July 19, 2016 Mr. Joshua Teitelbaum, Chairman Office of Textiles …web.ita.doc.gov/tacgi/PeruTPAReqTrack.nsf... · 2016. 8. 15. · How contacted and on what date: E-mail, on September

July 19, 2016

Mr. Joshua Teitelbaum,

Chairman

Committee for the Implementation of Textile Agreements

Office of Textiles and Apparel

U.S. Department of Commerce

14th and Constitution Ave., NW

Washington, DC 20230

Subject: Commercial Availability Request Under the United States-Colombia Trade

Promotion Agreement Implementation Act PUBLIC VERSION

Dear Mr. Teitelbaum:

On behalf of Spataro Napoli S.A. and pursuant to Section 203(o)(4) of the United States-

Colombia Trade Promotion Agreement (U.S.-Colombia TPA) Implementation Act and the

Interim Procedures set forth in 77 Fed. Reg. 66588 (November 6, 2012), Agathon Associates

requests that the fabrics described herein be added to the list in Annex 3-B of the U.S.-Colombia

TPA ("CTPA") in an unrestricted quantity. Spataro Napoli S.A. was founded by Don Domingo

Spataro in 1958 in the city of Santiago de Cali, Colombia, the company is focused on the

production of the best shirts for men and boys. Among the brand names under which Spataro

Napoli's shirts are marketed are Camarucci, Roland, Arrow, and Manhattan.

1. Detailed Product Description.

Woven fabrics of cotton, containing by weight 85% or more of combed cotton, suitable for use in

the production of men's and boys' shirts and similar apparel as specified in Attachment A:

Product Specifications. This product is what is commonly known in the trade as "men's shirting

fabric," and while it may have other uses, the production of men's dress shirts is a major end use.

We understand that under the CTPA commercial availability process end use is not, as is the case

with some other procedures, relevant, and we introduce it here merely to help clarify why the

single subject fabrics is classified under nine different subheadings in the Harmonized Tariff

Schedule of the United States ("HTSUS"). The HTSUS breaks out woven fabric of 85% or more

of combed cotton by type of weave and stage of finishing, all of which might be men's shirting

fabrics.

PUBLIC VERSION U.S.-Colombian Commercial Availability Request

Agathon Associates, on behalf of Spataro Napoli S.A

July 19, 2016, Page 2 of 14

What distinguishes men's shirting fabrics is the high yarn count (the fineness of the yarns

used in forming the fabrics). Within the trade, men's shirting fabric is regarded a single

recognizable product, even though it is provided for in nine HTSUS subheadings.

2. Quantity

Spataro Napoli S.A requires 750,000 linear meters of fabric per year, delivered in equal

monthly shipments, the first shipment due 60 days following order placement, for use in

the productions of men's shirts and similar apparel in Colombia for export to the United

States under the provisions of the CTPA.

3. Due Diligence

(i) Generally.

For the record of names and addresses of suppliers contacted see Attachment B.

(ii) Identification of U.S.-Colombia TPA Suppliers.

Spataro's representatives in the United States made initial contact with:

(a) The National Council of Textile Organizations,

(b) The U.S. Department of Commerce Office of Textiles and Apparel "Made

in U.S.A." database and, and

(c) U.S. yarn cotton yarn spinners (to obtain the names of their U.S. or

Colombian customers who might be able to weave the subject fabrics).

In determining the commercial availability of the subject product in Colombia, Spataro's

representative in Colombia and Julio Spataro, Manager for Spataro Napoli S.A.,

consulted:

(a) Cotton, Fibers, Textile and Apparel Chamber, ANDI (National Business

Association of Colombia),

(b) Apparel Export Management Office, ProColombia (Colombia’s Export

Promotion Agency), and

(c) Trade Relations Office, Ministry of Trade, Industry and Tourism.



July 19, 2016, Page 3 of 14

(iii) Use of Third Parties and Business-to-Business Contact.

The U.S. third-party representatives for Spataro were David Trumbull, Principal of

Agathon Associates and former Vice President for International Trade for the National

Textile Association, and Nick Hahn, former President of Cotton Incorporated, and

President & CEO of Hahn International, Ltd.

The Colombian third-party representative for Spataro was Paulina Jaramillo, an

independent consultant and former Sourcing Manager for Latin America for VF

Corporation with more than 10 years working in Colombia on product development and

vendor management.

