2223163

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Lina M. Khan, Chair

 Rebecca Kelly Slaughter

Alvaro M. Bedoya 

In the Matter of

CHAUCER ACCESSORIES, INC., a 

corporation, also d/b/a CHAUCER 

LEATHER CORP.;

BATES ACCESSORIES, INC., a corporation, 

also d/b/a THOMAS BATES, TB PHELPS, 

DAVID SPENCER SHOES, and CUSTOM 

BRAND FOOTWEAR;

BATES RETAIL GROUP, INC., a corporation; 

and

THOMAS P. BATES, individually and as an 

officer of CHAUCER ACCESSORIES, 

INC.; BATES ACCESSORIES, INC.; and 

BATES RETAIL GROUP, INC.

DOCKET NO. 

COMPLAINT

The Federal Trade Commission, having reason to believe that Chaucer Accessories, Inc., 

a corporation; Bates Accessories, Inc., a corporation; Bates Retail Group, Inc., a corporation; and 

Thomas Bates, individually and as an officer of Chaucer Accessories, Inc., Bates Accessories, 

Inc., and Bates Retail Group, Inc. (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 Chaucer Accessories, Inc. (“Chaucer”), also doing business as Chaucer 

Leather Corp., is a Massachusetts corporation with its principal office or place of business at 143 

Essex St., Haverhill, Massachusetts 01832.

2. Respondent Bates Accessories, Inc. (“Bates Accessories”), also doing business as 

Thomas Bates, TB Phelps, David Spencer Shoes, and Custom Brand Footwear, is a Delaware 
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corporation with its principal office or place of business at 370 Portsmouth Ave., # 211, 

Greenland, New Hampshire 03840.

3. Respondent Bates Retail Group, Inc. (“Bates Retail Group”) is a New Hampshire 

corporation with its principal office or place of business at 36 Piscataqua St., P.O. Box 243, New 

Castle, New Hampshire 03854.

4. Respondent Thomas P. Bates (“Bates”) is the president and owner of Chaucer 

Accessories, Bates Accessories, and Bates Retail Group. Individually or in concert with others, 

he controlled or had the authority to control, or participated in the acts and practices of Chaucer, 

Bates Accessories, and Bates Retail Group, including the acts and practices alleged in this 

complaint. His principal office or place of business is the same as that of Bates Accessories.

5. Respondents Chaucer Accessories, Bates Accessories, and Bates Retail Group 

(collectively, “Corporate Respondents”) have operated as a common enterprise while engaging 

in the unlawful acts and practices alleged below. Respondents have conducted the business 

practices described below through an interrelated network of companies that have common 

ownership, officers, managers, business functions, employees, and office locations; and 

commingled funds. Because these Corporate Respondents have operated as a common 

enterprise, each is jointly and severally liable for the acts and practices alleged below. 

Respondent Bates has formulated, directed, controlled, or had the authority to control, or

participated in the acts and practices of the common enterprise alleged in this complaint.

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

distributed products to consumers, including belts, bags, wallets, and shoes.

7. 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

8. Respondents have sold consumer goods for over 40 years. Among other things, 

Respondents manufacture, advertise, and sell leather and fabric belts, bags, and wallets. 

Respondents also advertise and sell shoes.

9. In some instances, Respondents label, advertise, and sell their products directly to 

consumers.

10. In other instances, Respondents label, advertise, and sell their products to third party 

trade customers for resale to consumers as private-labeled products under the third party 

retailers’ own brand names.

11. In numerous instances, Respondents have published promotional materials stating or 

implying all their products are all or virtually all made in the United States.
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12. For example, Respondents’ websites, including chaucerleather.com, thomasbates.com, 

and davidspencershoes.com, have featured banners with the claims “Made in USA” or “Hand 

Crafted in the USA.” These claims were visible on every page of the sites.

13. Respondents also marketed their products as “Made in the USA” in catalogs and thirdparty online marketplaces, including amazon.com.

