182 3095

UNITED STATES OF AMERICA

BEFORE THE FEDERAL TRADE COMMISSION

COMMISSIONERS: Joseph J. Simons, Chairman

Maureen K. Ohlhausen 

Noah Joshua Phillips 

Rohit Chopra

Rebecca Kelly Slaughter

In the Matter of

SANDPIPER OF CALIFORNIA, INC., a corporation

and

PIPERGEAR USA, INC., a corporation.

DOCKET NO.

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.
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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).

Featuring American Made products developed 

and manufactured by our sist er company, 

PiperGear USA. We offer manufact uring 

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. 

I USA 

~ sandpiperofca • Follow 

sandpiperofca It's all about the details ... 

#sc111t.lpiperoflc1lifumic1 #soc #IJaLkpac:k 

#camouflage #camo #camping #madeinusa 

PATRIOT SERIES 

U S MUl IY S.0 C. 
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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 _______ day of _______, 20__, has 

issued this Complaint against Respondents.

By the Commission.

[Donald S. Clark]

Secretary

SEAL: