Bausch & Lomb Incorporated and Consolidated Subsidiaries - Page 86

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          quality standards further demonstrates the substantiality of the            
          assembly operations conducted by each of those corporations.                
               Respondent also contends that the assembly operations at               
          issue did not require a sufficient investment in physical capital           
          to be substantial in nature.  Although we agree with respondent             
          that the respective sunglass assembly operations conducted by B&L           
          Ireland and B&L Hong Kong did not require a large investment in             
          physical capital, her contention ignores the fact that those                
          operations required a substantial investment in human capital in            
          order to produce quality sunglasses.  Without a trained and                 
          experienced workforce, neither B&L Ireland nor B&L Hong Kong                
          would have been able to produce quality sunglasses that met B&L's           
          quality standards.  In fact, both B&L Ireland and B&L Hong Kong             
          experienced significant quality problems during their respective            
          first years of operation.  Those operations could not readily be            
          relocated since they were dependent on a trained and experienced            
          workforce.  In fact, the IDA considered B&L Ireland's sunglass              
          assembly operations to create jobs of a sufficiently permanent              
          nature to warrant the issuance of training grants to compensate             
          B&L Ireland for the period during which its employees were not              
          efficient at producing quality sunglasses.                                  
               Respondent further contends that the actual assembly of                
          sunglasses by B&L Ireland and by B&L Hong Kong did not require              
          substantial amounts of time to accomplish and therefore cannot be           





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