2223096 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Lina M. Khan, Chair 

Rebecca Kelly Slaughter 

Christine S. Wilson 

Alvaro M. Bedoya 

In the Matter of 

ELECTROWARMTH PRODUCTS, LLC, 

a limited liability company, and DOCKET NO. C-4779

DANIEL W. GRINDLE, individually and as an 

officer of ELECTROWARMTH 

PRODUCTS, LLC. 

COMPLAINT 

The Federal Trade Commission, having reason to believe that Electrowarmth Products, 

LLC, a limited liability company, and Daniel W. Grindle, individually and as an officer of 

Electrowarmth Products, LLC (collectively, “Respondents”), have violated the provisions of the 

Textile Fiber Products Identification Act, the Textile Fiber Rule, and the Federal Trade 

Commission Act, and it appearing to the Commission that this proceeding is in the public 

interest, alleges: 

1. Respondent Electrowarmth Products, LLC (“Electrowarmth”), also doing business as 

ElectroWarmth or Electro-Warmth, is an Ohio limited liability company with its principal office 

or place of business at 513 South Market Street, Danville, Ohio 43014. 

2. Respondent Daniel W. Grindle (“Grindle”) is Electrowarmth’s Owner and President. 

Individually or in concert with others, he controlled, had the authority to control, or participated 

in the acts and practices of Electrowarmth, including the acts and practices alleged in this 

Complaint. His principal office or place of business is the same as that of Electrowarmth. 

3. Respondents have manufactured, advertised, labeled, offered for sale, sold, and 

distributed textile fiber products to consumers, including heated “bunk warmer” mattress pads 

for truck bunks, and other bedding. 

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. 
Respondents’ Business Practices 

5. Respondent Grindle incorporated Electrowarmth in 2010. Electrowarmth is a successor 

to and owns all assets of two now-defunct entities that sold bedding products since 1939. 

6. Electrowarmth currently sells fabric mattress pads of varying sizes and dimensions with 

built-in heating wires designed to warm pads to the operator’s desired temperature. The wires 

are controlled by attached thermostats. Electrowarmth’s pads come in various sizes to fit truck 

bunk mattresses (the “bunk warmer” products), residential mattresses, and massage tables. 

7. Respondent Grindle is Electrowarmth’s sole Owner and President and holds sole 

responsibility for and oversight over all Electrowarmth’s marketing claims. 

8. Prior to 2019, Respondents used USA textiles in their bunk warmer products and labeled 

the finished products as “Made in USA.” 

9. In 2019, however, Electrowarmth experienced a steep decline in sales. Specifically, a 

major truck stop operator stopped purchasing and stocking Electrowarmth bunk warmers, citing 

low demand and a preference for lower cost electric blankets. To cut costs and remain 

competitive, Respondent Grindle decided to move production overseas and stop using USA 

textiles. 

10. Accordingly, Respondent Grindle contracted with a company in China to wholly 

manufacture and package Electrowarmth truck bunk warmers. Respondent Grindle instructed 

the Chinese manufacturer to make and package Electrowarmth’s products “exactly the same” as 

they were previously manufactured in the United States. 

11. Respondents have disseminated or caused to be disseminated advertisements, packaging, 

and promotional materials for their bunk warmer products, including, but not necessarily limited 

to, the attached Exhibits A through D. These materials numerous contain statements and 

depictions relating to U.S.-origin, including that the products are “Made in USA,” “Made in the 

USA since 1939,” or “made-in-America products”: 

2 
 

"ght's 

o__star 

problems 

• Pre-warms your bed 

rives out dampness 

o fumes, noise, or vibrations 

utomatic eomfort'Control 

s----- --rhermostat 

~ El ectroWa rmth 

About See all 

0 Heated mattress pads, massage table 

warmers and 12-volt bunk warmers. Made 

in the USA since 1939 

0 Since 1939 ElectroWarmth has been 

manufacturing heated mattress pads that 

allow for an incredibly restful night of 

sleep. Contrary to heated blankets, our 

highly safe, energy saving heated 

mattress pads are designed to be slept 

on, not under. These made-in-America 

products are manufactured to the highest 

standards and provide users with a simple 

way to achieve a comfortable night of rest 

without worry of slipping blankets, 

laundry needs or safety concerns. 