These third parties assisted Spataro Napoli S.A in identifying potential suppliers and

introduced Julio Spataro, Manager, Spataro Napoli S.A to those potential supplies.

Substantive communications were then handled directly between Spataro Napoli S.A and

the individual potential supplier companies, and were made at the level appropriate to

communicate information on the fabrics needed, the specifications and standards, and the

reason for those standards.

(iv) Description of the Subject Product

Attachment A: Product Specification was provided to all potential suppliers and

represents reasonable product specifications.

(v) Provision of Samples

Spataro provided samples to Inman, and we understand they were viewed by Cotswold as

well. No other entities were provided samples and none were provided to Spataro.

(vi) Substitutability of Products

While woven fabrics of 85% or more of combed cotton yarn coarser than 60s are

available, they are not substitutable. Finer yarns yield a woven fabric which is

distinctively different in appearance and weight from fabrics of coarser yarns. Men's

dress shirts cannot be made of such heavier fabric of coarser yarns.

4. Substitutability of Products

One U.S. weaver, Hamrick Mills, offered a fabric woven of coarser yarns (40Nm), such

fabric is, for the reasons stated above, not suitable for the type of shirts that Spataro

makes. Colombian weavers Textilia and Fabricato also offered fabrics, but they too were

40s.



July 19, 2016, Page 4 of 14

Attachment A: Product Specifications

Woven fabric of combed cotton yarns, of 85% or more by weight of cotton, of yarn count

of 60Nm or higher (60 Nm or finer), of various constructions and finishes, classified in

Harmonized Tariff Schedule of the United States subheadings 5208.22, 5208.29,

5208.32, 5208.33, 5208.39, 5208.42, 5208.43, 5208.49, and 5208.52.

Quantity needed is 750,000 liner meters.

Attachment B: Due Diligence Communications

1. Trade association or other entity, other than weavers, in USA or Colombia

Name of the organization: National Council of Textile Organizations, US

The name and title of the person contacted with contact information:

Auggie Tantillo, President, [email protected]

Sara Beatty, Director of International Trade, [email protected]

202-684-2999

1701 K St, NW # 625

Washington, DC 20006

How contacted and on what date: E-mail, on September 3, 2015.

Contacts:

Sep 3, 2015. Consolidated list of yarn and fabrics required by Colombian companies,

including woven fabric of 85% or more of combed cotton of yarns of 60s or fine, was

sent to NCTO to be distributed to its members.

Sep 23-25, 2015. The following companies responded to the distribution email: Milken

& Company, Burlington Industries, Copland Industries and Metcalf Brothers. Did not

receive any communication from producers interested in the 100% cotton fabrics.

o Burlington interested in three companies on consolidated list, all looking for

wool fabrics. Did not express interest in Spataro request.

o Metcalf (a division of The Brickle Group, manufacturers of wool and wool

blend fabrics for uniforms) confirmed over the phone that products are 100%

made off-shore.

o Milken interested in the synthetic woven fabrics, no interest in cotton expressed.

o Copland interested in the 100% polyesters, no interested in cotton expressed.

mailto:[email protected]




July 19, 2016, Page 5 of 14

Name of the organization: National Business Association of Colombia (ANDI)


Juliana Calad, Director of Chamber: Cotton, Fibers, Textile and Apparel,

[email protected]

+57 (1) 326 8500

Calle. 73 No. 8-13 Torre A, piso 6

Bogota, Colombia

How contacted and on what date: Meetings, e-mail.

Contacts:

May 5, 2015. First meeting held with ANDI to discuss company needs/fabrics and

sourcing challenges under CTPA.

July 6, 2015: List of Spataro’s technical specs sent to ANDI for dissemination to

Colombian fabric producers.

July 10, 2015: Juliana Calad sends technical specs to Fabricato, Coltejer, PatPrimo,

Telas Liverpool, Linda Lana, Protela, and Textilia

July – December 2015: continuous coordination with ANDI, ProColombia, and

Colombia’s Ministry of Trade to reach out to all potential Colombian suppliers.

Name of the organization: Colombia Export Agency (ProColombia)


Catalina Hernandez, Manager of Apparel Exports, [email protected]

+57 (1) 5600 100

Calle 28 N. 13 A 15 Piso 36

Bogotá, Colombia

How contacted and on what date: Meetings, e-mail.

