DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-61,306

ANALOG DEVICES, INC
SANTA CLARA, 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 revealed that criteria (a)(2)(A)(I.C) and
(a)(2)(B)(II.B) were not met.
The investigation was initiated on April 13, 2007 in
response to a petition filed on behalf of workers of Analog
Devices, Inc., Santa Clara, California. The workers at the
subject firm were engaged in activities related to the trimming
and probing (which includes slicing, dicing and testing) of
wafers in preparation for packaging.
Workers of the Final Test Department within the subject
facility were certified eligible to apply for trade adjustment
assistance on November 21, 2003 (TA-W-53,236). That
certification expired on November 21, 2005.
This investigation revealed that the subject firm did not
import wafers or integrated circuits during the period under
investigation.
The wafers or integrated circuits produced at the subject
plant (and packaged, by an unaffiliated firm) are shipped abroad
and further processed into finished semiconductors before being
returned to the United States. Thus any imports are not like or
directly competitive with the articles produced at the subject
plant.
Corporate-wide sales of wafers and integrated circuits
produced by Analog Devices increased in 2006 compared with 2005,
and also increased in January through March 2007 compared with
the same period in 2006.
The predominant cause of separations at the subject firm is
the shift of production at Santa Clara 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., Santa Clara, 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, as amended.
Signed in Washington, D.C., this 29th day of May 2007


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