[Federal Register Volume 61, Number 195 (Monday, October 7, 1996)]
[Notices]
[Pages 52459-52465]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 96-25336]
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DEPARTMENT OF JUSTICE
Antitrust Division
United States v. Ixtlera de Santa Catarina, S.A. de C.V. and MFC
Corporation; Proposed Final Judgment and Competitive Impact Statement
Notice is hereby given pursuant to the Antitrust Procedures and
Penalties Act, 15 U.S. Sec. 16(b)-(h), that a proposed Final Consent
Judgment, Stipulation and Competitive Impact Statement have been filed
with the United States District Court for the Eastern District of
Pennsylvania in the above-captioned case.
On September 26, 1996, the United States filed a civil antitrust
Complaint to prevent and restrain Ixtlera de Santa Catarina, S.A. de
C.V. (``Ixtlera'') and MFC Corporation from conspiring to fix prices
and allocate the sales volume of tampico fiber imported and sold in the
United States in violation of Section 1 of the Sherman Act (15 U.S.C.
Sec. 1). Tampico fiber is a vegetable fiber grown in Mexico and used as
a filler in industrial and consumer brushes.
The Complaint alleges that the defendants agreed with unnamed co-
conspirators to (1) fix the prices of tampico fiber imported into the
United States; (2) fix the resale prices charged in the United States
distributors; and (3) allocate tampico fiber sales among United States
distributors.
The proposed Final Judgment would prohibit the defendants from
entering into any agreement or understanding with any other processor
or distributor of tampico fiber to:
(1) Raise, fix, or maintain the price or other terms or conditions
for the sale or supply of tampico fiber;
(2) Allocate sales, territories or customers for tampico fiber;
(3) Eliminate or discourage new entry into the tampico fiber
market; and
(4) Eliminate or otherwise restrict the supply of tampico fiber to
any customer.
The proposed Final Judgment would also prohibit defendants form
communicating with any other processor, supplier or distributor
regarding future price information, information regarding sales volume,
the location or identity of customers, eliminating or discouraging new
entrants into the tampico fiber market, or eliminating or restricting
the supply of tampico fiber to any customer. In addition, the proposed
Final Judgment would prohibit the defendants from adhering to any
resale pricing policy and defendant Ixtlera from suggesting resale
prices and form terminating or threatening to terminate any distributor
for that distributor's pricing. Finally, the proposed Final Judgment
would also prohibit Ixtlera from merging with the Mexican tampico fiber
processor Fibras Saltillo, S.A. de C.V. without providing the Antitrust
Division with ninety (90) days notice to review the transaction.
Public comment is invited within the statutory sixty (60) day
period. Such comments will be published in the Federal Register and
filed with the Court. Comments should be addressed to Robert E.
Connolly, Chief, Middle Atlantic Office, U.S. Department of Justice,
Antitrust Division, The Curtis Center, 6th and Walnut Streets, Suite
650 West, Philadelphia, PA 19106 (telephone number 215-597-7405).
Rebecca P. Dick,
Deputy Director of Operations.
In the United States District Court for the Eastern District of
Pennsylvania
United States of America, Plaintiff, v. Ixtlera de Santa
Catarina, S.A. de C.V.; and MFC Corporation, Defendants. Civil
Action No. 95-6515, Judge Jay C. Waldman.
Stipulation
It is stipulated by and between the undersigned parties, by their
respective attorneys, that:
(1) The parties consent that a final judgment in the form hereto
attached may be filed and entered by the Court at any time after the
expiration of the sixty (60) day period for public comment provided by
the Antitrust Procedures and Penalties Act, 15 U.S.C. Sec. 16(b)-(h),
without further notice to any party or other proceedings, either upon
the motion of any party or upon the Court's own motion, provided that
plaintiff has not withdrawn its consent as provided herein;
(2) The plaintiff may withdraw its consent hereto at any time
within said period of sixty (60) days by serving notice thereof upon
the other party hereto and filing said notice with the Court;
(3) In the event the plaintiff withdraws its consent hereto, this
application shall be of no effect whatever in this or any other
proceeding and the making of this stipulation shall not in any manner
prejudice any consenting party to any subsequent proceedings.
Dated: September 26, 1996.
For the Plaintiff:
Joel I. Klein,
Acting Assistant Attorney General.
Rebecca P. Dick,
Deputy Director of Operations.
Robert E. Connolly,
Chief, Middle Atlantic Office.
Respectfully submitted,
Edward S. Panek,
Michelle A. Pionkowski,
Roger L. Currier,
Joseph Muoio,
Attorneys, Antitrust Division, U.S. Department of Justice, Middle
Atlantic Office, The Curtis Center, Suite 650W, 7th and Walnut Streets,
Philadelphia, PA 19106, Tel.: (215) 597-7401.
For the Defendants:
Gordon B. Spivack,
Ixtlera de Santa Catarina, S.A. de C.V.
Roxann E. Henry,
MFC Corporation.
Final Judgment
Plaintiff, the United States of America, filed its complaint on
September 26, 1996. Plaintiff and defendants, by their respective
attorneys, have consented to the entry of this final judgment without
trial or adjudication of any issue of fact or law. This final judgment
shall not be evidence against or an admission by any party to any issue
of fact or law.
[[Page 52460]]
Defendants have agreed to be bound by the provisions of this final
judgment pending its approval by the Court.
Therefore, before the taking of any testimony and without trial or
adjudication of any such issue of fact or law herein, and upon consent
of the parties, it is hereby ordered, adjudged, and decreed as follows:
I
Jurisidiction
This Court has jurisdiction of the subject matter of this action
and of each of the parties consenting hereto. The complaint states a
claim upon which relief may be granted against defendants under Section
1 of the Sherman Act, 15 U.S.C. Sec. 1.
II
Definitions
As used in this final judgment:
A. ``Agreement'' means any contract, agreement or understanding,
whether oral or written, or any term or provision thereof.
B. ``Person'' means any individual, corporation, partnership,
company, sole proprietorship, firm or other legal entity.
C. ``Tampico fiber'' is a natural vegetable fiber produced by the
lechugilla plant and grown in the deserts of northern Mexico. It is
harvested by individual farmers, processed, finished and exported to
the United States and worldwide, where it is used as brush filling
material for industrial and consumer brushes. It is available in
natural white, bleached white, black, gray and a wide variety of
mixtures.
D. ``Resale price'' means any price, price floor, price ceiling,
price range, or any mark-up, formula or margin of profit relating to
tampico fiber sold by distributors.
III
Applicability
A. This final judgment applies to each of the defendants and to
their owners, officers, directors, agents, employees, subsidiaries,
successor and assigns, and to all other persons in active concert or
participation with any of them who shall have received actual notice of
this final judgment by personal service or otherwise.
B. Each defendant shall require, as a condition of any sale or
other disposition of all, or substantially all, of its stock or assets
used in the manufacture or sale of tampico fiber, that the acquiring
party or parties agree to be bound by the provisions of this final
judgment, and that such agreement be filed with the Court.
IV
Prohibited Conduct
As to tampico fiber imported into or sold in the United States:
A. Each defendant is enjoined and restrained from directly or
indirectly entering into, adhering to, maintaining, furthering,
enforcing or claiming any rights under any contract, agreement,
arrangement, understanding, plan, program, combination or conspiracy
with any other processor, supplier or distributor of tampico fiber to:
(1) Raise, fix, or maintain the prices or other terms or conditions
for the sale or supply of tampico fiber;
(2) Allocate sales volumes, territories or customers for tampico
fiber;
(3) Discourage or eliminate any new entrant into the tampico fiber
market; or
(4) Restrict or eliminate the supply of tampico fiber to any
customer;
B. Each defendant is enjoined and restrained from communication
with any processor, supplier or distributor (other than its own
processor, supplier or distributor) of tampico fiber regarding any
current or future price, price change, discount, or other term or
condition of sale charged or quoted or to be charged or quoted to any
customer or potential customer for tampico fiber, whether communicated
in the form of a specific price or in the form of information from
which such specific price may be computed;
C. Each defendant is enjoined and restrained from distributing to
any processor, supplier or distributor (other than its own processor,
supplier or distributor) of tampico fiber price lists or other pricing
material that is used, has been used, or will be used in computing
prices or terms or conditions of sale charged or to be charged for
tampico fiber;
D. Each defendant is enjoined and restrained from communicating
with any processor, supplier or distributor (other than its own
processor, supplier or distributor) of tampico fiber regarding
information pertaining to the volume of sales of tampico fiber or the
location or identity of customers;
E. Each defendant is enjoined and restrained from communicating
with any processor, supplier or distributor regarding discouraging or
eliminating any new entrant into the tampico fiber market or
restricting or eliminating the supply of tampico fiber to any customer;
F. Ixtlera is enjoined and restrained from directly or indirectly
entering into, adhering to, maintaining, furthering, enforcing or
claiming any right under any contract, agreement, understanding, plan
or program with any distributor to fix or maintain the prices at which
tampico fiber sold by Ixtlera may be resold or offered for sale by any
distributor;
G. Ixtlera is enjoined and restrained from directly or indirectly
adopting, promulgating, suggesting, announcing or establishing any
resale pricing policy for tampico fiber;
H. Ixtlera is enjoined and restrained from threatening any
distributor with termination or terminating any distributor on the
basis of that distributor's pricing; or discussing with any present or
potential distributor any decision regarding termination of any other
distributor for any reason directly or indirectly related to the other
distributor's resale pricing, provided, however, that nothing herein
shall prohibit Ixtlera from terminating a distributor for any reason
other than the distributor's resale pricing;
I. MFC is enjoined and restrained from directly or indirectly
entering into, adhering to, maintaining, furthering, enforcing or
claiming any right under any contract, agreement, understanding, plan
or program with any supplier to fix or maintain the prices at which
tampico fiber may be resold or offered for sale by MFC or any other
distributor;
J. Each defendant is enjoined and restrained from participating or
engaging directly or indirectly through any trade association,
organization or other group in any activity which is prohibited in IV
(A)-(I) above; and
K. Ixtlera is enjoined and retrained from merging with, acquiring
all or part of the assets or securities of, or selling all or part of
its assets or securities to the Mexican tampico fiber processor Fibras
Saltillo, S.A. de C.V., or its owners, officers, directors, agents,
employees, subsidiaries, successors and assigns without first providing
plaintiff with at least 90 days written notice prior to closing the
transaction for the purpose of investigation the proposed transaction.
