9823588

UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION

In the Matter of

THE WIRE WORKS, INC., and ELECTRODES, INC., corporations.

DOCKET NO. C-3908

COMPLAINT

The Federal Trade Commission, having reason to believe that The Wire Works, Inc., and Electrodes, Inc., corporations ("respondents"), have 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 Wire Works, Inc. is a Connecticut corporation with its principal office or place of business at 252 Depot Road, Milford, Connecticut.

2. Respondent Electrodes, Inc. is a Connecticut corporation with its principal office or place of business at 252 Depot Road, Milford, Connecticut. Electrodes, Inc. is the exclusive distributor for The Wire Works, Inc.

3. Respondents have manufactured, advertised, labeled, offered for sale, sold, and/or distributed products to the public, including drawn brass wire sold as electrical discharge machining ("EDM") wire electrodes.

4. The acts and practices of respondents alleged in this complaint have been in or affecting commerce, as "commerce" is defined in Section 4 of the Federal Trade Commission Act.

5. Respondents have disseminated or have caused to be disseminated advertisements and labels for their EDM wire electrodes product, including but not necessarily limited to the attached Exhibits A and B. These advertisements and labels contain the following statements:

A. "[M]anufactured right here in the USA" (Exhibit A); and

B. "Made in USA" (Exhibit B).

6. Through the means described in Paragraph 5, respondents have represented, expressly or by implication, that their EDM wire electrodes product is made in the United States, i.e., that all, or virtually all, of the components of their EDM wire electrodes product are of U.S. origin, and that all, or virtually all, of the labor in manufacturing their EDM wire electrodes product is performed in the United States.

7. In truth and in fact, a substantial portion of the components in their EDM wire electrodes product is, or has been, of foreign origin, and a substantial amount of the labor in manufacturing the EDM wire electrodes product is, or has been, performed in Mexico. Therefore, the representations set forth in Paragraph 6 were, and are, false or misleading.

8. The acts and practices of respondents 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 sixth day of December, 1999, has issued this complaint against respondents.

By the Commission, Commission Leary not participating.

Benjamin I. Berman
Acting Secretary

SEAL: