16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001 #00070

Submission Number:
Michael Meyers
Initiative Name:
16 CFR Part 23, Guides for the Jewelry, Precious Metals, and Pewter Industries; Project No. G711001
Response by Kathy Jones and Michael Meyers with respect to comments from jewelers and consumers regarding the proposed jewelry guidelines under consideration by the FTC -- Specifically - proposed rule Section 23.27(b)(1): We were first introduced to Emeryl gemstones in the fall of 2013. Our initial introduction included being able to meet Pat Coughlin at one of his resellers while on a cruise vacation. Prior to seeing the gemstones, the port and shopping staff on the cruise ship were very clear in explaining to us that the newly discovered and available gemstones were a merely a form of beryl and in no way as valuable as a traditional emerald. Our purchases were made that day with a complete and thorough understanding about the type, quality and value of the Emeryl gemstones we were purchasing. We were even provided the opportunity to read the training manual that resellers had been provided by the Yellow Emerald Mining Company. The manual provided us additional insight into: · The history of its discovery · What a Emeryl Jewelstone is which included statements that "Gemologically these are natural premium golden beryl gemstones" and also that the Emeryl gemstone possesses "the same physical properties of a green emerald except for the trace element of iron which causes the color to be yellow". · Key selling benefits including its limited availability, color shifts and clarity · Features of the brand: Emeryl including that it is extremely durable, its price was approximately 1/10th of the price of a similar quality green emerald and that "Emeryl is the same species of gemstones as green emeralds, morganite and aquamarine -- Beryl". In fact the manual even included a 1 page comparison of the Emeryl Jewelstone to the Green Emerald which highlighted similarities and differences The phrase "yellow emerald" absolutely conveyed useful information to the us as consumers. It told us we were purchasing a product that is the same class as an emerald, the same composition as an emerald, and in most cases, has better clarity to typical green emeralds. As consumers who have purchased Emeryl gemstones on multiple occasions and intend to continue to do so, we strongly feel we have been well informed and not misled into thinking that we are buying the equivalent of a green emerald. Furthermore, we fully understand we're buying a product that has some similarities to green emeralds, but some differences, and that the product has nothing like the price or resale value of a green emerald.