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EXHIBI 1
MARCH
 | A. BONNART S.A. |
|
| Fine Jewelers since 1966 | Specializing in repair and
Restoration of Fine Time Pieces |
March 2, 2006
John Read, Chief, Litigation, III
Antitrust
Division, U.S. Dept. of Justice
325 7th Street,
NW Room 300
Washington, DC 20530
Dear Chief Read:
My name is Mario Makar, it has been brought to my attention about the Rolex settlement. Back in
2003 I was in contact with Sen. Elizabeth Dole, (enclosed are the letters that we exchanged), I
wrote with concerns of not only myself but other watchmakers of a situation that was going on.
I hope that you may take the time and read over the enclosures. From a personal note, a fine of
$750,000 to a multi-million dollar company, like Rolex is an insult to our justice.
I also had contact with the following people, also from the Justice Dept., Mike Dashefsky and Bob McQuirk. Other then the fine I
have seen no results, and it would be a shame, such a large Corporation could "buffalo: their way through the Justice
System.
Sincerely, /s/
Mario Makar,Owner
A. Bonnart Jewelers
4508 E.Independence Blvd. #115
Charlotte, NC 28205
4508 E. independence Blvd. • Suite 115 • Charlotte, NC 28205 • (704) 536-5525
MEMBER: JA • AWI • NCWA • WJCM • NAWCC • BBB |
The very foundation of the small business tradesmen in America, be it watchmakers or automobile mechanics ad
depend on one common thing and that is a free and open market in which to compete. I have always believed that
anti-trust laws, including the Sherman Act and other fair trade and competition laws were put there to propect the
consumer. But somehow these conglomerates have found a way around such basic principles and now hold a
monopoly over us all.
Watchmaking has been in America since it's inception and most of the machinery used to make watches was
developed here in the U.S. long before the Swiss. Watchmaking takes many years of school and almost 10 years of
apprenticeship to obtain a competent skill level to work on some of the most complicated watches today.
I am requesting that you join wih other elected officials in Washington and initiate an investigation by the U.S.
Department of Justice.
We already have laws and rulings regarding this matter. No new laws need to be made. I want to know why the DOJ is
not enforcing those laws.
This is why I am seeking your guidance and assistance on the best course of action regarding this issue. Through my
contacts in the watch jewelry industry I already have many people ready to step forward to bring this injustice into the
light.
All I ask for is a chance to compete in a fair and open market.
Sincerely,
Mario Makar, Owner
A. Bonnart Jewelers
4508 E. Independence Blvd. #115
Charlotte, NC 28205
704-536-5525
E-mail Makarm@Bellsouth.net
Enclosures:
ELIZABETH DOLE
NORTH CAROLINA
120 Russell Senate Office Building
Washington, DC 20510
(202) 204-6342
Fax: (202) 224-1100 |
United States Senate
WASHINGTON, DC 20510 |
COMMITTEES:
ARMED SERVICES
BANKING, HOUSING, AND
URBAN AFFAIRS
AGRICULTURE, NUTRITION, AND
FORESTRY
SPECIAL COMMITTEE ON AGING |
July 24,2003
Mario Maker, Owner
A. Bonnart S.A.
4508 E. Independence Blvd., Suite 115
Charlotte, North Carolina 28205
Dear Mr. Maker:
Thank you for sharing your concerns with my office. Many Americans
turn to the federal government for assistance, and I know it can be difficult to
know which agency or department to go to for help. My office is here to
assist you in getting the answers you need.
I have forwarded your correspondence to officials at the United States
Department of Justice with the request that they give your case their full
attention and report back to me. As soon as I receive more information, I will
be in touch with you.
Your concerns are very important to me, and I will do everything I can
to help ensure that your situation is addressed in a timely manner.
|
|
_______________/s/________________
|
ED/am
RALEIGH OFFICE:
310 New Bern Avenue
Suite 122
Raleigh, NC 27601
(919) 856-4630
Fax: (919) 856-4053 | | | SALISBURRY OFFICE:
225 North Main Street
Suite 304
Salisbury, NC 28144
(704) 633-5011
Fax: (unreadable) |
SCHILLER - PIEPER COMPANY
1 N HOWARD STREET ROOM 303
BALTIMORE MD 21201
March 15, 2006
John Read, Chief
Litigation III
Antitrust Division
U S Department of Justice
325 7th Street NW Room 300
Washington DC 20530
RE: Rolex Watch USA Inc
Dear Chief Read:
I have been a watchmaker in Baltimore Maryland for the past 40 years. During
that time, it has been extremely difficult and almost impossible for independent
watch repairers to obtain watch parts from Rolex as it has been their policy to
not sell watch parts to independent watch repair facilities or watchmakers.
Rolex's policy also prohibits watchmakers from reselling spare watch parts
under any circumstance.
If the 1960 consent decree is terminated, it will become even more difficult, if not
virtually impossible, to obtain watch parts from Rolex. If this is the case it will
preclude independent watchmakers from adequately servicing their customers
who have purchased Rolex watches. Please do not allow this inequity to
continue or have this situation become even worse than it already is today.
Should you need any additional information on this topic or to have me share 40
years worth of frustration with this issue, please do not hesitate to contact me.
Sincerely,
/s/
Burke H Pieper, Jr.
Watchmaker
James Sadilek ••• Watchmaker
230 Annapolis Avenue
Carson City, Nevada 89703
Telephone: 775.885.7072
E-mail: ccwatchmaker@gmail.com
Specializing in the repair of high grade and vintage Swiss mechanical watches.
Member: A.W.I., N.A.W.C.C. and B.H.I.
March 20, 2006
John Read, Chief, Litigation III
Antitrust
Division, U.S. Department of Justice,
325 7th
Street, NW, Room 300
Washington, DC 20530 |
Stamp: RECEIVED
MAR 3 0 2006 (initials)
LITIGATION III, ANTITRUST DlV.
U.S. DEPT. OF JUSTICE |
March 20,2006
Dear Mr. Read,
In regard to the DOJ press release of February 28, 2006 reporting upon the
setting aside of a 1960 consent decree, the press release states in part: "...During
its investigation of Rolex's alleged decree violations, the Department determined
that, as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore
should be terrminated..."
As a professional watchmaker engaged in the trade since 1969, I cannot
understand how the DOJ investigators could have arrived at this conclusion. I
can attest that independent watchmakers' access to repair parts for most Swiss
luxury brand watches over the past ten years has become increasingly more
limited. When I began this profession, one could buy repair parts, without
restriction, from wholesale watch material suppliers. Now, one must petition
each individual Swiss firm for a parts purchasing account, which is only granted
either after either fulfilling a number of conditions, or not granted at all. For
example, there are, according to Department of Labor statistics, about 5,000
watch repairers in the U.S.; only about 10% have access through parts accounts
to Rolex watch repair parts.
While the DOJ action in the press release refers only to Rolex Watch U.S.A., the entire Swiss luxury watch market has varying degrees of restrictive
repair parts supply policies, which make it very difficult for the independent
Watch repairers to practice their trade. Some Swiss firms will not sell repair
parts to anyone, no matter what their qualifications; all repair work must be sent
to their factory repair centers.
If the DOJ was of the opinion that the Swiss watch industry was engaging
in anticompetitive practices in 1960, it defies logic for the DOJ now to make the
assumption that the situation has been alleviated when in fact it has become
much worse presently, with respect to repair parts supply, than anytime in the
last thirty-five years.
I don't know what sort of legal mechanisms are available to remedy the
current situation, but the country's independent watchmakers are not being
fairly treated, and the DOJ should consider studying this matter much more
closely from the viewpoint of the independent watch repairer before making a
decision to set aside the 1960 decree. In fact, the DOJ, in my opinion, ought to
investigate the current restrictive policies of many Swiss firms who were not
parties to the 1960 ruling and perhaps initiate a new legal action.
Regards,
James Sadilek - Carson City NV - U.S.A.
ccwatchmaker@gmail.com
www.ccwatchmaker.com |
/s/ |
APRIL
1722 Madison Avenue
Toledo, Ohio 43624 |
 | Tel 419/243-3720
Fax 419/243-0321 |
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, D.C. 20530 |
April 25,2006 |
Dear Mr. Read,
I am writing in response to the Memorandum of United States in Response to Motion
of Rolex Watch USA Inc., for Order Terminating Final Judgement Supplemental to
Civil Action No. 96-170. Dated February 28, 2006.
It is my opinion that the U.S. Department of Justice would be grossly negligent
allowing the Termination of the Final Judgement.
In the Memorandum of United States in Response to Motion, Article 1 it states: The
Primary concern of the United States was the collective, Cartel-like behavior of the
watch companies, importers, and associations. The Cartel-like behavior still exists
today, the individual watch companies now form 'Groups" that work independently,
but together. The Swatch Group, Richemont Group, LVMH Group, Rolex, Audemars
Piquet and others all work to form policies together and yet are all independent of each
other.
Each of the "Groups" now are working towards what Rolex was just fined $750,000
dollars for Limiting distribution of parts for repair, controlling pricing policies, and
restricting the resale of parts.
Under Article III, reasons the United States Tentatively Consents to Termination
under A., Changes in the Watch Industry, the primary harm that he Final Judgement
sought to remedy was the Cartel-like behavior. Change the name from Cartel to Group
and you have an identical situation.
Also under A. you state that Switzerland is no longer the dominate supplier of
watches. Watch manufacturing overall by shear numbers is not dominated by the
Swiss, but from a Luxury Brand standpoint the Swiss control over 99% of the market.
Although the 6% figure of watches produced by Switzerland maybe accurate, that is
only in total volume of watches produced, Not Dollar Value. A figure of 40% is a more
accurate figure for total dollar value. There is a difference.
The statement that United States watch consumers can buy a wide range of products
from manufacturers across the globe is true. But only from Switzerland can you find
the luxury brands being produced. They have a total monopoly of the luxury brands,
from production to distribution of spare parts. Complete control of pricing, and now
total dominance of the repair. Where does it stop?
Under B. The Final Judgement is no longer Necessary, you address vertical restraints
as being justified as a means of watch part distribution. It is more true today than in the
1960's. Again you point out the domination of the Swiss Cartel, change the name to the
Swiss Groups, and again you have the same situation as the 1960's. There seems to be a
pattern forming.
Under D. Conclusion, you state that he Final Judgement was designed to restore and
maintain competition in an industry that, at the time, was prone to collusion. Each of
the afore mentioned Groups have now established identical policies of parts
distribution, parts pricing, and parts resale. Does this not smell of collusion?
It would be negligent of the Justice Department to drop the Final Judgement and
allow all of the Swiss Watch Manufacturers to do exactly what Rolex was fined
$750,000 dollars for doing. If it was illegal then, then it is still illegal now!
A similar complaint has been filed by the European Confederation of Watch and
Clock Repairers Associations established in Belgium. See copy of complaint attached.
Again the Groups are attempting to restrict distribution of spare parts to the European
Union as they are attempting to do in the United States.
In conclusion, as President of one of the largest Watch Material Distributors in the
United States, with over 35 years of experience in the industry it is not hard for me to
see thru this charade. With some deliberate misuse of percentages as to volume instead
for value it is easy to sway people not familiar with our industry. It would be a grave
mistake and not in the Best Public Interest to terminate this judgement.
It took 10 years just to get the U.S. Justice Departments attention in this matter. Please
don't allow a group of fast talking New York Lawyers to juggle some large numbers in
front of people that are not completely familiar with our industry. As they portray their
clients as small players in the total equation.
Sincerely,
/s/
Gerald A. Wilson
President
Attachments Enclosed
 | Wholesale Watch Materials • Tools and Findings • Jewelry • Boxes |  |
COMPLAINT PURSUANT TO ARTICLE 7 OF REGULATION (EC) No 1/2003
I. Information regarding the complainant and the undertaking(s) or association of undertakings giving rise to the complaint
1. Give full details on the identity of the legal or natural person submitting the complaint. Provide
a contact person (with telephone number, postal and e-mail address) from whom supplementary
explanations can be obtained
Complainant is the Confédération Européenne des Associations d' Horlogers-Réparateurs
(CEAHR) [European Confederation of Watch & Clock Repairers' Associations]. This
Confederation was established in Belgium as an international association with a scientific
and pedagogic objective, in accordance with the Belgian law of 25 October 1919, as
modified. It is situated at 4, rue Jacques de Lalaign, 1040 Brussels. The bylaws will be
published in the Moniteur Beige when approved by the Minister of Justice, who is in the
process of examining them.
Presently 7 national associations are members; they are from Belgium: (Association
Nationale des Horlogers-Réparateurs), Italy (Confartigianato, Federazione Nazionale
Artigianato Artistico and C.N.A./ASNART, Associazione Nazional Artigianato Artistico),
France (FNAMAC), United Kingdom (British Horological Institute), Netherlands
(Nederlandse Juweliers en Uurwerkenbranche), and Austria (WKO). These national
associations have as members small and medium-sized enterprises (SME's) engaged in
maintenance, repair and restoration of clocks and watches.
[if the Commission wishes the addresses and other information concerning these Associations can
be supplied]
| Contact person: | Mr. P. Mathijsen, Advocaat
Avenue de la Joyeuse Entrée 1,1040 Bruxelles
Tél. 02 230 46 69
Fax : 02 231 00 35
e-mail: mathijsen@eu-law.be |
2. Identify the undertaking(s) or association of undertakings whose conduct the complaint relates
to, including where applicable, all available information on the corporate group to which the
undertaking(s) complained of belongs and the nature and scope of the business activities pursued
by them. Indicate the position of the complainant vis-à-vis the undertaking(s) or association of
undertakings complained of (e.g. customer, competitor).
The complaint is directed against:
- The Swatch Group, Faubourg du Lac 6, Case Postale 1712, 2501 BIENNE, Switzerland,
Tél. 00 41 32 343 68 11, fax: 00 41 32 343 69 11, info@swatchgroup.com. This group
comprises sixteen watch producers from Switzerland operating under their own trade
mark, among which only the following, producers of expensive1 watches, are concerned
by the complaint: Blancpain, Breguet, Omega and Glashütte and also Lemania and
Fréderick Piguet which only produce watch movements; all these firms were formerly
suppliers of spare parts to the watch repairers in the EU; [this group still supplies the
Belgian repairers, but refuses to supply the Germans and Austrians]
- Richemont International SA, Boulevard James-Fazy 8, 1201 GENEVE, Switzerland,
tel. 00 41 22 715 37 11, Fax: 00 41 22 715 17 65. This group comprises 11 watch
producers from Switzerland operating under their own trade mark, among which
the following are producers of expensive watches: IWC, Jaeger-LeCoultre, Lange &
Söhne, Piaget, Vacheron-Constantin, Cartier and Panerai; they were formerly
suppliers of spare parts to watch repairers in the EU;
- LVMH, 30, avenue Hoche, F-75008 PARIS, for the following producers: Zenith and
Tag-Heuer;
- Rolex SA, rue François Dussaud 3-7, Case Postale 430, 1211 GENEVE, Switzerland,
tel. 00 41 22 302 22 00; independent watch maker; was formerly a supplier to
repairers in the EU; and
- Manufacture des Montres Rolex SA, rue David-Moning 9, 2501 BIENNE,
Switzerland, tél. 00 41 32 328 44 44 ; Fax : 00 41 32 328 41 21. Was also formerly a
supplier of spare parts to watch repairers in the EU;
- SA de la Manufacture d'Horlogerie Audemars Piguet et Cie, Route de France 216,
1348 LE BRASSUS, Switzerland, tél; 00 41 21 845 14 00, an independent watch
maker; was formerly a supplier of spare parts to watch repairers in the EU and
- Patek Philippe SA Manufacture d'Horlogerie, Pont-du-Centenaire 141, Case
Postale 2654, 1211 GENEVE 2, Switzerland, tél. 00 41 22 884 2020. fax : 00 41 884 20
40 , info@patek.com An independent watch maker; was formerly a supplier of
spare parts to watch repairers in the EU.
[The addresses of all the firms belonging to the groups could be supplied if the Commission so
desires]
II. Details of alleged infringement and evidence
3. Set out in detail the facts from which, in your opinion, it appears that there exists an
infringement of Article 81 or 82 of the Treaty. Indicate in particular the nature of the products
(goods and services) affected by the alleged infringement and explain, where necessary, the
commercial relationships concerning those products. Provide all available details on the agreements
or practices of the undertakings and associations of undertakings to which the complaint relates.
Indicate, to the extend possible, the relative market positions of the undertakings concerned by the
complaint.
- Infringement of Articles 81 EC
The exact nature of the Groups referred to above is not known to the complainant, but the
fact that the twenty seven or so undertakings they represent and the three independent
watchmakers mentioned above have practically at the same time (about two years ago)
applied the same policy of refusal to supply spare parts of their expensive watches,
indicates that their exists an agreement or concerted practice between them.
The object/effect of their agreement/concerted practice is, generally speaking - there are
exceptions (ETA being one) -, to eliminate all competition in the watch repair field from
independent watch repairers outside Switzerland. The EU watch repairers who used to
compete with the Swiss repairers and the representatives of the Swiss watch makers in the
EU and repairers installed in the Community, are now strongly restricted in doing so. The
result is that, practically speaking, any repair to a 'good' Swiss watch must now
necessarily be entrusted to these representatives who in the majority of cases send the watch to Switzerland. These representatives are no longer
allowed to sell spare parts to independent watch repairers in the EU.
It is important to note at the onset that watch repair is in fact limited to watches of a
certain value; indeed, cheap watches are simply replaced. Expensive watches, on the
other hand, are valued by their owner and therefore, when they stop working, they are
brought in for repair. The demand for watch spare parts therefore exist practically only
for expensive watches and it is precisely the producers of expensive watches or
movements who refuse to supply spare parts to independent repairers.
From the above it also follows that the repair of valuable watches constitutes the bulk of
the watch repairer's work and of his income.
Another important point is that the repair of an expensive watch requires original spare
parts, first because of their specific technical characteristics but also because of their
appearance. Even if it were possible to replace a part by a non-original one, this would
not be accepted by the watch owner because of differences in appearance.
Therefore, without original spare parts, expensive watches cannot be repaired by
independent repairers.
The agreements between the Swiss watch makers and their representatives in the EU
would probably be considered by some as "selective distribution systems", as defined in
Article 1 (d) of the block-exemption Regulation 2790/99 ([1999] O.J. L336/21). However,
in Complainant's opinion, said Regulation cannot be invoked by the Groups and Undertakings referred
to in this complaint (and their representatives in the EU), for the following reasons.
Article 4 of said Regulation declares the block exemption not applicable in case the buyer
(here the enterprises which belong to the so-called selective distribution system in the EU)
is restricted in his ability to set the price of the repair service. It appears that the latter is, in
this case, determined exclusively by the Swiss watchmakers, which they represent.
Furthermore, the block exemption is rendered non applicable by the restrictions imposed
by the Swiss watch manufacturers on the buyers of spare parts which are part of the
so-called selective distribution system (and which might still carry out some repairs), to
sell these spare parts to independent watch repairers. See in this respect particularly
paragraph (b) of Article 4: "The exemption...shall not apply to vertical agreements which,
directly or indirectly, in isolation or in combination with other factors under the control of the
parties, have as their object: (b) the restriction...of the customers to whom, the buyer may sell the
contract goods or services, except...", (the exceptions do not apply in this case, therefore the
block exemption does not apply).
In its letter of March 2002 to Mr Tarondo (p. 224 of the "Collection of Evidence" of October
2000, in the Commission's possession), the Federation of the Swiss Watch Industry
pretends that the "restrictive policy about spare parts applied by the Swiss makers...is not
contrary to the Community law regarding distribution" and bases this statement on the
fact that they do not reach the 30% threshold provided for in Article 3.1 of Regulation
2790/1999 ([1999] O.J. L336/21) on the application of Article 81(3) of the Treaty to
categories of vertical agreements and concerted practices. The Swiss Federation thereby
overlooks the other provisions of said Regulation such as Article 4 (referred to above) and
Article 6 mentioned in the next Paragraph of this complaint.
