UNITED STATES DEPARTMENT OF LABOR

Employment and Training Administration

TA-W-96,562

LEE ENTERPRISES, INCORPORATED
LEE BHM CORP., OMAHA WORLD-HERALD, ADVERTISING DEPARTMENT
INCLUDING WORKERS WHOSE WAGES WERE REPORTED
UNDER LEE BHM CORP., AND UNDER BH MEDIA GROUP, INC.
OMAHA, NEBRASKA

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 October 16, 2020 and
filed on October 19, 2020 by a State Workforce Office, on behalf of workers and former workers of
Lee Enterprises, Incorporated, Lee BHM Corp., Omaha World-Herald, Advertising Department,
Omaha, Nebraska (hereafter referred to as the "worker group"). The group of workers also consists
of workers whose wages were reported under Lee BHM Corp., and under BH Media Group, Inc.
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 production of print and digital
advertisements and are not separately identifiable by product.

The petition alleged that worker separations, or threats thereof, were due to foreign trade
because, "Graphic Design Department was outsourced to India for the Omaha World Herald after
it was purchased by Lee Enterprises from BH Media Group earlier this year. The same department
was outsourced several years ago in several other papers owned by Lee Enterprises".

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
Lee Enterprises, Incorporated, Lee BHM Corp., Omaha World-Herald, Advertising Department,
including workers whose wages were reported under Lee BHM Corp., and under BH Media Group,
Inc., Omaha, Nebraska, who are engaged in activities related to the production of print and digital
advertisements 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 Lee Enterprises, Incorporated, Lee BHM Corp., Omaha World-Herald,
Advertising Department, including workers whose wages were reported under Lee BHM
Corp., and under BH Media Group, Inc., Omaha, Nebraska, who became totally or partially
separated from employment on or after October 16, 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 7th day of March, 2021.

/s/ Jessica R. Webster
_______________________
JESSICA R. WEBSTER
Certifying Officer, Office of
Trade Adjustment Assistance