Comment 5: Gray, W. Blake

Please issue a definition of "Estate" that requires any wine including the word in its brand name, or anywhere on the front label, to be actually grown and bottled completely on the winery's property. "Estate" implies that a wine is produced in-house. To call a wine Smith Estate Cabernet Sauvignon implies that there is a Smith Estate, that wine grapes are grown there and that wine is made from them there. If that is not the case, the wine should be called Smith Cabernet Sauvignon. The former name could deceive some consumers; the latter name cannot. There are an infinite number of potential brand names that do not include the word "estate." There is no reason to allow potentially deceptive information on wine labels. And there is no reason a wine must be called "estate" when it is not an estate-bottled wine. Please consider the needs of consumers in this case above the desires of businesses marketing to them. Also, please do NOT grandfather in existing brand names that include the word "estate." This penalizes not only consumers, but wineries which actually do create true estate wines. It will not be an undue hardship for any winery to remove the word "estate" from its brand name.