DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-82,353

COMCAST CABLE
WEST DIVISION
REPAIR CALL SERVICE GROUP
BEAVERTON, OREGON

TA-W-82,353A

COMCAST CABLE
WEST DIVISION
BILLING CALL SERVICE GROUP
BEAVERTON, OREGON

TA-W-82,353B

COMCAST CABLE
WEST DIVISION
RESIDENTIAL INBOUND SALES GROUP
INCLUDING ON-SITE LEASED WORKERS FROM MANPOWERGROUP SOLUTIONS
BEAVERTON, OREGON

TA-W-82,353C

COMCAST CABLE
WEST DIVISION
CUSTOMER RETENTION GROUP
BEAVERTON, OREGON

Determinations 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.
Workers of a firm may be eligible for worker adjustment
assistance if they satisfy the criteria of subsection (a), (b)
or (e) of Section 222 of the Act, 19 U.S.C. § 2272(a), (b) and
(e). For the Department of Labor to issue a certification for
workers under Section 222(a) of the Act, 19 U.S.C. § 2272(a),
the following three criteria must be met:
(1) The first criterion (set forth in Section 222(a)(1) of the
Act, 19 U.S.C. § 2282(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.

(2) The second criterion (set forth in Section 222(a)(2) of the
Act, 19 U.S.C. § 2272(a)(2)) may be satisfied in one of two
ways:
(A) Increased Imports Path:
(i) sales or production, or both, at the workers' firm
must have decreased absolutely, AND
(ii) (I) imports of articles or services like or directly
competitive with articles or services produced or
supplied by the workers' firm have increased, OR
(II)(aa) imports of articles like or directly
competitive with articles into which the
component part produced by the workers' firm was
directly incorporated have increased; OR
(II)(bb) imports of articles like or directly
competitive with articles which are produced
directly using the services supplied by the
workers' firm have increased; OR
(III) imports of articles directly incorporating
component parts not produced in the U.S. that are
like or directly competitive with the article
into which the component part produced by the
workers' firm was directly incorporated have
increased.
(iii) the increase in imports described in clause (ii)
contributed importantly to such workers' separation
or threat of separation and to the decline in the
sales or production of such firm.

(B) Shift in Production or Supply Path:
(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
(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; and
(ii) the shift described in clause (i)(I) or the
acquisition of articles or services described in
clause (i)(II) contributed importantly to such
workers' separation or threat of separation.

Section 222(c) of the Act, 19 U.S.C. § 2272(c), defines the
terms "Supplier" and "Downstream Producer." For the Department
to issue a secondary worker certification under Section 222(b)
of the Act, 19 U.S.C. § 2272(b), to workers of a Supplier or a
Downstream Producer, the following criteria must be met:
(1) 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;

(2) 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

(3) 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.

Workers of a firm may also be considered eligible if they
are publicly identified by name by the International Trade
Commission as a member of a domestic industry in an
investigation resulting in a category of determination that is
listed in Section 222(e) of the Act, 19 U.S.C. § 2272(e).
The group eligibility requirements for workers of a firm
under Section 222(e) of the Act, 19 U.S.C. § 2272(e), can be
satisfied if the following criteria are met:
(1) the workers' firm is publicly identified by name by
the International Trade Commission as a member of a
domestic industry in an investigation resulting in--
(A) an affirmative determination of serious injury or
threat thereof under section 202(b)(1);
(B) an affirmative determination of market disruption
or threat thereof under section 421(b)(1); or
(C) an affirmative final determination of material
injury or threat thereof under section
705(b)(1)(A) or 735(b)(1)(A) of the Tariff Act of
1930 (19 U.S.C. 1671d(b)(1)(A) and
1673d(b)(1)(A));

(2) the petition is filed during the 1-year period
beginning on the date on which--
(A) a summary of the report submitted to the
President by the International Trade Commission
under section 202(f)(1) with respect to the
affirmative determination described in paragraph
(1)(A) is published in the Federal Register under
section 202(f)(3); or
(B) notice of an affirmative determination described
in subparagraph (1) is published in the Federal
Register; and

