DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-54,024

MILFORD MARKETING, INC.
FRANKLIN, MICHIGAN

Negative Determinations Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended (19 USC 2273), the Department of Labor herein presents
the results of an investigation regarding certification of
eligibility to apply for worker adjustment assistance.
The investigation was initiated on January 15, 2004 in
response to a petition filed on behalf of workers at Milford
Marketing Inc., Frankford, Michigan. Workers were engaged in
operating a call center, selling subscriptions, fund raising and
similar activities.
The investigation revealed that the petitioning workers of
this firm or subdivision do not produce an article within the
meaning of Section 222 of the Act. The Department of Labor has
consistently determined that the performance of services does
not constitute production of an article, as required by Section
222 of the Trade Act of 1974, and this determination has been
upheld in the U.S. Court of Appeals.


Workers at the firm or subdivision may be certified only if
their separation was caused importantly by a reduced demand for
their services from a parent firm, a firm otherwise related to
their firm by ownership, or a firm related by control.
Additionally, the reduction in demand for services must
originate at a production facility whose workers independently
meet the statutory criteria for certification, and the reduction
must directly relate to the product impacted by imports. These
conditions have not been met for workers at this facility.
Conclusion
After careful review, I determine that all workers of
Milford Marketing Inc., Frankford, Michigan are denied
eligibility to apply for adjustment assistance under Section 223
of the Trade Act of 1974.
Signed in Washington, D. C., this 2nd day of February 2004.

/s/ Richard Church
______________________________
RICHARD CHURCH
Certifying Officer, Division of
Trade Adjustment Assistance