U.S. DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-62,630

LLINK TECHNOLOGIES, LLC
BROWN CITY, MICHIGAN

Notice of Affirmative Determination
Regarding Application for Reconsideration

By applications dated March 3, 2008 a company official
requested administrative reconsideration of the Department of
Labor’s Notice of Negative Determination Regarding Eligibility to
Apply for Worker Adjustment Assistance, applicable to workers and
former workers of the subject firm. The denial notice was signed
on January 29, 2008 and published in the Federal Register on
February 13, 2008 (73 FR 8370).
The initial investigation resulted in a negative
determination based on the finding that imports of interior trim
automotive components and subassemblies did not contribute
importantly to worker separations at the subject firm and no
shift of production to a foreign source occurred.
In the request for reconsideration, the petitioner provided
additional information regarding the subject firm customers.
The Department has carefully reviewed the requests for
reconsideration and the existing record and determined that the
Department will conduct further investigation to determine if the
workers meet the eligibility requirements of the Trade Act of
1974.
Conclusion
After careful review of the applications, I conclude that
the claim is of sufficient weight to justify reconsideration of
the Department of Labor's prior decision. The application is,
therefore, granted.
Signed in Washington, D.C., this 11th day of March, 2008.

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

4510-FN-P


DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-62,630

LLINK TECHNOLOGIES, LLC
BROWN CITY, MICHIGAN

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 January 3, 2008 in response
to a petition filed by a company official on behalf of workers at
Llink Technologies, LLC, Brown City, Michigan. The workers at the
subject firm produce interior trim automotive components and sub-
assemblies (sun visors).
The subject firm on May 10, 2007 was denied eligibility to
apply for trade adjustment assistance (TAA) (TA-W-61,214) based on
no import increases and/or a shift in production abroad.
The investigation revealed that criteria (a)(2)(A)(I.C) and
(a)(2)(B)(II.B) were not met.
The investigation revealed that the subject firm did not
import interior trim automotive components and sub-assemblies (sun
visors) during 2006 or 2007, nor shift production to a foreign
country during the relevant period.
The investigation further revealed that the subject firm’s
employment decline was attributed to a loss of export sales.
In addition, 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 of the facts obtained in this
investigation, I determine that all workers of Llink Technologies,
LLC, Brown City, Michigan, are denied eligibility to apply for
adjustment assistance under Section 223 of the Trade Act of 1974
and alternative trade adjustment assistance under Section 246 of
the Trade Act of 1974.
Signed in Washington, D.C. this 29th day of January, 2008

/s/ Elliott S. Kushner

______________________________
ELLIOTT S. KUSHNER
Certifying Officer, Division of
Trade Adjustment Assistance





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