(3) the workers have become totally or partially
separated from the workers' firm within--
(A) the 1-year period described in paragraph (2); or
(B) notwithstanding section 223(b)(1), the 1-year
period preceding the 1-year period described in
paragraph (2).
The investigation was initiated in response to a petition
filed on January 18, 2013 by three workers on behalf of workers
of Comcast Cable (subject firm), West Division, Repair Call
Service Group (TA-W-82,353), Billing Call Service Group (TA-W-
82,353A), Residential Inbound Sales Group (TA-W-82,353B), and
Customer Retention Group (TA-W-82,353C), Beaverton, Oregon.
The workers' firm is engaged in activities related to the supply
of cable, internet, and telephone services. Specifically, the
subject worker groups include workers that engage in employment
related to repair customer service calls (TA-W-82,353), billing
customer service calls (TA-W-82,353A), residential inbound sales
services (TA-W-82,353B), and customer retention services (TA-W-
82,353C). The Residential Inbound Sales Group (TA-W-82,353B)
includes on-site leased workers from ManPowerGroup Solutions.
During the course of the investigation, information was
collected from the workers' firm and the petitioning workers.
With respect to Section 222(a)(2)(A)(ii) of the Act, the
investigation revealed that the subject firm did not import
services like or directly competitive with those supplied by
workers in the Residential Inbound Sales Group and the
Customer Retention Group. Because the workers of the afore-
mentioned groups provide services used internally in support
of the operations of the subject firm, the Department did not
conduct a customer survey.
With respect to Section 222(a)(2)(B) of the Act, the
investigation revealed that the subject firm did not shift the
supply of services provided by the Residential Inbound Sales
Group and the Customer Retention Group, or like or directly
competitive services, to a foreign country or acquire the
services provided by the Residential Inbound Sales Group and
the Customer Retention Group, or like or directly competitive
services, from a foreign country.
With respect to Section 222(b)(2) of the Act, the
investigation revealed that neither the Residential Inbound
Sales Group nor the Customer Retention Group, are either a
Supplier or a 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).
Finally, the group eligibility requirements under Section
222(e) of the Act, have not been satisfied either because the
workers' firm has not been publically identified by name by the
International Trade Commission as a member of a domestic
industry in an investigation resulting in an affirmative finding
of serious injury, market disruption, or material injury, or
threat thereof.
With regard to workers at Comcast Cable, West Division,
Repair Call Service Group (TA-W-82,353) and Billing Call
Service Group, (TA-W-82,353A), Beaverton, Oregon, Section
222(a)(1) has been met because a significant number or
proportion of the workers in the Repair Call Service Group and
the Billing Call Service Group have become totally or partially
separated, or are threatened to become totally or partially
separated.
Section 222(a)(2)(B) has been met because the workers'
firm has acquired from a foreign country services like or
directly competitive with those services supplied by the subject
workers, which contributed importantly to worker group
separations at Comcast Cable, West Division, Repair Call
Service Group (TA-W-82,353) and Billing Call Service Group,
Beaverton, Oregon (TA-W-82,353A).
Conclusion
After careful review of the facts obtained in the
investigation, I determine that the requirements of Section 222
of the Act, 19 U.S.C. § 2272, have not been met and, therefore,
deny the petition for group eligibility of Comcast Cable, West
Division, Residential Inbound Sales Group, including on-site
leased workers from ManPowerGroup Solutions, Beaverton, Oregon
(TA-W-82,353B) and Comcast Cable, West Division, Customer
Retention Group, Beaverton, Oregon (TA-W-82,353C) to apply for
adjustment assistance, in accordance with Section 223 of the
Act, 19 U.S.C. § 2273.
Furthermore, I determine that workers of Comcast Cable,
West Division, Repair Call Service Group and Billing Call
Service Group, Beaverton, Oregon, who are engaged in activities
related to the supply of repair customer service calls and
billing customer service calls, respectively, 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 Comcast Cable, West Division, Repair Call
Service Group, Beaverton, Oregon (TA-W-82,353) and
Comcast Cable, West Division, Billing Call Service Group
Beaverton, Oregon (TA-W-82,353A), who became totally or
partially separated from employment on or after December
27, 2011 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 9th day of April 2013

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