Page 1 of 2 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

April 16, 2019 

Concerned Citizens 

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

 In the Matter of Underground Sports Inc., d/b/a Patriot Puck; Hockey Underground Inc., 

d/b/a Patriot Puck; Ipuck Inc., d/b/a Patriot Puck; IPuck Hockey Inc., d/b/a Patriot 

Puck; and George Statler III, Matter No. 1823113, C-4674

Dear Concerned Citizens: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreements in the above-referenced proceedings. The Commission has considered your 

comments and placed them on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comments, you stated that the Commission should impose tougher rules and 

penalties on companies that knowingly make deceptive “Made in USA” claims. 

The above-referenced proceedings are administrative settlements. The FTC Act does not 

allow the agency to obtain fines or a litigated judgment for consumer redress in administrative 

litigation.1 Our primary goal in cases such as these is to stop deceptive advertising by putting the 

Respondents under order. If, in the future, Respondents violate their orders, the Federal Trade 

Commission could pursue civil penalties of up to $42,530 per violation. 

Administrative consent orders securing at least 20 years of conduct relief buttressed by 

the threat of significant penalties have been largely successful in keeping companies under order 

from making deceptive “Made in USA” claims. To date, the FTC has only had cause to initiate 

two civil penalty order enforcement proceedings against the more than twenty prior respondents 

in cases involving U.S.-origin claims.2

 

 

1 Fines are similarly unavailable as a remedy in federal court actions, although Section 13(b) of 

the FTC Act allows the FTC to pursue monetary equitable relief in addition to prohibitory relief 

in that venue. 

2 See https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systemspay-110000-civil-penalty (announcing settlement with iSpring that imposed a $110,000 civil 

penalty for violating prior order regarding U.S.-origin claims); https://www.ftc.gov/newsevents/press-releases/2006/06/ftc-alleges-stanley-made-false-made-usa-claims-about-its-tools 

(announcing settlement with Stanley Works that imposed a $205,000 civil penalty for violating 

prior order regarding U.S.-origin claims).
Page 2 of 2

However, as noted in Commissioner Slaughter’s and Chairman Simons’s statement

issued in conjunction with the announcement of the above-referenced proceedings, the 

Commission agrees there may be cases where it can further maximize its enforcement reach 

through strategic use of additional remedies. For example, there may be cases in which 

consumers paid a clear premium for a product marketed as “Made in USA” or made their 

purchasing decision in part based on perceived quality, safety, health or environmental benefits 

tied to a U.S.-origin claim. In such instances, additional remedies such as monetary relief or 

notice to consumers may be warranted. Requiring law violators to provide notice to consumers 

identifying the deceptive claim can help mitigate individual consumer injury—an informed 

consumer would have the option to seek a refund, or, at the very least, stop using the product.

Although the Commission’s review of available remedies is ongoing, we have 

determined that a forward-looking plan is a more effective and efficient use of Commission 

resources than re-opening and re-litigating the above-referenced proceedings, which began well 

before the current complement of Commissioners were instated. Therefore, after considering 

your comments, the Commission has determined that the relief set forth in the draft Decisions

and Orders is appropriate and sufficient to remedy the violations alleged in the complaints.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decisions and Orders in final form without modification. The final Decisions and 

Orders and other relevant materials are available on the Commission’s website at 

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

work, and we thank you again for your comments.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary
 

Page 1 of 3 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

April 16, 2019 

Consumers Union 

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

 In the Matter of Underground Sports Inc., d/b/a Patriot Puck; Hockey Underground Inc., 

d/b/a Patriot Puck; Ipuck Inc., d/b/a Patriot Puck; IPuck Hockey Inc., d/b/a Patriot 

Puck; and George Statler III, Matter No. 1823113, C-4674

Dear Mr. Brookman: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreements in the above-referenced proceedings. The Commission has considered your 

comments and placed them on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comments, you expressed concern that the Commission’s approach in the abovereferenced proceedings is too lenient to deter deceptive “Made in USA” claims in the 

marketplace. Accordingly, you stated that the Commission should reconsider the pending 

settlements and incorporate additional remedies, including monetary damages and notice to 

consumers. 

The above-referenced proceedings are administrative settlements. The FTC Act does not 

allow the agency to obtain fines or a litigated judgment for consumer redress in administrative 

litigation.1 Our primary goal in cases such as these is to stop deceptive advertising by putting the 

Respondents under order. If, in the future, Respondents violate their orders, the Federal Trade

Commission could pursue civil penalties of up to $42,530 per violation. 