ElectroWarmth heated mattress pads are 

held securely in place under the fi tted 

sheet, where it remains protected from 

wear and tear, as well as soiling. These 

fe • n carbon monoxide 

Breezeway Screens is at Iowa 80 - The World's Largest Trucksto p. 

July 8, 2021 , Walcott, IA· 0 

Great start to the 180 jamboree. Breezeway Screens pay for 

themselves in 1 night of not idling you r truck. Combined product 

just a few days payback. 

0 12 1 Comment 

.JI.. , a,~ 

Exhibits A-B (product label and packaging). 

Exhibit C (ElectroWarmth Facebook page). 

3 
::: 0 0 • • 

- at Iowa 80 - The World's Largest Truckstop. 

0 Comment ~ Share 

Write a comment... Q @ el Q 

Press Enter to post 

Exhibit D (Tradeshow materials). 

12. At the time the statements described in Paragraph 11 were published or disseminated, the 

products advertised were wholly manufactured, labeled, and packaged in China. 

VIOLATION OF THE TEXTILE FIBER PRODUCTS IDENTIFICATION ACT AND 

TEXTILE RULES 

13. The Textile Fiber Products Identification Act, 15 U.S.C. §§ 70-70k (the “Textile Act”), 

governs, inter alia, the labeling and advertising of textile fiber products manufactured, sold, 

advertised, or offered for sale in commerce. See 15 U.S.C. § 70a. 

14. Pursuant to the Textile Act, a textile fiber product is misbranded if “a stamp, tag, label, or 

other means of identification, or substitute therefor authorized by section 70c of this title, is not 

on or affixed to the product showing in words and figures plainly legible . . . [, i]f it is an 

imported textile fiber product[,] the name of the country where processed or manufactured[; or 

i]f it is a textile fiber product processed or manufactured in the United States, it be so identified.” 

15 U.S.C. § 70b(b). 

15. The Textile Act further provides that “a textile fiber product shall be considered to be 

falsely or deceptively advertised in any mail order catalog or mail order promotional material 

which is used in the direct sale or direct offering for sale of such textile fiber product, unless 

such textile fiber product description states in a clear and conspicuous manner that such textile 

fiber product is processed or manufactured in the United States of America, or imported, or 

both.” 15 U.S.C. § 70b(i). 

16. Pursuant to Subsection 70e of the Textile Act, 15 U.S.C. § 70e(c), the Commission 

promulgated the Textile Fiber Rule, 16 C.F.R. Part 303 (“Textile Rules”). The Textile Rules 

provide, in relevant part: 

4 
a. “Beddings,” defined to include “all . . . textile fiber products used or intended to be 

used on or about a bed or other place for reclining or sleeping,” are subject to the 

Textile Act and Textile Rules. 16 C.F.R. §§ 303.1; 303.45(a). 

b. Imported textile products must be labeled with the name of the country where the 

imported product was processed or manufactured. 16 C.F.R. § 303.33(a)(1). 

c. A textile product either (1) made in the United States in whole or in part of imported 

materials; or (2) partially manufactured in a foreign country and partially 

manufactured in the United States must contain a label disclosing those facts. 

16 C.F.R. § 303.33(a)(3). 

d. Product descriptions for textile products advertised in mail order catalogs or mail 

order promotional materials must state clearly and conspicuously that the product was 

made in the United States, imported, or both in a manner that is consistent with the 

origin labeling of the product advertised. 16 C.F.R. § 303.34. 

17. A violation of either the Textile Act or the Textile Rules constitutes an unfair or 

deceptive act or practice in violation of the FTC Act. See 5 U.S.C. §§ 70a and 70e. 

