DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-61,189

ANALOG DEVICES, INCORPORATED
SUNNYVALE, CALIFORNIA

Negative Determination Regarding Eligibility
To Apply for Worker Adjustment Assistance
And Alternative trade 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 group eligibility
requirements for directly-impacted (primary) workers under Section
222(a) the Trade Act of 1974, as amended, can be satisfied in
either of two ways:
I. Section (a)(2)(A) all of the following must be satisfied:
A. a significant number or proportion of the workers in such
workers' firm, or an appropriate subdivision of the firm,
have become totally or partially separated, or are
threatened to become totally or partially separated;
B. the sales or production, or both, of such firm or
subdivision have decreased absolutely; and
C. increased imports of articles like or directly competitive
with articles produced by such firm or subdivision have
contributed importantly to such workers' separation or
threat of separation and to the decline in sales or
production of such firm or subdivision; or





II. Section (a)(2)(B) both of the following must be satisfied:

A. a significant number or proportion of the workers in such
workers' firm, or an appropriate subdivision of the
firm, have become totally or partially separated, or are
threatened to become totally or partially separated;
B. there has been a shift in production by such workers' firm
or subdivision to a foreign country of articles like or
directly competitive with articles which are produced by
such firm or subdivision; and

C. One of the following must be satisfied:
1. the country to which the workers' firm has shifted
production of the articles is a party to a free trade
agreement with the United States;
2. the country to which the workers' firm has shifted
production of the articles is a beneficiary country
under the Andean Trade Preference Act, African Growth
and Opportunity Act, or the Caribbean Basin Economic
Recovery Act; or
3. there has been or is likely to be an increase in
imports of articles that are like or directly
competitive with articles which are or were produced
by such firm or subdivision.

The investigation was initiated on March 27, 2007 in
response to a petition filed on behalf of workers at Analog
Devices, Inc., Sunnyvale, California. The workers are engaged in
employment related to the production of semiconductor wafers.
The semiconductor wafers produced by the subject plant were
shipped to an affiliated facility for further processing.
The investigation revealed that criteria (a)(2)(A)(A)(I.C)
and (a)(2)(B)(II.B) were not met.


The investigation revealed that corporate-wide sales at the
subject firm increased in 2006 as compared with 2005 and during
the January through March 2007 period over the corresponding 2006
period.
The investigation also revealed that the subject firm did
not import wafers, nor shift a significant portion of wafer
production to a foreign country during the relevant period. The
company shifted some production to Ireland; however that
production is not being imported back to the Untied States.
The investigation further revealed that the layoffs at the
subject plant are related to plant production being transferred
to another domestic location.
In accordance with Section 246 the Trade Act of 1974 (26 USC
2813), as amended, the Department of Labor herein presents the
results of its investigation regarding certification of
eligibility to apply for alternative trade adjustment assistance
(ATAA) for older workers.
In order for the Department to issue a certification of
eligibility to apply for ATAA, the worker group must be certified
eligible to apply for trade adjustment assistance (TAA). Since
the workers are denied eligibility to apply for TAA, the workers
cannot be certified eligible for ATAA.



Conclusion
After careful review, I determine that all workers of Analog
Devices, Inc., Sunnyvale, California, are denied eligibility to
apply for adjustment assistance under Section 223 of the Trade
Act of 1974, and are also denied eligibility to apply for
alternative trade adjustment assistance under Section 246 of the
Trade Act of 1974.
Signed in Washington, D.C. this 25th day of May 2007.


/s/Elliott S. Kushner
______________________________
ELLIOTT S. KUSHNER
Certifying Officer, Division of
Trade Adjustment Assistance