Bedrock Quartz Letter Quartz Imports Under Siege | Page 2

1. In the “scope” Cambria included all the “downstream products” which means they included any fabricated goods such as finished countertops. So, by their own selection they included in the scope the very product that fabricators produce. 2. Cambria simultaneously made the claim that the fabrication industry should not be included in the industry because fabricators have “minimal investments, few employees, little complexity and they add minimal value to the quartz slab.” This is absolutely false. It has become clear that there are at least 10,000 -15,000 fabricators in the US, they employee at least 120,000 people, that they add far more value to the product and have far more employees than are in the quartz slab production process. Also, the ITC was given examples of fabricated countertop pricing from Cambria dealers. These examples demonstrated that there is significantly more value added through fabrication operations than Cambria adds through slab production. The examples demonstrated 3 to 4 times more “added- value” is created in fabrication operations than is created in slab production. From an industry (fabrication) that Cambria claims adds “minimal or little” value. 3. Cambria claims that the fabricators are insignificant. This claim is made because they are “speaking for” and representing that they are the industry. If their false narrative is disproved, then Cambria loses. 4. The scope has been expanded (just last week) to include glass/quartz products and glass products even though Cambria does not and has not ever produced something with glass in it. 5. There were 15 fabricators who responded to the producer’s questionnaire. None of Cambria’s fabricators responded. Cambria then claimed the data was “skewed” because those that responded only cared about importing quartz from China. Yes, the questionnaire was difficult, but it’s too bad more didn’t respond to provide the data about added-value, employment and investment. 6. The basis of the argument is that the domestic industry, defined by Cambria as the quartz slab industry, has been injured. They have based this on declining profits (still profitable) on the part of Cambria. They have misrepresented the truth in these arguments. During the time of analysis, they funded their crazy marketing movie (3-4 million or more), they opened sixteen new distribution centers (and loaded them all with inventory) and then they claim that their operating profits are down only because they couldn’t raise prices enough and that their sales were down because of Chinese imports. 7. In the final ITC hearing, LG (Viatera) testified that the industry is not injured, and they have been enjoying ongoing growth even with imports from China and elsewhere. Our industry didn’t come together strongly on the Chinese case. Many of you figured your businesses would be better off if imports were curtailed from China. But do you really think that shutting down China, India and Turkey and maybe Spain will benefit our industry of fabricators, importers and suppliers? Once quartz is no longer available via China, India and Turkey do you think that the remaining suppliers will have enough material to provide for our industry’s needs? No way. Or will Cambria broaden its distribution model and start selling to all of the previously unwashed where it has previously operated very exclusively? Or will Cambria increase its exclusivity, to drive already high prices up even further? Their record shows prices will rise. I hope we can come together more than we have previously. Are you willing to allow Cambria to continue to assert and claim that they represent the industry because the fabricators are too simple and small and are simply not relevant? That’s what Cambria is hoping. If you are willing to help in some capacity, through information, legal costs and statements, please let me know. Alan Jorgensen Bedrock Quartz, [email protected]