UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,302

RICHMOND TIMES

ADVERTISING PRODUCTION AND DESIGN OUTSOURCING GROUP

INCLUDING WORKERS WHOSE WAGES WERE REPORTED UNDER

BH MEDIA GROUP, INC. AND LEE BHM CORP.

RICHMOND, VIRGINIA

TA-W-96,302A

FREDERICKSBURG FREE LANCE-STAR

ADVERTISING PRODUCTION AND DESIGN OUTSOURCING GROUP

INCLUDING WORKERS WHOSE WAGES WERE REPORTED UNDER

BH MEDIA GROUP, INC. AND LEE BHM CORP.

FREDERICKSBURG, VIRGINIA

TA-W-96,302B

BRISTOL HERALD COURIER

ADVERTISING PRODUCTION AND DESIGN OUTSOURCING GROUP

INCLUDING WORKERS WHOSE WAGES WERE REPORTED UNDER

BH MEDIA GROUP, INC. AND LEE BHM CORP.

BRISTOL, VIRGINIA

TA-W-96,302C

SWVA TODAY

ADVERTISING PRODUCTION AND DESIGN OUTSOURCING GROUP

INCLUDING WORKERS WHOSE WAGES WERE REPORTED UNDER

BH MEDIA GROUP, INC. AND LEE BHM CORP.

WYTHEVILLE, VIRGINIA

Certification Regarding Eligibility

To Apply for Trade Adjustment Assistance for Workers

In accordance with Section 223 of the Trade Act of 1974, as
amended ("the Act"), 19 U.S.C. § 2273, the Department of Labor
("Department") herein presents the results of an investigation
regarding certification of eligibility to apply for Trade
Adjustment Assistance ("TAA") for workers.

The investigation was initiated in response to a TAA petition
dated September 23, 2020 and filed on September 23, 2020 by a State
Workforce Office, on behalf of workers and former workers of
Richmond Times, Advertising Production and Design Outsourcing
group, including workers whose wages were reported under BH
Media Group, Inc. and Lee BHM Corp., Richmond, Virginia (TA-W-
96,302); Fredericksburg Free Lance-Star, Advertising Production
and Design Outsourcing group, including workers whose wages were
reported under BH Media Group, Inc. and Lee BHM Corp.,
Fredericksburg, Virginia, (TA-W-96,302A); Bristol Herald
Courier, Advertising Production and Design Outsourcing group,
including workers whose wages were reported under BH Media Group,
Inc. and Lee BHM Corp., Bristol, Virginia, (TA-W-96,302B); and
SWVA Today, Advertising Production and Design Outsourcing group,
including workers whose wages were reported under BH Media Group,
Inc. and Lee BHM Corp., Wytheville, Virginia, (TA-W-96,302C);
(hereafter referred to as the "worker group"). During the
investigation the petitioner clarified the worker group, thus
paring down the worker group locations.

In accordance with 20 C.F.R. 618.110 a worker group is
defined as, ""¦inclusive of teleworkers and staffed workers."

The worker group is engaged in activities related to the
supply of advertising production and design outsourcing services
and workers are not separately identifiable by service.

The petition alleged that worker separations, or threats
thereof, were due to foreign trade due to work being outsourced
domestically and internationally.

During the course of the investigation, the Department
collected information from the petitioner(s), the workers' firm,
and other relevant sources.

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:

Employment Criterion

(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.

20 C.F.R. 618.225(c)(1)(ii) states that an "Analysis of
separation data must generally consist of a: "(A) Comparison of
employment on the petition date to employment on the date that is
1 year prior to the petition date; (B) Review of employment
activity during the 1-year period prior to the petition date; and
(C) Review of evidence provided by the workers' firm regarding
actual and threatened separations that occur, or are scheduled to
occur, after the petition date."

The Department determines that the employment criterion has
been met.