Even if the block exemption would apply, the Commission would have to withdraw the
benefits thereof, pursuant to Article 6 of said Regulation, since the vertical agreements to
which it might apply "nevertheless have effects which are incompatible with the
conditions laid down in EC Article 81(3) EC. Indeed, the agreements between the Swiss
undertakings setting up the Groups and the agreements between the member
undertakings and their representatives in the common market do not seem to fulfil the
conditions provided for in EC Article 81(3) as analysed in the Commission's "Guidelines
on the application of Article 81(3) of the Treaty" ([2004] O.J. C 101/97) at pages 104 to 114).
Indeed, these agreements:
- do not provide any "efficiency gains", since they do not "contribute[s] to promoting
technical and economic progress" (EC Article 81(3)); indeed by eliminating the
watch repair trade in the Community, they, on the contrary, cause technical and
economic regress in the EU; indeed, a whole profession risks to be eliminated: the
number of independent watch repairers is in strong regress, watch repairers schools
are closing down and wholesalers who used to supply watch spare parts are
disappearing ; a whole Small and Medium-sized Enterprise sector of job-providers
is at risk;
- do not "allow[ing] the consumers a fair share of the ... benefits" (EC Article 81(3))
resulting for the Swiss watch makers and repairers from the limitations they have
imposed with regard to trade in goods (spare parts) and services (watch repair).
Indeed, not only does the consumer no longer have the choice of his service
provider, but repairs take longer and have become much more expensive for the
end-consumer due to the higher tariffs of the above mentioned Swiss groups and companies and the necessity of sending the
watch to Switzerland;
- do in fact "impose on the undertakings concerned restrictions which are not
indispensable to the attainment of these objectives" (EC Article 81(3)(a)); in the case
under review the "objectives" of the Swiss agreements are neither the promotion of
technical progress in the Community, nor the allocation of a fair share of the
resulting benefits to the consumer; this third condition can therefore not be
fulfilled;
- finally, the agreements do, as indicated above, "afford such undertakings the
possibility of eliminating competition in respect of a substantial part of the
products in question." [here: trade in watch spare parts and repair services] (EC
Article 81(3)(b)); indeed, as indicated, all competition between independent watch
repairers and their Swiss competitors has been or is threatened to be, eliminated.
Another consequence of this policy is that all trade between Member States of Swiss watch
spare parts has been eliminated, as indicated above.
Consequently, the two criteria needed for the application of the prohibition of Article
81(1) EC are fulfilled: appreciable effect on trade, on the one hand, and effective restriction
of competition on the other. The conclusion can only be that EC Article 81(1) was violated
by the Groups and Undertakings complained of.
- Infringement of Article 82 EC
The groups and undertakings referred to above occupy, together with the other groups of
Swiss watch makers, a total joint monopoly/dominance. Indeed there do not exist
anymore, within the Community, any watch producers (capable of competing with the
Swiss). In itself this does not constitute an infringement of Community competition rules,
but the fact that these dominant groups/undertakings prevent the supply of practically all
relevant watch spare parts to independent watch repairers in the EU and prevent thereby
the exercise of repair services within the Community, constitutes an abuse.
As described in EC Article 82(a), the above-mentioned groups and undertakings "directly
or indirectly [impose] unfair purchase and selling prices or other unfair trading
conditions". The latter have been described above and consist in the refusal to sell spare
parts and making it practically impossible to repair valuable watches (the only ones that
count) outside Switzerland.
Possible exemptions from the prohibition of Articles 81 and 82 EC
According to Complainant, the Groups and Undertakings concerned by the complaint
cannot, as stated above, invoke the selective distribution block exemption, neither can they
hide behind any trade mark they might have deposited, since the trade mark is only
destined to prevent unauthorised copies to be made of said product; the trade mark itself
cannot and does not prevent trade in the said product, on the contrary, it facilitates it; the
sole purpose of a trade mark is to guarantee the authenticity of the product.
As for possible other intellectual property rights, the fact that the products covered by such
rights have been sold in the Member States by the owners of those rights, or with their
permission, exhausts their right to prevent others from selling them in those Member
States. See in this respect the case law of the European Courts. According to the Court of
Justice, "although the Treaty does not affect the existence of rights recognised by the legislation of a
Member State with regard to industrial and commercial property, the exercise of such rights may
nevertheless fall within the prohibitions laid down by the Treaty. Article [30] EC only admits
derogations from the free movement of products in order to protect industrial and commercial
property to the extend to which such derogations are justified for the purpose of safeguarding rights
which constitute the specific matter of such property ". [italics supplied]
In other words, an intellectual property right may never be used to prevent the free
movement of goods.
There are several other court cases where this position was confirmed; they can be
supplied by complainant if the Commission so wishes;
Intellectual property rights cannot, therefore, be invoked by the Swiss Groups and
Undertakings concerned by this Complaint, to justify their refusal to sell watch spare parts
to watch repairers established in the EU.
With regard to the de minimis Notice ([2001] O.J. C368/13.), complainant would like to
point out that it cannot be invoked by the Groups and Undertakings concerned by this
complaint since Point 11, (1) (b) of said Notice prevents the Commission from considering
that the agreements in question does "not appreciably restrict competition", indeed, they
contain the following hardcore restriction:
The agreements constitute 'agreements between competitors' (the Groups) and they have
as their object "the limitation of.. .sales".
As for the relations between the individual producers and their representatives in the
EU (non competitors), the same applies (see point 11 (2) (b) of the Notice referred to
above).
4. Submit all documentation in your possession relating to or directly connected with the facts set
out in the complaint (for example, texts of agreements, minutes of negotiations or meetings, terms of
transactions, business documents, circulars, correspondence, notes of telephone conversations...).
State the names and address of the person able to testify to the facts set out in the complaint, and in
particular the persons affected by the alleged infringement. Submit statistics or other data in your
possession which relate to the facts set out, in particular where they show developments in the
marketplace (for example information relating to price and price trends, barriers to entry to the
market for new suppliers etc.).
Numerous documents setting out the alleged facts i.e. refusal to sell spare parts in the
Community to independent watch repairers, have already been submitted to the
Commission in October 2002 in a bundle entitled: "COLLECTION OF EVIDENCE
REGARDING ANTI-COMPETITIVE ACTIONS ADOPTED BY EU AND EXTRA-EU
WATCH PRODUCERS AND IMPORTERS". It contains 318 pages of mainly letters from
suppliers refusing to supply spare parts.
Particularly interesting is the letter on page 188 from Time Products UK since it openly
state that the Girard-Perregaux factory in Switzerland will not supply materials directly to
retailers in the Community and secondly that they themselves will not supply materials to
non-account customers.
The complainers are not in possession of any other documentation regarding the
supposed agreements referred to above between Swiss watch or clock work makers and
their representatives in the EU, neither of the agreements existing between the members
of the Groups mentioned.
As for persons able to testify to the facts set out in the complaint, and in particular the
persons affected by the alleged infringements, their names appear in the documents
transmitted to the Commission under the name "COLLECTION OF EVIDENCE
REGARDING ANTI-COMPETITION ACTIONS" of October 2002. In case the
Commission wishes to receive a shorter list, Complainant will endeavour to make a
selection.
5. Set out your view about the geographical scope of the alleged infringement and explain, where
that is not obvious, to what extend trade between Member States and between the Community and
one or more EFTA States that are contracting parties of the EEA Agreement, may be affected by
the conduct complained of.
As described above, the effects of the refusal to sell watch spare parts to independent
watch repairers in the EU, are felt in practically all the Member States; where the new
Member States are concerned, lack of contact until recently has not allowed the
complaining Confederation to obtain sufficient information.
As for trade in repair services and watch spare parts for valuable watches between
Member States, as indicated, it has been completely eliminated.
III. Finding sought from the Commission and legitimate interest
6. Explain what finding or action you are seeking as a result of proceedings brought by the Commission
The complainant asks the Commission to decide, as referred to in Article 7.1 of Regulation
1/2003, that the Groups and Undertakings to which the complaint relates have infringed
Articles 81 and 82 EC and must put an end to the infringement i.e. resume and authorise
the delivery of watch spare parts to independent watch repairers in the Community.
The complainants are of the opinion that the infringement is serious enough to
warrant the imposition by the Commission of a heavy fine.
7. Set out the grounds on which you claim a legitimate interest as complainant pursuant to Article 7 of Regulation (EC) No 1/2003. State in particular how the conduct complained of affects you and explain how, in your view, intervention by the Commission would be liable to remedy the alleged grievances.
The complaining Confederation represents the interests of the National Associations,
members of the Confederation; they in turn represent the interests of the individual
independent watch repairers in the various Member States. The fact that the latter have
been seriously affected in their trade by the refusal of the Groups and Undertakings
concerned by the complaint to supply them with watch spare parts was demonstrated
above in the answer to question 3. These directly affected SME's have delegated the
defence of their interests to their national Associations; the latter have, in turn, delegated
the collective defence of the interests of their members to the complaining Confederation.
(See in this respect Paragraphs 36ff of the "Commission Notice on the handling of
complaints by the Commission under Article 81 and 82 of the EC Treaty" ([2004] O.J.
C101/65).
IV. Proceedings before national competition authorities or national courts
8. Provide full information about whether you have approached, concerning the same or closely
related subject-matter, any other competition authority and/or whether a lawsuit has been brought
before a national court. If so, provide full details about the administrative or judicial authority
contacted and your submissions to such authority.
As the Commission can ascertain from the letter in annex from the Ministry of Economic
Affairs in Brussels, section Prices and Competition, of 19.05.2000, contact was established
with the Belgian competition authorities. The latter advised to send them a formal
complaint. This is being worked on, the problem being that important modifications
occurred in the composition of the Confederation, so that the complaint had to be
redrafted.
Contacts were established many years ago by the French Association with their
national competition authorities, but no formal complaint was filed; in The
Netherlands the national Association contacted the competition authorities, but
without results.
The problem with a recourse to national authorities, whether judicial or administrative, is
that their decision would only affect the situation in a given Member State, while, as
indicated, the effects of the infringement do concern the whole Community. Only a
Commission Decision can remedy the problem faced by all the watch repairers in the EU.
As for the Community interest of the case, it seems to Complainant that the criteria
mentioned in Paragraph 44 of the above mentioned Commission Notice on the handling
of complaints ([2004] O.J. C101/65), even if these criteria are not exhaustive, do indicate
that such an interest does indeed exist, at least can not be excluded.
Indeed:
- national courts cannot bring a solution, as shown above;
- seriousness for the SME's-watch repairers - their survival is threatened - and the
perennial character of the infringement;
- the Commission investigation seems well advanced;
- the practices have not ceased, on the contrary the refusal-to-supply-policy spreads
to more and more former suppliers, and are therefore not likely to cease in the
absence of a Commission decision;
- the Groups and Undertakings concerned do certainly not agree to change their
conduct;
Declaration
The complainant hereby declares that the information provided in the present form C to
Regulation (EC) No 1/2003 is given entirely in good faith.
For the European Confederation of Watch and Clock Repairers'
Associations A.I.S.B.L.
|
|
P. Mathijsen Advocaat
Brussels, June 2004
|
Annex: Letter of the Belgian Ministry of Economic Affairs
FOOTNOTES
1 Manufacturers of lower-priced watches generally speaking do supply spare parts.
MAY
John Read, Chief, Litigation III, Antitrust
Division
US Department of Justice
325 7th
Street NW, Room 300
Washington, DC 20530
May 2, 2006
Dear Sir,
It is with great disappointment that I write to you in regard to the termination of
a Consent Decree between the Department Of Justice and a group of Swiss
watch manufacturers. According to the AWCI, the DOJ has found fault with
Rolex's practices concerning distribution and availability of spare parts, and has
reached an agreement with Rolex to settle this dispute. At the same time the
DOJ has found that the consent, decree is no longer relevant and that the
protections afforded by the decree are unnecessary. Nothing could be further
from the truth.
Rolex's policies are far less restrictive than many other watch companies that
independent jewelers struggle with on an ongoing basis. In the past few years,
the number of companies that will no longer sell any spare parts to support their
watches has ballooned alarmingly. In past years only the most elite, expensive
watch brands maintained restrictive parts policies; now the trend,has become
more of the norm than the exception and entry level brands have followed suit.
Carrier, a brand which has made parts unavailable for years, used to offer
non-authorized agents a token discount when watches were sent to Carrier for
service. That policy was then changed to charging the same retail that any
consumer would pay if they sent the watch to them directly. Recently we
received a letter informing us that non-authorized agents could not send any
jobs to Cartier under any circumstances—paying retail was no longer enough
and that any packages sent would be refused and returned unrepaired.
These sorts of restrictions dramatically harm the market place in a variety of
ways. Consumers who need watches repaired have to send them to factory
service centers where estimates can take up to a month, pricing is grossly
inflated, and jobs can take up to a year to complete. Very often these same jobs
could be completed by a competent shop at a fourth of the price and an eighth of
the time with the same degree of quality and proficiency. To exacerbate the
situation, these service centers insist on replacing parts that are completely
unnecessary or strictly cosmetic, at great cost to the customer. To
make an automotive analogy, imagine being told that to repair your
transmission, you must also pay for a new dashboard or get no service at all, and
that the parts for your transmission are not available elsewhere. In fact your car
can be repaired by them and them alone, or be taken to the junk yard.
The customer, the jeweler who sold the watch, and the independent tradesman
are all hurt by these circumstances; the first by the costs and loss of use of their
property, the second by the loss of the customer's faith and satisfaction, and the
third by being unable to or prohibited from performing the job for which they
were trained.
I appreciate the recent recognition of the need to encourage young watchmakers
to enter the job market and the efforts of the AWCI to help trained watchmakers
to further their careers, raising the level of competence of the pool of
watchmakers in the United States. However, as the schools affiliate themselves
with the manufacturers, they lose the ability to strenuously object to various
policies, or risk losing the assistance that is required to keep these programs
viable and current. Nor do the schools inform their students that the only jobs
they will be qualified for upon graduation will be at factory service centers.
Should one of those graduates try to set up their own store or work for an
independent one, they would quickly find themselves relegated to changing
batteries and straps and probably, be unable to provide the most basic services
on the majority of fine Swiss brands.
The degree to which the Swiss watch manufacturers unfairly control the market
varies . Some brands will still distribute parts to a limited extent. Some have
adopted a policy that the parts that they are willing to sell should be sold at the
same price any consumer would pay, eliminating a wholesale rate, which then
forces the repairman to overcharge the customer for the work.
I strongly believe that the Department of Justice should both abandon the idea of
allowing the consent decree to expire and begin to enforce the protections that it
provided originally. At the same time the list of companies that need to comply
with the decree should be expanded. I understand that the direction that current
government policy has shifted from the ideal of protection from monopolization
to allowing market dynamics prevail, but there is no market unless there is some
form of competition. The consumer should be allowed a choice that exists in
almost any other industry.
Thank you for your consideration in this matter. If I can be of service
documenting some of these issues, please feel free to contact me.
Sincerely,
/s/
Alex Hofberg
President, Watchworks Inc.
711 SW 10th Avenue • Portland, Oregon 97205 • Tel: 503/223.1368 • Fax: 503/223.7292
270 E. CROSSVILLE ROAD • ROSWELL, GEORGIA 30075 • (770) 645-8555 • WWWCAPETOWNDIAMOND.COM
May 3, 2006
John Read
Chief, Litigation III, Antitrust Division
U.S. Department of Justice
235 7th Street, NW, Room 300
Washington, D.C. 20530
Dear Mr. Read:
I urge you to understand that there are thousands of us in the watch repair
business and who are involved in the sales of pre-owned watches who are being
grossly harmed by Rolex, and will be even further harmed by the termination of
the 1960 Final Judgment against them and the other Swiss watch manufacturers.
In the interest of public welfare, I urge you to look at this matter from our perspective.
Many of the watchmakers in America are disabled veterans who depend on the
repair and rehabilitation of used Rolexes to support our families and literally keep
us alive. It is obvious that the reason that Rolex does not want us to prosper is that
they can't stand the competition.
I am the head of a small family business. We buy and sell pre-owned Rolexes and
repair them and depend on a supply of parts so that we can have an adequate
amount of wares to offer our clientele. We really need help.
I have been involved in a legal feud with the Rolex Watch Company for over
fifteen years, and it has cost me in excess of $600,000 to defend myself against their
sham lawsuits, whereby they continue to use the American legal system to punish
me. And all this simply because they view me as a competitor.
The anticompetitive practices of the Swiss watch industry have long been apparent.
The $750,000 fine to Rolex amounts to no more than a slap on the wrist to such an
enormously profitable company as the Rolex Watch Company. And, as Rolex goes,
so will the rest of the Swiss watch manufacturers. We are fighting for salvation and
need help. Please!
I am in business for almost forty years, and without Rolex parts, I am a dead duck. I
have tried to work with the Justice Department, but to no avail. This appears to be
my last round, and quite possibly the last round for the American way of life.
Because I am not a man of letters, I cannot adequately describe to you the legal
atrocities that Rolex and Cartier have leveled against us. I would, however, be glad
to have my attorney call you, if you should wish, so that he could put it into a legal
perspective. This would probably suit you better than the ranting and raving of a
70-year-old disabled gentleman.
I must say, however, that it would not be in the public interest, or provide any
public benefit to allow the termination of the Final Judgment from 1960.
Unfortunately, we're nothing but a bunch of helpless, penniless, and—for the most
part— disabled American workers, and we just can't provide ourselves with the help
that is needed so badly.
It was United States consumers and workers who helped to make the Swiss watch
industry as great and prosperous as it has become today. However, by closing the
pipelines of necessary supplies and parts with the threat of massive lawsuits for any
who dare stand against the manufacturers of these watches, a great and grand
portion of America's citizenry will be forced to go on the dole and become
mendicants.
I would prefer to beg you for consideration before this happens. I beg of you, sir:
Please grant us some succor from the threat of this fate. Not to do so would be a
victory of avarice above democracy.
With hope,
/s/
CARL MARCUS
Capetown Diamond
| |
CLG
Capetown Luxury Group
FINE WATCHES, DIAMONDS, AND ESTATE JEWELRY
CARL MARCUS
(800) 442-7866 • (770) 645-8555 • FAX (770) 645-0450
VISIT OUR WEBSITE: www.capetowndiamond.com
CARL@capetowndiamond.com |
| ATLANTA | BEVERLY HILLS | NEW YORK |
August 18,2005
Alberto Gonzalez
United States Department of
Justice
950 Pennsylvania Ave,
N.W.
Washington, D. C.
20530-0001
Dear Mr. Attorney General,
I am certain that your days are full with what are most likely more important things
than my plight. But, because I am at my wits end and in danger of losing my
livelihood, it was suggested to me to write to you by the New York State Attorney
General.
My name is Carl Marcus. I and my family are the owners of a small jewelry company
by the name of Capetown Diamond Corporation. I am nearly 70 years of age and for 35
years I have been involved in the business of discounting fine Swiss watches,
diamonds, and precious jewelry worldwide.
Along with this letter, I am including a series of ads which I generally run in the New
York Times. Should my plight peak your interest, you may wish to learn more about
me by visiting our corporate website at www.capetowndiamond.com. Although my
website may give the impression that we're a larger company than we really are, be
assured that we are a small firm operated by my wife, my son, two German shepherds,
and four long-term employees.
I guess by all yardsticks, I am the quintessential New York Jewish businessman. I am
the oldest son of a Romanian refugee, the first of seven, and was actually born on a
kitchen table in the Bronx. My wife is the oldest daughter of an immigrant Puerto
Rican postman.
