Advisory opinion letter: the relationship between the Independent Wire Producers Association 1 Not reproduced…

June 8, 1977, Dear Harry:

Pursuant to our telephone conversation today, I enclose herewith a copy of the presentation made by the Independent Wire Producers Association in December 1976 before the Office of The Special Representative for Trade Negotiations concerning the bilateral agreement between the European Coal and Steel Community and the Japanese Ministry of International Trade limiting exports of Japanese steel to Europe.! I refer you specifically to pages 4-14, and to Exhibit 1, which contains the relevant TSUSA numbers for carbon steel wire rod.

Should you have any further questions, please contact me at your

earliest convenience.
Sincerely,
/s/ Beth C. Ring

Second Supplemental Letter Relative to Request May 19, 1977 Dear Harry, This is to confirm our telephone conversation today concerning the relationship between the Independent Wire Producers Association 1 Not reproduced herein.

1 Not reproduced herein.

ADVISORY OPINIONS 1183 (“the Association”) and the management firm of Smith, Bucklin & Associates, Inc. (“Smith Bucklin”). It was your concern that the closeness of this relationship might jeopardize the anonymity of the member companies in their submitting data to Smith Bucklin pursuant to the proposed reporting system.

Brian Cassedy, an employee of Smith Bucklin, acts as the managing director of the Association. Mr. Cassedy functions as the managing director under authority granted by the Board of Directors of the Association. Since Mr. Cassedy would be under instructions by the Board not to disclose the identity of any reporting member company to any other reporting member company, it would be a violation of his employment and his fiduciary duty to violate such instructions. Mr. Cassedy has advised me that he will recommend to the Board of Directors that the Association engage the services of Tyson, Belzer & Associates, Inc. to make the statistical compilations and dissemination for the Association. Enclosed herewith is a brochure from Tyson, Belzer & Associates, Inc., which explains the nature of their services and confirms that the information to be reported would be kept on a confidential basis.* This brochure states: “It is our policy to work only at the Association level. No consultations are ever provided to individual firms. No information is ever released. To avoid even accidental data disclosures, many of our analyses contain tight security provision for processing data and presenting results.” (Emphasis added). I have also enclosed a description of an example of the type of project conducted to Tyson, Belzer & Associates, Inc.* This description shows that economic and statistical analysis were compiled to form the basis of a presentation before the United States Tariff Commission (now the United States International Trade Commission). It was very nice meeting you yesterday. Should you have any further questions, do not hesitate to call me at your convenience. Sincerely, /s/ Beth C. Ring First Supplemental Letter Relative to Request