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in its sunglass assembly operations in Ireland.
In addition to incentives provided by the IDA and the
Government of Ireland, B&L considered the following factors in
selecting Ireland as the site for a sunglass assembly facility:
(1) The ability to have goods shipped from Ireland duty-free
within the European Economic Community (EEC) because of that
country's membership in the EEC, (2) Ireland's proximity to North
Africa, the Middle East, and Europe, (3) Ireland's low labor
costs, and (4) economies gained by association with the existing
contact lens facility in Waterford, Ireland.
In addition to opening a sunglass assembly facility in
Ireland during 1982, B&L decided to open a sunglass assembly
facility in Hong Kong during that year. During the early 1980s,
B&L Hong Kong experienced rapid growth in the sale of sunglasses
that it purchased from B&L. Because it experienced long lead
times on finished sunglasses shipped from the United States, B&L
Hong Kong found it necessary to maintain large inventories to
avoid running out of certain SKUs of sunglasses. The cost of
maintaining large inventories during the early 1980s was high
because interest rates were approximately 18 percent at that
time. In an effort to reduce costs and improve customer service,
in early 1981, Mr. Y.H. Chan, the managing director of B&L Hong
Kong from 1975 and throughout the years at issue, proposed to
William Godfrey (Mr. Godfrey), the president of B&L Inc.'s
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