Contacts:

May 4, 2015. First meeting held with ProColombia to discuss possibility of assisting

Colombian companies with short-supply process. List of potential companies and

products were discussed; Spataro men’s shirting fabric was included.

May 5, 2015: ProColombia contacts trade associations and interested parties to inform

them of a potential project to help companies with short-supply identified.

July 2015: ProColombia held teleconferences and conducted plant visits with

companies to better understand products in question. (Spataro was visited on Aug 13,

2015)

July – December 2015: continuous coordination with ANDI, ProColombia, and

Colombia’s Ministry of Trade to reach out to all potential Colombian suppliers and

gather lessons learned on short-supply process under CTPA.




July 19, 2016, Page 6 of 14

2. Weavers in Colombia or USA contacted

Name of the organization: Hamrick Mills Inc, US


Jim Hopkins, Sales, [email protected]

Roy Lockett, Sales, [email protected]

864-380-7769

P.O Box 48

Gaffney, SC 29342

How contacted and on what date: E-mails

Did you send or receive any samples? No

Was any substitutable product offered? If so, why was it necessary to reject it? Hamrick

offered 40's yarn. This kind of yarn is coarser than Spataro's requirements

Contacts:

Oct 27, 2015: Hamrick Mills was contacted by email (Jim Hopkins and Roy Lockett of

Hamrick Mills).

Oct 30, 2015: Jim Hopkins responded saying request was beyond its manufacturing

capabilities. Their maximum end count is 128 epi in a 67" gr. Width.

Jan 18, 2016: Julio Spataro emails Jim Hopkins (October contact was by a third-party

representative, Hamrick offered a substitutable yarn, so Spataro made direct business-

to-business contact) to inquire about capacity to produce, placing order for AYN 50’s to

140’s and requesting delivery within 60 days.

Jan 18, 2016: Jim Hopkins notes “there may be specialty weavers out there that we are

not aware of who could make this cloth, but I don’t know who or where they are.”

Name of the organization: Mount Vernon Mills, US


Ned Cochrane, VP, and Secretary, [email protected], 864-688-7164

P.O. Box 100

503 S. Main Street,

Mauldin, SC 29662



Was any substitutable product offered? If so, why was it necessary to reject it? No

Contacts:

Oct 16, 2015: email sent to Ned Cochrane expressing interest in sourcing cotton fabric

for men’s shirting AYN: 50’s – 140/2.

Oct 16, 2015: response from Ned Cochrane; no interest. "Does not fit our current

product mix."

Jan 18, 2016: Julio Spataro emails Ned Cochrane to inquire about capacity to produce,

placing order for AYN 50’s to 140’s and requesting delivery within 60 days. No

response.

Jun 17, 2016: Follow-up email sent to Ned Cochrane requesting re-confirmation on

capacity to produce. No response received. (Re-contact because MV's initial response






July 19, 2016, Page 7 of 14

could be read ambiguously as "not interested now" or "not interested at all.)

Jun 22, 2016: Tried reaching Ned Cochrane by phone; left voicemail.

Name of the organization: Inman, US


Norm Chapman , President, [email protected]

Rob Chapman, Chair, [email protected]

Sales Dept, [email protected]

Davis Patton, VP Sales, [email protected], 864-472-0256

864-472-2121

PO Box 207

300 Park Rd.

Inman, SC 29349


Did you send or receive any samples? Yes

Was any substitutable product offered? No

Contacts:

Oct 15, 2015: email sent to Norm and Rob Chapman and to Sales Department

expressing interest in sourcing cotton fabric for men’s shirting AYN: 50’s – 140/2. No

response received.

Jan 18, 2016: Julio Spataro emails Norm and Rob Chapman to inquire about capacity to

produce, placing order for AYN 50’s to 140’s and requesting delivery within 60 days.

Jan 19, 2016: Norm Chapman responds stating they have the ability to make these

fabrics and have done so on many occasions.

Jan 20, 2016 (phone conversation and email exchange with Davis Patton) Inman is a

greige goods weaver, no finishing capability, but works with a contract finisher in the

US, Cotswold Industries, who has the potential for supplying at least up to 80/1’s and

80/1’s/2ply.

Jan 27, 2016 Julio Spataro emails Davis Patton to confirm he is sending samples and

would like to receive a price quote for fabrics meeting the yarn-forward rule under the

CTPA. Samples sent via DHL on Jan 27,2016. Letter is sent with the samples requesting

price quote based on 1,000 meters per color for AYN 50’s-120/2.