Both she and I being depression babies, we were taught by our parents that all things are
possible in America, provided you go to school and work hard. If you did these things,
you could make a good living. I always believed that, and in my case, it almost became
true.
Now here's my problem: Over the last three years, both my wife and I have become
victims of persecution by several major European watch and jewelry manufacturers
and miners of diamonds. In our minds, all we're guilty of is working hard and perhaps
being more superior marketers than our competition.
The first company to start harassing us through the American judicial system was
the Rolex Watch Company. They have become very upset with me due to my
pricing policy and our
method of adding exceptional value to a Rolex timepiece. We are not only discounters,
but we fancy ourselves designers and innovators.
The Rolex Watch Company has been resting on its laurels for many years with aging
management, afraid to make any changes. Their only concession to modern style was
that they offered diamond and gemstone accessories to adorn modern timepieces.
Years ago, when I started learning the jewelry manufacturing business, I discovered
that Rolex's price for their gemstone enhancements was egregiously high. This prompted
me and my wife, and we developed a beautiful set of gemstone accessories. We then
sent our accessories to the International Gemological Institute, along with Rolex's
factory made accessories, to scientifically prove to our clients that our accessories were
commensurate in quality and workmanship with Rolex's much more costly diamond
accessories.
Of course, this stirred up the Rolex watch company. Then when some of my competitors
started to get into the act, (even I have competition, but we learn to live with it in
America) my wife and I came up with another ingenious idea.
We found out one day that the Rolex Watch Company publicly espoused the dictum
that a Rolex watch was built to last indefinitely. When I combined this knowledge with
the fact that Rolex has always been very, very, very, slow to change styles, and that
most models went unchanged year after year, I came to the idea that the least expensive
way for somebody to own a beautiful Rolex would be to buy one of our totally
refurbished pre-owned Rolex watches. Thus, a whole new industry was established.
We opened this venture with an explosion of business and, unfortunately, Rolex very
quickly learned what competition would be. The pre-owned Rolex marketing has
become so successful that it would almost take a brain dead schmuck to consider
anything else.
Of course, this has greatly upset Rolex's marketing network. Their jewelers were
hard-pressed to figure out how to sell an 18K Yellow Gold Man's President for over
$20,000 when I was presenting watches that were albeit older models for as little as
$7,900. Then, when somebody wanted a diamond face for their Rolex, where Rolex was
charging $1,750, we would offer our clients an official Rolex dial which we added
genuine diamonds to for only $650.
But, of course, many Rolex jewelers were able to persevere under the assault by
discounters. As we both know, Mr. Attorney General, discounting has not eliminated
commerce in America. Tiffany & Co. is still thriving as are Neiman Marcus and other
citadels of retail marketing. What the Rolex, Cartier, and Piaget Watch Companies have
done is to resort to heavy-handed de facto harassment.
Instead of competing with me on an even playing field, Rolex had the temerity to accuse
me of counterfeiting. Their contention was that anybody who would add aftermarket
accessories to a Rolex watch would be committing a felony act of counterfeiting.
More unfortunately for me, Rolex found a group of attorneys ready to pander
themselves and harass me with what has become most expensive litigation. One firm
produced a posse of armed federal agents at my door. Armed with a search warrant,
they literally harassed my wife, my son, I in the middle of a business day in July of 1990.
Shortly thereafter, through bulldog persistence, Rolex got a panel of judges in the 9th
circuit (I believe) to agree with them that watches amended with diamond accessories
were indeed counterfeit. Well as Charles Dickens said, sometimes the law is an ass.
Dozens of small entrepreneurs around the United States found themselves in the thick of
felony counterfeiting. One young man in Florida who was newly in business was so
harassed by the rapacious legal firm that Rolex was using at the time, that he committed
suicide by shooting himself in the head.
Rolex has since discovered that by instigating vexatious and inane lawsuits, they
can quickly enervate the small businessman. The field of intellectual property
attorneys is slim and expensive. Most of us little guys cannot handle the bills.
Finally, a few years back, I found a marvelous attorney who believed in us and he got
Rolex to give me a settlement agreement. With this agreement I could continue to vend
their product with aftermarket accessories, provided I give proper disclosure.
Then, along came the Internet, which bred a pernicious band of liars and counterfeiters.
But the Marcus family of good Bronx and stubborn Puerto Rican stock persevered
through it all and continued offering the most intense values that could be offered.
Where Rolex offers a two-year service warranty on their new watches, we bested them
by offering a lifetime warranty on pre-owned watches. For clients who live out of town,
we send them a self-sealing mailing box with packing materials - at no cost to them to
them - to send their repairs to us. Where Rolex turn-around is four to six weeks, we are
often able to offer service overnight.
My wife's and my marketing worked out so well that our client list is composed of a
great deal of America's most important citizens and movers-and-shakers. When a
customer visits our website, we even supply thousands of written testimonials with
names and contact information for those doubting our integrity. William F. Buckley
has even purchased from us. I even have an autographed picture from Ted Koppel.
My wife and I have absolutely built a better mousetrap. Besides the world beating a path
to our doors, and army of lawyers hired by European price fixers are slowly trying to
squeeze the life out of us.
In a valiant effort to lower our profile and overhead, I moved from Beverly Hills - my
father was right when he said if I worked hard I could live well - to Georgia. The cost of
living was considerably less expensive than in California. I had the notion that if I was to
lower my profile
from that of a Beverly Hills jeweler and set up my base of operations, maybe Rolex
would get off my case.
But, shortly after I reached Georgia's green hills, I was served with a massive lawsuit,
not to mention a brain hemorrhage. In raking over the coals, Rolex's lawyers
discovered that somewhere in the bowels of the settlement agreement that Rolex had
me sign during the federal invasion of my premises years earlier, they had buried
some arcane stipulation that, in any display advertising, I had to make the name of my
company at least a quarter of the total height of the Rolex watches displayed in that ad
- not just once, but twice.
Additionally, we were also required not to put the name Rolex on any signs or on any
place in our building that might in any way allude to the fact that we sold Rolex
watches.
But, voila, Rolex's attorneys were able to drum up a case. I am not hiding behind the
fact that I had a stroke, which may have given me some disability in judging numbers,
but when they pointed out than an ad that I ran in the New York Times was out of
specs as the name "Capetown" was about a quarter of an inch out of proportions to the
terms of the settlement agreement, it has since cost me over $300,000 in attorney's fees.
This expensive and malicious litigation continues through today and the bills keep
mounting up with no end in sight. The case is now buried with Federal Judge Clarence
Cooper who has been mulling about what to do for what is now two years.
So, my wife, my employees, and I live in fear, never knowing when the end will come.
We have become victimized by America's free enterprise.
If the judge was to issue a preliminary injunction, POOF there goes our life's work, all
because we found a better way to market watches diamonds and jewelry rather than
by utilizing the set European retail price, which does not provide their retailers to ever
discount.
In the past couple of years, we have been served papers from Rolex, Cartier, and the
De Beers diamond certificate.
Mr. Attorney General, it just doesn't seem fair. Can anything be done to stop this?
Any suggestions or help you could offer would be much appreciated.
I thank you for your time.
Best Regards,
Carl Marcus
Capetown Diamond
September 01, 2005
Alberto Gonzalez
United States Department of
Justice
950 Pennsylvania Ave,
N.W.
Washington, D. C.
20530-0001
Dear Mr. Attorney General,
In regards to my previous missive, which was written to you while I was in an
emotional state, I fear I did not make myself very clear. Perhaps I am calling on your
office for help when no help is available. The legal premise that I am seeking your help
with is that foreign retailers - namely Rolex, Cartier, DeBeers - are very tacitly
preventing me from exorcising my right, if indeed I have that right, to free enterprise
by launching vexatious lawsuits against my company of which they know full well
that a small company cannot afford.
By doing so, I feel that it is a de facto form of price fixing, which several of my attorneys
advise me is not legal in America. I would hope that price fixing in any way shape or
manner - even if it is slyly disguised in the form of a mindless lawsuit — should be
considered illegal intervention in the rights of Americans to do business.
If it is not legal to fix prices, I fear that by allowing this insidious practice to go on, we
are allowing foreign corporations to change the very foundation that America has
been built upon.
For a small family business, the continual legal harassment is akin to a Mafioso
firebombing the store. I hope that, on this tact, you will have some power to help our
group. By our group, there is a legion of men who are semi-retired, retired, veterans,
etc - all Americans - who are in similar business to mine - particularly in the watch
repair industry. The reason that a party would bring the watch to an individual
watchmaker is that they generally charge less and can operate much quicker than a
larger corporation.
To get a better idea of what I do for a living, you might wish to take a look at my
website: www.capetowndiamond.com.
Recently, Rolex issued an edict that they would no longer sell parts to most
independent watchmakers - including my own. In what seemed like a nanosecond,
some malevolent-minded Rolex executive took away the income from thousands of
people, who depended on that income to make a living - many of them elderly
gentleman who had no one to turn to.
I and several other fraternal organizations have attempted to form a legal defense
fund, or perhaps even solve this deceitful practice politically. However, most
watchmakers are submissive souls. By nature, their profession seems to attract silent,
sedentary, make-no-waves guys - a defenseless group that could certainly use some
help.
Further into the food chain, we have the consumer who is now chained to the
manufacturer for parts, eliminating all significant competition. For me to file a suit
against these corporations for what I think are egregious legal atrocities would not be
financially possible. What I hope to do is to make enough noise through the avenues of
the press such as the Wall Street Journal and the New York Times, thereby bringing
some adverse publicity to the foreign pirates who are causing this.
When I presented this to Elliot Spitzer, he thought my premises might have had merit
and thus suggested I contact you. So, I sincerely hope that you won't write me off as a
crackpot or a nutcase. If I am indeed tilting your windmills, it would be kind to advise
me that I am.
But, Mr. Attorney General, I strongly suspect that Rolex, Cartier, Richemont, Louis
Vuitton, DeBeers, et al are committing crimes against the very fabric of our democracy.
If need be, I am sure that I can generate several score of notarized affidavits from
members of the trade stating how they have been put upon by those foreign pirates.
Just to give you an idea of how egregious these folks are, it is a well-known fact that
DeBeers has for years totally controlled the diamond production and distribution of
the United States diamond market. Recently, in one of my business journals, I read that
they were now going to go vertical, which is a 21st century catchword for stifling your
competition. They announced that they would now be opening up retail stores all over
the United States - Manhattan, Beverly Hills, etc - thereby going into competition with
all of the companies they had been supplying for years.
This information stimulated the marketing part of my brain. I did a little research and
found out that their retail prices are insanely high. So, I ran an ad in the New York
Times (see enclosed) showing a perfectly colorless and flawless diamond at an insanely
low price. I bought it years ago and have been sitting on it ever since. Even at the low
price I offered it at, I would still have made some money.
So, here is poor old me in Roswell, Georgia, operating out of a clearing in the forest.
Next thing I know, DeBeers served papers on me. When my attorney asked them why,
it seems that a partnership company formed between DeBeers and Louis Vuitton is at
the throat of the DeBeers Diamond Syndicate and vice versa, trying to win the DeBeers
trademark in the United States.
In my mind, the real reason for the legal service against me is that I was offering a
diamond for $33,000 that they were asking $500,000 for. What other information could
I give them about their partners and opponents? I don't know anything about them
that they don't know already.
Every time we get served with one of these legal inquiries, it costs our company
thousands of dollars or more, it takes a lot of energy, and it depresses all of us, because
it is contrary to what I
believe: If you work hard and can legally best your competition, you have a right to
succeed. I and my family are becoming victims of our ingenuity and enterprise.
Mr. Attorney General, there is something in the woodpile. With hope, your busy
schedule will allow you to look into it.
I am hopefully awaiting your decision,
Carl Marcus
Capetown Diamond
To: John R. Read
Chief, Litigation III Section,
Antitrust Division, US Department of Justice
325 7th Street, NW, Suite 300
Washington, D.C. 20530
May 9, 2006
Gentlemen,
I'm writing this letter in response to the upcoming decision on the 1960 Consent Decree
between the US Government and several Swiss Watch companies.
I am a small businessman in business for over 32 years who is a distributor of clock
repair material for Atmos clocks manufactured by Jeager LeCoultre. We had been doing
business with them for over 10 years. Out of the blue they declared they no longer
supply material to wholesale distributors. This has put a dent in our business and
affected thousands of clock repair shops around the country and around the world who
depend on a source of repair material to make a living.
This narrow minded discriminatory decision has had a detrimental affect on my
business as well as the small businesses we sold to. To let these large companies off the
hook while they continue to make huge profits off retail sales while not allowing repair
shop to receive material to service their goods is unconscionable. I hope you will see fit
to rule against these companies who will not sell replacement material to service their
merchandise.
Thank you,
/s/
Steven Berger
Star Fellow, National Association of Watch and Clock Collectors.
AWCI
BHI
Antiquarian Horological Society
Timesavers
Box 12700 • Scottsdale, AZ 85267 • USA
1-800-552-1520 • 480-483-3711
Fax 480-483-6116
info@timesavers.com • http://www.timesavers.com
 | Sheldon D. Warren
1300 E. 86th Street
Indianapolis, EM 46240
Ph 317-414-3891
E.mail sheldon57@juno.com |
Wednesday, May 10,2006
John R. Read
Chief, Litigation III Section,
Antitrust Division, US Department of Justice
325 7th Street, NW, Suite 300
Washington, D.C. 20530
Dear Mr. Reed,
Abandonment of the 1960 Consent Decree between the watchmaking industry and the
United States Government isn't the answer. Strengthening the Consent Decree would be
most desirable. It should be strengthened to the extent of making spare parts available for
repair purposes to all watches sold on the American marketplace.
The result of withholding spare parts is destroying the watchmaking industry in this
country. Few are entering the profession because of the unavailability of spare parts,
consumers are held hostage to repair shops who have spare parts available to them and
huge profits are being made as a result of the withholding of spare parts from the
marketplace.
Sincerely yours,
/s/
Dashefsky, Michael
| From: | Hinman, Elizabeth |
| Sent: | Thursday, May 11, 2006 2:56 PM |
| To: | Dashefsky, Michael; Read, John; Hale, Nina; Lewis, Lynette |
| Subject: | FW: A badly thought out move by the U.S. Government |
An email regarding Rolex from the Antitrust-Internet Comments inbox. Thanks!
Liz
-----Original Message-----
From: ishioka@gol.com [mailto:ishioka@gol.com]
Sent: Wednesday, May 10, 2006 3:4 6 AM
To: ATR-Antitrust - Internet
Subject: A badly thought out move by the U.S. Government
Dear Sir or Madam,
The United states intends to drop an anti-trust judgement against the
Swiss Watch industry as outlined in the following document
www.usdoj.gov/atr/cases/f214800/214815.htm
Specifically named in this complaint is the Rolex Watch Company.
As many other watchmakers other than myself have testified , the same
abuses that cause the United States to bring anti trust proceedings
against Rolex and several other importers of Swiss watches back in the
1950s still exist today. Despite the fact that the watch business has
changed massively, Rolex in particular continues the same abusive
practices that led to this action many years ago.
In particular Rolex and other Swiss makers limit their supply of parts to
legitimate and certified watch makers under the spurious claim that only
special trained watchmakers can repair their watches. A mechanical watch
is essentially no more complex than a ringer washing machine. It is a
child of the 19th Century and by modern standards it is a relatively
simple machine. If a washing machine manufacturer claimed that only
someone with special training—which conveniently, no American had—could
fix their washing machines, they would be laughed out of court.
This is precisely the same situation that exists today in regard to
mechanical watches. Although in volume they may be less than 10% of the
market, in terms of value, they are well over 60% of the contemporary
watch market, so, in business terms, they are very important indeed.
Limiting the availability of parts may help Rolex's profitability, but it
removes a source of income from the American watchmaker and causes an
artificial shortage where none exists in spare parts. The big loser in
the end is the American consumer, who must pay inflated prices for parts
and repair work that only Rolex can be the judge of.
There are many far more important anti-trust cases before the government
than this one. But the fact that the same accusations are being leveled
against the Swiss watch industry and Rolex in particular over 50 years
since this action began should convince one that the leopard does not
change his spots nor Rolex its' behavior.
Respectfully,
William T.Stonehill
Watchmaker,
Member American Watch and Clock Maker's
Institute
JON W. HORTON
AWCI/CMW, MBHI, NAWCC
530 South Wheeling Ave., Tulsa, OK, 74104
918.592.0870
jonhorton@cox.net
Friday, May 12, 2006
John R. Read,
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington D.C. 20530
Re: Abolishing the Swiss Consent Decree
Dear Mr. Read,
Please do not allow the abolition of the Swiss consent decree that has protected small service centers like myself
for many years.
We have a very hard time as it is getting spare parts for luxury brands. The Swiss have formed "Groups" instead of
the former "Cartels". The net effect on small service centers like mine has never been even close to being what we
need for fair competition. To delete the Decree could easily put American service centers for Swiss made watches
out of business.
Please use your influence to keep or even strengthen fair trade of services to Swiss made watches that are done in
the USA.. I can be reached by email at iwhorton.usa@cox.net or by phone at 918-592-0870 or the mailing address
above if someone wants to discuss this matter.
Thank you for listening.
Best regards,
/s/
Jon W. Horton
Certified Master Watchmaker
American Watchmakers
Institute
Member British Horological Institute
National
Association of Watch and Clock Collectors
POND COTTAGE
FRISTON, EASTBOURNE
EAST SUSSEX BN20 OAL
(01323) 422422
John R. Read
Chief, Litigation III Section
Antitrust Division, US Dept of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530 | May 12, 2006. |
Re: Rolex USA,Inc: Proposed Termination of Consent Judgment
Dear Mr. Read,
I oppose the proposed termination of the consent judgment in this matter. I
am an independent watchmaker repairing a variety of watches made over
the past 200 years. I am an American citizen, resident in England.
The consent judgment as it stands is a positive force for competition in
that it makes it possible for small unaffiliated businesses like mine to obtain
Rolex parts in the US. In England and in Europe, Rolex is far more restrictive
in the sale of its parts. Indeed, commonly-needed parts (such as winding
crowns) are obtainable here only in a generic, non-Rolex form: they are made
by someone other than Rolex to meet this need. Most parts however are
available only from Rolex.
Relieving Rolex of the healthy free market in which in the US it has been
obliged to participate will result in less work for independents, less choice for
consumer/owners of Rolex products and less competition on repair pricing.
There is no more justification for this than there would be to restrict the sale
of car parts. Imagine the uproar if your Department proposed to allow Ford
to refuse to sell gaskets, pistons or filters for their vehicles—even to their
owners!
The reasons cited by Mr. Dashefsky for termination (see his
Memorandum at sec. III) are naïve and do not reflect present day reality. Yes,
there have been great changes in the watch industry. Of, say, a billion
watches produced world-wide each year today, 980 million are cheap,
virtually irreparable and disposable. They are of less total value than the
remaining 20 million watches which come principally from Switzerland.
Fifty years ago, the Swiss dominated on value, as they still do today, and also
on volume, where today they do not. Their dominance is, I suggest, in the
more important area! What the Swiss make today is high grade and worth
repairing. This is not true of 99% of the remainder of world production.
The collective convention of the Swiss may have gone. But if you look a
little bit at the behaviour of the Swiss government, Swiss banks and the
principal watch companies, you will find that they work together in a way
which would be impossible in the US. The best example of this was the
successful defense of mechanical watch makers in the '70s and '80s when the
new quartz movements, which are electronic, nearly ended mechanical
production. The industry has the backing of the Swiss nation to a degree
unimaginable in our country. To suggest that it is now no longer dominant is
naive because where it matters, as in product value, it is the most significant
world player. And there is no longer any domestic competition in the US.
A consequence of the judgment is to make it a bit easier for independent
watchmakers to compete with manufacturers on repairs. That does not seem
wrong to me. Other than to enable Rolex to behave in the US as they behave
elsewhere in the world, there is no reason to amend this useful, sensible consent judgment
and I ask that you reconsider your proposal so as to conclude that the Final
Judgment of March 9, 1960 be allowed to continue in force. Other Swiss
watch manufacturers will be watching this matter and will, I am sure,
follow the path that the Department is now preparing to illuminate. I
suggest that the well-trodden one deserves continued use.
I would be happy to try to answer any questions which you or your
associates might have on any of these matters. My Swiss and world
production figures are from recollection but they are accurate as to the great
split in value between the Swiss production and that of the rest of the world.
Thank you for your consideration and inclusion of my views.
|
|
_______________/s/________________
Charles R. Peck
|
| cc | American Watchmakers
Institute
Hon Edward M.
Kennedy |
A-1 Watch Company
8777 E.
Broadway Blvd.
Tucson, AZ. 85710
1-520-731-2663
Dear Mr. Read: May 15, 2006
I am sending you this letter in regards to the consent decree that Rolex Watch Co. is trying to
end.
I am a second-generation watchmaker and my son is the third. Our family has been in the watch
repair business since my father graduated from Bradley School of Horology in 1930.1 have
repaired watches since I was 13 years old (now 51)
My direct experience with the watch industry is with the company called Norman M. Morris
Corporation,
which is the original marketing and parts distributor for Omega Watches.
When I could buy parts direct from them I would pay $10.00 to $15.00 for a part called the
Crown (the part
you wind the watch with.) These parts are needed to protect the watch from dirt, dust and
moister from
entering the watch.
Now that the company called The Swatch Group controls the Omega watches and parts they
have taken
away our ability to buy parts for their watches. We have to buy them from an independent
supplier. One of
which advertises in the AWCI magazine called the Horological Times. The same parts that I
described are
now costing between $26.00 and $56.00 for the same exact items. This puts the watchmakers and
the
consumer at a disadvantage. The parts have gone up so much that only a small profit is
available. As you
know profit is not the most important part of any business however it is necessary to keep the doors open.
If you are not aware The SWATCH GROUP controls the manufacture of Omega,
Rado, Tissot, Blancpain,
Breguet, Calvin Kline, Certina, Endura (Case Company) ETA (watch mechanism manufacture)
Favre & Perret, Flick Flak, Glashutte Original, Hamilton, Leon Hatot, Jaquet-Droz, Lanco, Lemania,
(movement manufacture) Longines, Mido, Nivarox-Far (mainspring manufacturer), Record, Renata,
(watch batteries manufacture), Union, Unitas, (watch movement manufacture) Universo, (watch
hand manufacturer), and last but not least Valjoux the company that makes movements for
Breitling, Sinn, Baume & Mercier, Bell & Ross and 90% of the high grade mechanical chronograph
movements.
In the last five years I have been refused parts purchase from other companies.
Patek-Phillipe, Bulgari, Jaeger - Lecoultre, Breitling, and others.
The inability for me and other watchmakers to obtain genuine and original factory parts creates
an unfair playing field in the sense that the factory service centers have all of the parts they need
and if the consumer sends the watch to them they can repair it with genuine factory parts. The
problem with this is the factory services charge almost double and the length of time for repair is
a minimum of four to six weeks. Out shop repairs and delivers watches within ten days to two
week providing we do not get a back order on the parts or refusal from the manufacture to
purchase.
The use of generic parts on an old Bulova or Elgin is OK, but a person that wears a high-grade
watch wants only genuine external and internal parts used in the repair. The use of non-genuine
parts devaluates the item and increases it's chances of getting full of water or dirt because the
generic parts are not manufactured to the same specs as the originals. Use of non-genuine
material is like taking your new Lexus to a shop and they tell you that they can only get parts
made in China or Hong Kong.
John R. Reed
Chief, Litigation III Section
Antitrust Division, US Department of Justice
325 - 7 th Street, N.W, Suite 300
Washington, D.C. 20530
Dear Sir
This responds to your request for comments in regard to the Restrictive Parts Policies of a number of watch companies acting in accordance with the Swiss Watch Federation. I am sure you are aware, the Swiss Watch Federation
is an umbrella organization, set up to establish guidelines and to set policies regarding watch and watch parts promotion and distribution.
I have fought the Swiss Watch Federation and these policies for years and finally realized that without government intervention, it will be impossible to change the policy. However, a number of watch companies separately
established their own restrictive distribution policies in an attempt to eliminate the private sector, including independent watch technician and watch material supply houses. These companies claim the policies are for quality control
purposes, however, the effect is control of the after sales, parts and repair business even out of warranty repairs to be completed by their factory technicians and enforce the policy by refusing to sell parts and related material. The
results are the elimination of competition and consumer over charges. The consumer and watch technician-repairmen are the victims. Personally, I can not stay in business without parts to repair watches.
To fine Rolex $ 750,000 is of no consequences. Unless large enough to be felt by impacting profits, fines will not work. Neither will tariffs.
However, the US watch business and markets are immensely important to the Swiss and their economy. Prohibiting imports of Swiss made watches would get immediate attention - almost certainly resulting in changes in the
material distribution policies.
Respectfully,
Hans Eckert
/s/
Hans Eckert
European Watch Service
P.O. Box 91092
Long Beach, CA 90809-1092
Hanswatch1@aol.com
Shop / 562-439-2474
Wednesday, May 17,2006 America Online: hanswatchl
John R. Read
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
325 7th Street NW, Suite 300
Washington D.C. 20530
From
Dwight McCartney
P.O.Box 57
Wilkeson,
WA 98396
May 18, 2006
Dear Mr. Read,
I am told that the Justice Department is considering eliminating the antitrust
regulation which
govern Swiss watch industry in America..
You should be made aware that this action will have a detrimental effect on my own
business.
You see, I am a watchmaker, and it is very likely that Rolex and the other companies
will restrict
or refuse parts availability to me.
I have made my living repairing watches ever since I graduated from Kansas City
School of
Watchmaking in 1977. The KCSW was a highly regarded school and founding member
of the
American Watchmaker-Clockmakers Institute Research and Education Council.
Also, please be aware that since I will not be getting Swiss parts to repair watches
with, I would
have to use after market parts which are sometimes inferior. Rolex has required that
their dealers
refuse to service any watch with non Rolex parts, so you can see that the end
consumer will also
be harmed by these anti competitive practices.
I ask you to consider carefully what action will truly be of benefit to all American
citizens, not
just the ones who have been chosen by foreign companies.
Thank you,
Dwight McCartney
/s/
 | Old Father Time
11138 Air Park Road, Suite J, Ashland, VA 23005
Telephone: (804) 798-8868 • Fax: (805) 798-8869
|
May 25, 2006
John R. Read, Chief
Litigation III Section
Antitrust Div., US Dept. Of Justice
325 7th
Street, NW, Suite 300
Washington, DC
20530
Dear Mr. Read:
I write to you regarding the consent decree involving luxury watch manufacturers. It's important that this
decree be retained intact and without compromise. America's watch industry has undergone many changes over the
last 60+ years, as you know. Many of the American watch manufacturers were literally put out of business because
of international acquisitions. The larger Swiss houses eliminated most of their US competition for the manufacture of
fine time pieces. It appears they are now attempting to finish the job by eliminating American watchmaking
ENTIRELY.
American watchmakers rely on the repair and restoration of finer timepieces as a staple to their business.
Denying access to parts for these repairs will begin a quickly declining spiral down, until the point where no
American watchmaker can remain in business at all. At that point, American will have once again lost a valuable art
form forever.
Companies like Rolex make enormous profits every year from US consumers. Once the sale is made,
Rolex will leave Americans no alternative but to return their watch for service - a six month proposition if history is
any guide, and at enormously obscene costs.
I am the owner of a mid-sized watch repair facility outside Richmond, Virginia. The decision regarding
this consent decree will very likely determine my fate.
Respectfully,
/s/
Barbara D. Williams
Visit Us On the Web at http://www.oldfathertime.com
Or E-Mail us at Watchmaker@oldfathertime.com
| Attn: John R. Reed | May 25, 2006 |
I Howard Cromartie am an AWI Member  25159, I am a certified Rolex
Watch Maker and trained on other Swiss Watches. I am 68 Years old and
worked for Reeds Jewelers for 23 years. I am now retired from Reeds Jewelers
and Rolex will not sell me parts to service Rolex Watches and other Swiss
Watches. I do not support the Consent Decree, this is American we live in not
other countries. Rolex is depriving me of income by not selling me parts and I
am well qualified. Also other Swiss watch companies will not sell me parts.
Sincerely,
Howard W. Cromartie
4094 Beattys Bridge Rd.
Atkinson, NC 28421 Phone 910-283-6084
/s/
270 E. CROSSVILLE ROAD • ROSWELL, GEORGIA 30075 • (770) 645-8555 • WWWCAPETOWNDIAMOND.COM
May 26, 2006
Mr. John R. Read
Chief, Litigation III Section
Antitrust Division US Department of Justice
325 7th Street NW Suite # 300
Washington, DC 20530
Dear Mr. Read,
I am writing you in hopes that you would not dissolve the consent decree regarding
Rolex Watch Co. and the rest of the foreign Swiss watch manufacturers, who I'm
sure are hoping you will.
Don't let Rolex BS you. The company is run by an adamant pack of greedy jackals.
As an adjunct to this letter I am sending you a letter I wrote to Mr. Gonzalez, from
which I have not received a reply.
I urge you to believe me that when I tell you that the fine watch business, in
America, with the emphasis on repairs is growing in leaps and bounds. The
manufacturers Rolex, Cartier, Ebel, Breitling, Omega, Jaeger LeCoultre, Audemars
Piguet, et. al. are providing slow and expensive repair solutions to consumers.
There is a division of men and woman, a good many of them disabled veterans and
a fine group the most of which belong to the AWCI. All we ask is that you do not
allow these foreign entities to curtail the availability of spare parts so that we may
continue to repair these watches and offer the public an alternative. We are
making our living on restoring and servicing fine Swiss watches. Rolex for no
good reason took away my son's parts account, shortly after he was married.
Through hit and miss we have been supporting him for over a year. But without the
availability of Factory Made Rolex parts both my son and I cannot exist. I know
Justice is busy and there are certainly cases more urgent than this but if you will
read the letters I sent to Mr. Gonzalez I am sure it will give you an idea of what
America means to us. It means free enterprise, and fairness to all. It is not fair to
allow a rich, fat cat like Rolex and the others to not offer us repair parts. Without a
steady supply of factory watch parts I, my family and my employees will perish -
along with a little bit of what was America. We are not asking for much, and as I
told Mr. Gonzalez I don't want myself, my family, my grand child and disabled war
veteran employees standing in front of the justice department with a tin cup
begging you to allow us to stay in business.
Now you might say. "Well get a lawyer". We have already spent over $600,000
on legal fees fighting these Swiss manufacturers. In the final analysis the only
justice that will prevail will come from the US Department of Justice. I am not a
man of letters Mr. Read, I am disabled and can only type with one hand. I can
perhaps verbalize my plight easier on the phone but please understand that the
greed and avarice that prompted the consent decree years ago hasn't changed.
It's human nature, whenever an opportunity is available to squeeze out an extra
buck somebody will do it. This is why justice must be continually vigilant. There
is no reason why you won't do anything. Rolex U.S.A. is making it most difficult
to earn a living these days. They are selling thousands of watches a year in the
U.S.A. And all of these watches are subject to malfunctions. Without the
availability of these parts, just exactly how do we make a living?
I know the justice department employees are quite insulated from the real world,
it is impossible to phone you but with my dying breath. Every trade association
in America is inflamed about your lack of motivation and concern. (Please see
attachment.) Bear in mind that it is hard to feel sympathetic because they are
paying so much to get their Rolex repaired. Remember, we talked about
American families that do this for a living, just as you work for the government
for a living. There are a lot of woman and children and elderly Americans who
have a lot at stake if you make the wrong decision. We are not talking about
Mexicans and Iraqis, we are talking about American citizens who have spent as
much as thirty years learning their trades. It is just not fair to allow a greedy
Swiss monopolistic company to subjugate us. I anxiously await your reply!!!
Sincerely,
/s/
Carl
Marcus
Chairman of Capetown
Diamond
CC: New York Times
CC: Washington Post
CC: Wall Street
Journal
CC: Larry
King Live
CC:CNN
Capetown Diamond
www. Capeto wndiamond.
com
800-442-7866 Fax
770-645-0450
Carl@capetowndiamond.com
May 26, 2006
John R. Read,
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
3257th Street, NW, Suite 300
Washington D.C, 20530
Dear Sir:
The action of the Swiss Watch Companies in refusing to sell
me or my suppliers parts takes business away from me. These
companies want the watch owners to send their watches to their
chosen repair shops that charge more than twice my prices for
the same work.
I have been in this location for many years and have customers
that know my work and would rather have me make the repairs.
However when a quality watch needs parts I want to be able to
use factory original ones, at the present these are not
available. Some generic parts are available to me but I inform
my customers that for original parts they have to send the
watch to the factory authorized locations. Most of the watch
owners will not do this for they are leery of sending their
valuable watch to some unknown place. Plus do you realize how
many things are lost in shipping. From my experience lost
items are greater now than any time in the past.
Sincerely,
Winford Rawls
_______________/s/________________
PO Box 510
Tylertown Ms 39667
3728 Hwy 377 South  Fort Worth, Texas 76116
Phone 560-1338 Email bill@billpeoples. com
May 26, 2006
To John R. Read
US Department of Justice
Dear Sir
I feel strongly that Rolex and other high cost watch manufacturers are doing the small Mom and Pop
shops a disservice. I feel that we should be allowed to purchased parts to repair their watches, either
from them or from watch material house. I have been in the business of repairing watches for over 20
years and have worked on numerous Rolex Watches. But, now it's impossible to get some parts, and
those parts I do get are generic parts. I would prefer to use genuine Rolex parts.
I was allowed to purchase parts from Rolex for several years and on November 20, 2002,1 received a
letter from Rolex stating that effective that date I would no longer be able to purchase parts from Rolex;
and future stated that they would not give a reason why they would no longer sell me parts. See
attached copy of their letter.
/s/
Bill Peoples CC
Owner
Rolex Watch Service Corp. Rolex Building 2651 North Harwood Dallas, Texas 75201 Telephone (214) 871-0500
November 20, 2002
Billy M. Peoples
3728 Hwy.
377 South
Fort Worth, TX
76116
Re: Account 993266
Dear Mr. Peoples,
After careful review of your spare-parts account, we are herewith informing you of our decision to discontinue
our business relationship. Your Rolex spare parts account has been officially closed as of today's date.
For more information, you may refer to your agreement, which provides in the Policy Statement, under General
Policies, 4th item, that "Both the parts account and Rolex are free, at any time and for any reason, to discontinue
their business relationship, without cause and without prior notice."
In compliance with this agreement, we will not discuss the details of our decision.
Sincerely,
ROLEX WATCH SERVICE CORP.
/s/
Khaled Elrawi
Spare Parts
Manager
Bangkok Beverly Hills Brussels Buenos Aires Caracas Cologne Dallas Geneva Hong Kong Jakarta Johannesburg London
| | 223 Scottdale Road,
B-308
Lansdowne, PA
19050
May 26, 2006 |
Mr. John R. Read, Chief
Litigation III Section, Antitrust Division
US Department of Justice
325 7th Street, NW, Suite 300
Washington D.C. 20530
Dear Mr. Read:
I am a watchmaker and clockmaker, and I am concerned about the
dropping of the consent decree involving Rolex and its recently changed
policies regarding spare parts resale restrictions, voiding of warranties if
generic parts are used, and fixing minimum and maximum prices,
despite the position taken by any professional organizations to which I
belong, such as the AWCI.
The watch industry has changed due to technological advances during
the last 40 years, altering the number of lower-priced units sold in the US.
The volume and manufacturers of luxury watches has not significantly
changed in terms of units sold. The defendants targeted by the consent
decree deal primarily in the luxury watch market, with little or no
participation in the low-end market. Therefore using the addition of
quartz movements, Timex, Bulova, Seiko, and other low-priced
alternatives, (given as a reason to change laws in place governing the
luxury watch market), seems to be an incorrect application of the rule of
reason in place of the per se rule.
The dropping of the consent decree could put Rolex's revised policies in
violation of certain Sherman Antitrust Act provisions. These provisions
include vertical price restraints in regard to fixing minimum and
maximum prices, non-vertical price restraints in regard to spare part
resale restrictions, and tying contract violations in regard to the policy
voiding warranties if generic parts are used.
Material houses will be affected by the dropping of the consent decree,
which will in turn have a direct impact on AWCI members' ability to
make timely and profitable repairs in their businesses. One fact that may
not have been recognized by the AWCI Board of Directors is the true
financial history of material houses compared to the luxury watch
brands.
The original judgment has vertical restraints that the Department of
Justice deemed necessary as a means of watch parts distribution in the
1960's. This was designed to keep the Swiss Cartel from restricting the
flow of parts necessary for the watch repair trade to operate. The "Swiss
Cartel", as it was known, may not exist today in name only. The common
business practices of today's Swiss Watch Groups, who work together,
produces the same result of the illegal Cartel from
earlier decades. The companies may have changed their names to "Groups", but
what was against the law in i960 is still illegal today.
I hope the potential adverse impact on my ability to earn a living is considered
by the government.
Sincerely,
/s/
Anthony J. Ambruso
Peter J. LeCody
Regional
Franchise Owner
Fast-Fix
Jewelry Repairs
8687 N.
Central Expressway
2320
NorthPark Center
Dallas,
Texas 75225
(214)361-2811
x4
May 27, 2006
John Read
Chief, Litigation III, Antitrust
Division
325 7th Street NW, Room
300
Washington DC 20530
Dear Mr. Read:
I understand that USDOJ, Antitrust Division, will be ruling soon on removal of a
consent degree between the government and several Swiss watch manufacturers,
including Rolex, that has been in place since 1960.
While I am in generally in favor of canceling the consent decree regarding the
distribution of spare parts to authorized resellers, the main thorny problem still
remains on predatory pricing policies from some Swiss watch manufacturers
and their U.S. Distributors.
While some manufacturers only make their replacement parts available through
a tight distribution network of the "good ole boys", some other manufacturers
and U.S. based distributors have one price for the retailers of their watches and
a higher price for those who are trained in watch repair skills, but do not carry
the watch brand. This puts companies like ours at a distinct pricing
dis-advantage to our consumers. This is not a level playing field.
If independent car repair facilities were not able to obtain genuine replacement
parts for their customers, or were forced to pay a higher price from the
manufacturer or distributor, this would put them in an uncompetitive position.
Example: if the Ford Motor Company were to charge their dealers $100.00 for a
headlamp and charge an independent repair facility $175.00 for the same item,
most independent repair shops would soon be out of business. The same
dual-pricing scheme happens to watch repairers everyday. We get a royal
screwing from watch manufacturers and distributors on pricing. We need a
level playing field.
Sincerely,
/s/
Peter J. LeCody
May 28,2006
John Read
Chief, Litigation 111,
Antitrust Division,
U.S. Department of Justice
325 7th Street NW, Room 300
Washington, DC 20530
Dear Mr. Read:
I am writing to you regarding the motion of Rolex Watch USA for an
order terminating final judgment of Civil Action 96-170. My opinions are based
on 30 years experience in the watch industry working for one of the major firms
that imports and distributes watch parts to the trade.
I believe that it is not in the public's best interest to terminate the final
judgment.
Section 1 of supplement to civil action No. 96-170 refers to the Collective
Convention of the Swiss Watch Industry. This cartel like behavior still exists
today as the watch companies' act in unison. Sales of parts are to those that are
deemed worthy of the "privilege." The sale of parts is contingent upon using the
part only for a particular repair, not reselling the part to a third party, charging
a "suggested" amount for the repair, acquiring certain tools and equipment, and
many more guidelines that can be found in Rolex's policy statement. Rolex is
not the only firm to have these guidelines. Most of the Swiss luxury watch firms
have similar terms.