Administrative consent orders securing at least 20 years of conduct relief buttressed by 

the threat of significant penalties have been largely successful in keeping companies under order 

from making deceptive “Made in USA” claims. To date, the FTC has only had cause to initiate 

two civil penalty order enforcement proceedings against the more than twenty prior respondents 

 

1 Fines are similarly unavailable as a remedy in federal court actions, although Section 13(b) of 

the FTC Act allows the FTC to pursue monetary equitable relief in addition to prohibitory relief 

in that venue. 
Page 2 of 3

in cases involving U.S.-origin claims.2 

The Decisions and Orders in these matters strike a careful balance between addressing 

the deceptive conduct alleged in the Complaints without constraining non-deceptive claims or 

imposing undue burden. Notably, these cases do not involve significant consequential damages 

to consumers. The particular products at issue—hockey pucks, backpacks, and wallets—

function as advertised, and consumers do not incur additional costs to use or return these 

particular products. Accordingly, standard dissemination of the Decisions and Orders through 

the Commission’s usual channels—including publication on the website, notices in the Federal 

Register, blog posts, and social media posts—should sufficiently put consumers on notice of 

these actions.

3

You correctly note that the Commission has the legal authority to seek restitution in the 

first instance in federal court pursuant to Section 13(b) of the FTC Act, and that the Commission 

need not demonstrate that consumers paid a price premium to seek such a remedy. The 

statement issued by Commissioner Slaughter and Chairman Simons in conjunction with the 

announcement of the above-referenced proceedings does not argue that the Commission must 

make such a showing. Rather, the statement suggests that, as the Commission reviews “Made in 

USA” matters going forward, whether consumers paid a price premium or based their purchasing 

decision on health or safety concerns might be important factors for the Commission to take into 

account when determining the appropriate remedies to pursue for a particular case. 

Although the Commission’s review of available remedies is ongoing, we have 

determined that a forward-looking plan is a more effective and efficient use of Commission 

resources than re-opening and re-litigating the above-referenced proceedings, which began well 

before the current complement of Commissioners were instated. Therefore, after considering 

your comments, the Commission has determined that the relief set forth in the draft Decisions

and Orders is appropriate and sufficient to remedy the violations alleged in the complaints.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decisions and Orders in final form without modification. The final Decisions and 

Orders and other relevant materials are available on the Commission’s website at 

 2 See https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systemspay-110000-civil-penalty (announcing settlement with iSpring that imposed a $110,000 civil 

penalty for violating prior order regarding U.S.-origin claims); https://www.ftc.gov/newsevents/press-releases/2006/06/ftc-alleges-stanley-made-false-made-usa-claims-about-its-tools 

(announcing settlement with Stanley Works that imposed a $205,000 civil penalty for violating 

prior order regarding U.S.-origin claims).

3 In contrast, the Commission determined that a consumer notice provision was appropriate in the 

recently-settled iSpring matter, which involved a company that reverted to making false U.S.-

origin claims for water filtration systems in violation of a previous FTC order. See 

https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systems-pay110000-civil-penalty.
Page 3 of 3

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

work, and we thank you again for your comments.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary
 

Page 1 of 3 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

 

 

 April 16, 2019 

Mr. Alan Wachs

Smith, Gambrell & Russell, LLP

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

Dear Mr. Wachs: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreement in the above-referenced proceeding. The Commission has considered your comment 

and placed it on the public record pursuant to Rule 4.9(b)(6)(ii) of the Commission’s Rules of 

Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comment, you stated that your client was harmed by the conduct alleged in the 

Commission’s complaint. Accordingly, you requested that the Commission reopen the 

proceeding to require: (1) an admission of liability; and (2) one year of corrective advertising. 

The Commission carefully considers the facts of each case in determining whether an 

admission is appropriate. Although the Commission has very rarely required first-time offenders 

to admit liability, we regularly pursue such relief in conjunction with contempt actions. Agency 

regulations specifically contemplate settlements stating that respondents neither admit nor deny 

liability. See 16 CFR § 2.32 (stating that consent agreements “may state that the signing thereof 

is for settlement purposes only and does not constitute an admission by any party that the law has 

been violated as alleged in the complaint”). Consistent with these regulations, the consent 

agreement with Respondents included this language. 

