DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-73,581

DELL PRODUCTS LP
A SUBSIDIARY OF DELL, INC.
EAST COAST FULFILLMENT CENTER
NASHVILLE, TENNESSEE

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(c) of the Act, 19 U.S.C. § 2272(c), can be
satisfied if the following criteria are met:
I. a significant number or proportion of the workers in
the workers' firm or an appropriate subdivision of the
firm have become totally or partially separated, or
are threatened to become totally or partially
separated;

II. the workers' firm is a Supplier or Downstream Producer
to a firm that employed a group of workers who
received a certification of eligibility under Section
222(a) of the Act, 19 U.S.C. § 2272(a), and such
supply or production is related to the article or
service that was the basis for such certification; and

III. either
(A) the workers' firm is a supplier and the component
parts it supplied to the firm described in paragraph
(2) accounted for at least 20 percent of the
production or sales of the workers' firm; or
(B) a loss of business by the workers' firm with the firm
described in paragraph (2) contributed importantly to
the workers' separation or threat of separation.

Section 222(d) of the Act, 19 U.S.C. § 2272(d), defines the
term "Supplier" as "a firm that produces and supplies directly
to another firm component parts for articles, or services used
in the production of articles or in the supply of services, as
the case may be, that were the basis for a certification of
eligibility under subsection (a) [of Section 222 of the Act] of
a group of workers employed by such other firm."
The investigation was initiated in response to a petition
filed on February 26, 2010 on behalf of workers of Dell
Products LP, a subsidiary of Dell, Inc., East Coast
Fulfillment Center, Nashville, Tennessee. The workers are
engaged in activities related to final assembly, packaging, and
shipping services of computer systems.
The investigation revealed that workers of East Coast
Fulfillment Center, who supply final assembly, packaging, and
shipping services, meet the criteria as Suppliers for
secondary worker certification.
Criterion I has been met because a significant number of
the workers at East Coast Fulfillment Center have been totally
or partially separated or threatened with separation during
the relevant period.
Criterion II has been met because the East Coast
Fulfillment Center supplies final assembly, packaging, and
shipping services directly to a firm with a TAA-certified
worker group, and the services supplied were related to the
production of articles that were the basis for the TAA
certification.
Criterion III has been met because the loss of business
by the East Coast Fulfillment Center with the TAA-certified
firm, with respect to final assembly, packaging, and shipping
services, contributed importantly to worker separations at the
Nashville, Tennessee facility.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Dell Products LP, a
subsidiary of Dell, Inc., East Coast Fulfillment Center,
Nashville, Tennessee, who supply final assembly, packaging,
and shipping services, meet the worker group certification
criteria under Section 222(c) of the Act, 19 U.S.C. § 2272(c).
In accordance with Section 223 of the Act, 19 U.S.C. § 2273, I
make the following certification:


"All workers of Dell Products LP, a subsidiary of Dell,
Inc., East Coast Fulfillment Center, Nashville, Tennessee,
who became totally or partially separated from employment
on or after February 16, 2009, 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 23rd day of November, 2010


/s/Michael W. Jaffe
______________________________
MICHAEL W. JAFFE
Certifying Officer, Office of
Trade Adjustment Assistance