Section 3 of the supplement cites tremendous changes in the watch
industry as a reason for termination. What industry has not? Experienced
change? The idea that the Swiss are no longer a dominant force in the watch
industry is based on facts twisted to the benefit of the luxury watch firms by
their attorney. While they do not produce as many units as they once had, they
do have an overwhelming majority of dollars in annual sales not only to the US
but worldwide. See attached page from the Swiss Watch Federation.
Section A of the supplement also suggests the pin-lever movement as a
cause of the decline of the Swiss watch. I submit to you cheap watches have
been around a lot
longer than the pin-lever movement (the dollar watches made by American
firms at the turn of the century). A distinction must be made between a luxury
watch and a disposable watch. While the
American consumer has a wide range of watches to choose from, if they want a
luxury watch, they must buy a Swiss watch. Terminating the Final Judgment
would only give Carte Blanche for the Swiss firms to sell at whatever price they
choose inflating value by restricting access. They have removed the consumers'
right to where and by whom they would have their watch serviced.
It is my opinion and that of many others that the plan and ultimate goal
of the Swiss watch firms is to eliminate any third party involvement in the sale
and repair of their watches. A watchmaker depends on a supply house to have
parts for many brands as well as sundries, purchasing from one source lowers
shipping costs as well as time spent ordering. Since before the turn of the
century supply houses have provided a reliable and efficient network to
distribute parts for the watch factories. We now find ourselves dismissed
without regard from the factories for helping keep their brands alive. To stay in
business we must raise the prices of products we do sell. The cost of doing
business increases and the cost's all are passed on to the consumer. Many of us
have gone out of business.
An analogy is you purchase a Ford car and are told you must have it
serviced at the Ford dealership. This includes even oil changes or they will void
your warranty. Another scenario, you buy a used Ford from your neighbor to
fix-up and give to your son or daughter, but you find that some of the repair is
more complicated than you first thought. You decide to bring it to your local
mechanic. The mechanic at the local service station is unable to purchase a part
needed, you are told you must bring it to the Ford dealer. You are then told by
the Ford dealer they cannot work on your car because it previously worked on
by someone other than them and does not have all original factory made parts.
The only way they will fix the car is a complete overhaul using original Ford
parts. This type of situation is very unfair and does not allow for a free
marketplace.
Terminating the final judgment will only to serve perpetuate the decline
of the American watchmaker. The only place to service the watch will be the
watch companies own service centers. Jewelry stores will be reluctant to sell
these brands since they will be difficult or impossible to service. This would be
the justification the Swiss firms are looking for in order to open their own
company outlets completing the cycle of complete control.
Rolex's violations of the agreement only show their lack of respect for
American law and the American people. The settlement amount of $ 750,000 is
ludicrous; Rolex spends considerably more sponsoring yacht races. Small and
vague classified ads placed in trade magazines that would cause little notice
seemed pointless. The magazines chosen were not the best choices as they are
not the magazines that are commonly read by the watchmaker and watch trade.
Before a decision is reached I would ask that the person or persons
responsible for this decision visit a few local jewelers and ask firsthand their
views.
Sincerely,
Thomas D McRoy
908 Erdner Ave
Pittsburgh, PA
15202
 |
Fédération de I'industrie horlogère suisse FH
Verband der
Schweizerischen Uhrenindustrie FH
Federation of the Swiss
Watch Industry FH |
The Swiss and world watchmaking industry in 2005
Swiss watch exports
Introduction
After die success of 2004, Swiss watch exports
registered another record year in 2005. With
double-digit growth, they easily cleared die
12-billion franc mark. Growth in the sector has
accelerated since 2003 and maintained a high
level throughout 2005.
[D]
Swiss watch exports achieved a total value of
12.323 billion francs in 2005, an increase of
10.9%, or 1.2 billion francs, over 2004. This
positive trend should continue in 2006, but at
a slightly less sustained rate.
Exports of finished watches
Exports of finished watches represented a large
part of die overall value. Accounting for 11.4
billion francs, they grew by 12.0%, which was
more than other products in the sector. 24.3
million Swiss watches were exported in 2005;
this corresponded to 840,000 units fewer than
last year, a decline of 3.3%. The long-term
downward trend in volume, therefore,
persisted throughout 2005. This reflects a shift
in the market structure, to which the sector is
gradually adapting.
Trend of the different materials
18-carat gold watches enjoyed the strongest
percentage increase in 2005. Particularly
dynamic, they grew by 17.0% for a total value
of 3.3 billion francs. Steel watches, however,
represented the largest part in value terms,
realising 4.9 billion francs. At +10.3%, the
increase in this highly popular material was
slighdy below the average. Also occupying an
important place in watch exports were
bimetallic products - principally gold/steel -
which, at 1.8 billion francs, enjoyed a
year-on-year increase of 13.3%. These three
materials generated close to 90% of the total
value. At the same time, platinum watches
recorded an increase of 17.2% in value, though
the number of sales was comparatively
modest.
[D]
In volume terms, the results presented a
different picture. Bucking the general trend,
steel watches grew by 13 million units for an
increase of 1.8%. More than one watch in two
exported by Swiss watch companies in 2005
was made of steel. This positive development,
however, was far from sufficient to compensate
for the decline registered in other materials.
Mechanical and electronic watches
The rise in the value of mechanical timepieces
(+16.7%) more than tripled that of electronic
timepieces (+5.1%). In terms of units, however,
the trends were the opposite: mechanical
products gained 8.8%, while the others slipped
back 5.0%, resulting in 1.1 million fewer units.
Mechanical watches, therefore, continued to
gain ground, accounting for over 62% of the
total value, but for less than 14% of the total
units.
Trend of the main markets
Swiss watch exports grew on all five continents
in 2005. Asia accounted for the lion's share with
42.9% of the total value. With an increase of
11.2%, approximately 5.3 billion francs, it
reflected the world average. Europe, despite
being slightly behind, enjoyed very satisfactory
results, with 4.1 billion francs (+8.1%). Sales on
the Old Continent accelerated throughout the
year, testifying the region's strong dynamics.
Exports to the sector's third important market, the American continent,
increased by 13.7%, to 2.7 billion francs, and
sustained this rate throughout 2005. Despite
their small share of the market, both Oceania
and Africa proved to be very dynamic. The
former exceeded its 2004 results by 26.8%, with
142.7 million francs, the latter by 21.1 %, with
115.1 million. Both enjoyed accelerated growth
throughout the twelve-month period.
Geographical distribution (in CHF million)
| Countries |
Value 2005 |
Change in % |
Share in % |
|---|
| USA |
2,147.7 |
+14.5% |
17.4% |
| Hong Kong |
1,768.3 |
+7.7% |
14.3% |
| Japan |
1,145.1 |
+15.7% |
9.3% |
| Italy |
842.1 |
+8.4% |
6.8% |
| France |
660.3 |
+8.1% |
5.4% |
| Oth.
Countr. |
5,760.4 |
+10.5% |
46.7% |
| Total |
12,323.8 |
+10.9% |
100.0% | |
The United States, the Swiss watch industry's
leading market, continued to enjoy the strong
growth it had already experienced in 2004.
Although exports to Hong Kong were slower,
they continued to grow. In Japan, the upward
trend accelerated throughout the year and
ended on a high note, confirming the recovery
in this important market. In Europe, the leading
markets recorded very satisfactory results: Italy
continued to roll along smoothly, while France
accelerated noticeably at the end of the year.
And the turnaround in Germany meant that it
finished the year above the European average.
Last but not least was the excellent performance
enjoyed by Swiss watch manufacturers in
China, Taiwan and South Korea.
World watch exports
The figures quoted here illustrate watch
exports and imports by the main countries
concerned. They do not represent data for
world watch production. While this may be
estimated at around 1.2 billion timepieces, the
export and import figures are in fact higher
because a product may be re-exported and
therefore stated twice. However, this data does
clearly reflect the forces involved and
highlights the global trends of the branch.
In 2005, Switzerland consolidated its position as
the world's leading exporter of horological
products. The value of its exports reached 10
billion dollars, the best result in its history. In
local currency terms (excluding currency
exchange effects), growth stood at 11% against
2004. This was by far the strongest increase
among the world's main watch exporting
countries. In the same period, Hong Kong
exported or re-exported goods worth 6 billion
dollars, mainly to the United States, China,
Japan and Switzerland. This figure was up just
slighdy by 1% year on year. Among the leading
trio, China posted exports worth 2 billion
dollars, 4% down on 2004.
Horological exports from Germany, taking all
products together, were worth 1 billion dollars,
nearly 4% higher than in the previous year. The
biggest decline was reported by Japan with a
near 9% contraction of exports to 951 million
dollars.
Exports of finished watches
In volume terms, China was the biggest
exporter of finished watches in 2005. But at 880
million units the quantities concerned were
15% down on 2004. In second place, Hong
Kong experienced a similar reduction with
timepiece exports worth over 600 million.
Ranking first in value terms, Switzerland came
third on volume. It was far behind the Asian
manufacturers with 24 million timepieces
exported, 3% down year on year.
Main watch exporting countries
| Countries |
Units in
millions |
Change
ii |
| China |
884.6 |
-15% |
| Hong
Kong |
627.3 |
-15% |
| Switzerland |
24.3 |
-3% |
| Germany |
10.8 |
+2% |
| USA |
10.7 |
-7% |
| UK |
7.7 |
+86% |
| France |
6.3 |
+5% |
The main watchmaking countries were not all active
in the same product categories. Watches
exported by China, for the most part electronic,
were sold at an average price of 1 dollar
(ex-works price). This value was slightly higher
in the case of timepieces leaving Hong Kong at
6 dollars. But these figures bear no comparison
with Swiss watches for which the average
export price peaked at 377 dollars in 2005.
Somewhere between these two extremes,
products exported by European countries and
the United States were worth between 30 and
60 dollars.
World watch imports
The five leading watch importing markets all
increased their demand by several per cent in
2005. Hong Kong took the equivalent of 4.6
billion dollars in horological products, many of
which were re-exported. The value of goods
imported into the United States was 3.9 billion
dollars. At 2.2 billion dollars, Japanese watch imports
showed the steepest increase. Switzerland
and Germany reported similar figures,
with 1.2 billion dollars each.
For further information, please consult: www.fhs.ch
© Federation of the Swiss Watch Industry FH 2006
Dashefsky, Michael
| From: | Hinman, Elizabeth |
| Sent: | Tuesday, May 30, 2006 9:49 AM |
| To: | Dashefsky, Michael; Read, John; Hale, Nina; Lewis, Lynette |
| Subject: | FW: cases/f214800/214815.htm |
FYI, comments re: Rolex from the Antitrust-Internet Comments email inbox.
Thanks,
Liz
-----Original Message-----
From: carlk@evcohs.com [mailto:carlk@evcohs.com]
Sent: Tuesday, May 30, 2006 1:13 AM
To: ATR-Antitrust - Internet
Subject: cases/f214800/214815.htm
i would like to comment on the consent decree the Rolex watch Co. is
seeking to dissolve. as a watchmaker it is critical that be able to
obtain repair parts for the watches i repair, the justification for
dissolving the consent decree simply does not exist. the Swiss watch
groups contrary to what is be alleged have actually increased their
share of the luxury or high end watch market. that portion of the total
watch market has increased, and is predicted to continue to do so in
near future. the Swiss groups continue to restrict the flow of watch
parts required to repair their watches, which intern restricts my
ability to earn a living. it also increases the costs to the watch
owners. what was against the law in 1960 is still illegal today. i hope
the justice dept. will take a very serious look at the ramifications of dissolving the consent decree before it takes action. thank you
May 30, 2006
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice
325 7th Street, NW, Suite 300
Washington, DC 20530
RE: 1960 Consent Decree requiring watch factories to supply parts
As the Executive Coordinator of the International Watch and Jewelry Guild, our
organization represents 4400 members nationwide who earn their living in the
watch industry. Our members support thousands of local watchmakers and
watch industry suppliers across the Country. These people are dedicated to
serving their communities and supporting this country's continuing need for
high quality craftsmen. These local, skilled watchmakers' service quality watches
at fair prices for the American consumer.
We are writing formally as a group to request that you do not rescind your 1960
decree which was established to protect the American consumer from unfair
trade practices by the Swiss watch industry. We read with some great surprise as
you state that the "decree is no longer necessary to protects competition and
should therefore be terminated". This is an extraordinary statement, which we
think would be difficult to support. The decree was established in 1960 because
the Swiss watch industry was engaged in unfair trade practices. They supplied
54% of the watches sold in the United States, which represented 99% of the
luxury market. The Swiss industry would have you believe that the decree is
obsolete today because they only supply 6% of the watches sold in the United
States now. However, they still control 99% of the luxury watch market.
If the decree is rescinded the Rolex Watch Company will pay a small
insignificant fine but the American consumer and the American Watchmaker
will pay a much higher price. Once you release them from their obligations to
supply replacement parts to service watches they will gradually stop supplying
them. This will force every skilled independent watchmaker in the United States
out of business and it will severely impact the independent jewelers who makes
up an important part of every local economy in the United States. In addition
every consumer who owns a luxury watch will have to send their watch to a
regional service center for service which will probably be done at two or three
times what their local neighborhood jeweler charges. This in an injustice and
should not be encouraged by the Justice Department.
Would rescinding the decree set a dangerous precedent? The United States
government is not in the business of putting hard working American out of
business for the benefit of the Swiss government? But if the decree is rescinded
what is to stop German automobile manufactures from deciding that they no
longer want to supply replacement parts to American independent mechanics?
Since Rolex Watch Company engages in endless acts of illegal activities with the
decree in effect why would they any differently I the decree was rescinded?
Rescinding this decree will result in a total American monopoly by the Rolex
Watch Company and the rest of the Swiss manufactures will follow suit. The
Swiss watch industry will make many millions of dollars from this action and
the American consumer will be left paying for it.
If this decree was necessary in 1960 because of unfair trade practices it is more
necessary today particularly in the case of the Rolex Watch company. Because
Rolex is so powerful in Switzerland they actually have the power to prevent
small Swiss companies from manufacturing quality generic parts under the
threat of a suit. This is simple Blackmail and would not be acceptable in any
American court.
In very simple terms the United States Justice Department should not be in the
business of supporting companies that act against the principles of the working
class and the American consumer. As Americans we believe in certain principles
of free enterprise and hard work and those principles should to supported and
nurtured by every Government agency. We respectfully request that you give
consideration to our points and deny the request to terminate the 1960 decree.
Thank you,
/s/
Christina
LeDou1x
IWJG
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in
the United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Patricia Dworkin
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Robbie Dworkin
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Bradley Dworkin
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed, Efraim Shameyev
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Roberto Taborga
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Gabriel Gonzalez
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Charles A. Janssen
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would he
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Breg Esses
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the Swiss watch
industry gaining total control over the watch industry in America' The luxury watch industry has become ever more
popular in the United States in the past fifteen yeaps and the Decree is not only necessary, it is imperative.
Signed, Kurt Rothaw
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of die luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the
Swiss watch industry gaining total control over the watch industry in America. The luxury watch
industry has become ever more popular in the United States in the past fifteen years and the
Decree is not only Jiecessary, it is imperative.
Signed,
/s/
Steve Mrozinski
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
/s/
Signed,
James R. Bullock
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
H. Vernon Massey
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
die mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/ Ron Hogan
/s/ Jerry Hogan
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and die consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Gerald Wilson
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Justus "Jud" Delaney
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Marc P. Santiago
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Cynthia Marie Andolina
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative,
Signed,
/s/
Sal C. Andolina
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Mary Beth Croisdale
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Michael Joseph Croisdale
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Cassandra Ann Croisdale
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Kimberly A. Milani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Robert J. Croisdale
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Sara S. Milani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Chicago Watch Brokers
54 E. Madison St. #209
Chicago IL 60602
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster competition
and to protect anti-competitive practices as well as to protect the American consumer. While
today, the Swiss watch industry only controls 6% of the watches sold in the United States, that
figure continues to represent 99 % of the luxury watch market. The Swiss watch makers would
have the United States government believe that it is not necessary to regulate them with
anti-trust legislation since they only control 6% of the market. This argument, however, is
misleading as the need for anti-trust legislation to protect both American consumers and
American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the
Swiss watch industry gaming total control over the watch industry in America. The luxury watch
industry has become ever more popular in the United States in the past fifteen years and the
Decree is not only necessary, it is imperative.
Signed,
/s/
Jeff Morris
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who earn
their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years, the
decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster competition
and to protect anti-competitive practices as well as to protect the American consumer. While
today, the Swiss watch industry only controls 6% of the watches sold in the United States, that
figure continues to represent 99 % of the luxury watch market. The Swiss watch makers would
have the United States government believe that it is not necessary to regulate them with anti-trust
legislation since they only control 6% of the market. This argument, however, is misleading as the
need for anti-trust legislation to protect both American consumers and American watchmakers is
equally important today as it was in 1960 since the Swiss watch industry dominates the luxury
market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be unable
to obtain parts to service Swiss watches and it would leave the American consumers at the mercy
of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the
Swiss watch industry gaining total control over the watch industry in America. The luxury watch
industry has become ever more popular in the United States in the past fifteen years and the
Decree is not only necessary, it is imperative.
Signed,
/s/
Peter Fossner
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Stanley Drucker
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the Swiss watch
industry gaining total control over the watch industry in America. The luxury watch industry has become ever more
popujawrrthe United States in the past fifteen years and the Decree is not only necessary, it is
imperative.
Signed,
/s/
Thomas G. Milani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Lee C. Moore
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in die United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates die luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship meir watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave die American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over die watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
me Decree is not only necessary, it is imperative.
Signed,
Peter Dosill
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Harvey Marcus
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Yury Isakov
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Paolo Manzols
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in
the United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Sarkir Demirdjian
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Pamela Danielias
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Silva Danielias
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in die United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across die United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Peylak Demirdjian
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who earn
their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years, the
decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster competition
and to protect anti-competitive practices as well as to protect the American consumer. While
today, the Swiss watch industry only controls 6% of the watches sold in the United States, that
figure continues to represent 99 % of the luxury watch market. The Swiss watch makers would
have the United States government believe that it is not necessary to regulate them with anti-trust
legislation since they only control 6% of the market. This argument, however, is misleading as the
need for anti-trust legislation to protect both American consumers and American watchmakers is
equally important today as it was in 1960 since the Swiss watch industry dominates the luxury
market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be unable
to obtain parts to service Swiss watches and it would leave the American consumers at the mercy
of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the
Swiss watch industry gaining total control over the watch industry in America. The luxury watch
industry has become ever more popular in the United States in the past fifteen years and the
Decree is not only necessary, it is imperative.
Signed,
/s/
Peter Barshtak
John R Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Jeff Bernard
Not only should this decree not be rescinded, it needs to be enforced. We are already at the mercy of many companies who will not sell parts.
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Burley Bullock
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Robert Wingate
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Pavel Katsen
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Roger Jensvold
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read,
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Tony Crabtree /s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Sandy Lox
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Mark Smith
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Eric Ku
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Mavel Strauss
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read,
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Viken Berghoutian
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
?
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Nory Yezekyan
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In I960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
David Fineblit
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Wayne Ellison
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in
the United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Arlon Barton
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Pete Harvey
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Sultani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Jonathan Zach
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed, Omer Zach
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Mark Nance
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
? Graig Small
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Jack Tamil
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the .