Administrative consent orders containing this language and securing at least 20 years of 

conduct relief buttressed by the threat of significant penalties have been largely successful in 

keeping companies under order from making deceptive “Made in USA” claims. To date, the 

FTC has only had cause to initiate two civil penalty order enforcement proceedings against the 

more than twenty prior respondents in cases involving U.S.-origin claims.1

 

 

1 See https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systemspay-110000-civil-penalty (announcing settlement with iSpring that imposed a $110,000 civil 

penalty for violating prior order regarding U.S.-origin claims); https://www.ftc.gov/newsevents/press-releases/2006/06/ftc-alleges-stanley-made-false-made-usa-claims-about-its-tools 
Page 2 of 3

The Decision and Order in this matter strikes a careful balance between addressing the 

deceptive conduct alleged in the Complaint without constraining non-deceptive claims or 

imposing undue burden. Notably, this case does not involve significant consequential damages 

to consumers. The particular products at issue—backpacks and wallets—function as advertised, 

and consumers do not incur additional costs to use or return these particular products. 

Accordingly, standard dissemination of the Decision and Order through the Commission’s usual 

channels—including publication on the Commission’s website, notices in the Federal Register, 

blog posts, and social media posts—should sufficiently put consumers on notice of this action.

2

However, as noted in Commissioner Slaughter’s and Chairman Simons’s statement

issued in conjunction with the announcement of the above-referenced proceeding, the 

Commission agrees there may be cases where it can further maximize its enforcement reach 

through strategic use of additional remedies. For example, there may be cases in which 

consumers paid a clear premium for a product marketed as “Made in USA” or made their 

purchasing decision in part based on perceived quality, safety, health or environmental benefits 

tied to a U.S.-origin claim. In such instances, additional remedies such as monetary relief or 

notice to consumers may be warranted. Requiring law violators to provide notice to consumers 

identifying the deceptive claim can help mitigate individual consumer injury—an informed 

consumer would have the option to seek a refund, or, at the very least, stop using the product. 

Furthermore, if the Commission determines that merely prohibiting future misrepresentations 

would not dispel misperceptions conveyed through prior misrepresentations, the FTC may order 

corrective advertising, as you propose. See Warner-Lambert Co. v. FTC, 562 F.2d 749 (D.C. 

Cir. 1977). 

Although the Commission’s review of available remedies is ongoing, we have 

determined that a forward-looking plan is a more effective and efficient use of Commission 

resources than re-opening and re-litigating the above-referenced proceeding, which began well 

before the current complement of Commissioners were instated. Therefore, after considering 

your comment, the Commission has determined that the relief set forth in the draft Decision and 

Order is appropriate and sufficient to remedy the violations alleged in the complaints.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decision and Order in final form without modification. The final Decision and 

Order and other relevant materials are available on the Commission’s website at 

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

 

(announcing settlement with Stanley Works that imposed a $205,000 civil penalty for violating 

prior order regarding U.S.-origin claims).

2 In contrast, the Commission determined that a consumer notice provision was appropriate in the 

recently-settled iSpring matter, which involved a company that reverted to making false U.S.-

origin claims for water filtration systems in violation of a previous FTC order. See 

https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systems-pay110000-civil-penalty.
Page 3 of 3

work, and we thank you again for your comment.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary
 

Page 1 of 2 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

April 16, 2019 

Mr. Max Parker

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

Dear Mr. Parker: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreement in the above-referenced proceeding. The Commission has considered your comment 

and placed it on the public record pursuant to Rule 4.9(b)(6)(ii) of the Commission’s Rules of 

Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comment, you question whether Respondents comply with the Berry 

Amendment, 10 U.S.C. § 2533a, to the extent that they sell products to the Department of 

Defense (“DoD”). You also raise concerns that Respondents may be violating their order. 

The FTC regulates claims of U.S. origin under its general authority to act against 

deceptive acts and practices. Marketers seeking to use U.S.-origin claims to sell their products to 

consumers must comply with Section 5 of the FTC Act, which requires companies to possess 

substantiation for their marketing claims. The Berry Amendment does not cover business to 

consumer or business to business transactions. Instead, it relates specifically to, and applies 

standards that apply only to, country-of-origin claims used in DoD procurement and contracting 

processes. Compliance with the Berry Amendment is therefore outside the scope of the FTC’s 

enforcement authority and, accordingly, the above-referenced proceeding. Questions and 

concerns about the Berry Amendment should be directed to the DoD.

