has caused to be distributed certain of its Husky combination wrenches and sockets marked with the following statements:

"U.S.A."; or

"Made in U.S.A."

Proto Mechanics Tools

6. Respondent has disseminated or has caused to be disseminated advertisements, catalogs, packaging, labeling, and other promotional materials for certain of its Proto combination wrenches and teardrop ratchets, including but not necessarily limited to the attached Exhibits K through L, that contain the following statements or depictions:

A. Catalog, Exhibit K:

Logo consisting of the words "Made in U.S.A.," appearing next to a silhouette of the continental United States that is covered by the U.S. flag.

B. Stanley Catalog, Exhibit L:

"Proto was the first hand tool manufacturer to produce and market the combination wrench in the United States"; and

Photographs of combination wrenches marked "U.S.A."

C. Packaging and labeling:

"Made in the U.S.A."

7. Respondent has distributed or has caused to be distributed certain of its Proto combination wrenches and teardrop ratchets marked with the following statements:

"U.S.A."; or

"Mfg. U.S.A."

Blackhawk Mechanics Tools

8. Respondent has disseminated or has caused to be disseminated promotional materials for certain of its Blackhawk combination wrenches, open end wrenches, box end wrenches, flare nut wrenches, sockets, ratchets, flex handles, wrench sets, and socket sets that contain the following statements or depictions:

"America’s Best";

Photographs of certain tools marked "U.S.A.";

"Made in America"; or

"American-Made."

9. Respondent has distributed or caused to be distributed certain of its Blackhawk combination wrenches, sockets, flex handles, box end wrenches, flare nut wrenches, and open end wrenches marked with the following statement:

"U.S.A."

Challenger Mechanics Tools

10. Respondent has disseminated or has caused to be disseminated promotional materials for certain of its Challenger combination wrenches, sockets, combination wrench sets, box end wrench sets, open end wrench sets, and cold chisel sets that contain the following statements or depictions:

Photographs of a combination wrench marked "U.S.A.";

Photographs of sockets marked "Proto U.S.A.";

Photographs of cold chisels marked "U.S.A."; or

Photographs of combination wrench sets, box end wrench sets, an open end wrench set, and a cold chisel set in roll-up pouches that state "Made in U.S.A."

11. Respondent has distributed or caused to be distributed certain of its Challenger sockets, combination wrenches, open end wrenches, box end wrenches, flare nut wrenches, and cold chisels marked with the following statement:

"U.S.A."

Master Mechanic Mechanics Tools

12. Respondent has disseminated or has caused to be disseminated certain of its Master Mechanic combination wrenches, sockets, and socket sets with labeling or other promotional materials that contain the following statement:

"Made in U.S.A."

13. Respondent has disseminated or has caused to be disseminated certain of its Master Mechanic combination wrench sets and socket sets with packaging, labeling, or other promotional materials that contain the following statement and depiction:

"Made in U.S.A." next to an American flag.

14. Respondent has distributed or caused to be distributed certain of its Master Mechanic combination wrenches, flex handles, and sockets marked with the following statement:

"U.S.A."

Stanley Mechanics Tools

15. Respondent has distributed or caused to be distributed packaging, labeling, or other promotional materials for certain of its Stanley combination wrenches, box end wrenches, open end wrenches, ratchets, combination wrench sets, and socket sets that contain the following statements or depictions:

"Made in U.S.A.";

"U.S.A.";

"Tools made in U.S.A. Case made in Taiwan.";

A logo consisting of an eagle head on an American flag and the words "Made in U.S.A.";

Photographs of combination wrench sets and an open end wrench set with "Made in U.S.A." on their packaging; or

A silhouette of the United States showing Stanley plant locations.

16. Respondent has distributed or caused to be distributed certain of its Stanley combination wrenches, open end wrenches, and box end wrenches marked with the following statement:

"U.S.A."

Caterpillar Mechanics Tools

17. Respondent has distributed or caused to be distributed certain combination wrenches and cold chisels that it manufactures for Caterpillar marked with the following statement:

"U.S.A."

John Deere Mechanics Tools

18. Respondent has distributed or caused to be distributed certain combination wrenches and sockets that it manufactures for John Deere marked with the following statement:

"U.S.A."

Martin Mechanics Tools

19. Respondent has distributed or caused to be distributed certain ratchets, flex handles, and sockets that it manufactures for Martin marked with the following statement:

"U.S.A."

Wilde Mechanics Tools

20. Respondent has distributed or caused to be distributed certain sockets that it manufactures for Wilde marked with the following statement:

"U.S.A."

21. Through the means described in Paragraphs 4 through 20, respondent has represented, expressly or by implication, that certain of its mechanics tools are made in the United States, i.e., that all, or virtually all, of the component parts of such mechanics tools are made in the United States, and that all, or virtually all, of the labor in manufacturing such mechanics tools is performed in the United States.

22. In truth and in fact, a significant portion of the components of certain of respondent’s mechanics tools is, or has been, of foreign origin. Therefore, the representation set forth in Paragraph 21 was, and is, false or misleading.

23. The acts and practices of respondent as alleged in this complaint constitute unfair or deceptive acts or practices in or affecting commerce in violation of Section 5(a) of the Federal Trade Commission Act.

THEREFORE, the Federal Trade Commission this __ day of __________ , , has issued this complaint against respondent.

By the Commission.

Donald S. Clark
Secretary

SEAL: