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pensing Technology at Cuyahoga Community College. We have found
that there are significant differences between the assembly of
prescription glasses and the assembly of noncorrective sunglas-
ses. We did not find Dr. Cohen's opinions to be helpful in
resolving the issues in these cases, and we do not rely on them
in making our findings and reaching our conclusions herein.
Both parties rely on the opinions of engineers. Petitioners
rely on the opinions of Harry W. Matthews, Jr. (Mr. Matthews), an
engineer employed by Arthur D. Little's Manufacturing and Trans-
portation Industries Section, who had no experience in the sun-
glass industry. Although Mr. Matthews concluded that B&L Ireland
and B&L Hong Kong constituted separate manufacturing entities, he
did not address whether the assembly operations of each of those
companies were generally considered to constitute the manufacture
of sunglasses. We also question some of the facts underlying Mr.
Matthews' analysis. For example, he concluded that the respec-
tive sunglass assembly operations of B&L Ireland and B&L Hong
Kong involved approximately 65 steps in order to assemble metals,
70 steps to assemble leathers, and an additional 95 steps to
apply leather to metal frames.33 He further concluded that the
33 The number of steps that Mr. Matthews concluded are required
for the assembly of sunglasses does not include a number of
support operations, such as incoming inspections and quality
audits.
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