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  1. I was wondering if anyone had experience with or could provide sites to information regarding determining the manufacturer for purposes of a GSA Schedule contract. Here's some background: A company designs and creates the specs for a product and has a supplier take those specs and make a product. The company does 100% of the design/specifications and retains complete ownership of the intellectual property. The supplier is 100% responsible for physically producing the product. The company then sells that product to the public under its brand as the manufacturer. Both company and supplier are US-based and the country of origin of the product is US. Who is the manufacturer for purposes of disclosing to GSA and getting a letter of supply, the company or the supplier? I understand that "place of manufacture" is defined in the FAR as the place where the product is physically put together, but I cannot find a statutory site or any case law on defining the manufacturer in this type of instance. My concern is related to letters of supply. If you consider the purpose of the letter of supply (TAA compliance and supply concerns), then it seems as if GSA would want a letter of commitment from the supplier in this case, especially since the supplier controls production. Any thoughts?
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