BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 926
                                                                  Page  1

          CONCURRENCE IN SENATE AMENDMENTS
          AB 926 (Ruskin)
          As Amended  September 4, 2009
          Majority vote
           
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          |ASSEMBLY:  |80-0 |(May 26, 2009)  |SENATE: |40-0 |(September 10, |
          |           |     |                |        |     |2009)          |
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           Original Committee Reference:    J.,E.D. & E.

          SUMMARY  :   Requires every solicitation that appears in the  
          California State Contracts Register, or specified requests for  
          proposals relating to the furnishing of equipment, materials,  
          supplies, or telecommunications to contain the following  
          statement, "It is unlawful for any person engaged in business  
          within this state to sell or use any article or product as a  
          "loss leader," as defined.   

           The Senate amendments  modify the disclosure requirements to  
          reduce the potential cost of implementing the measure.   

           EXISTING LAW  :

          1)Establishes the State Contract Act, administered through the  
            Department of General Services (DGS), for the purpose of  
            providing guidance on state contracting for goods, services,  
            and information technology.

          2)Prohibits a person engaged in business in California to sell  
            any product at less than the cost or give away any product for  
            the purpose of injuring competitors or destroying competition.  
             More specifically, existing law defines a  "loss leader" as  
            selling a product at less than cost:

             a)   Where the purpose is to induce, promote or encourage the  
               purchase of other merchandise;

             b)   Where the effect is a tendency or capacity to mislead or  
               deceive purchasers or perspective purchasers; or,

             c)   Where the effect is to divert trade from or otherwise  
               injure competitors.









                                                                  AB 926
                                                                  Page  2

           AS PASSED BY THE ASSEMBLY  , this bill required every solicitation  
          that appears in the California State Contracts Register, or  
          specified requests for proposals relating to the furnishing of  
          equipment, materials, supplies, or telecommunications to contain  
          the following statement, "It is unlawful for any person engaged  
          in business within this state to sell or use any article or  
          product as a "loss leader," as defined.  The bill also made  
          other technical, nonsubstantive changes relating to the Small  
          Business Procurement Act.   

          FISCAL EFFECT  :  According to the Senate Appropriations  
          Committee, the cost for implementing this measure, prior to the  
          provisions added on the Senate Floor, is up to $70,000 in fiscal  
          year 2009-10 and up to $60,000 in 2010-11.

           COMMENTS  : 

          1)In August of 2008, DGS released an internal compliance audit  
            of an office supply contract with Office Depot, Inc (Office  
            Depot), Contract No. 1S-06-75-55.  In this contract, DGS had  
            consolidated the state's primary office supply purchases into  
            a single contract with the expectation of the state receiving  
            significant discounts. 

            Key issues investigated included whether the contract complied  
            with state pricing rules and the small business and DVBE  
            contracting requirement that they serve a commercially useful  
            function (CUF).  In its findings the audit stated that over  
            all, Office Depot had met the CUF requirements and that items  
            covered in the contract had been accurately priced.  However,  
            the audit found $34,399 (13%) in over-charges on items  
            identified within the contract.

            Further, the auditor identified approximately 16,000 items  
            ($14.2 million) that had been purchased by the state that were  
            not specifically covered in the contract and therefore  
            received no discounts.  While initially, Office Depot stated  
            that they were not aware of any contract limitation on  
            offering "off-contract" products within their catalog and  
            online ordering website, Office Depot ultimately agreed to  
            repay the state $2.5 million.

            In addition to the issues addressed above, the audit  
            identified some shortcomings in the state's administration of  
            this contract.  As a result, DGS states that it has made  








                                                                  AB 926
                                                                  Page  3

            improvements to its contract oversight and administration  
            functions to better manage multi-faceted programs like the  
            Office Depot contract in the future.   

          2)While the scope of the Office Depot audit included a review of  
            whether the pricing generally conformed with state laws, the  
            author contends that the audit should have specifically  
            addressed the issue of whether Office Depot engaged in the  
            illegal activity of using certain low cost products as a loss  
            leader to either win the contract or in the implementation of  
            the contract.

            Historically, many state agencies have used their office  
            supply contracts to meet their annual 25% procurement goal for  
            small businesses and their 3% goal for DVBEs.  By bundling the  
            state office supply contract, many small businesses believe an  
            important business opportunity is being eliminated.  Small  
            businesses are potentially already at a disadvantage to larger  
            office suppliers who have access to bulk discounts.   
            Therefore, enhanced enforcement of this existing loss leader  
            law is central to small businesses ongoing ability to obtain  
            state contracting opportunities. 

            According to the author, when DGS was asked whether they had  
            audited for violations of the loss leader law, the auditors  
            responded that they were not aware of the law.  The author  
            states that implementation AB 926 addresses this lack of  
            knowledge of a 1950s law by placing a reference to it within  
            the State Contracting Code.

           
          Analysis Prepared by  :    Toni Symonds / J., E.D. & E. / (916)  
          319-2090 



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