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

Mr. Jay Zidell, President
Tube Forgings of America, Inc.
5200 NW Front Avenue
Portland, OR 97210-1110

Re: Tube Forgings of America, File No.

Dear Mr. Zidell:

The Division of Enforcement staff has conducted an investigation involving an allegation that Tube Forgings of America, Inc. ("Tube Forgings") 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.

Staff had received a complaint that Tube Forgings stamps its pipe fittings "USA" although the steel in Tube Forgings' pipe fittings is imported. Your company asserts that other than being stamped "USA," the pipe fittings are not advertised or otherwise promoted as U.S. made. Your company has also provided information that shows that the percentage of foreign content in these pipe fittings is a de minimis amount of the pipe fittings' total manufacturing cost.

The staff has concluded that no compliance action against Tube Forgings 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