Proposed Consent Agreement In the Matter of Transitions Optical, Inc., FTC File No. 091-0062
To whom it may concern: This is a response to your ruling "against" Transitions Optical. Although the issues between manufacturers of photochromic materials "should" be resolved with your 4-0 vote and ruling, please look at the "bigger" picture with Essilor in the focus of your lenses. You must be aware Essilor is a 49% shareholder of Transitions Optical with PPG Industries. The FTC has not done enough to limit the domination Essilor continues to have in the wholesale manufacturing of optical lenses with or without this ruling. We expect Essilor uses the profits from all of its world wide businesses to nearly completely dominate the wholesale optical lens manufacturing business in the United States today. Although the "rest of the world" is outside of the United States, and outside of our United States Department of Justice system, Essilor now nearly completely dominates the Australian wholesale optical lens market today, for example. Essilor uses aggressive tactics to gain market share with coupons for "free" product, free anti-reflective coatings, and more, for which independently owned companies cannot compete. Add "buying up" other wholesale optical laboratories, Essilor has near total domination in the United States today. Essilor continues to purchase companies in the United States nearly every month. These purchases are more often purchases of 80% of the company stock with a "buy-out" later on (sometimes in two years), if the "sales of the business are maintained". And if you wish to really know the "real" numbers of wholesale optical laboratories that Essilor actually purchases, the companies purchased, and for how much, we suggest you subpeona the records of HPC Puckett & Company: Thomas F. Puckett Managing Director PO Box 9063 Rancho Santa Fe, CA 92067 858-756-4915 Office 858-204-8777 They also have a Topeka Office: Jason A. Meyer Managing Director 5835 SW 29th Street Suite 203 Topeka, KS 66614 785-273-0017 Office 785-845-7550 Mobile HPC Puckett & Company advertise "We continue to serve the Optical and Communications Industries in completing over $7.0 Billion in transactions for our clients." The FTC is "asleep at the wheel" in regards to Essilor, overall. It appears the FTC thinks that the total domination of the wholesale optical business in the United States today by three companies is enough competition for Essilor, with Essilor being one of the three. The general public is not aware how they are effected, only that their glasses come "from somewhere else." Essentially, Essilor can do what it wants, any time, any place. The largest wholesale optical business in the United States today is Essilor, a French company. It is also the largest on Earth. The second and third players in the United States today are Zeiss and Hoya. German and Japanese ownership, respectively. Don't overlook Vision Service Plan either. VSP is now using "mergers and acquisitions" in the same way as Essilor. Using history as your guide, we suggest you look up Bausch and Lomb, and American Optical. These companies are your guide as to what happened a few decades ago, and what to do about it. The FTC came in and "fixed" the problem of "domination". You can do the same today. It is time for the FTC to come in and "fix" the problem of domination of the wholesale optical lens manufacturing business again, only the current company name now, is Essilor. Respectfully submitted.