The FTC’s Bureau of Consumer Protection Enforcement Division routinely monitors 

order compliance. The Division assigns experienced compliance attorneys to each completed 

case. They are responsible for ensuring that Respondents file timely compliance reports. With 

that information in hand, they evaluate the reports and conduct compliance reviews to make sure 

the order is having its intended effect. If a report leaves them with questions, they follow up 

with the Respondents for more information. Sometimes the result is a full investigation of 

possible order violations. Administrative consent orders securing at least 20 years of conduct 

relief buttressed by the threat of significant penalties have been largely successful in keeping 

companies under order from making deceptive “Made in USA” claims. If, in the future, 

however, the Enforcement Division determines that Respondents have violated their order, the 
Page 2 of 2

Federal Trade Commission could pursue civil penalties of up to $42,530 per violation.

Your comment does not propose any revisions to the draft Complaint or Decision and 

Order. Therefore, after considering your comment, the Commission has determined that the 

relief set forth in the draft Decision and Order is appropriate and sufficient to remedy the 

violations alleged in the complaint.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decision and Order in final form without modification. The final Decision and 

Order and other relevant materials are available on the Commission’s website at 

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

work, and we thank you again for your comment.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary
 

Page 1 of 2 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

April 16, 2019 

Mr. Raphael Wakefield

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

Dear Mr. Wakefield: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreement in the above-referenced proceeding. The Commission has considered your comment 

and placed it on the public record pursuant to Rule 4.9(b)(6)(ii) of the Commission’s Rules of 

Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comment, you stated that the above-referenced proceeding should be reopened to 

include a substantial financial penalty. 

The above-referenced proceeding is an administrative settlement. The FTC Act does not 

allow the agency to obtain fines or a litigated judgment for consumer redress in administrative 

litigation.1

 Our primary goal in cases such as this one is to stop deceptive advertising by putting 

the Respondents under order. If, in the future, Respondents violate their order, the Federal Trade 

Commission could pursue civil penalties of up to $42,530 per violation. 

Administrative consent orders securing at least 20 years of conduct relief buttressed by 

the threat of significant penalties have been largely successful in keeping companies under order 

from making deceptive “Made in USA” claims. To date, the FTC has only had cause to initiate 

two civil penalty order enforcement proceedings against the more than twenty prior respondents 

in cases involving U.S.-origin claims.2

 

 

1 Fines are similarly unavailable as a remedy in federal court actions, although Section 13(b) of 

the FTC Act allows the FTC to pursue monetary equitable relief in addition to prohibitory relief 

in that venue. 

2 See https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systemspay-110000-civil-penalty (announcing settlement with iSpring that imposed a $110,000 civil 

penalty for violating prior order regarding U.S.-origin claims); https://www.ftc.gov/newsevents/press-releases/2006/06/ftc-alleges-stanley-made-false-made-usa-claims-about-its-tools 

(announcing settlement with Stanley Works that imposed a $205,000 civil penalty for violating 

prior order regarding U.S.-origin claims).
Page 2 of 2

However, as noted in Commissioner Slaughter’s and Chairman Simons’s statement

issued in conjunction with the announcement of the above-referenced proceeding, the 

Commission agrees there may be cases where it can further maximize its enforcement reach 

through strategic use of additional remedies. For example, there may be cases in which 

consumers paid a clear premium for a product marketed as “Made in USA” or made their 

purchasing decision in part based on perceived quality, safety, health or environmental benefits 

tied to a U.S.-origin claim. In such instances, additional remedies such as monetary relief or 

notice to consumers may be warranted. Requiring law violators to provide notice to consumers 

identifying the deceptive claim can help mitigate individual consumer injury—an informed 

consumer would have the option to seek a refund, or, at the very least, stop using the product.

Although the Commission’s review of available remedies is ongoing, we have 

determined that a forward-looking plan is a more effective and efficient use of Commission 

resources than re-opening and re-litigating the above-referenced proceeding, which began well 

before the current complement of Commissioners were instated. Therefore, after considering 

your comment, the Commission has determined that the relief set forth in the draft Decision and 

Order is appropriate and sufficient to remedy the violations alleged in the complaints.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decision and Order in final form without modification. The final Decision and 

Order and other relevant materials are available on the Commission’s website at 

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

work, and we thank you again for your comment.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary
 

Page 1 of 2 

UNITED STATES OF AMERICA

FEDERAL TRADE COMMISSION

WASHINGTON, D.C. 20580

Office of the Secretary

April 16, 2019 

Senators Brown, Baldwin, and Murphy 

RE: In the Matter of Sandpiper of California, Inc. and PiperGear USA, Inc., 

Matter No. 1823095, C-4675 

In the Matter of Underground Sports Inc., d/b/a Patriot Puck; Hockey Underground Inc., 

d/b/a Patriot Puck; Ipuck Inc., d/b/a Patriot Puck; IPuck Hockey Inc., d/b/a Patriot 

Puck; and George Statler III, Matter No. 1823113, C-4674

Dear Senators: 

Thank you for commenting on the Federal Trade Commission’s proposed consent 

agreements in the above-referenced proceedings. The Commission has considered your 

comments and placed them on the public record pursuant to Rule 4.9(b)(6)(ii) of the 

Commission’s Rules of Practice, 16 C.F.R. § 4.9(b)(6)(ii).