Feb 1, 2016 Inman (Davis Patton) confirms receipt of samples and wants to know

volume required.

Feb 3, 2016 Julio Spataro responds to Patton requesting price quote.

Feb 11, 2015 Spataro resends his email to Patton requesting price quote for samples

sent to Inman.

Feb 11, 2015 Patton responds telling Spataro to contact Steve Marrandino at Cotswold

first for the finishing.

Feb 15, 2016 Emailed Patton confirming Spataro prefers to deal directly with the fabric

producer, i.e. Inman Mills, rather than the converter, Cotswald, and requesting Inman

respond with confirmation on finished prices, minimums, deliveries, put-up etc.

Feb 15, 2016 Davis Patton responds saying they have capability to run greige yarn dyed

shirting fabrics, but are not a fabric finisher. Inman is requesting Spataro communicate

directly with a finisher or converter regarding their needs.

Feb 16, 2016 Spataro sends email to Cotswold (Steve Marrandino), with a copy to







July 19, 2016, Page 8 of 14

Inman, letting them know fabrics have been sent to Inman with a request for quote.

Spataro asks Cotswold to contact Inman for the cuttings.

Feb 18, 2016 Julio Spataro emails Davis Patton requesting price quotes for greige

goods. (No response from Inman.)

Feb 19, 2016 Cotswold (Steve Marrandino) confirms Cotswold has looked at the fabrics

and cannot make them. Davis Patton from Inman was copied on the email.

Feb 23, 2016 Julio Spataro requests price quotes from Inman based on samples sent via

DHL on Jan 27, 2016. No response.

Name of the organization: Cotswold Industries


Steve Marrandino, Sales, [email protected], 212-689-3432

10 E. 40th Street

New York, NY 10016


Did you send or receive any samples? Yes


Contacts:

Feb 16, 2016 Spataro sends email to Cotswold (Steve Marrandino), with a copy to

Inman, letting them know fabrics have been sent to Inman with a request for quote.

Spataro asks Cotswold to contact Inman for the cuttings.

Feb 19, 2016 Cotswold (Steve Marrandino) confirms Cotswold has looked at the fabrics

and cannot make them. Davis Patton from Inman was copied on the email.

Feb 23, 2016 Julio Spataro requests price quotes from Inman based on samples sent via

DHL on Jan 27, 2016. No response.

Name of the organization: Alice MFG, US


Ellison Smyth McKissick, Chairman and CEO, [email protected], phone number not available

Brad Wurst, VP Sales, [email protected], 203-656-3399

208 E 1st Ave

Easley, SC 29640, USA




Contacts:

Oct 16, 2015: email sent to Ellison Smyth McKissick expressing interest in sourcing

cotton fabric for men’s shirting AYN: 50’s – 140/2. No response received.

Jan 18, 2016: Julio Spataro emails Ellison Smyth McKissick to inquire about capacity

to produce, placing order for AYN 50’s to 140’s and requesting delivery within 60 days.

No response received.

May 6, 2016: reached out to Brad Wurst (via telephone call) to inquire about 60s and

above. Alice confirmed it no longer manufactures these fabrics for fine shirting.




July 19, 2016, Page 9 of 14

May 16, 2016: Julio Spataro emails Bard Wurst to inquire directly about fine fabrics of

50s and above. (Second contact made because it was no clear whether Mr. McKissick

saw the emails.)

May 16, 2015: Brad Wurst confirms Alice does plain woven fabrics ranging from 18/1

to 50/1.

Name of the organization: Weavetec, USA


Harold Pennington Jr. Vice President, [email protected]

864-839-9660

124 North Charleston Street

P.O. Box 579

Blacksburg, SC 29702

How contacted and on what date: E-mail

Did you send or received any samples? No


Contacts:

Jan 21, 2016: Technical specs sent to Pennington via email (50/1’s to 120/1’s and

120’s/2).

Jan 25, 2016: Pennington confirmed they don't weave anything finer than 30/2 yarns.

Name of the organization: Fabricato, Colombia


Carlos Alberto De Jesus, Presidencia, [email protected]

Juan David Valencia, International Sales, [email protected]

57 (4) 4483500 ext: 2425

Carrera 50 # 38-320, Bello,

Antioquia, Colombia

How contacted and on what date: E-mail



Contacts:

Sep 15, 2015, 04:18pm: Technical specs sent.

