DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-71,150

SETON COMPANY
AMERICAS SALES DIVISION
FARMINGTON HILLS, MICHIGAN

Certification Regarding Eligibility
To Apply for Worker Adjustment Assistance

In accordance with Section 223 of the Trade Act of 1974, as
amended ("Act"), 19 U.S.C. § 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 workers of a firm
under Section 222(a) of the Act, 19 U.S.C. § 2272(a), are
satisfied if the following criteria are met:
I. The first criterion (set forth in Section 222(a)(1) of the
Act, 19 U.S.C. § 2272(a)(1)) requires that a significant
number or proportion of the workers in the workers' firm
must have become totally or partially separated or be
threatened with total or partial separation.

II. The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied if either:

(i)(I) there has been a shift by the workers' firm to a
foreign country in the production of articles or
supply of services like or directly competitive with
those produced/supplied by the workers' firm; or
(i)(II) there has been an acquisition from a foreign
country by the workers' firm of articles/services that
are like or directly competitive with those
produced/supplied by the workers' firm.



III. The third criterion requires that the shift/acquisition
must have contributed importantly to the workers'
separation or threat of separation. See Section
222(a)(2)(B)(ii) of the Act, 19 U.S.C. §
2272(a)(2)(B)(ii).

The investigation was initiated in response to a petition
filed on June 11, 2009 by a company official on behalf of
workers of Seton Company, Americas Sales Division, Farmington,
Hills, Michigan. The workers are engaged in employment related
to the supply of customer care, sales and marketing services.
The worker group excludes workers at the Seton Company,
Farmington Hills, Michigan facility who transferred to and are
then later separated from the Seton Company, West Bloomfield,
Michigan facility. The worker group excludes workers at the
Seton Company, Farmington Hills, Michigan facility who are not
a member of the American Sales Division.
The investigation revealed that workers of Seton Company,
Americas Sales Division, Farmington, Hills, Michigan, who are
engaged in employment related to the supply of customer care,
sales and marketing services, meet the criteria for
certification.
Criterion I has been met because a significant proportion
or number of workers at Seton Company, Americas Sales
Division, Farmington, Hills, Michigan, have been totally or
partially separated, or threatened with such separation,
during the relevant period.
Criterion II has been met because Seton Company, Americas
Sales Division, Farmington, Hills, Michigan, has shifted to a
foreign country services like or directly competitive with the
customer care, sales and marketing services supplied by the
worker group.
Criterion III has been met because the shift of customer
care, sales and marketing services to Costa Rica contributed
importantly to worker group separations at Seton Company,
Americas Sales Division, Farmington, Hills, Michigan.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Seton Company,
Americas Sales Division, Farmington, Hills, Michigan, who are
engaged in employment related to the supply of customer care,
sales and marketing services, meet the worker group
certification criteria under Section 222(a) of the Act, 19
U.S.C. § 2272(a). In accordance with Section 223 of the Act, 19
U.S.C. § 2273, I make the following certification:



"All workers of Seton Company, Americas Sales Division,
Farmington, Hills, Michigan, who became totally or
partially separated from employment on or after June 10,
2008, through two years from the date of certification, and
all workers in the group threatened with total or partial
separation from employment on the date of certification
through two years from the date of certification, are
eligible to apply for adjustment assistance under Chapter 2
of Title II of the Trade Act of 1974, as amended."
Signed in Washington, D.C., this 19th day of March, 2010


/s/Del Min Amy Chen
______________________________
DEL MIN AMY CHEN
Certifying Officer, Division of
Trade Adjustment Assistance