In your comments, you expressed concern that the Commission’s approach in the abovereferenced proceedings neither adequately penalizes the Respondents in these matters, nor is 

likely to deter other companies from making deceptive “Made in USA” claims in the 

marketplace. Accordingly, you stated that the Commission should use its full authority pursuant 

to Section 5 of the FTC Act to incorporate additional remedies into the settlements, including 

monetary damages and compelled admissions. 

The above-referenced proceedings are administrative settlements. The FTC Act does not 

allow the agency to obtain fines or a litigated judgment for consumer redress in administrative 

litigation.

1

 Our primary goal in cases such as these is to stop deceptive advertising by putting the 

Respondents under order. If, in the future, Respondents violate their orders, the Federal Trade 

Commission could pursue civil penalties of up to $42,530 per violation. 

The Commission carefully considers the facts of each case in determining whether an 

admission is appropriate. Although the Commission has very rarely required first-time offenders 

to admit liability, we regularly pursue such relief in conjunction with contempt actions. Agency 

regulations specifically contemplate settlements stating that respondents neither admit nor deny 

liability. See 16 CFR § 2.32 (stating that consent agreements “may state that the signing thereof 

is for settlement purposes only and does not constitute an admission by any party that the law has 

been violated as alleged in the complaint”). Consistent with these regulations, the consent 

 

1 Fines are similarly unavailable as a remedy in federal court actions, although Section 13(b) of 

the FTC Act allows the FTC to pursue monetary equitable relief in addition to prohibitory relief 

in that venue. 
Page 2 of 2

agreement with Respondents included this language.

Administrative consent orders containing this language and securing at least 20 years of 

conduct relief buttressed by the threat of significant penalties have been largely successful in 

keeping companies under order from making deceptive “Made in USA” claims. To date, the 

FTC has only had cause to initiate two civil penalty order enforcement proceedings against the 

more than twenty prior respondents in cases involving U.S.-origin claims.2

 

However, as noted in Commissioner Slaughter’s and Chairman Simons’s statement

issued in conjunction with the announcement of the above-referenced proceedings, the 

Commission agrees there may be cases where it can further maximize its enforcement reach 

through strategic use of additional remedies. For example, there may be cases in which 

consumers paid a clear premium for a product marketed as “Made in USA” or made their 

purchasing decision in part based on perceived quality, safety, health or environmental benefits 

tied to a U.S.-origin claim. In such instances, using the federal court forum to pursue additional 

remedies such as monetary relief or notice to consumers may be warranted. Requiring law 

violators to provide notice to consumers identifying the deceptive claim can help mitigate 

individual consumer injury—an informed consumer would have the option to seek a refund, or, 

at the very least, stop using the product.

Although the Commission’s review of available remedies is ongoing, we have 

determined that a forward-looking plan is a more effective and efficient use of Commission 

resources than re-opening and re-litigating the above-referenced proceeding, which began well 

before the current complement of Commissioners were instated. Therefore, after considering 

your comments, the Commission has determined that the relief set forth in the draft Decision and 

Order is appropriate and sufficient to remedy the violations alleged in the complaint.

At this time, the Commission has determined that the public interest would best be served 

by issuing the Decision and Order in final form without modification. The final Decision and 

Order and other relevant materials are available on the Commission’s website at 

http://www.ftc.gov. It helps the Commission’s analysis to hear from a variety of sources in its 

work, and we thank you again for your comments.

By direction of the Commission, Commissioners Slaughter and Chopra dissenting.

April J. Tabor

Acting Secretary

 2 See https://www.ftc.gov/news-events/press-releases/2019/04/marketer-water-filtration-systemspay-110000-civil-penalty (announcing settlement with iSpring that imposed a $110,000 civil 

penalty for violating prior order regarding U.S.-origin claims); https://www.ftc.gov/newsevents/press-releases/2006/06/ftc-alleges-stanley-made-false-made-usa-claims-about-its-tools 

(announcing settlement with Stanley Works that imposed a $205,000 civil penalty for violating 

prior order regarding U.S.-origin claims).