Count I 

18. As set forth in Paragraph 6, Respondents market or sell textile fiber products used or 

intended to be used on or about a bed or other place for reclining or sleeping, including warming 

mattress pads for truck bunks and residential beds. 

19. As set forth in Paragraph 11, Respondents label or have labeled and advertise or have 

advertised the origin of such textile fiber products as USA. 

20. As set forth in Paragraph 12, these textile fiber products were wholly imported from 

China. 

21. Therefore, through the means described in Paragraphs 10-12 and 18-20, Respondents 

have introduced, advertised, offered for sale, or sold textile fiber products that are mislabeled or 

falsely or deceptively advertised, in violation of Sections 70a and 70b of the Textile Act, 15 

U.S.C. §§ 70a and 70b, and Sections 303.33 and 303.34 of the Textile Rules, 16 C.F.R. §§ 

303.33 and 303.34. 

22. Respondents’ violations of the Textile Act and Textile Rules constitute deceptive acts or 

practices, in or affecting commerce, in violation of 5(a) of the FTC Act. See 15 U.S.C. §§ 70a 

and 70e. 

23. Therefore, the acts and practices of Respondents as alleged in Paragraphs 18-22 

constitute unfair or deceptive acts or practices in violation of Section 5(a) of the Federal Trade 

Commission Act. 

5 
THEREFORE, the Federal Trade Commission this 25th day of October, 2022, has 

issued this Complaint against Respondents. 

By the Commission. 

April J. Tabor 

Secretaiy 

SEAL: 

6 
12 

Sleep----~------r---· Paysfor itself in fuel savings 

Without Idling • Enjoy• better night's slee,_..--..__. 

__• 950/o Efficient - no starting--~.,_. 

problems 

• Pre-warms your bed ------. Drives out dampness--~~-----.;.~ 

'- -.-=----. No fumes, noise, or vibrations 

Automatic Comfort Contro1~­

;;....-:..:=~...;..;..... Thermostat-----------

~------~ • Safe - no carbon monoxide__.,_.__~..,

• Portable - plugs into lighter --·~=---

rantJr~~-.wl!!~INfll~ 

• an oyabe tt. 

• •s~a 'l'l\cl•.-.t 

Exhibit A 
• Pays for itself in fuel savings 

• Enjoy a better night's sleep 

• 95% Efficient- no starting 

problems 

• Pre-warms your bed 

• Drives outdampness 

• No fumes, noise, 

or vibrations 

• Automatic Comfort Control 

Thermostat 

• Safe - no carbon monoxide 

• Portable - plugs into 

lighter socket 

• One year warranty 

• Made in USA 

Exhibit B 
ElectroWarmth 

4.3 (6 reviews) · Medical & health 

3/21/22, 12:17 PM (4) ElectroWarmth I Facebook 

4

Q Oo o. ffil + • • CP 0 

■ Send message 

Hi! Please let us know how we can help. 

General 

■ 221 people like this 

■ 223 people follow this 

■ Medical & Health · Heating, Ventilating & Air Conditioning Service 

Business details 

ElectroWarmth ■ Send message ■ Like 

1-\UUlllUlldl C:OllldU ,mo 

■ http://electrowarmth.com/ 

■ (800) 990-4622 

■ sales@electrowarmth.com 

■ Typically replies within a few hours 

Send message 

More info 

■ About 

Heated mattress pads, massage table warmers and 12-volt bunk warmers. 

