|Received:||10/11/2005 06:00:50 PM|
|Organization:||Pat Lewis Designs|
|Agency:||Federal Trade Commission|
|Rule:||Guides for the Jewelry, Precious Metals, and Pewter Industries|
|Docket ID:||To Be Added|
Comments:I am writing to request that platinum Guides not be amended reducing the platinum content from 850 to 500 parts per thousands pure platinum and no other platinum group metals. As a designer/manufacturer of fine platinum/gold jewelry I feel that the consumer does not adequately understand the difference in pricing when it comes to determining price differences in products. Amending the Guides would further confuse most consumers who already voice a lot of skepticism about jewelry and the big markups. A typical consumer response is "platinum is platinum" or "gold is gold" to quite common in the marketplace. Amending platinum, other than deluting the vary nature of the product is to capitalize on the naiivety of the consumer regardless of the literature or sales presentatiion that may accompany the product. Consumers, in general today, are obsessed with price and the "art of the deal". To reduce platinum content to 500 from 850 perpetuates that line of illogical thinking. If the product proposed to reflect less than 850 is marketed another name should be utilized. In addition to the consumer possibly misuderstanding the value of a platinum marked product less than 850, many jewelers may not be aware of the significance either. If a goldsmith repairs a platinum stamped piece of jewelry they know the heat required to repair the platinum piece will be much higher than other metalurgical products used in jewelry manufacturing. When high heat is touched to a platinum marked product under 850 who is responsible for possible damage to the metal or gemstone (think heat sensitive gemstones too). Not all repair shops use a laser machine due to its high cost as most repairs do not require a laser to repair the jewelry. Who is responsible-----the goldsmith, the retailer who sold it, the manufacturer? We don't need more potential litigation. To market a duluted platinum product as platinum further causes confusion in a marketplace that already suffers a negative image in too many consumers minds. If you have any doubts there will probably be another TV expose depicting the industry with doubt. Don't add to the consumers confusion already established.