Sep 17, 2015, 07:38pm: Fabricato confirmed they don’t have AYN ≥ 50’s fabrics in

their portfolio.

Nov. 9, 2015: Phone call to Juan David Valencia to specify we are looking for a weaver

of fine yarns 50-140. We explained that we have found a supplier of these yarns in the

U.S. and are looking for a weaver. Juan David confirmed Fabricato does not weave fine

yarns. Follow-up email to the conversation was sent to request that if production

capacity changes, to please let us know.

July 7, 2016: Emailed product description. (Re-contacted because original email

included, along with product description, spec sheet that included other products, which

could have been confusing.)

July 7, 2016: Response email confirmed does no fabric finer than 40s.






July 19, 2016, Page 10 of 14

Name of the organization: Manufacturas Eliot (Pat Primo), Colombia


Guillermo Elías Criado, Sales Director, [email protected]

María Fernanda Camacho, Sales Director Industrial Line, [email protected]. +57-1-405-5252

Calle 18a No. 69b – 06

Bogota, Colombia

How contacted and on what date: E-mail, phone calls, meetings



Contacts:

Sep 08, 2015, 8:00pm: Technical specs sent.

Sep 15, 2015: visited Pat Primo’s showroom; provided with the technical department

contact information (María Fernanda Camacho)

Sep 16, 2015: specs sent to María Fernanda Camacho with explanation about needing

fabrics to meet CTPA rules of origin.

Sep 17, 2015: María Fernanda Camacho responds stating PatPrimo’s products don’t

meet CTPA rules of origin.

Sept 17 and 23: clarification requested on whether any of PatPrimo’s product offerings

met CTPA’s rules of origin.

Sep 23, 2015 Maria Fernanda Camacho responded stating products didn't meet

requirements to comply origin under CTPA because of the yarn used

Oct 15, 2015: PatPrimo confirms they can do 100% cotton 50’s-140/2 but without

CTPA origin.

Oct 20, 2015: requested PatPrimo re-confirm that fabrics did not comply with CTPA

origin. Confirmation received same day.

Nov 9, 2015: email sent to Guillermo Elias letting them know we have identified a U.S.

yarn supplier (Buhler Yarns) for men’s fine shirting and inquire whether PatPrimo/Eliot

has the capacity and interest in importing the yarn and producing the fabrics needed.

Nov 09, 2015: Guillermo Criado confirmed Pat Primo has the capacity to import and

weave the fabrics and requests quantities needed

Nov 10, 2015: email to Guillermo Criado confirming Spataro produces with about

750,000 meters of fabric a year. Contact info for Buhler Yarns forwarded.

Nov 11, 2015: Julio Spataro met with company rep and places order from Manufacturas

Eliot.

Nov 30, 2015: Julio Spataro emails Guillermo Elias to inquire about order made.

Nov 30, 2015 Guillermo Elias responds that he is looking into it.

Dec 7, 2015: Julio Spataro emails Guillermo Elias to inquire about order made on Nov

11, 2015.

Dec 14, 2015: Julio Spataro emails Guillermo Elias to request update on the price, date

of production, and a certificate of origin confirming it is U.S. yarn.

Dec 14, 2015: Guillermo Elias responds that he is looking into it.

Jan 17, 2016: Julio Spataro emails Guillermo Elias and Maria Fernanda Camacho to

inquire about capacity to produce, placing order for AYN 50’s to 140’s via email and

requesting delivery within 60 days.





July 19, 2016, Page 11 of 14

Jan 18, 2016: Guillermo Elias responds confirming they are looking into the request.

Jan 21, 2016: Guillermo Elias responds again saying they are interested and can

produce, requests to speak in further detail.

Feb 3, 2016: Julio Spataro emails Guillermo Elias confirming he will send designs so

that Eliot can provide a price quote for 50s. Julio confirms that the fabric needs to

comply with CTPA rules of origin to be considered originating.

Feb 11, 2016 Julio Spataro emails Guillermo requesting confirmation that the yarn was

produced in either the U.S. or Colombia. In this email, Spataro confirms its

understanding that PatPrimo does not currently have the capacity to weave fabrics of

60s and above.

Feb 12, 2016 Guillermo Elias responds to email requesting a meeting with Spataro, to

which Spataro confirms availability.

Feb 13, 2015 Email exchanges regarding possible meeting.

