[1823095] 

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 

SANDPIPER OF CALIFORNIA, INC., a corporation C-4675

and 

PIPERGEAR USA, INC., a corporation. 

COMPLAINT 

The Federal Trade Commission, having reason to believe that Sandpiper of California, 

Inc., a corporation, and PiperGear USA, Inc., a corporation (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 Sandpiper of California, Inc. (“Sandpiper”) is a California corporation with 

its principal office or place of business at 687 Anita Street, Suite A, Chula Vista, CA 91911. 

2. Respondent PiperGear USA, Inc. (“PiperGear”) is a California corporation with its 

principal office or place of business at 687 Anita Street, Suite A, Chula Vista, CA 91911. 

3. Respondents Sandpiper and PiperGear have operated as a common enterprise while 

engaging in the unlawful acts and practices alleged below. Because these Respondents have 

operated as a common enterprise, each of them is jointly and severally liable for the acts and 

practices alleged below. 

4. Respondents have advertised, labeled, offered for sale, sold, and distributed products to 

consumers, including, but not limited to, backpacks and travel bags. Respondents advertise these 

products online, including, but not limited to, on their websites, sandpiperca.com and 

pipergearusa.com. Respondents offer for sale, sell, and distribute their products throughout the 

United States. 
Featuring American Made products developed 

and manufactured by our sister company, 

PiperGear USA. We offer manufacturing 

options to meet Berry Amendment, NAFT A, 

GSA or Buy American Act requirements. The 

growth and success of our US manufacturing 

plant is a great source of pride to us. 

USA 

sandpiperofca It's all about the details ... 

#sandpipernfcalifornia #soc #backpack 

#camouflage #camo #camping #madeinusa 

PATRIOT SERIES 

5. 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. 

6. Respondents have disseminated or have caused to be disseminated advertisements and 

promotional materials for their products, including, but not necessarily limited to, the attached 

Exhibits A-D. These materials contain the following statements and depictions, among others: 

A. “Featuring American Made products developed and manufactured by our 

sister company, PiperGear USA” 

(Exhibit A, Sandpiper website); 

B. “Made in the USA” 

(Exhibit B, PiperGear website); 

C. “#madeinusa” 

(Exhibit C, Sandpiper Instagram posting); and 

D. “U.S. Made by S.O.C.” 

(Exhibit D, Sandpiper Instagram posting, photograph of Sandpiper trade show 

material). 

2 
 

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

in Paragraph 6, Respondents have represented, expressly or by implication, that all of their 

backpacks, travel bags, and other products are all or virtually all made in the United States. 

8. In fact, more than 95% of Respondent Sandpiper’s products are imported as finished 

goods, and approximately 80% of Respondent PiperGear’s products are either imported as 

finished goods or contain significant imported components. Respondents import products or 

components from Mexico and China. For certain wallets imported from Mexico as finished 

goods, Respondents hid truthful country-of-origin information on the back of tags, and inserted 

cards that prominently displayed false U.S.-origin claims. 

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

made in the United States are false or unsubstantiated. 

COUNT I 

(False or Unsubstantiated Representation) 

10. In connection with the manufacturing, labeling, advertising, promotion, offering for sale, 

sale, or distribution of their products, Respondents have represented, directly or indirectly, 

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

States. 

11. In fact, more than 95% of Respondent Sandpiper’s products are wholly imported, and 

approximately 80% of Respondent PiperGear’s products are either imported as finished goods or 

contain significant imported components. Therefore, the representation set forth in Paragraph 10 

is false or misleading, or was not substantiated at the time the representation was made. 

VIOLATION OF SECTION 5 

12. 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 sixteenth day of April, 2019, has 

issued this Complaint against Respondents. 

By the Commission, Commissioner Slaughter and Commissioner Chopra dissenting.

April J. Tabor 

Acting Secretary 

SEAL: 

3 
. . 

SA- R 10F 1CA 10RNIA 

QUALITY TRAVEL IlACS & BACKPACKS SINCE 1980 

Iii~ ,. 