Made in the USA since 1939. 

https://www.facebook.com/E lectroWarmth-1990008664613030/abouV?ref=pa ge _internal 1/2 

Exhibit C 

p. 1 of 2 
3/21/22, 12:17 PM (4) ElectroWarmth I Facebook 

4

Q Oo o. ffil + • • CP 0 

■ Additional information 

Since 1939 ElectroWarmth has been manufacturing heated mattress pads 

that allow for an incredibly restful night of sleep. Contrary to heated blankets, 

our highly safe, energy saving heated mattress pads are designed to be slept 

on, not under. These made-in-America products are manufactured to the 

highest standards and provide users with a simple way to achieve a 

comfortable night of rest without worry of slipping blankets, laundry needs or 

safety concerns. ElectroWarmth heated mattress pads are held securely in 

place under the fitted sheet, where it remains protected from wear and tear, 

as well as soiling. These easy to care for sleep-aids will ensure you get a night 

of rest you deserve! ElectroWarmth products are backed by a one year 

warranty and a 30 day satisfaction guarantee, but many of our mattress pads 

have been in use for 30 years or more and have never needed a repair! To 

learn more about our products or to order a heated mattress pad throughout 

Ohio, Indiana, or anywhere in the United States, don't hesitate to contact the 

friendly team at ElectroWarmth. 

Not only does electrowarmth manufacture and sell high quality heated 

mattress pads for California king, king, queen, full and twin sized beds, but 

we offer an array of other products. For the masseuse we sell massage table 

warmers, ensuring your clients have a great experience from the very get go. 

We also sell 12 volt bunk warmers that are suitable for boats, motorhomes 

and semi trucks. Our 12 volt bunk warmers allow you to get the rest you 

need, no matter where you are! 

We stand behind all our products with a 30 day satisfaction guarantee and a 

one year warranty. Should you not find the comfort and warmth you're 

looking for within the first month of use feel free to send it back, and we'd be 

happy to refund your money. Likewise, should you experience any technical 

issues within the first one year we will repair or replace your ElectroWarmth 

product Call us toll free at (855) 478-7899 to learn more or to place an order 

for heated mattress pads, bunk warmers or massage table warmers in Ohio 

and the rest of the United States. See less 

https://www.facebook.com/E lectroWarmth-1990008664613030/abouV?ref=pa ge _internal 

Exhibit C 

p. 2 of 2 

2/2 
i facebook.com/Breezeway-Screens-1671567719555537 /photos/pcb.4195415237170760/4195415183837432 :. 

...

... 0 •

0 

• 

ave Fuel and En ine Wear 

A Gr,: - a t Iowa 80 - The World't:. Largest Truck£-top. a t Co m bination 

rfJ Like 0 Comment ~ Share 

1,.,: .... ......-•ff.•• foll/WI• '~ Write a comment. . fi.<'lroWo,rnth11 

a, ..z:ewo~ ,,.., .....,.,..,_i... p,.d, Pfe~s Enter to post t, ...clil \lll,uilow Sc:fffl'I" 

-,...,,.,,"...,...,.,...... ".... :~-:::.:::\~-"- - , .• ,., .-~.._ .. _ .. ..w,.... _ . (__ 

::::::.::-::::::;:-~1---• :~:-·\~-

ExhibitD 
12 

Sleep----~------r---· Paysfor itself in fuel savings 

Without Idling • Enjoy• better night's slee,_..--..__. 

__• 950/o Efficient - no starting--~.,_. 

problems 

• Pre-warms your bed ------. Drives out dampness--~~-----.;.~ 

'- -.-=----. No fumes, noise, or vibrations 

Automatic Comfort Contro1~­

;;....-:..:=~...;..;..... Thermostat-----------

~------~ • Safe - no carbon monoxide__.,_.__~..,

• Portable - plugs into lighter --·~=---

rantJr~~-.wl!!~INfll~ 

• an oyabe tt. 

• •s~a 'l'l\cl•.-.t 

Exhibit A 
• Pays for itself in fuel savings 

• Enjoy a better night's sleep 

• 95% Efficient- no starting 

problems 

• Pre-warms your bed 

• Drives outdampness 

• No fumes, noise, 

or vibrations 

• Automatic Comfort Control 

Thermostat 

• Safe - no carbon monoxide 

• Portable - plugs into 

lighter socket 

• One year warranty 

• Made in USA 

Exhibit B 
ElectroWarmth 

4.3 (6 reviews) · Medical & health 

3/21/22, 12:17 PM (4) ElectroWarmth I Facebook 

4

Q Oo o. ffil + • • CP 0 

■ Send message 

Hi! Please let us know how we can help. 

