DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-91,830

EPSILON DATA MANAGEMENT, LLC
A SUBSIDIARY OF ADS ALLIANCE DATA SYSTEMS, INC.
INCLUDING ON-SITE LEASED WORKERS FROM SOGETI AND THEOREM
IRVINE, TEXAS


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:
(1) a significant number or proportion of the
workers in such workers' firm have become totally or
partially separated, or are threatened to become
totally or partially separated;
(2)(B)(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/acquisition must have contributed
importantly to the workers' separation or
threat of separation.

The investigation was initiated in response to a petition
filed on May 20, 2016 by a company official on behalf of workers
of Epsilon Data Management, LLC, a subsidiary of ADS Alliance
Data Systems, Inc., Irvine, Texas (Epsilon Data Management,
LLC). The workers' firm is engaged in activities related to the
supply of data driven marketing and consulting solutions and
services.
The subject worker group includes on-site leased workers
from Sogeti and Theorem
During the course of the investigation, information was
collected from the petitioner/workers' firm and public sources.
Section 222(a)(1) has been met because a significant
number or proportion of the workers in Epsilon Data Management,
LLC 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 shifted to a foreign country the supply of services
like or directly competitive with the data driven marketing and
consulting solutions and services supplied by the workers which
contributed importantly to worker group separations at Epsilon
Data Management, LLC.

Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of Epsilon Data
Management, LLC, who are engaged in activities related to the
supply of data driven marketing and consulting solutions and
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 Epsilon Data Management, LLC, a subsidiary
of ADS Alliance Data Systems, Inc., including on-site
leased workers from Sogeti and Theorem, Irvine, Texas, who
became totally or partially separated from employment on or
after May 16, 2015, 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 10th day of August 2017.
/s/Del Min Amy Chen
______________________________
DEL MIN AMY CHEN
Certifying Officer, Office of
Trade Adjustment Assistance