IHMl 

Sandpiper of California | Company 

HOME PRODUCTS USER PHOTOS COMPANY MEDIA CONTA

Sandpiper of California Established in 1980, SOC produced and sold products primarily in Southern California. You will find SOC products in retail locations around the world. For over 3 decades our quest for quality has been a progression to provide the best products for our customers. Our basic philosophy is to provide a great product at a fair price, and provide superior customer service. Featuring American Made products developed and manufactured by our sister company, PiperGear USA. We offer manufacturing options to meet Berry Amendment, NAFTA, GSA or Buy American Act requirements. The growth and success of our US manufacturing plant is a great source of pride to us. Working with law enforcement and US military personnel is an honor and privilege, and essential to our success by providing relevant product designs and features. By keeping it simple we maintain consistency in our manufacturing quality and service levels, while improving our products and increasing sales growth opportunities. We invite new retail partners and manufacturing opportunities no matter how big or small. 

Piper Gear Recreational and outdoors collection. Great for hikes, day trips or school. Modern colors and contemporary designs. PGUSA Piper Gear USA is the manufacturing sister company of Sandpiper of California. PG USA provides additional options to customers providing materials and assembly to cover the full range of manufacturing requirements. Berry Amendment, Buy American Act, NAFTA, as well as overseas production. http://www.pipergearusa.com/ 

COMPAN

http://www.sandpiperca.com/company.php[1/25/2018 1:41:12 PM] 
Sandpiper of California | Company 

Sandpiper of California ABOUT US EXPLORE PRODUCTS FOLLOW US 

687 Anita Street, Suite A 

Home Gear Packs Chula Vista, CA 91911 Company Facebook Products Pack Mule Frames Contact 

Disaster Quickpack (619) 424-2222 Warranty Twitter Preparedness Piper Gear info@sandpiperca.com Returns 

Pack Features Business & Travel FAQ Videos S.O.C. Tactical YouTube Media 

Get E-mail Updates! User Gallery Bugout Zombie Packs Events 

Clearance & Overstock Instagram Catalogs 

Dealers Terms 

© 2016 Sandpiper of California. All rights reserved. | Privacy Policy | Site Map 

http://www.sandpiperca.com/company.php[1/25/2018 1:41:12 PM] 

Exhibit A 

p. 2 of 2 
.I ... J ..rtJ;...::::..s=-=~:..:,.),l 

l 

\ . -- ______,,,... . -. 1 

• • -~ ~ :iNUFACTURING & SEWN GOODS PROD

HOME PROTOTYPES COMPANY SERVICES CONTACT 

PiperGear USA PiperGear USA, Inc. is the manufacturing sister company of Sandpiper of California, Inc. PiperGear USA was established in 2007 as a solution to provide the U.S. Department of Defense (DOD) with Berry Amendment compliant products. Located in Chula Vista, California, just 6 miles from downtown San Diego, California, PiperGear USA is now a leading manufacturer of tactical nylon products and sewn goods equipment. Read more... 

PiperGear USA ABOUT US 

687 Anita Street 

Company Chula Vista, CA 91911 Services Contact (619) 424-2222 

info@sandpiperca.com 

• TACTICAL GEAR • PACKS, POUCHES & BAGS • CUSTOM DESIGNS • PROTOTYPES 

PROTOTYPES 

Tactical Gear Packs Pouches 

• BERRY CO• BUY AME• NAFTA • OVERSEA

S.O.C. 

Gear PaBugout Piper GBusinesQuickp
S.O.C. Tactical 

Clearance & Overstock 

© 2016 PiperGear USA. All Rights Reserved. | CAGE Code: 5XPU8 | Site Map 

Exhibit B 

p. 2 of 2 
•.instagram.com/ p/ BAtGI_ 4oqWr/ ?taken-by=sandpiperofca 

Tools lelp 

P y i C [ Sandpiper of California (@s ... x 

sandpiperofca • Fol

sandpiperofca It's all about t

#sandpiperofcalifornia #soc #camouflage #camo #campi

00 

19 likes 

JANUARY 18. 2016 

Log in to like or comment. 
.instagram.com/p/BA2umzNlqZW/7taken-by=sandpiperofca 

Tools Help 

p i C I e Sandpiper of California (@s ... X 

sandpiperofca • Fol

sandpiperofca Last day @sh

day to enter the Pack Mule K

value). Come by booth 32303 

#shotshow #packmule #hun

00 

27 likes 

JANUARY 22, 2016 

Log in to like or comment.