By. Joseph B. Allegretti, Allegretti & Company, 9200 Mason Avenue, Chatsworth, Calif.
October 31, 1979.
Re: United States v. Emerson Electric Co., Civ. No. 79 C 1144
John L. Burley, Esq., ... United States Department of Justice, Antitrust Division...
Dr. Mr Burley: At the request of Emerson Electric Co., I am writing to provide you with background information and a description of the business of Allegretti & Company to assist you in evaluating my Company as a prospective purchaser of the Ridge Portable Electric Tool assets.
Prior to its incorporation as Allegretti & Company on April 20, 1960, the business was conducted as a partnership between my father, Albert J. Allegretti, and my uncle, Joseph A. Allegretti. The original partnership was formed in 1934, but it was not until 1947 that it became engaged in what can be described as its present business. In that year, the firm entered the lawn and garden business with the production of a hand edger.
,P.In 1954 the firm produced its first electric product, also a lawn edger. We began making our own electric motors in 1958 and continue to do so today. Although our original production of motors was limited to universal motors for our own requirements, we have since expanded our motor operations to include the production of permanent magnet motors sd in addition to our own motor requirements, the supply of electric motors (of both types) to other firms.
For example, between 1965 and 1971 we supplied motor to Roper Corporation for use in electric lawnmowers which Roper manufactured for Sears, Roebuck & Company. We have supplied motors and finished product on a private label basis (since 1973) for Weed Eater, Inc. (which was acquired by Emerson Electric Co. in 1977). We present supply motors for use in foot processors manufactured by the Hamilton Beach Division of Scovill; for use in vacuum cleaners, and are in the process of developing motors for use in garbage disposal units. To facilitate the continued expansion of our motor business, we increased our physical capabilities for the production of electric motors by purchasing three facilities from a subsidiary of Nabisco in 1978.
The electric motor produced by Allegretti are either usable or readily adaptable for use in portable electric tools and it is our intention to produce at Allegretti motors for use in the products that will be manufactured as a result of the purchase by Allegretti of the Ridge Portable Electric Tool program.
In 1974 Allegretti purchased an injection molding company (which we have since great expanded), which provides us with plastic molding capability of the type used in the portable electric tool business. It is our intention to use our internal plastic molding capabilities in the portable electric tool business.
...The financial statements of the [Allegretti] Company are not publicly available and are highly confidential. Therefore, I am extremely reluctant to supply you with a copy of our financial statements....
With respect to engineering and product design development capabilities, Allegretti employs approximately 12 engineers, some of whom have electric motor capability. ... Sears, Roebuck & Company is a very large customer of Allegretti and has been since 1948. Over the years Allegretti has sold hand edgers, electric edgers, electric leaf blowers and electric string trimmers to Sears. The products sold to Sears are private label products which are re-sold by Sears under its own brand names.
Allegretti also sells lawn and garden products under its own "Paramount" brand to other large retailers, including K Mart, Treasure (a division of J. C. Penney), and Home Center Hardware subsidiaries of W. R. Grace. In addition, Allegretti sells its products to lawn and garden distributors throughout the country including such major distributor cooperatives as Liberty and Allied, and major retailer cooperatives such as Ace and Cotter (True Value).