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sunglass assembly operations conducted by B&L Ireland and B&L
Hong Kong to constitute the manufacture of sunglasses. Respon-
dent expresses no position as to whether we should look to that
or any other industry to determine whether those operations
constitute the manufacture of sunglasses. We take respondent's
silence to mean that she agrees with petitioners' position that
the pertinent industry is the sunglass industry.
In any event, we agree with petitioners' position. See
Garnac Grain Co. v. Commissioner, supra at 26-27; Webb Export
Corp. v. Commissioner, supra at 148. The products at issue
herein are sunglasses. Sunglasses involve at least two distinct
market segments: (1) Low-end or regular sunglasses, and
(2) high-end or quality sunglasses. Sunglasses constitute a
separate and distinct product from prescription eyeglasses.
Sunglasses have noncorrective lenses, are tailored to fit a
standard face, and are assembled prior to reaching the retailer.
In contrast, prescription eyeglasses contain individually finish-
ed lenses, are tailored for a specific prescription and to fit an
individual face, and are assembled by retail optical shops. We
also note that the sunglass industry has its own trade organiza-
tion, viz., the Sunglass Association of America (SAA), and that
the American National Standards Institute (ANSI) has established
standards for the sunglass industry to follow.
Our next inquiry is whether the sunglass industry generally
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