14. In fact, in numerous instances, Respondents’ shoes, belts, and other products were wholly 

imported or contained significant imported content.

15. In numerous instances, Respondents represented to third-party trade customers that their 

private-labeled belts and accessories were made in the United States and provided those trade 

customers with labeling and promotional materials featuring U.S.-origin claims for use in the 

marketing and sale of such products.

16. In fact, in numerous instances, these products contained significant imported content.

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

virtually all made in the United States deceive consumers.

18. Additionally, in numerous instances, Respondents imported belt straps from Taiwan, 

affixed buckles to the straps in the United States, and labeled the finished belts as “Made in USA 

from Global Materials.” Respondents then advertised and sold these belt straps through their 

own websites and catalogs and third-party platforms featuring prominent “Made in USA” claims.

19. U.S. Customs and Border Protection (“CBP”) determined that, in fact, the products 

described in Paragraph 18 were not “Made in USA from Global Materials” because attaching a 

buckle to a belt strap is a minimal assembly operation that does not change the name, character, 

or use of an imported belt strap.

20. In numerous instances in which the Respondents made the representations described in 

Paragraph 18, CBP determined Respondents’ products were wholly imported with de minimis 

finishing in the United States.

21. Therefore, Respondents’ express or implied representations that the products described in 

Paragraph 18 are wholly or partially made in the United States are false or unsubstantiated.

Bates’s Knowledge

22. At all times relevant to this Complaint, Respondent Bates has maintained 100% 

ownership over the Corporate Respondents and served as the Corporate Respondents’ President.

23. Respondent Bates is responsible for the Corporate Respondents’ product development, 

sourcing, descriptions, and governing policies.
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24. At all times relevant to this Complaint, Respondent Bates had direct knowledge of the 

Corporate Respondents’ overseas purchases and importation practices.

25. Respondent Bates has served as the Corporate Respondents’ primary contact with CBP

regarding appropriate country-of-origin labeling for imported products including, but not limited 

to, the belt straps described in Paragraph 18.

Count I

False or Misleading Made in USA Advertising Claims

26. In numerous instances, in connection with the advertising, promotion, offering for sale, 

sale, or distribution of belts, shoes, and other products, Respondents have represented, directly or 

indirectly, expressly or by implication, that their products are all or virtually all made in the 

United States.

27. In fact, in numerous instances in which Respondents have made the representations set 

forth in Paragraph 26, Respondents’ products were not all or virtually all made in the United 

States. Indeed, in numerous instances they were wholly imported or incorporated significant 

imported components.

28. Therefore, Respondents’ representations as set forth in Paragraph 26 are false or 

misleading, or were not substantiated at the time the representations were made.

Count II

False or Misleading Made in USA from Global Materials Advertising Claims

29. In numerous instances, in connection with the advertising, promotion, offering for sale, 

sale, or distribution of seven styles of belts, Respondents have represented, directly or indirectly,

expressly or by implication, that those belts are “Made in USA from Global Materials.”

30. In fact, in numerous instances in which Respondents have made the representations set 

forth in Paragraph 29, Respondents’ products were not “Made in USA from Global Materials.”

Indeed, in numerous instances they were wholly imported with de minimis finishing in the 

United States.

31. Therefore, Respondents’ representations as set forth in Paragraph 29 are false or 

misleading, or were not substantiated at the time the representations were made.

Count III

Means and Instrumentalities

32. Respondents have distributed the promotional materials described in Paragraph 26 to 

trade customers for use in the marketing and sale of Respondents’ products, including privatelabeled products. In so doing, Respondents have provided the means and instrumentalities to 

these trade customers for the commission of deceptive acts or practices.
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Violation of Section 5

33. 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 _______, 20__, has 

issued this Complaint against Respondents.

By the Commission.

[April J. Tabor]

Secretary

SEAL: