172 3197 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Maureen K. Ohlhausen, Acting Chairman 

Terrell McSweeny 

In the Matter of ) 

) 

BOLLMAN HAT COMPANY, a company, ) 

and ) DOCKET NO. C-

) 

SAVEANAMERICANJOB, LLC, a limited ) 

liability company, ) 

) 

jointly d/b/a AMERICAN MADE MATTERS. ) 

) 

COMPLAINT 

The Federal Trade Commission, having reason to believe that Bollman Hat Company, a 

company, and SaveAnAmericanJob, LLC, a limited liability company, jointly d/b/a American 

Made Matters (collectively, “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 Bollman Hat Company is a Pennsylvania company with its principal office 

or place of business at 110 East Main Street, Adamstown, Pennsylvania 19501. 

2. Respondent SaveAnAmericanJob, LLC is a Pennsylvania limited liability company with 

its principal office or place of business at 110 East Main Street, Adamstown, Pennsylvania 

19501. SaveAnAmericanJob, LLC is a wholly owned subsidiary of Bollman Hat Company, and 

Bollman Hat Company is SaveAnAmericanJob, LLC’s sole member. 

3. Bollman Hat Company and SaveAnAmericanJob, LLC (collectively, “Respondents”) 

jointly do business as American Made Matters, a Pennsylvania fictitious name. Respondents 

have operated as a common enterprise while engaging in the unlawful acts and practices alleged 

below. Because Respondents have operated as a common enterprise, each of them is jointly and 

severally liable for the acts and practices alleged below. 

4. Respondents have advertised, labeled, offered for sale, sold, and distributed products to 

consumers, including, but not limited to, hats sold under the Bollman, Bailey Western, Betmar, 

Country Gentleman, Eddy Bros., Helen Kaminski, Jacaru, Kaminski XY, Kangol, Karen Kane, 

Pantropic, and private label brand names. Respondents advertise these products online, 
 

 

 

 

 

 

 

 

 

 

 

 

 

including, but not limited to, on their website, hats.com, and in stores. Respondents offer for 

sale, sell, and distribute their products throughout the United States. 

5. Respondents have advertised, offered for sale, sold, and distributed memberships in their 

“American Made Matters” program to companies wishing to make U.S.-origin claims for their 

products. Respondents primarily advertise their “American Made Matters” program to 

businesses online including, but not limited to, on their website americanmadematters.com, and 

through their social media accounts. Respondents primarily advertise their “American Made 

Matters” program members’ products to consumers online, including, but not limited to, through 

their website and social media accounts. 

6. 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. 

“Made in USA” Claims for Bollman Hats 

7. Respondents have disseminated or have caused to be disseminated advertisements and 

promotional materials for their products, including, but not necessarily limited to, the attached 

Exhibits A-E. These materials contain the following statements, among others: 

A. “American Made Matters”; “Choose American” (Exhibit A, product tag); 

B. “Buy American! American Made Matters Choose American” (Exhibit B, 

Bollman website); 

C. “American Made Matters”; “Choose American” (Exhibit C, Bollman 

website); 

D. “Made in USA since 1868”; “Made in the USA for 100 Years or More”; 

“‘Made in USA’ hats for 147 years and counting” (Exhibit D, Bollman 

Twitter page); 

E. “#americanmadematters #madeintheusa #buyamerican” (Exhibit E, Bollman 

Facebook page). 

8. In numerous instances, including, but not limited to, the promotional materials shown in 

Exhibits A-E, Respondents have represented, expressly or by implication, that all of their 

products, including, but not limited to, hats, are all or virtually all made in the United States. 

9. In fact, more than 70% of the hat styles Respondents sell are wholly imported as finished 

products. Of the remaining styles, many contain significant imported content. 

10. Therefore, Respondents’ express or implied representations that all of their products are 

made in the United States are false. 

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American Made Matters Program 

11. In 2010, Respondents introduced a U.S.-origin seal for marketers to use to boost the 

credibility of “Made in USA” claims. The seal, depicted below, is associated with “American 

Made Matters,” which is a fictitious name registered to Respondents (“AMM”): 

12. In numerous instances, including, but not limited to, the promotional materials shown in 

Exhibits A-E, Respondents have prominently displayed the American Made Matters seal in their 

promotional materials. This seal represents by implication that Respondents’ hats have been 

endorsed or certified by an independent third party. 

13. In fact, AMM is a fictitious name owned by Respondents, and Respondents’ hats have 

not been endorsed or certified by an independent third party. 

14. In addition to featuring the seal in their own marketing materials, Respondents license 

use of the seal to other companies wishing to make “Made in USA” claims for their products. 

15. Companies that wish to use the AMM seal must apply for program membership through 

Respondents’ website at www.americanmadematters.com. Respondents grant AMM 

membership to any company, product, or entity that self-certifies it meets Respondents’ 

membership standard, pays the $99 annual licensing fee, and self-identifies either a United 

States-based manufacturing factory, or at least one product with a U.S.-origin label. 

16. AMM membership includes a license to use Respondents’ seal on products and in 

marketing materials, a member page on Respondents’ website, and Respondents’ commitment to 

advertise the member’s products as “Made in USA” through their websites and social media 

channels. 

17. To meet Respondents’ standard, AMM members must certify that at least 50% of the cost 

of at least one of their products was incurred in the United States, with final assembly or 

transformation in the United States. Respondents do not rely on an independent or objective 

evaluation to confirm that members meet their standard. 