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Marc Lotker
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Alfredo Klaus
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department
to determine that as a result of significant changes in the watch industry during the past 45
years, the decree is no longer necessary to protect competition and therefore should be
terminated. It appears that the Department's investigation failed to take into account important
variables that triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
#1512
Robert T. Lesesne
Atlanta, GA
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster competition
and to protect anti-competitive practices as well as to protect the American consumer. While
today, the Swiss watch industry only controls 6% of the watches sold in the United States, that
figure continues to represent 99 % of the luxury watch market. The Swiss watch makers would
have the United States government believe that it is not necessary to regulate them with
anti-trust legislation since they only control 6% of the market. This argument, however, is
misleading as the need for anti-trust legislation to protect both American consumers and
American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Michael Maron
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
#2808
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Don Dema???t
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Ron Ge?nenigen
Oak Brook, IL 60523
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Mr
/s/
BM Milani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Sunil Daryani
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Manoj Daryani
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever morepopular in the United States in the past fifteen years and
the Decree is not only necessary, itis^fnperative.
Signed,
/s/
Seth Larrabane
NY. NY
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss
watch industry gaining total control over the watch industry in America. The luxury watch
industry has
become ever more popular in the United States in the pasrfifteen years and the Decree is not
only
necessary, it is imperative.
Signed,
/s/
Jeffrey Bassach
NY. NY.
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
/s/
Robert Ramos
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Tommy Labret
John R Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. , importers of Swiss watches and watch parts from engaging in anti-competitive practices
in the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and the Swiss watch
industry gaining total control over the watch industry in America. The luxury watch industry has become ever more
popular in the United States in the past fifteen years and the Decree is not only necessary, it is
imperative.
Signed,
/s/
Suresh Sangani
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Ronny Levi
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This argument,
however, is misleading as the need for anti-trust legislation to protect both American consumers
and American watchmakers is equally important today as it was in 1960 since the Swiss watch
industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
/s/
Signed,
Bijan Jand
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Gurminder Singh
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Hitpaul Singh
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
James F. Henshaw
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Barry Shochat
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
Fred Hakiman
/s/
Hakiman Gem ?
5 S. Wabash Suite 1212
Chicago, IL 60603
JUNE
John R. Read
Chief, Litigation III
Section
352 7th Street NW,
Suite 300
Washington, DC
20530
June 1,2006
Dear Mr. Read,
I am writing to formally request that you do not rescind the 1960 consent decree
that Prohibits U.S. importers of Swiss watches and watch parts from engaging in
anticompetitive practices in the U.S. watch industry. I am in the secondary watch
market and find that the Swiss companies as a whole are not willing to sell the
parts necessary to repair the watches, that they sell here in the US, to anyone but
Authorized Service Centers.
As an example, this would be like General Motors only selling parts to their
DEALERS SO THAT IF YOU WANTED YOUR CAR FLXED YOU HAD TO
TAKE IT TO THE DEALER YOU BOUGHT IT FROM. I'm sure that you see the
problem.
The Swiss companies are saying the they are doing this to protect the consumer
when in actuality they are doing it for pure greed. I have no problem with profit
motive but the service that the companies are providing the watch buying public
is appalling. The average time for a watch to be serviced by any of the big watch
companies (Rolex, Swatch group etc) is six to eight WEEKS and sometimes
longer. It has gotten so bad, that I personally know of several Jewelers here in
Phoenix that are getting out of the watch selling business because they cannot
give their customers the "after sales" service that they feel they deserve and
expect even through the Authorized service centers.
The well-trained independent watchmakers here in the U.S., many trained by
the Swiss companies themselves, are ready and willing to take care of the
American consumer provided they can buy the parts from the manufacturers.
Please help them do so by not rescinding the 1960 consent and I urge you to look
into the Swiss watch industries lack of service to their American customers.
Thank you for your consideration in this matter.
David Fetz
Customer
Service/Repair
Inventory Adjusters Inc.
3437 E McDowell Rd.
Phoenix, AZ 85008
Mr. John R. Read, Chief
Litigation III
Section
Antitrust Division
US Department
of Justice
325 7th Street, NW—Suite 300
Washington, D.C. 20530 |
June 1, 2006 |
Re: Termination of Rolex Consent Decree
Dear Mr. Read:
I am strongly in support of maintaining and in fact strengthening of the 1960 Swiss consent decree. If this decree is lifted every
independent watchmaker and jeweler in the United States will be put out of business within a few short years, of this I am certain. I
am a third generation American watchmaker and a manufacturer of a small luxury line of watches made in Switzerland. As such I
am in a position to express a knowledgeable and educated opinion on this subject, and I am considered an expert in this field. I
understand your department is prepared to terminate the agreement based on several factors; two main ones being the
consumer's "options" when buying a watch and whether or not Rolex "dominates" the marketplace.
DOES THE CONSUMER HAVE OPTIONS WHEN BUYING A WATCH?
Rolex has taken the position that the consumer has many options when buying a watch so the decree should be lifted. This
decree is not about options at the point of purchase. It is about options when the time comes to service the watch. It is highly
unlikely that the consumer will be informed at the time of purchase that their local watchmaker will never be able to get parts for
the routine maintenance of their fine watch. By default the consumer in fact has no options.
It is accepted practice for us as consumers to take a new "under warranty" product to an "authorized factory service center".
Imagine that "authorized factory service center" was actually a "factory owned service center". Typically when the warranty has
expired, most of us look for a competent skilled professional to handle our repairs. Someone we can have a friendly and trusted
relationship with. We also want the work done in a timely manner at a fair price and we do not want to be charged for unnecessary
work. These are American traditions and I believe the Department of Justice should foster these important relationships. It is in the
best interests of independent American tradesman and the American consumer. Would you Mr. Read purchase a luxury car if you
understood in advance that every routine service would have to be done by the "factory owned service center" and you had no
options?
DOES ROLEX DOMINATE THE MARKET PLACE?
No other privately held company in the world can boast that:
- They are the world's largest consumer of
gold.
- They have threatened the United States
Customs Department so many times that
customs agents joke "that they work for
Rolex".
- They are the largest buyer of print ad
space in the world.
- They have the resources to pressure the
United States Department of Justice into
terminating a decree that was
established to protect the American
consumer from unfair trade practices.
- They have for 20 years flagrantly
disregarded American Law and paid a
mere $750,000 fine for it.
- They can put any company in Switzerland out of business with legal actions for simply making a spring that can be used in one
of their watches.
- They will put every independent watchmaker in the United States out of business if they prevail.
- They can stop any critical article about their company by simply threatening to either withdraw their advertising budget, or by
an expensive law suit.
OF COURSE THEY DOMINATE THE MARKET PLACE, AT LEAST FIGURATIVELY.
It is very convenient for Rolex to question its market dominance to support its argument to rescind the 1960 antitrust decree
against it. They may not sell more watches then Seiko but they are the worlds Keystone Watch Company, nobody involved in the
watch industry in America, Japan or Switzerland would disagree. The only thing that prevents them from literally dominating is
simply their intent.
IF THIS DECREE IS TERMINATED:
The American consumer will be forced to spend nearly twice as much as is customary for servicing their watches. The factory
typically replaces parts that do not need to be changed; and since they have a monopoly on these parts they can charge anything
they want for them. The consumer will not know what is necessary and what is unnecessary since they will not have a relationship
with the technician at the service center. The factory will control every aspect of the repair.
WHEN THE DECREE IS TERMINATED:
Every other watch company in Switzerland will be drafted in behind Rolex. They will waste no time in asking for the same
considerations, even though they are already holding back most parts. Will the Department of Justice consider them individually
and as such accept that they are not a monopoly or at some time will the Department decide that as a group all these watch
companies constitute a monopoly and the consumer has no "options" and they do "dominate" the field?
SETTING A DANGEROUS PRECEDENT:
What if all the automobile manufactures in Germany decide that terminating this decree should apply to them as well? Will the
Department of Justice consider that the consumer has "other options" and these German manufactures do not "dominate" the
market and release them from their responsibilities also?
ECONOMIC FORCES:
The argument can be made that the Department of Justice should not be legislating on issues that would normally be resolved by
market forces which would give consumer options. In other words, if the watch companies are charging too much for their parts
then other companies will fill the void. This will not happen because Rolex is to powerful and because they are a vertical company
and can destroy any competitor. They can for example lower their prices (as they did a few years ago) for a short time while a
competitor is trying to get a foothold in the market. Because of modern production techniques those factories most watch parts
can be manufactured very cheaply.
UNFAIR TRADE PRACTICES AND BRAND PROTECTION:
Briefly, let's take a moment to discuss the Rolex position with respect to its quality and brand name protection. Of course, we all
understand that a company wants to protect its reputation. Many aftermarket products in other industries are licensed if patents
protect them. But there is a disturbing trend in the watch
industry with respect to Rolex. Rolex goes out of its way to redesign simple parts so that they now require special tools for repair.
Parts inside some of these assemblies are designed to wear out prematurely. These are the cheapest parts to manufacture and
they own the rights to the special tools to fix the assembly. In many cases these special tools are not available to the skilled
independent watchmaker. If they are available they are very expensive. In some cases high quality aftermarket tools are available
but Rolex forbids their use. In some cases they will sue a Swiss company for making the tool. In some cases if they discover that
the watchmaker is using one of these tools they will cancel their parts account.
Could you imagine Chrysler suing Goodyear because they manufacture a tire that can be used on one of their cars? Well that is
quite a normal attitude with Rolex. Several years ago I went with a partner to Switzerland and tried to have some parts made to fit
some older Rolex watches. I was told by the owners of the small factory that since these parts could be used in a Rolex they did
not want to make them. It was not that they did not want the business; it was just that if Rolex got wind of it they might be sued and
it was not worth it to them.
Over two thousand years ago a Greek named Archimedes invented the screw. He also set forth many of the modern principles of
mechanics. The Rolex Watch Company behaves as if they own these principles? It is the belief that they own the rights to certain
dimensions of parts that can be used in their products, such as mainsprings, wheels or levers. Archimedes patents ran out a long
time ago. But it seems as though Rolex does not respect that fact.
ORIGINAL OR AFTERMARKET, WHICH ARE BETTER?
There has always been a battle in Switzerland about generic parts, which are sold for much less then the original ones. Years ago
there were many small precision factories in Switzerland with the tooling to produce parts that could be used in Rolex and other
brand watches. In many cases they were superior to those that Rolex used. Superior, how was this possible you may wonder?
Well a watch part can easily be designed to wear out sooner rather then later. As an example, several years ago Rolex produced
the caliber 2130. This watch had a clutch wheel that continually failed. Rolex "redesigned" parts of this movement but never really
corrected the problem. In the interim, the consumer was forced to foot the bill for unending repairs to a watch they believed to be a
quality product. This is not an uncommon problem. In the case of mainsprings, high quality aftermarket mainsprings have been
designed so as not to prematurely break as do genuine mainsprings. Most of these small specialty manufacturers, which make
aftermarket parts, have either been purchased by the Swiss factories involved in exclusive parts contracts, or have been coerced
not to make aftermarket Rolex or brand parts, the rest are simply out of business.
THE DOMINATE QUESTION:
It is very convenient for Rolex to question its market dominance to support its argument to rescind the 1960 antitrust decree
against it. If the decree is lifted the windfall for Rolex will be substantial. However the windfall to the rest of the Swiss watch
industry will be ten times that. These other Swiss companies may by brand seem small but they are all owned by much larger
holding companies such as LVMH, Swatch and the Richemont Group. They are also vertically integrated companies and, as such,
control nearly every sector of Swiss watch production.
WHAT IS THE SOLUTION?
In late May of last year economic interests in Switzerland began an orchestrated effort to seek a free trade agreement with the
United States. Lobbyists in Washington have already addressed this issue and the urgency is such that a proposed agreement
must be negotiated and signed by 2007 before the current
administration leaves office. Among those greatly benefiting from such an agreement would be the Swiss watch companies and
multinational holding companies such as LVMH, Swatch and the Richemont group.
The United States is currently the most important market for Swiss watches, with consumption of approximately eighteen percent
of its total production. American consumers spent nearly $1.7 Billion on Swiss watches in 2004. The 2004 import tax derived from
these imports amounted to $55 Million and is the single largest sector of US Customs revenue.
I respectfully request that The United States Department of Justice seriously consider the impact of a Swiss Free Trade
Agreement. In addition to all that I have mentioned earlier in this letter, such a free trade agreement would result in the United
States losing a significant revenue and import taxation on myriad other Swiss products.
I strongly recommend that if the United States is prepared to offer Switzerland a free trade agreement then independent
watchmakers should have, in return unrestricted access to all Swiss factory replacement parts. It is very little to ask for.
It may seem Mr. Read that you are not receiving enough letters on this subject. I have spoken with many small independent
watchmakers that still do have limited access to parts from Rolex about this issue. I have asked them to contact the Department of
Justice to express their views. Sadly, but understandably none would risk their fragile relationship with Rolex by sending a letter as
they are sure they would have their parts account terminated. I do not have a parts account with Rolex and do not need one
therefore I am not concerned. I am expressing my views on behalf of all the independent watchmakers I work with.
In conclusion, I would like to share a story and make this one final point. One of my favorite watchmakers is a man in his 60s. He
has been a watchmaker for over 50 years working on Rolex watches. He is the most skilled watchmaker I have ever had to honor
to work with. The other day he looked at me and said "Before they (Rolex) will send me a new part they make me waste my time
sending back the old worthless worn out part as if I am some kind of a criminal".
It is important that the United States Department of Justice understands that there can be no fair competition with a company like
Rolex. If the Rolex Watch Company is comfortable putting Swiss companies out of business what will they do with American
companies when the decree is terminated? They simply do not believe in free trade and they never will. Please do not terminate
the 1960 decree, which was established to protect American consumers and thousands of dedicated decent people who work in
the watch and jewelry industry in the United States.
Respectfully Yours,
/s/
Sig Shonholtz
8840 Beverly Boulevard, West Hollywood, California 90048 USA
Phone [310] 271-9163 Facsimile [310] 271-1473
info@guillerminmollet.com
| | 301 E. Healey St.
Champaign, Illinois 61820-5508
June 3, 2006 |
Mr. John R. Read, Chief, Litigation III
Section
Antitrust Division, U.S. Department of
Justice
325 Seventh St. NW, Suite 300
Washington, D.C. 20530
Dear Sir:
I object extremely to restraints in trade which make it
impossible
for me to buy genuine parts for my customers which rightfully trust me
to make proper repairs on their watches. For example, Rolex parts.
They should be forced to engage in free trade, not allowed to increase
further their refusals to sell parts and deal with material houses
and
tradesmen.
Mr. John R. Read, Chief
Litigation III Section
Antitrust Division
US Department of Justice
325 7th Street, NW—Suite 300
Washington, D.C. 20530 |
June 3, 2006 |
Reference: Planned Termination of the 1960 Rolex Consent Decree
Dear Mr. Read:
As a private citizen with a personal involvement in the watch industry I would like to express my views on the Department of
Justices decision to rescind the 1960 consent decree. Please consider my opinion when making your decision.
The nominal fine of $750,000 that your department has levied against the Rolex Watch Company is nothing for them to pay
against the windfall profits they will gain by the termination of the decree and by extension to the rest of the Swiss watch
companies. Rolex would have us all believe that since the consumer has a choice when buying a watch, that they therefore
do not have a monopoly. I assure you Mr. Read that once the decree is rescinded the Swiss watch industry will have a choke
hold on every independent watchmaker and jeweler in the United States. When that happens they will, without a doubt,
cause every independent watchmaker and jeweler be put out of business.
Rolex is blatantly collapsing two issues into one. The first is whether consumers have enough choice or "options" when they
buy a watch. Of course the consumer has many, almost too many "options", but the decree is set forth to protect the
consumer from the Swiss monopolies after the customer has purchased the watch, when it is too late. You can be sure that
no consumer will have "options" when it comes time to service their watch. That is a monopoly, and in my opinion the intent
of the law is to prevent dominance rather than react to after it is too late.
The argument is that in 1960 the Swiss watch industry controlled over 50% of the American watch market and today they
only control 6%. However the percentage that they controlled of the luxury market in 1960 was 99% and that figure has not
changed. So it is, that while times may have changed, circumstances have not.
WHAT IS THE SOLUTION?
Economic interests in Switzerland are lobbying the United States Government for a free trade agreement. The Swiss
lobbyists in Washington are trying to finalized this agreement before the current administration leaves office. Among those
greatly benefiting from such an agreement would be the entire Swiss watch industry and the multinational holding companies
such as LVMH, Swatch and the Richemont group.
I would support the new trade agreement with one simple and small request, which is that the Swiss watch factories agree to
unrestricted supply of Swiss factory replacement parts. This I believe is in the long term best interests of the American
consumer and independent American watchmakers.
I strongly recommend that if the United States is prepared to offer Switzerland a free trade agreement then independent
watchmakers should have in return unrestricted access to all Swiss factory replacement parts. The original existing decree
should be strengthened and enforced.
Sincerely
/s/
Concerned Private Citizen
Hollander, Taryn L.
| From: | little.leah@gmail.com |
| Sent: | Monday, June 05, 2006 6:22 PM |
| To: | ATR-Antitrust - Internet |
| Subject: | Reference: Planned Termination of the 1960 Rolex Consent Decree - PLEASE DON'T |
Mr. John R. Read,
Chief
June 3, 2 0 06
Litigation III Section (handwritten note: lit 3)
Antitrust Division
US
Department of Justice
325 7th
Street, NW?Suite 300
Washington, D.C. 20530
Reference: Planned Termination of the 1960 Rolex Consent Decree
Dear Mr. Read:
As a private citizen with a personal involvement in the watch industry I would
like to express my views on the Department of Justices decision to rescind the
1960 consent decree. Please consider my opinion when making your decision.
The nominal fine of $750,000 that your department has levied against the Rolex
Watch Company is nothing for them to pay against the windfall profits they will
gain by the termination of the decree and by extension to the rest of the Swiss
watch companies. Rolex would have us all believe that since the consumer has a
choice when buying a watch, that they therefore do not have a monopoly. I
assure you Mr. Read that once the decree is rescinded the Swiss watch industry
will have a choke hold on every independent watchmaker and jeweler in the
United States. When that happens they will, without a doubt, cause every
independent watchmaker and jeweler be put out of business.
Rolex is blatantly collapsing two issues into one. The first is whether
consumers have enough choice or "options" when they buy a watch. Of course
the consumer has many, almost too many "options", but the decree is set
worth to protect the consumer from the Swiss monopolies after the customer
has purchased the watch, when it is too late. You can be sure that no
consumer will have "options" when it comes time to service their watch. That
is a monopoly, and in my opinion the intent of the law is to prevent dominance
rather than react to after it is too late.
The argument is that in 1960 the Swiss watch industry controlled over 50% of
the American watch market and today they only control 6%. However the
percentage that they controlled of the luxury market in 1960 was 99% and that
figure has not changed. So it is, that while times may have changed,
circumstances have not.
WHAT IS THE SOLUTION?
Economic interests in Switzerland are lobbying the United States Government for
a free trade agreement. The Swiss lobbyists in Washington are trying to
finalized this agreement before the current administration leaves office. Among
those greatly benefiting from such an agreement would be the entire Swiss watch
industry and the multinational holding companies such as LVMH, Swatch and the
Richemont group.
I would support the new trade agreement with one simple and small request,
which is that the Swiss watch factories agree to unrestricted supply of
Swiss factory replacement parts. This I believe is in the long term best
interests of the American consumer and independent American watchmakers.
I strongly recommend that if the United States is prepared to offer
Switzerland a free trade agreement then independent watchmakers should have
Ln return unrestricted access to all Swiss factory replacement parts. The
original existing decree should be strengthened and enforced.
Sincerely
Concerned Private Citizen
Dear Mr. Read:
As a private citizen with a personal involvement in the watch industry I would
like to express my views on the Department of Justices decision to rescind the
1960 consent decree. Please consider my opinion when making your decision.
