UNITED STATES OF AMERICA
FEDERAL TRADE COMMISSION
WASHINGTON, D.C. 20580

Mr. John W. Armaly, Jr.
President
Armaly Sponge Company
P.O. Box 611
1900 Easy St.
Walled Lake, Michigan 48390

Re: Armaly Brands Company, File No. 992-3171

Dear Mr. Armaly, Jr.:

The Division of Enforcement staff has conducted an investigation involving an allegation that Armaly Sponge Company ("Armaly") has violated the Federal Trade Commission's "all or virtually all" standard for domestic country of origin claims and Section 5 of the Federal Trade Commission Act. A complaint received by staff alleged that Armaly's natural sea sponges were packaged in boxes stating "Harvested from the coastal waters of the USA," yet the sponges were imported from the Bahamas.

In order to promote a product with an unqualified domestic origin claim, a product should contain no more than a de minimis or negligible amount of foreign content. Because Armaly's sea sponges may be harvested from non-U.S. waters, an unqualified domestic origin claim may not be appropriate. Armaly, however, has informed staff that it had determined to change its packaging to state simply "Processed in the USA" prior to being contacted by staff regarding the above complaint.

The staff has concluded that no compliance action against Armaly is indicated at this time. Accordingly, the investigation has been closed. This action is not to be construed as a determination that a violation may not have occurred, just as the pendency of an investigation should not be construed as a determination that a violation has occurred. The Commission reserves the right to take such further action as the public interest may require.

Sincerely,

Elaine D. Kolish
Associate Director