Shift/Acquisition Criterion

(2)(B)(i)(I) there has been a shift by the workers' firm to
a foreign country in the production of articles or the
supply of services like or directly competitive with
articles which are produced or services which are
supplied by such firm; or

(II) such workers' firm has acquired from a foreign
country articles or services that are like or directly
competitive with articles which are produced or services
which are supplied by such firm;

According to 20 C.F.R. 618.225(c)(2)(ii), "Analysis of
acquisition data must generally consist of a: (1) Comparison of
shift data on the petition date to shift/acquisition data that is
1 year prior to the petition date; (2) Review of shift/acquisition
activity during the 1-year period prior to the petition date; and
(3) Review of evidence provided by the workers' firm regarding
shift/acquisition activity scheduled to occur after the petition
date."

The Department determines that the acquisition criterion has
been met.

Contributed Importantly Criterion

(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.

Sec. 222(c) of the Trade Act and 20 C.F.R. 618.110 defines
contributed importantly as "a cause that is important but not
necessarily more important than any other cause."

According to 20 C.F.R. 618.225(c)(3)(i), "Analysis of impact
of acquisition data on worker separations must generally consist
of determining: (A) Whether there are one or more events or factors
that lessen or sever the causal nexus between the acquisition
activity and worker separations or threat of separation; (B) What
percentage of the workers' firm sales or production declines was
attributable to the firm's acquisition activity; (C) Whether
operations at the workers' firm domestic facility or facilities
decreased at the same or at a greater rate than contractor or
licensee operations in the foreign country; and (D) Whether there
are other events or factors that mitigate or amplify the impact of
acquisition activity on the workers' firm. (ii) Whether there are
other events or factors that mitigate or amplify the impact of
shift activity on the workers' firm. (B) The impact may be
determined using a quantitative or qualitative analysis."

The Department determines that the contributed importantly
criterion has been met.

Conclusion

After careful review of the facts obtained in the
investigation, I determine that workers of Richmond Times,
Advertising Production and Design Outsourcing group, including
workers whose wages were reported under BH Media Group, Inc. and
Lee BHM Corp., Richmond, Virginia (TA-W-96,302); Fredericksburg
Free Lance-Star, Advertising Production and Design Outsourcing
group, including workers whose wages were reported under BH
Media Group, Inc. and Lee BHM Corp., Fredericksburg, Virginia,
(TA-W-96,302A); Bristol Herald Courier, Advertising Production
and Design Outsourcing group, including workers whose wages were
reported under BH Media Group, Inc. and Lee BHM Corp., Bristol,
Virginia, (TA-W-96,302B); and SWVA Today, Advertising Production
and Design Outsourcing group, including workers whose wages were
reported under BH Media Group, Inc. and Lee BHM Corp.,
Wytheville, Virginia, (TA-W-96,302C); who are engaged in
activities related to the supply of advertising production and
design outsourcing 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 Richmond Times, Advertising Production and
Design Outsourcing group, including workers whose wages
were reported under BH Media Group, Inc. and Lee BHM Corp.,
Richmond, Virginia (TA-W-96,302); Fredericksburg Free
Lance-Star, Advertising Production and Design Outsourcing
group, including workers whose wages were reported under BH
Media Group, Inc. and Lee BHM Corp., Fredericksburg,
Virginia, (TA-W-96,302A); Bristol Herald Courier,
Advertising Production and Design Outsourcing group,
including workers whose wages were reported under BH Media

Group, Inc. and Lee BHM Corp., Bristol, Virginia, (TA-W-
96,302B); and SWVA Today, Advertising Production and Design
Outsourcing group, including workers whose wages were
reported under BH Media Group, Inc. and Lee BHM Corp.,
Wytheville, Virginia, (TA-W-96,302C); who became totally or
partially separated from employment on or after September 23,
2019 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 29th day of April, 2021.

/s/ Hope D. Kinglock
_______________________
HOPE D. KINGLOCK

Certifying Officer, Office of

Trade Adjustment Assistance