202 3025 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman 

Noah Joshua Phillips 

Rohit Chopra 

Rebecca Kelly Slaughter 

Christine S. Wilson 

In the Matter of 

WILLIAMS-SONOMA, INC., a corporation, 

d/b/a Williams Sonoma, Williams Sonoma DOCKET NO. C- Home, Pottery Barn, Pottery Barn Kids, 

Pottery Barn Teen, West Elm, Rejuvenation, 

Outward, and Mark & Graham. 

COMPLAINT 

The Federal Trade Commission (“FTC” or “Commission”), having reason to believe that 

Williams-Sonoma, Inc., a corporation, also doing business as Williams Sonoma, Williams 

Sonoma Home, Pottery Barn, Pottery Barn Kids, Pottery Barn Teen, West Elm, Rejuvenation, 

Outward, and Mark & Graham ( “Respondent” or “Williams-Sonoma”), has 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 is a Delaware corporation, with its principal place of business at 3250 Van 

Ness Avenue, San Francisco, CA 94109. 

2. Respondent has advertised, labeled, offered for sale, sold, and distributed home products 

to consumers, including cookware, furniture, light fixtures, linens, small electronics, and others. 

Respondent advertises these home products in stores and online, including, but not limited to, on 

its websites and social media platforms. Respondent offers for sale, sells, and distributes its 

products throughout the United States. 

3. The acts and practices of Respondent alleged in this complaint have been in or affecting 

commerce, as “commerce” is defined in Section 4 of the Federal Trade Commission Act. 

4. In 2018, the Commission received reports that Respondent disseminated Internet 

advertisements and promotional materials for Pottery Barn Teen organic mattress pads stating 

those products were “Crafted in America from local and imported materials.” When consumers 
 

 

 

 

 

purchased the mattress pads, they discovered that the pads were, in fact, made in China. 

5. After receiving and verifying these reports, the FTC contacted Williams-Sonoma, which 

quickly updated its website to include correct country-of-origin information for this product. As 

part of the FTC’s inquiry, the FTC instructed Respondent to undertake a larger review of its 

country-of-origin verification process. 

6. On June 13, 2018, in response to Williams-Sonoma’s quick action to update its claims, 

explanation that the mattress pad misrepresentation was an isolated instance of human error, and 

commitment to a multi-step verification process to prevent deceptive country-of-origin claims, 

FTC staff closed its investigation with a letter on the public record in lieu of formal enforcement 

action. See Exhibit A. The staff’s letter specified that it “should not be construed as a 

determination that there was no violation of Section 5 . . . [and t]he Commission reserves the 

right to take such further action as the public interest may require.” 

7. In May 2019, the FTC received a report that despite Williams-Sonoma’s statements 

leading to the staff’s closing letter, Respondent continued to disseminate advertisements and 

promotional materials, including through its website and social media platforms, which 

deceptively claimed certain categories of Williams-Sonoma products were all or virtually all 

made in the United States. 

8. Specifically, since June 13, 2018, to induce consumers to purchase Goldtouch Bakeware, 

Rejuvenation-branded products, and Pottery Barn Teen and Pottery Barn Kids-branded 

upholstered furniture products, Respondent disseminated or caused to be disseminated 

advertisements that contain the following statements and depictions, among others: 

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A. Goldtouch Bakeware is made in America or in the USA 

(Company website and catalogue). 

3 
B. Rejuvenation-branded products are made in America or in the USA 

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(Company website and emails). 

C. Pottery Barn Teen and Pottery Barn Kids-branded upholstered furniture is 

made in America or in the USA 

(Company video). 

9. In numerous instances, including, but not limited to, the promotional materials referenced 

in paragraph 8, Respondent has represented that all Goldtouch Bakeware, Rejuvenation-branded 

products, and Pottery Barn Teen and Pottery Barn Kids-branded upholstered furniture products, 

including raw materials and subcomponents, were all or virtually all made in the United States. 

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10. In fact, numerous Goldtouch Bakeware products, Rejuvenation-branded products, and 

Pottery Barn Teen and Pottery Barn Kids-branded upholstered furniture products are wholly 

imported, or contain significant imported materials or components. 

11. Therefore, Respondent’s broad claims that all Goldtouch Bakeware products, 

Rejuvenation-branded products, and Pottery Barn Teen and Pottery Barn Kids-branded 

upholstered furniture products are all or virtually all made in the United States deceive 

consumers. 

Count I 

False or Unsubstantiated Representation – Made in USA 

12. In connection with the advertising, promotion, offering for sale, or sale of Goldtouch 

Bakeware products, Rejuvenation-branded products, and Pottery Barn Teen and Pottery Barn 

Kids-branded upholstered furniture products, Respondent has represented, directly or indirectly, 

expressly or by implication, that such products, including the materials and subcomponents used 

to make such products, are all or virtually all made in the United States. 

13. In fact, in numerous instances, Respondent’s Goldtouch Bakeware products, 

Rejuvenation-branded products, and Pottery Barn Teen and Pottery Barn Kids-branded 

upholstered furniture products are wholly imported or incorporate significant imported materials 

or subcomponents. Therefore, the representations set forth in paragraph 12 are false or 

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

Violations of Section 5 

14. The acts and practices of Respondent 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 Respondent. 

By the Commission. 

[April J. Tabor] 

[Acting Secretary] 

SEAL: 

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