18. Respondents have disseminated, or have caused to be disseminated, advertisements and 

promotional materials for AMM, as well as materials for members to use to promote their 

products as made in the United States including, but not necessarily limited to, the attached 

Exhibits F-L. These materials contain the following statements, among others: 

A. With an American Made Matters Membership/Sponsorship, “You will 

increase sales to consumers and businesses who are actively looking to 

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buy American Made Products” (Exhibit F, American Made Matters 

Website); 

B. “Does your business produce or sell #MadeinUSA products? Increase 

your reach with us.” (Exhibit G, American Made Matters Twitter page); 

C. “American Made Matters® is an organization made of over 375 member 

and sponsor companies. Our members are manufacturers who represent 

various industries from apparel and toys to steel fabrication and cleaning 

supplies. Sponsors include American made retailers, patriotic 

organizations and local businesses who understand that American made 

truly matters.” (Exhibit H, American Made Matters website); 

D. “Shop as a consumer . . . for consumers looking to shop for American 

made products directly from our members and sponsors.” (Exhibit I, 

American Made Matters website); 

E. “American Made Directories” (Exhibit J, American Made Matters 

website); 

F. “#MadeinUSA”; “Buy American”; “Made in USA”; “Start your American 

Made product search with American Made Matters”; “Choose 

#AmericanMade whenever possible. Start your search for #madeinUSA 

products with us.” (Exhibit K, American Made Matters Facebook page); 

G. “Support the #AmericanDream. How? By buying #AmericanMade 

products! AmericanMadeMatters.com” (Exhibit L, American Made 

Matters Twitter page). 

19. In numerous instances, including, but not limited to, the promotional materials shown in 

Exhibits F-L, Respondents have represented by implication that entities and products using 

AMM marketing materials or featured on the AMM website have been independently and 

objectively evaluated for compliance with Respondents’ membership standard. 

20. In fact, entities and products using Respondents’ AMM logo or marketing materials have 

not been independently and objectively evaluated for compliance with any standard. 

21. In numerous instances, including, but not limited to, the promotional materials shown in 

Exhibits F-L, Respondents have represented that products sold by American Made Matters 

members are all or virtually all made in the United States. For example, Respondents promote a 

directory of members on their AMM website as a list of manufacturers selling U.S.-origin 

products, and regularly highlight members on their social media channels as selling U.S.-origin 

products. 

22. In fact, Respondents do not possess a reasonable basis substantiating claims that products 

sold by American Made Matters members are all or virtually all made in the United States. 

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23. In numerous instances, including, but not limited, to the promotional materials shown in 

Exhibits G-L, Respondents have distributed promotional materials to third-party marketers for 

use in the marketing and sale of those third parties’ products. 

24. In so doing, Respondents have provided third-party marketers with the means and 

instrumentalities to deceive consumers. For example, several of Respondents’ members have 

used Respondents’ AMM logo or other materials to promote products that contain significant 

imported content. 

COUNT I 

(False or Unsubstantiated Representation – Respondents’ Products) 

25. In connection with the manufacturing, labeling, advertising, promotion, offering for sale, 

sale, or distribution of their products, Respondents have represented, directly or indirectly, 

expressly or by implication, that all of their products, including, but not limited to, all hats, are 

all or virtually all made in the United States. 

26. In fact, in many instances, Respondents’ products are wholly imported. In other 

instances, Respondents source significant inputs to their products from overseas. Therefore, the 

representation set forth in Paragraph 25 is false or misleading, or was not substantiated at the 

time the representation was made. 

COUNT II 

(False or Misleading Representation – Independence of AMM) 

27. In connection with the labeling, advertising, promotion, offering for sale, or sale of their 

hats, such as through the use of their American Made Matters seal, Respondents have 

represented, directly or indirectly, expressly or by implication, through the use of the American 

Made Matters seal that an independent organization has reviewed and endorsed their products as 

Made in the United States. 

28. In truth and in fact, American Made Matters is not an independent organization reviewing 

and endorsing Respondents’ products as Made in the United States. Respondents created the 

“American Made Matters” seal, and use it in connection with the labeling, advertising, 

promotion, offering for sale, and sale of their own products. Therefore, the representation set 

forth in Paragraph 27 is false or misleading. 

COUNT III 

(False or Misleading Representation – AMM) 

29. In connection with the advertising, promotion, offering for sale, or sale of membership to 

the American Made Matters program, Respondents have represented by implication, directly or 

indirectly, that each entity or product licensed to use their logos or marketing materials has been 

independently and objectively evaluated for compliance with Respondents’ membership 

standard. 

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30. In fact, products and entities using Respondents’ membership logo have not been 

independently and objectively evaluated for compliance with Respondents’ membership 

standard. Therefore, the representation set forth in Paragraph 29 is false or misleading. 

COUNT IV 

(False or Unsubstantiated Representation – Third Party Products) 

31. Respondents have represented on their websites and social media, directly or indirectly, 

expressly or by implication, that all AMM members sell products that are all or virtually all 

made in the United States. 

32. In truth and in fact, in numerous instances, the representation in Paragraph 31 was false 

or misleading, or was not substantiated at the time the representation was made. 

COUNT V 

(Means and Instrumentalities) 

33. Respondents have distributed the promotional materials described in Paragraph 18 to 

third-party marketers for use in the marketing and sale of those third parties’ products. In so 

doing, Respondents have provided the means and instrumentalities to these third-party marketers 

for the commission of deceptive acts or practices. 

VIOLATION OF SECTION 5 

34. 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 _______ day of _______, 2018, has 

issued this Complaint against Respondents. 

By the Commission. 

Donald S. Clark 

Secretary 

SEAL: 

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