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CPSC Persuaded Our Client’s Product Not a “Consumer Product” Subject to CPSC Recall Jurisdiction

After a distributor reported a product issue concerning our client’s product to the CPSC, Bob Littleton negotiated with the CPSC to reconsider the CPSC’s initial position that the product was a regulated “Consumer Product”. Ultimately, the CPSC General Counsel’s Office accepted the position we advocated in our briefing, reversed the Compliance Department’s initial finding of jurisdiction, and determined that our client’s product fell outside the CPSC’s jurisdiction.