UNITED STATES OF AMERICA 

FEDERAL TRADE COMMISSION 

WASHINGTON, D.C. 20580 

Office of the Secretary 

November 10, 2014 

C Host 

State of Iowa 

Re: In the Matter of Made in the USA Brand, LLC 

 File No. 142 3121, Docket No. C-4497 

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 request that the Commission fine Made in the USA Brand, LLC 

and punish its clients. You do not propose any revisions to the draft complaint or the consent 

agreement. 

The Commission is committed to preventing consumer deception, and believes the 

proposed order will accomplish this objective. In particular, Part I of the proposed order 

prohibits Respondent from representing that a covered entity meets Respondent’s accreditation 

standard, unless: (1) Respondent or its designee independently and objectively evaluates that the 

entity meets the standard; or (2) Respondent clearly discloses on the face of its logo and in all of 

its promotional materials that certified entities meet the standard through self-certification. Part 

II of the proposed order prohibits Respondent from making any country-of-origin claim about 

any product in its marketing materials unless: (1) the claim is true, not misleading, and 

Respondent has competent and reliable evidence substantiating the representation; or (2) for 

representations made through use of Respondent’s certification mark, Respondent clearly 

discloses that certified entities meet the standard through self-certification. Finally, Part III of 

the proposed order prohibits Respondent from providing others with the means and 

instrumentalities to make the claims prohibited in Parts I and II. 

The FTC Act does not allow the agency to obtain fines for initial violations. Our primary 

goal in cases such as this one is to stop deceptive advertising by putting the Respondent under 

order. If, in the future, Respondent violates its order, the Federal Trade Commission could 

pursue civil penalties. 

During its investigation into this matter, the Federal Trade Commission worked with 

several of Respondent’s clients to remediate potentially deceptive U.S.-origin claims and bring 

them into compliance with the law. Going forward, the FTC expects that the requirements set 

forth in the consent agreement will prevent Respondent’s clients from making deceptive claims. 
Therefore, after considering your comment, the Commission has determined that the 

relief set forth in the consent agreement 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. 

Donald S. Clark 

Secretary