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considers the respective assembly operations of B&L Ireland and
B&L Hong Kong to constitute the manufacture or production of sun-
glasses. In this respect, we find the opinions expressed by
petitioners' expert Mr. Nieh to be most instructive. Mr. Nieh
was employed by Polaroid in its sunglass business from 1956
through 1988. In addition to his participating in Polaroid's
sunglass business, Mr. Nieh participated in, and served as the
president of, the SAA and served on committees of ANSI in areas
relating to sunglass standards.
In his opening report, Mr. Nieh discussed the sunglass in-
dustry in general, including the differences between low-end or
regular sunglasses and high-end or quality sunglasses. He
described the importance of "appearance" and "fit" to the con-
sumer of quality sunglasses; that is to say, a consumer will not
purchase a pair of quality sunglasses that are priced two-to-ten
times higher than regular sunglasses unless they meet his or her
standards for appearance and fit. He described the sunglass
industry as a "cottage industry" because several levels of manu-
facturing, including parts fabrication and final assembly, are
necessary to convert raw materials into finished sunglasses. Al-
though Mr. Nieh recognized the importance of each level of manu-
facturing, he indicated that the sunglass industry considers the
assembler, which he referred to as the finished goods manufac-
turer, as the most important stage in the manufacture of quality
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