The nominal fine of $750,000 that your department has levied against the Rolex
Watch Company is nothing for them to pay against the windfall profits they will
gain by the termination of the decree and by extension to the rest of the Swiss
watch companies. Rolex would have us all believe that since the consumer has
a choice when buying a watch, that they therefore do not have a monopoly. I
assure you Mr. Read that once the decree is rescinded the Swiss watch industry
will have a choke hold on every independent watchmaker and
jeweler in the United States. When that happens they will, without a doubt,
cause every independent watchmaker and jeweler be put out of business.
Rolex is blatantly collapsing two issues into one. The first is whether
consumers have enough choice or "options" when they buy a watch. Of course the
consumer has many, almost too many "options", but the decree is set forth to
protect the consumer from the Swiss monopolies after the customer has purchased
the watch, when it is too late. You can be sure that no consumer will have
"options" when it comes time to service their watch. That is a monopoly, and in
my opinion the intent of the law is to prevent dominance rather than react to
after it is too late.
The argument is that in 1960 the Swiss watch industry controlled over 50% of
the American watch market and today they only control 6%. However the
percentage that they controlled of the luxury market in 1960 was 99% and that
figure has not changed. So it is, that while times may have changed,
circumstances have not.
WHAT IS THE SOLUTION?
Economic interests in Switzerland are lobbying the United States Government for
a free trade agreement. The Swiss lobbyists in Washington are trying to
finalized this agreement before the current administration leaves office. Among
those greatly benefiting from such an agreement would be the entire Swiss
watch industry and the multinational holding companies such as LVMH, Swatch
and the Richemont group.
I would support the new trade agreement with one simple and small request,
which is that the Swiss watch factories agree to unrestricted supply of Swiss
factory replacement parts. This I believe is in the long term best interests
of the American consumer and independent American watchmakers.
I strongly recommend that if the United States is prepared to offer
Switzerland a free trade agreement then independent watchmakers should have
in return unrestricted access to all Swiss factory replacement parts. The
original existing decree should be strengthened and enforced.
Sincerely,
Leah Setka
Los Angeles, CA
310.479.0347
Time Honored
| | 217 DORRIS PLACE
Stockton, California 95204
Phone: (209) 944 - 0900 |
June 5, 2006
John R. Read
Chief, Litigation III Section
Antitrust Division, U.S. Depart of Justice
325 7th Street, N.W., Suite 300
Washington D.C. 20530
Dear Mr. Read,
I am a second generation watchmaker celebrating my 30th year in this time honored
trade. I am a graduate of the WOSTEP program in Neuchatel, Switzerland and worked
for Cartier for four years in after sales service.
I am aware that many of my colleagues have been sending their comments
anonymously but I feel this situation is too serious to take that precaution. Make no
mistake about it, I feel I am writing this letter at my peril. You see, I am fortunate
enough to have secured a contract with Rolex USA that allows me to purchase their
spare parts. These contracts are highly prized by watchmakers because they can mean
the difference between eeking out a living or meeting with some manner of success.
The provisions of this contract allows Rolex USA to tell me what kind of shop I have to
have, what kind of tools I have to have and also what I can do with the parts after I
have purchased them. A few years ago I had to invest in a timing machine that cost
$1,750.00 because of my contractual agreement.
While the Swiss Cartel would have you believe that the situation regarding the
distribution of spare parts has changed dramatically in the last 40 years I truly believe
that the exact opposite is true. There were many independent watch companies back
then and more competition. Today many of the old companies are held together as part
of a "group". This arrangement gives them more control over the spare parts that are of
the utmost importance to the independent watchmaker. The Japanese products that
flood our market are not what makes me a living. The products from the Swiss Cartel
are and these companies are held in fewer hands today and they wield enormous
control. Don't let Rolex and the rest fool you they are trying to squeeze myself and the
watch parts distributors out of making a living. The situation is just as critical today as
it was in the 1950's if not more so.
Please do not disassemble the original consent decree. Keep it intact if you can. The
United States of America has an extremely rich watchmaking heritage. We must not let
it slip away.
/s/
Sincerely, Richard R Rogers, Watchmaker, WOSTEP 84/1
1722 Madison Avenue
Toledo, Ohio 43624 |
| Tel 419/243-3720
Fax 419/243-0321 |
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, D.C. 20530 |
June 5, 2006 |
Supplemental to Civil Action No. 96-170
Dear Mr. Read,
As a follow-up response to a letter sent by myself to you dated April 25, 2006,1 would like to
submit to you the following additional information.
Enclosed are copies including the front cover of a comprehensive report of 2005 US watch sales
with conclusive market data concerning the dominant Swiss Watch Companies. Mr. Read this
analysis was done without prejudice to any watch company, and was an independent retail
measure of the United States fine watch market.
As you can see from page 6 of the analysis, from total sales of $4.7 billion dollars, luxury watch
sales totaled $3.4 billion dollars or 73% of all dollar sales for watches. A far cry from the 6%
figure Rolex uses in their argument. Furthermore of the 47 top watch brands in the US market,
45 of the companies are of Swiss origin. I equate this to TOTAL MARKET DOMINATION of the
Luxury Watch Market.
As you can see from page 15 of the listing of Dollar Sales per brand, Rolex is NUMBER ONE in
this category. Also eight of the top ten brands are of Swiss origin. Again TOTAL MARKET
DOMINANCE. As was quoted in the A. Changes in the Watch Industry, "Switzerland is no
longer considered to be the most dominant supplier of watches" is a totally false statement.
In conclusion Mr. Read, I am sure you will agree that some of the information that Rolex
supplied to you was flawed and misleading at best. My question to you is, how much more
information supplied to you by Rolex is misleading?
THE CONSENT DECREE MUST BE KEPT IN PLACE!
Sincerely,
/s/
Gerald A. Wilson
President
Enclosures
| Wholesale Watch Materials • Tools and Findings • Jewelry • Boxes | |
[D]
Category Analysis: Luxury Watches
U.S. fine watch market tilts
toward high end in 2005
By Tom Kuczynski
| Overall, 2005 was a good year for many watch retailers and
brand owners in the United States, with consumers'
willingness to pay big bucks for luxury wristwatches
helping to nudge sales figures higher, especially for
independent jewelers.
The U.S. fine watch market—defined as watches sold
through fine jewelers with a manufacturer's suggested
retail (MSRP) of $50 or more—achieved $4.7 billion in
retail sales, representing an 8 percent increase over 2004,
according to LGI Network the Randolph, N.J.-based retail
measurement service company for the jewelry and watch
industry
The spoils of last year's watch sales victory were not
however, evenly distributed among retailers or brand
owners, LGI found. Growth, measured in both unit sales
and dollars, was concentrated on the upper end of the
price spectrum. Unit sales in the $5,000-plus price point
range, for example, grew 20 percent, year-over-year, while
unit sales in the $50-$150 range fell 6 percent. The robust
nature of the upper end of the market and the flagging
performance at the lower end appears to be a persistent
trend in the market.
On the brand front, it appears that success begets
success. The top-selling brands of 2004—those that
ranked in the top 10 in terms of unit or dollar sales—were
back on top again in 2005, with only minor shifts in
rankings. While some mega-brands achieved sales in
excess of $ 150 million, the median sales level for brands
that saw more than $10 million in sales last year was $32.7
million.
Seven brands enjoyed double-digit same-store sales
growth in terms of units last year while a total of 14 brands
achieved positive growth. By contrast 12 brands saw their
same-store unit sales fall by 10 percent or more. Overall, 23
watch brands with U.S. sales above $ 10 million achieved
lower same-store unit sales volumes in 2005 as compared to
2004.
Relatively strong market conditions, coupled with
perhaps, a healthy dose of business acumen, supported
an impressive performance from the nation's elite fine
watch retailers.The top 1 percent of fine watch retail
storefronts captured 15 percent of the year's sales, ringing
up more than $4 million in sales per storefront. By
comparison, for stores across the retail spectrum, the
median fine watch sales per storefront in 2005 were
$29,500. |
| About this data
The data in this article was
supplied by LGI Network of
Randolph, N.J. The firm
provides retail measurement
services for the jewelry and
watch industry using
point-of-sale and inventory
data to measure retail activity
and trends in the US. fine
watch market Information
captured by the service
includes sales results by
brand, model, case material,
gender, MSRP and
geographic region. For more
information on LGI, go to:
www.lginetwork.com |
|
Unit and dollar sales by price point
U.S. watch sales, 2005
| All about the high end
The US. fine watch market generated sales of $4.7 billion in
2005. This figure includes the original retail sale price of watches
which have a manufacturer's suggested retail price (MSRP) of
$50 or more, and are sold through independent retail jewelers,
jewelry-specific retail chains and the fine jewelry departments of
department stores in the United States. These figures do not
include the results of big-box discount chains or
company-owned, single-brand boutique retail stores.
In total, 6.9 million fine watches were sold in 2005. Of these,
83 percent had an MSRP of $500 or less, while 17 percent had
an MSRP above $500. However watches with an MSRP above
$500 disproportionately generated a total of $3.4 billion, or 73
percent of all dollar sales. Although watches priced above
$5,000 accounted for only 2 percent of all watches sold in terms
of units, these timepieces generated 36 percent of sales. |
|
U.S. watch market: Fine watch brand chart*
Based upon 2005 annual retail sales, by price point
| $150+ million |
|
Bulova
Citizen
Seiko |
Movado |
TAG Heuer |
Cartier
Rolex |
|---|
| $50-150 million |
Pulsar |
Swiss Army |
Raymond Weil
Wittnauer |
Baume & Mercier
Breitling
Omega
Rado |
Patek Philippe |
|---|
| $25-50 million |
Caravelle |
ESQ
Tissot |
Gucci
Longines
Michele |
Concord
Ebel |
Chopard
Franck Muller
IWC
Jaeger-LeCoultre
Officine Panerai |
|---|
| $10-25 million |
|
Coach
Hamilton |
Accutron
TechnoMarine |
Bedat & Co. Charriol
Corum David Yurman
Maurice Lacroix |
Audemars Piguet
Blancpain
Breguet
Girard-Perregaux
Harry Winston
Piaget
Ulysse-Nardin
Vacheron Constantin
Zenith |
|---|
| |
$50-150 |
$150-500 |
$500-1,500 |
$1,500-5,000 |
$5,000+ |
|---|
| |
Average MSRP |
|---|
*Brands listed in alphabetical order within each category
Sizzling seven lead the brand pack
In 2005, LGI Network tracked 55 active fine watch brands in
the United States through a 6,500-storefront retail panel and
a 30,000 storefront database of retailers. Most of the watch
brands, 47 in all, achieved projected annual retail sales in
excess of $10 million.
However; only seven of the 47
brands— Bulova, Cartier; Citizen, Movado, Rolex, Seiko and
TAG Heuer—passed the $150 million threshold in retail
sales. Looking more broadly at the market median annual
sales for the 47 fine watch brands shown in the chart above
as earning $10 million or more in annual revenue were
approximately $33 million. In other words, the
"typical" successful fine watch brand generates about $33
million per year in U.S. retail sales.
This is no small feat. Wrth a relatively small investment
required to enter the U.S. watch market, more than 300
brands identified by LGI Network compete for retail real
estate and consumer recognition.
The challenge of breaking out of the pack is considerable,
as evidenced by the modest number of brands that grow to
exceed $10 million in retail sales. In order to remain
competitive, brand managers must stay on top of which
products are selling, and figure out ways to achieve product
differentiation in an increasingly crowded market
LGI fine watch sales data
Top-selling fine watch brands
U.S. watch sales, 2005
| Rank |
Unit sales |
Dollar sales |
|---|
| 1 |
CITIZEN |
ROLEX |
| 2 |
SEIKO |
CITIZEN |
| 3 |
BULOVA |
SEIKO |
| 4 |
PULSAR |
MOVADO** |
| 5 |
CARAVELLE |
TAG HEUER** |
| 6 |
MOVADO |
BULOVA |
| 7 |
SWISS ARMY |
CARTIER |
| 8 |
ESQ* |
BREITUNG |
| 9 |
ROLEX* |
OMEGA |
| 10 |
TAG HEUER* |
PATEK PHILIPPE |
*Tie for 8th place
** Tie for 4th place
Top brands shuffle a bit
The list of the top 10 best-selling brands in 2005, based upon
unit sales and dollar sales, closely resembles the 2004 list.
Two brands, however, jumped up a notch this year: Bulova,
which ranked No. 4 in unit sales in 2004, climbed to the No. 3
position in 2005; and TAG Heuer which ranked No. 7 in dollar
sales for 2004, climbed to No. 4.
Brand growth*
U.S. watch market, 2005 vs 2004
| Same-store unit sales growth rate |
Number of brands |
|---|
| 20% + |
3 |
| 10% to 19% |
4 |
| 0% to 9% |
7 |
| -10% to -l% |
11 |
| <-10% |
12 |
| Overall market growth: |
-1% |
* Includes only brands with annual sales above $10 million
Fewer watches sold by most brands
While overall unit sales fell by 1 percent in 2005 versus
2004, several fine watch brands bucked the trend and
delivered double-digit growth.
In fact, of the 41 brands
reported on here, seven brands grew by 10 percent or
more and another eight brands exhibited positive unit sales
growth. The majority of brands, however, experienced
declining unit sales.
U.S. watch market: Unit sales, growth by price point
UNITS SOLD, BY PRICE POINT (2005 VS. 2004)
[D]
DOLLAR SALES GROWTH, BY PRICE POINT (2005 VS. 2004)
[D]
Looking at unit sales by price point, there was a clear divide in the market in 2005
Watches in the sub-$500 price range experienced low
single-digit increases to negative unit sales growth, while
watches in the $500-plus price point range saw moderate
to robust growth.
Similar, but even more pronounced than
last year's results, is the strength of the $5,000-plus
category, which experienced a 20 percent increase in unit sales and a 25 percent jump in dollar
sales.
With 83 percent of unit sales occurring in the
sub-$500 category, however overall unit sales dropped
1 percent. Reflecting the trend towards higher price
point sales, the average MSRP increased by 10
percent to $677.
Dashefsky, Michael
| From: | Hinman, Elizabeth |
| Sent: | Monday, June 05, 2006 9:17 AM |
| To: | Read, John; Hale, Nina; Dashefsky, Michael; Lewis, Lynette |
| Subject: | FW: Planned Termination of The 1960 Rolex Consent Decree |
FYI, comments re: Rolex from the Antitrust-Internet Comments email box.
Happy Monday,
Liz
-----Original Message-----
| From: | JonGoldfarb@adelphia.net [mailto:JonGoldfarb@adelphia.net] |
| Sent: | Sunday, June 04, 2006 10:36 AM |
| To: | ATR-Antitrust - Internet |
| Subject: | Planned Termination of The 1960 Rolex Consent Decree |
Mr. John R. Read, Chief
June 2, 2006
Litigation III Section
Antitrust Division
US
Department of Justice
325 7th
Street, NW?Suite 300
Washington, D.C. 20530
Reference: Planned Termination of The 1960 Rolex Consent Decree
Dear Mr. Read:
Please review this letter and the facts and points that it contains and take
these facts and points in to consideration prior to making a decision on
rescinding the 45 year-old Rolex Consent Decree. The Rolex Consent Decree
was created and intended to be a legally binding agreement imposed on Rolex
and several other Swiss watch companies because of ?unfair trade practices?
these watch companies practiced regarding the supply of replacement parts.
As punishment for lack of adherence to the existing Consent Decree, Rolex
has agreed to pay a nominal fine of $750,000 for more than 20 years of
Decree violations.
Rolex also claims they are not dominant in their market, but consider the
following facts:
- Swiss watch industry represents 6% of the total American watch market,
but Rolex accounts for 99% of the American luxury watch market (in 1960 when
the decree was imposed on Rolex for unfair trade practices, Rolex supplied over
50% of all the watches sold in America, but since 1960, there has been a
tremendous increase in the presence of low cost, entry level watches, which
greatly distorts Rolex?s misleading argument/position)
- The United States accounts for approximately 18% of Swiss watch total
production
- American consumers spent nearly $1.7 Billion on Swiss watches in 2004
- 2004 import tax derived from Swiss watch imports amounted to $55 Million
nd is the single largest sector of US Customs revenue (The United States
department of Justice should seriously consider the financial impact f a Swiss
Free Trade Agreement on the United States import tax)
- Rolex?s annual advertising budget exceeds the GNP of many small countries
- Rolex is the World?s largest manufacturer/producer of gold products
- Rolex has filed numerous legal actions against the United States Customs
Department
- Rolex has actually used their influence and power to prevent other Swiss
companies from making and selling superior aftermarket parts that fit Rolex
(There were many small precision factories in Switzerland with the tooling to
produce superior parts that can be used in Rolex and other brand watches, but
most of these small specialty manufacturers have either been purchased by
the Swiss factories, or have been coerced not to make aftermarket Rolex or
brand parts, or are out of business.)
- Rolex has often ?redesigned? parts but never really corrected the
problem, requiring the consumer to pay for recurring repairs
If this Consent Decree is rescinded, the following will be the negative
results:
- American Independent watchmakers will suffer due to lost service and most
will be forced out of business
- American consumers will be charged excess and unnecessary fees for repair
and service of their watches since they will be forced to spend nearly twice
as much for servicing their watches because the factory typically replaces
parts that do not need to be changed
- American consumers will experience excessive delays in waiting for their
watch to be repaired/serviced (Please note that consumers who have their
watches serviced/ repaired by a Rolex Service Center en already experiencing
tremendous delays.)
In further defiance of the existing Consent Decree, Rolex has recently
redesign standard parts so that those parts now require special tools for
disassembly. In many cases these special tools are not available to the
skilled independent watchmaker, and if the special tools are available,
Rolex charges excessive prices for these special tools, and in some cases
high quality aftermarket tools are available but Rolex forbids their use.
The Department of Justice should not expect to receive many letters from the
American independent watchmakers and merchants due to the fact that some
independent watchmakers that still do have limited access to parts from
Rolex, but they fear that their parts account and fragile relationship with
Rolex will be terminated.
Rather then considering rescinding the existing Consent Decree, the Decree
should be strengthened and enforced.
Please do not terminate the 1960 decree, which was established to protect
the American consumers and independent watchmakers and merchants who work in
the watch and jewelry industry in the United States.
Sincerely,
Jon Goldfarb
Dashefsky, Michael
| From: | Hinman, Elizabeth |
| Sent: | Monday, June 05, 2006 3:20 PM |
| To: | Read, John; Hale, Nina; Lewis, Lynette; Dashefsky, Michael |
| Subject: | FW: Request end to monopolistic privileges of Rolex Watch Company |
FYI, more comments re: Rolex from the Comments inbox.
Thanks!
Liz
-----Original Message-----
| From: | ken@wannabuyawatch.com [mailto:ken@wannabuyawatch.com] |
| Sent: | Monday, June 05, 2006 1:49 PM |
| To: | ATR-Antitrust - Internet |
| Subject: | Request end to monopolistic privileges of Rolex Watch Company |
To whom it may concern:
As an owner of a store specializing in sales and repairs of preowned and
vintage Rolex and other fine
Swiss watches, I request that the 1960 decree requiring Rolex watch
company
to engage in fair
trade practices remain in effect.
Rolex currently is permitted monopolistic business practices and has been
seeking to deny availability
of parts for repair of Rolex watches. Please do not further assist their
monopolisitic policies
which put my continued legal and valuable business operations in jeopardy.
Thank you,
Ken
Jacobs Phd
Wanna Buy
A Watch?
