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

Mr. Douglas R. Starrett
Chairman and CEO
L.S. Starrett
121 Crescent Street
Athol, MA 01331-1915

Re: L.S. Starrett, File No. 982 3582

Dear Mr. Starrett:

The Division of Enforcement staff has conducted an investigation involving an allegation that L.S. Starrett ("Starrett") 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.

The staff received a complaint alleging that Starrett had advertised and promoted its fiberglass blade measuring tapes as being made or manufactured in the United States, although the fiberglass blades of the measuring tapes were actually manufactured in Taiwan. Because Starrett's measuring tapes contained more than a negligible amount of foreign content, a "Made in USA" claim or other unqualified domestic origin claim would not be appropriate. Starrett has agreed to eliminate the words "American made" from its labels and cardboard hangers and to dispose of the balance of its packaging inventory.

The staff has concluded that no further action is warranted by the Commission 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


Last Modified: Friday, June 24, 2011