DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-94,202

DLR GROUP A/K/A EPSILON/CATAPULT MARKETING
A SUBSIDIARY OF ALLIANCE DATA
MINNEAPOLIS, MINNESOTA


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 October 4, 2018 on behalf of workers and former workers
of DLR Group also known as Epsilon/Catapult Marketing, a
subsidiary of Alliance Data, Minneapolis, Minnesota (subject
firm). The workers' firm is engaged in activities related to
the supply of marketing and branding services. The worker group
does not include on-site leased workers.
During the course of the investigation, information was
collected from the workers' firm.
Section 222(a)(1) has been met because 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.
Section 222(a)(2)(B) has been met because the workers'
firm has shifted to a foreign country the supply of a(n) the
service like or directly competitive with the service supplied
by the workers which contributed importantly to worker group
separations at the subject firm.
Conclusion
After careful review of the facts obtained in the
investigation, I determine that workers of the subject firm, who
are engaged in activities related to the supply of marketing and
branding 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 DLR Group also known as Epsilon/Catapult
Marketing, a subsidiary of Alliance Data, Minneapolis,
Minnesota, who became totally or partially separated from
employment on or after October 3, 2017 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 22nd day of February 2019.

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