8465
Melrose Ave
LA, CA
90069
tel 323 653-0467
fax 323 654-9101
email Ken@wannabuyawatch.com
Website WWW.WannaBuyAWatch.com
Member following Trade Associations:
National Association of Watch & Clock Collectors
International Watch & Jewelry Guild
American
Watchmakers Institute
OTHER
649 Brandon Town Ctr Mall
Brandon, FL 33511-4770
Phone: 813.655.9498
Fax:
813.664.1274
email: swellguy.
watchdoc@verizon.net
|
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| We Fix It Right Away
We Fix It Right In Front of You
We
Fix It Right!
John Read, Chief, Litigation III, Antitrust
Division, U.S. Department of Justice, 325 7th Street, NW, Room
300,
Washington, DC 20530
Re:
UNITED STATES OF AMERICA,
Plaintiff,
v.
THE WATCHMAKERS OF
SWITZERLAND
INFORMATION
CENTER, INC., ET AL
Defendants.
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Supplemental to
Civil Action No.
96-170
Date: February 28,
2006
Civil Part I Judge
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MEMORANDUM OF UNITED STATES IN RESPONSE TO
MOTION OF ROLEX WATCH U.S.A., INC. FOR
ORDER TERMINATING FINAL JUDGMENT
Dear Mr. Read,
When I read the MEMORANDUM OF UNITED STATES IN
RESPONSE TO MOTION OF ROLEX WATCH U.S.A., INC. FOR
ORDER TERMINATING FINAL JUDGMENT
I was amazed & appalled. I am a watchmaker not an attorney so I do
not know the relevant case law cited by Rolex USA. I do know when
something smells bad & this really stinks.
In 1991 Rolex cancelled about all of it's "mom & pop" dealerships in favor
of chain stores, thereby depriving a lot of store owners that had been good
paying accounts of Rolex for years of a large chunk of their livelihood. They also
restricted parts to dealerships thereby depriving watchmakers of a good portion
of our livelihood.
The swiss watch companies have almost all done the same. These
companies are now more restrictive & collusive than ever before.
I dont have a Rolex account even though, having worked at a dealership, I
know I'm as good or better than a lot of guys that do. Rolex gives you a
certification after a 1-week class. This means that there are a lot of substandard
watchmakers out there that are Rolex certified & Rolex knows it. My boss
wouldn't spend the money to spend the money on my class even though, or
because, he went himself & I'm a much better watchmaker. The AWCI
certification test is a week long. 1 week test vs. 1 week course.
Rolex & the other companies say they want to insure PROPER repairs but the
fact is they really want to keep as much money for themselves, which means
keeping as much as possible out of the hands of us independents. The response
to this complaint one time was that we should all get jobs with them. That's
restraint of trade, plain & simple. Also it doesn't take a good watchmaker to do a
crystal or stem & crown but these parts are also restricted. If I'm doing the work
on my own car, the dealership will sell me the part (if not the parts store) no
matter how bad a mechanic I am. If I screw it up that's my fault. Unlike watch
repairs, auto repairs can be a matter of life & death & the car manufacturers are
not restrictive at all.
The end result is a lot of American businesses have been hurt or gone
under, American watch repair technicians have been deprived of work, & the
American public gets to pay a lot more for products & services.
On the whole, we deserve better.
| |
Douglas S. Stuart
Renaissance Watch Repair
15100 SE 38th St. #746
Bellevue,WA 98006 |
Mr. John Read
Chief, Litigation HI, Antitrust Division
US Department of Justice
325 7th Street NW, Room 300
Washington DC 20530
Re: ROLEX vs. DOJ
Dear Mr. Read
At the end of February (02/28/06) the U.S. Department of Justice issued a press
release regarding the termination of a consent decree, which has been in effect
since 1960, regarding anticompetitive practices in the U.S. watch industry. I am
writing to you to urge the DOJ to keep in place the consent decree of 1960 which
was intended to give American watchmakers and material distributors access to
repair parts.
Quoting from the press release: "Rolex Watch U.S.A. Inc. has agreed to pay
$750,000 as part of a settlement with the Department of Justice that resolves
Rolex's alleged violations of a 1960 consent decree that prohibited U.S. importers
of Swiss watches and watch parts from engaging in anticompetitive practices in
the U.S. watch industry. ...During its investigation of Ro lex's alleged decree
violations, the Department determined that, as a result of significant changes in
the watch industry during the past 45 years, the decree is no longer necessary to
protect competition and therefore should be terminated..."
The struggle between independent American watchmakers and the Swiss luxury
watch industry has been going on for decades, and the consent decree of 1960 is
ample evidence that unfair trade practices were the industry-standard way of
doing business. In the intervening decades, nothing has changed... in fact the
problem has become worse! The consent decree has gone largely unenforced,
and I can attest that access to repair parts for most Swiss luxury brand watches
over the past ten years has become ever more limited. It used to be possible for a
watchmaker to buy repair parts without restriction from wholesale watch
material suppliers. Now, one must petition each Swiss manufacturer for a parts
purchasing account, which is only granted either after fulfilling a number of
conditions (many of which are highly anti-competitive, if not per se illegal), or in
many cases the account is not granted at all.
While this particular DOJ action refers only to Rolex Watch U.S.A., the
entire Swiss luxury watch industry has varying degrees of restrictive repair
parts supply policies,
which make it very difficult for the independent watchmakers to practice their
trade. Some Swiss firms will not sell repair parts to anyone, no matter what
their qualifications; all work must be sent to their factory repair centers (where
prices charged for parts and repairs can be unfairly manipulated).
If the DOJ was of the opinion that the Swiss watch industry was engaging in
anticompetitive practices in 1960, it defies logic for them now to make the
assumption that the situation has been alleviated when in fact it has become
much worse than anytime in the last thirty-five years. Rolex argues that the
industry landscape has changed and that when you view the overall watch
market share, the number of units produced by the Swiss watch manufacturers
has declined as a percentage of the overall units being produced in the world.
The DOJ has accepted this argument as reason to terminate the consent decree,
which shows a complete lack of understanding of the marketplace. It doesn't
matter how many millions of watches are being produced worldwide. The only
number that matters is how many WATCHES THAT CONSUMERS ARE
WILLING TO PAY TO HAVE REPAIRED are produced... and the Swiss luxury
watch manufacturers clearly dominate that market even more than they did in
1960. No one pays $300 to have their $50 Seiko wrist watch serviced... so to
include the vast numbers of low-cost watches as rationale for terminating the
consent decree is completely erroneous.
If Swiss watch manufacturers want open access to the American consumer, they
should be forced to comply with American laws and practices of free trade.
Terminating the consent decree will hurt the American consumer, and it will do
serious damage to the American watch repair industry by allowing the Swiss
manufacturers to run roughshod over the material distributors and the
independent American watchmakers. I urge the DOJ to reconsider the decision
to terminate the consent decree, and instead vigorously enforce the laws of the
land when it comes to the anti-competitive practices of the Swiss watch
manufacturers.
Thank you for your attention to this important matter.
|
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_______________/s/________________
Douglas S. Stuart
Watchmaker, Renaissance Watch
Repair
|
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Tom Schmitt
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Thomas Rankin
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Rick Klausner G.G.
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Douglas M. De Chance
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Robert E. De Chance
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Harry Rosendwetg Jr
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Zach Bernng
Bernng's Fine Jewerly
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
William L. Steele
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
/s/
Signed,
Cindy Mero
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Elizabeth Wilson
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed, /s/ Oscar Messina
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed, /s/ Jose Hernandez
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Micha Mettale: Micha Inc.
1851 San Diego Ave SD 92110
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Maurice
Tal Jewelers
5 S. Wabash
Chicago, IL 60603
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Howard Frum Jewelers
5 S. Wabash
Chicago, IL 60603
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/
Eddie Rodriguez
626 S. Lu Blvd.
Lu, NV 89101
John R. Read
Chief, Litigation III Section
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington, DC 20530
Dear Mr. Read.
I am writing to formally request that you do not rescind the 1960 consent decree that prohibited
U.S. importers of Swiss watches and watch parts from engaging in anti-competitive practices in
the U.S. watch industry. I belong to an organization that represents over 4400 members who
earn their living in the watch industry. These members support hundreds of watchmakers in the
United States who also earn their living servicing luxury watches.
The Justice Department's investigation of Rolex's alleged decree violations led the Department to
determine that as a result of significant changes in the watch industry during the past 45 years,
the decree is no longer necessary to protect competition and therefore should be terminated. It
appears that the Department's investigation failed to take into account important variables that
triggered the legislation to begin with.
In 1960 the Swiss watch industry controlled 54% of the watches sold in the United States which
represented 99% of the luxury watch market. The Decree was put into affect to foster
competition and to protect anti-competitive practices as well as to protect the American
consumer. While today, the Swiss watch industry only controls 6% of the watches sold in the
United States, that figure continues to represent 99 % of the luxury watch market. The Swiss
watch makers would have the United States government believe that it is not necessary to
regulate them with anti-trust legislation since they only control 6% of the market. This
argument, however, is misleading as the need for anti-trust legislation to protect both American
consumers and American watchmakers is equally important today as it was in 1960 since the
Swiss watch industry dominates the luxury market.
By rescinding the 1960 decree the Swiss watch factories would be under no obligation to supply
parts to local American craftsman to service their watches and the consumer would be forced to
ship their watches to a few factory service centers set up across the country. This would literally
force all local watchmakers across the United States out of business because they would be
unable to obtain parts to service Swiss watches and it would leave the American consumers at
the mercy of the Swiss watch industry.
What possible advantage could be gained by rescinding the 1960 Decree other than Rolex and
the Swiss watch industry gaining total control over the watch industry in America. The luxury
watch industry has become ever more popular in the United States in the past fifteen years and
the Decree is not only necessary, it is imperative.
Signed,
/s/ Shelley Sergent
Schmitt Jewelers
Phx, AZ 85020
Dear John Read,
I would like to see The Swiss Watch Groups products taxed and imported fees much higher. They are not doing America s business men or the people in our country any favors! We can't get parts to repair these watchs
Lets incourage American factories with incentives and tax breaks to once again domanate the U.S. watchmaking industry
We watchmakers in the U.S. have the knowhow and talend to turn this around!
Debra Warren
650
Vernon PI
Westfield, IN
46074
to:
John R. Read,
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington D.C. 20530
Dear Sir:
Don't abandon the 1960 Consent decree between the government and Swiss Watch
Companies. To do so would legalize restrictive practices of price control, spare parts control
and restrictive franchise agreements in this country.
Sincerely yours,
/s/
Debra Warren
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Ray Cherry
5128 South Rolling Road
Baltimore, MD 21227
rcherry@RavSoft.net |
John R. Read
Chief, Litigation III Section
Antitrust division, US Department of Justice
325 7th Street NW, Suite 300
Washington, DC 20530
Subject: Comments regarding Rolex Consent Decree
Mr. Read,
I am a part-time, independent watchmaker. Starting in the 1970s, I was able to
order repair parts from Rolex - initially from their offices in New York City, and
later from their offices in Texas. A few years ago, Rolex notified me that I could
no longer order spare parts. There was no reason given.
It is my opinion, and I must temper my remarks with the fact that I am not a
lawyer, that Rolex has cut off the supply of spare parts in order to create a
monopoly in the Rolex watch repair business. To repair a Rolex Submariner, I
would normally spend about $60 for parts (all gaskets, new mainspring, new
mainspring barrel, etc), which would yield a profit to Rolex of around $30. Now
that I can no longer repair Rolex watches (I would prefer to not perform repairs
with "generic" parts.), my customers must send their watches to Rolex who will
charge about $600 for the repair, of which $300 is probably profit. Rolex,
because of the restrictive, monopolistic practices has multiplied their profit by a
factor of 10. My profit went down by 100%. Does this seem fair?
Bottom Line: I believe that I have been injured by an illegal practice by Rolex,
and I strongly recommend that they be bared from doing further business in the
Untied States unless and until the spare parts issue has been resolved. The
damage that they are doing to the independent watchmaker far exceeds the
$750,000 that they agreed to pay.
A few notes:
(1) I agree with and support the stand by the Jewelry Industry Distributors
Association which points out that in the 1970s there were many watch parts
distributors in the United States. With Rolex (and other Swiss brands) not
selling parts to distributors, watch material distributors are rapidly going out of
business. In other words, Rolex is moving towards monopolistic control of
Rolex watch parts in the US.
(2) Similar situation in the UK and in Europe. You might want to look up the status
of the European lawsuit.
(3) Rolex is not the only Swiss watch company which is engaging in practices
which I consider to be monopolistic. There is a long list, which I will be
delighted to provide upon request.
(4) Most Rolex dealers and many independent watchmakers can purchase parts
from Rolex. These folks are forbidden from re-selling Rolex parts. The
monopolistic control is tight: Organizations can loose their parts accounts for
reselling.
Thank you for considering my input,
/s/
Ray Cherry.
PS: I am local. If you would like to chat about this in person, please let me
know. I can generally re-schedule my full-time job (software consulting) to
make time for meetings.
D. D. Berghold
211 Martinez Spring Dr.
Bozeman, MT 59718
John R. Read,
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington DC. 20530
I would like to offer my comments in regards to the dissolving of the decree that
has been proposed concerning Rolex Watch Corp. and other Swiss watch
companies.
I am a watchmaker with 20 years experience. In the last 5-8 years I have noticed
a trend in the trade that seems to be spreading; the lack of (and encumbrances
one is faced with) in regards to spare parts availability. I have maintained a
Rolex spare parts account for about 8 years and have felt somewhat belittled by
the fact that I have to submit an application nearly every year in order to
maintain this account. Additionally, I have to offer consent for a representative
to inspect my repair facility without advance notification. Being that my repair
facility is at my home, I felt that this was a significant invasion of my privacy. I
can understand that Rolex wants to maintain a level of quality control but this
seems a little bit beyond the norm of reasonable constraints. No other accounts
that I maintain require this kind of scrutiny.
In the past, I have tried to locate simple watch bracelet parts for a customer only
to find that the company will only sell me these parts if I have a complete retail
account and carry their watch brand. In some cases, companies are not allowing
my business to send watches in to the factory for service on behalf of my
customer. This is a crime. I am trying to offer a level of good customer service
for my clients and these watch companies are preventing me from offering a
valuable service to my customers unless I purchase their line of watches.
In a recent conversation with another watch repair facility that, incidentally had
their Rolex parts account cancelled because they were stocking some "after
market" Rolex parts. And, not being a Rolex dealership, they are not able to buy
parts from Rolex at all now. Additionally, I was told that this repair facility was
considering investing in one of the latest watch timing machines made by a
Swiss company. When they spoke with the company, they were offered a 10%
discount if they had a Rolex parts account. Who is sleeping with whom here?
As part of Rolex's requirements, it makes it unlikely (and probably against their
guidelines) that I would be able to sell their spare parts. On their annual
application for a parts account, I have to check the box "no" to indicate that I do
not re-sell parts. Is this
legal? Am I not allowed to go to Nappa Auto Parts, buy a muffler and resell is to
my customer? And now to use the auto parts store scenario example again, but
when an auto repair shop sets up shop to do business, does he have to jump
through the same hoops. Is he allowed to stock non genuine Ford parts to sell his
customer? Is he subjected to the same scrutiny and visits from the quality control
department as Rolex?
What business does Rolex care if I do or do not belong to a trade organization.
These trade organizations offer some instruction and historical information to
the trade. They offer other services such as a lending library and technical
information. But do these trade organizations mean that much to Rolex? Why is
it that when I ask to have training on servicing Rolex watches at their greatly
sponsored "Watch Technicum" in Pennsylvania, that I am denied because I "only
have a parts account". If Rolex is so concerned about the quality control issues,
then they ought to willingly accept a candidate to better his or her skills by
attending one of their clinics instead of sending a representative around the
country checking up of the integrity of those like me who hold a parts account.
I do not know if my words will be heard, but I have taken the time to offer my
thoughts because this is not simply my issue. There are many watchmakers in
this country who would like to be able to service their customers with whatever
brand of watch walks in for repair. It is actions and policies like Rolex that
prevent individuals like me from being able to not only service my customers,
but also better my skills as a watchmaker.
If you have any further questions or comments, please do not hesitate to contact
me.
Respectfully,
/s/
D. D. Berghold
![]()
Jewelry Industry Distributors Association
701 Enterprise Drive Harrison, OH 45030
Phone:513-367-2357
Fax: 513-367-1414
www.jida.info |
Attention AWCI Members:
Critical Spare Parts Issue Precedent Looms
JIDA s position on the Consent Decree
By Bill Nagle, President JIDA
In the last issue of Horological times, the AWCI Board of Directors took a
position not to support the continuation of the consent decree that Rolex seeks
to dissolve. The AWCI Board of Directors fails to think through the
ramifications of their action and its effect on the industry as a whole. This is the
industry from which YOU derive a living and a
future.
It is critical that our voices be heard in Washington D.C. on this matter.
Retaining the
consent decree in total is unlikely, but key portions must be kept in place in the
spirit of
fairness that US laws are based. Removing the decree in its entirety would allow
the
luxury brands legal latitude to operate as they have for the past several decades.
Rolex
has agreed to pay $750,000.00 in order to settle with the United States
Department of
Justice.
The final judgment prohibits certain defendants from imposing use restrictions
on watch
repairers. The United States charged that Swiss watch companies agreed to
regulate the
use, distribution, and pricing of watch repair parts. The primary harm that the
Final
Judgment sought to remedy was cartel behavior led by Swiss industry
organizations.
Contrary to the legal standards applicable to the termination of an antitrust final
judgment
with the consent of the United States, The US has not offered a reasoned and
reasonable
explanation of why the termination vindicates the public interest in free and
unfettered
competition .
The watch industry has changed due to technological advances during the last
40 years,
altering the number of lower-priced units sold in the US. The volume and
manufacturers
of luxury watches has not significantly changed in terms of units sold. The
defendants
targeted by the consent decree deal primarily in the luxury watch market, with
little or no
participation in the low-end market. Therefore using the addition of quartz
movements,
Timex, Bulova, Seiko, and other low-priced alternatives, (given as a reason to
change
laws in place governing the luxury watch market), seems to be an incorrect
application of
the rule of reason in place of per se rule.
The dropping of the consent decree could put Rolex s revised policies in
violation of certain Sherman Antitrust Act provisions. These provisions
include vertical price restraints in regard to fixing minimum and maximum prices,
non-vertical price restraints in regard to spare part resale restrictions, and tying
contract violations in regard to the policy voiding warranties if generic parts are
used.
Material houses will be affected by the dropping of the consent decree, which
will in turn
have a direct impact on AWCI members ability to make timely and profitable
repairs in
their businesses. One fact that may not have been recognized by the AWCI
Board of
Directors is the true financial history of Material houses compared to the luxury
watch
brands on AWCI. Did you know that during the past twenty-five years, various
material houses (JIDA members) have purchased approximately 80% of the
advertising in the Horological Times, which equates to well over $1,000,000.
The manufactures/brands only recent contributions come no where close to
matching that of the material houses
past and present support. Is the AWCI Board of Directors protecting the group
that truly pays the bills, or the prestigious brands for which they hope to be
associated with?
The original judgment has vertical restraints that the Department of Justice
deemed necessary as a means of watch parts distribution in the 1960 s. This was
designed to keep the Swiss Cartel from restricting the flow of parts necessary
for the watch repair trade to
operate. The Swiss Cartel, as it was known, may not exist today in name only .
The
common business practices of today s Swiss Watch Groups, who work together,
produces
the same result of the illegal Cartel from earlier decades. The companies may
have
changed their names to Groups , but what was against the law in 1960 is still
illegal today.
If you have any questions regarding this important development, please contact
your
local watch material house. There is a sixty-day public comment period that
expires on
June 6, 2006. You can send your comments directly to:
John R. Read,
Chief, Litigation III Section,
Antitrust Division, US Department of Justice,
325 7th Street, NW, Suite 300
Washington D.C. 20530
For further information regarding this pending action,
Please go to:
www.usdoj.gov/atr/cases/O14800/214815.htm