Feb 15, 2016 Spataro reaches out to Guillermo Elias again insisting the lack of

definitive intent to supply on behalf of PatPrimo has left it clear they don’t have the

capacity and that a meeting is not necessary.

Name of the organization: Textilia (Colombia)


Pedro Calle, Sales, [email protected]

Gloria Mesa, Comercial Advisor, [email protected]

+57 315 348 6734

Cl 76 52 D-112 Bdg 5 Itagüí

Medellin, Colombia

How contacted and on what date: E-mail, phone calls, meetings



Contacts:

Oct 17, 2015: {e-mail} First contact with Textilia

Oct 20, 2015: visited Textilia’s showroom. Textilia produces mainly polyester and

polyester blends fabrics.

Nov 09, 2015: Asked Textilia about the possibility of importing yarn from Buhler Yarns

and weaving it in Colombia to supply to Spataro. Textilia, through phone call with Julio

Spataro, confirmed they could produce the fabric made of finer yarns.

Nov 13, 2015: Julio Spataro requested official quotation from Textilia.

Nov 30, 2015: email sent to Pedro Calle to ask if they have been able to contact Buhler

to supply 50s yarn from them.

Nov 30, 2015: Pedro Calle responds via email confirming they only have 40s yarn and

have not been able to get 50s.

Jan 17, 2016: Julio Spataro emails Pedro Calle and Gloria Mesa to inquire about

capacity to produce, placing order for AYN 50’s to 140’s and requesting delivery within

60 days

Jan 18, 2016 Pedro Calle confirms via email they’re only doing up to 40's yarn.

Mar 10, 2016 Pedro Calle requests to see technical specs again.

Mar 11, 2016 Technical specs were resent to Pedro Calle. Clarification on whether they





July 19, 2016, Page 12 of 14

could now weave the fabrics was requested. No response received.

July 7, 2016: e-mail to Pedro Calle requesting confirmation of capacity to produce:

“Woven fabric of combed cotton yarns, of 85 % or more by weight of cotton, of yarn

count of 60Nm or higher (60 Nm or finer) of various constructions and finishes.”

July 7, 2016: Pedro Calle responds that they can produce, but that this year they are

producing 40s yarn reference.

July 14, 2016: email to Pedro Calle asking if Textilia has produced fabrics with 60 yarn

count before and ask for information on Textiia’s machinery.

July 15, 2016: Pedro Calle confirms that Textilia is currently only producing cotton

fabrics with 40 yarn count; noting fabrics of 60 yarn count can be made, but Texilia

doesn’t currently have the cost estimates. No response to inquiry as to past production

and no specifics as to capacity that support claim that the fabrics could be produced.

Name of the organization: Primatela (Colombia)


Oscar Giraldo, Fabrics Manager, [email protected]

+57 (1) 4137166

Carrera 63 No.17B-50. Oficina 101.

Bogotá, Colombia

How contacted and on what date: E-mail, phone calls on Sep 28, 2015



Contacts:

Sep 28, 2015: Telephone call to Oscar Giraldo. Summary of conversation: Primatela

does not produce; all fabrics distributed are imported from countries different than US.

Sep 28, 2015: Email sent to Oscar Giraldo to confirm phone conversation.

Name of the organization: Textiles Risaralda (Colombia)


Martha Escudero (unable to verify title) [email protected]

+57 6 511 7111; +57 3116352955

Cl 8 N 12 30.

Dos Quebradas Colombia




Contacts:

Sep 28, 2015: First contact with Textiles Risaralda; technical specs sent.

Oct 6, 2015: Follow-up phone call and email to Martha Escudero. No response.





July 19, 2016, Page 13 of 14

Name of the organization: Bogotana de textiles (Colombia)


Nelson Cruz Torres, Client Relations, +57 1 2900500, [email protected]

Calle 19 # 68A-20

Bogotá, Colombia




Contacts:

Sep 28, 2015: email sent to Bogotana confirming phone conversation.

Sep 28, 2015: Called Summary of conversation retold in email: Bogotana does not

produce; all of its fabrics are imported from countries different than US.


DavidT

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Documents

July 19, 2016 Mr. Joshua Teitelbaum, Chairman Office of Textiles …web.ita.doc.gov/tacgi/PeruTPAReqTrack.nsf... · 2016. 8. 15. · How contacted and on what date: E-mail, on September