General 

■ 221 people like this 

■ 223 people follow this 

■ Medical & Health · Heating, Ventilating & Air Conditioning Service 

Business details 

ElectroWarmth ■ Send message ■ Like 

1-\UUlllUlldl C:OllldU ,mo 

■ http://electrowarmth.com/ 

■ (800) 990-4622 

■ sales@electrowarmth.com 

■ Typically replies within a few hours 

Send message 

More info 

■ About 

Heated mattress pads, massage table warmers and 12-volt bunk warmers. 

Made in the USA since 1939. 

https://www.facebook.com/E lectroWarmth-1990008664613030/abouV?ref=pa ge _internal 1/2 

Exhibit C 

p. 1 of 2 
3/21/22, 12:17 PM (4) ElectroWarmth I Facebook 

4

Q Oo o. ffil + • • CP 0 

■ Additional information 

Since 1939 ElectroWarmth has been manufacturing heated mattress pads 

that allow for an incredibly restful night of sleep. Contrary to heated blankets, 

our highly safe, energy saving heated mattress pads are designed to be slept 

on, not under. These made-in-America products are manufactured to the 

highest standards and provide users with a simple way to achieve a 

comfortable night of rest without worry of slipping blankets, laundry needs or 

safety concerns. ElectroWarmth heated mattress pads are held securely in 

place under the fitted sheet, where it remains protected from wear and tear, 

as well as soiling. These easy to care for sleep-aids will ensure you get a night 

of rest you deserve! ElectroWarmth products are backed by a one year 

warranty and a 30 day satisfaction guarantee, but many of our mattress pads 

have been in use for 30 years or more and have never needed a repair! To 

learn more about our products or to order a heated mattress pad throughout 

Ohio, Indiana, or anywhere in the United States, don't hesitate to contact the 

friendly team at ElectroWarmth. 

Not only does electrowarmth manufacture and sell high quality heated 

mattress pads for California king, king, queen, full and twin sized beds, but 

we offer an array of other products. For the masseuse we sell massage table 

warmers, ensuring your clients have a great experience from the very get go. 

We also sell 12 volt bunk warmers that are suitable for boats, motorhomes 

and semi trucks. Our 12 volt bunk warmers allow you to get the rest you 

need, no matter where you are! 

We stand behind all our products with a 30 day satisfaction guarantee and a 

one year warranty. Should you not find the comfort and warmth you're 

looking for within the first month of use feel free to send it back, and we'd be 

happy to refund your money. Likewise, should you experience any technical 

issues within the first one year we will repair or replace your ElectroWarmth 

product Call us toll free at (855) 478-7899 to learn more or to place an order 

for heated mattress pads, bunk warmers or massage table warmers in Ohio 

and the rest of the United States. See less 

https://www.facebook.com/E lectroWarmth-1990008664613030/abouV?ref=pa ge _internal 

Exhibit C 

p. 2 of 2 

2/2 
i facebook.com/Breezeway-Screens-1671567719555537 /photos/pcb.4195415237170760/4195415183837432 :. 

...

... 0 •

0 

• 

ave Fuel and En ine Wear 

A Gr,: - a t Iowa 80 - The World't:. Largest Truck£-top. a t Co m bination 

rfJ Like 0 Comment ~ Share 

1,.,: .... ......-•ff.•• foll/WI• '~ Write a comment. . fi.<'lroWo,rnth11 

a, ..z:ewo~ ,,.., .....,.,..,_i... p,.d, Pfe~s Enter to post t, ...clil \lll,uilow Sc:fffl'I" 

-,...,,.,,"...,...,.,...... ".... :~-:::.:::\~-"- - , .• ,., .-~.._ .. _ .. ..w,.... _ . (__ 

::::::.::-::::::;:-~1---• :~:-·\~-

ExhibitD