Such notification shall include a complete description, English, of the
proposed transaction and the reasons therefor. Ixtlera agrees to
provide promptly all information, with English translations, reasonably
requested by plaintiff in connection with its investigation of the
proposed transaction, consents to the jurisdiction of the Court to
adjudicate the legality of the proposed or consummated transaction
under the antitrust laws of the United States and waives any objections
to venue. Nothing in this paragraph shall prohibit Miguel Schwarz,
Marx, principal of Ixtlera, from divesting to any person, without
[[Page 52461]]
notice, the 27.5 percent interest in Fibras Saltillo, S.A. de C.V.
which he currently holds.
V
Permitted Conduct
A. Other than Section IV(A) of this final judgment, nothing
contained in this final judgment shall prohibit a defendant from
negotiating or communicating with any processor, supplier or
distributor of tampico fiber or with any agent, broker or
representative of such processor, supplier or distributor solely in
connection with bona fide proposed or actual purchases of tampico fiber
from, or sale or tampico fiber to, that processor, supplier or
distributor.
B. Nothing contained in this final judgment shall prohibit
defendant MFC from unilaterally deciding to resell tampico fiber at
prices suggested by its supplier. However, any instance in which a
supplier suggests the prices at which MFC should resell tampico fiber
shall be reported in writing with a copy to MFC's Antitrust Compliance
Officer. This report shall state the date, time and place of the
communication, whether it was oral or written, the name and title of
the other person or persons involved in the communication, briefly
describe the pricing information provided, and if the communication was
written, have attached a copy of the document containing the reference
to the suggested resale prices. Such reports shall be retained in the
files of MFC, and copies thereof shall be delivered to the Antitrust
Division by the defendant on or about each anniversary date of this
final judgment.
C. Nothing contained in this final judgment shall prohibit Miguel
Schwarz Marx from obtaining information as to the prices Fibras
Saltillo charged A&L Mayer Associates, Inc. or any successor to A&L
Mayer Associates, Inc. that serves as a conduit between Fibras Saltillo
and its United States distributor for tampico fiber so long as the
pricing information is at least six months old and is used solely to
protect the value of Schwarz's investment in Fibras Saltillo under
Mexican law.
D. Nothing contained in this final judgment shall prevent (1) MFC
from being Ixtlera's exclusive distributor for tampico fiber in the
United States, (2) MFC and Ixtlera from conducing negotiations
regarding such an exclusive distributorship, or (3) Ixtlera from
deciding to appoint another company as its exclusive distributor in the
United States.
VI
Compliance Program
Each defendant shall establish within thirty (30) days of entry of
this final judgment and shall thereafter for so long as it or its
employees are engaged in the manufacture or sale of tampico fiber,
maintain a program to insure compliance with this final judgment, which
program shall include at a minimum the following:
A. Designating an Antitrust Compliance Officer responsible, on a
continuing basis, for achieving compliance with this final judgment and
promptly reporting to the Department of Justice any violation of the
final judgment;
B. Within sixty (60) days after the date of entry of this final
judgment, furnishing a copy thereof to each of its own, its
subsidiaries', and its affiliates' (1) officers, (2) directors, and (3)
employees or managing agents who are engaged in, or have responsibility
for or authority over, the pricing of tampico fiber; and advising and
informing each such person that his or her violation of this final
judgment could result in a conviction for contempt of court and
imprisonment, a fine, or both;
C. Within seventy five (75) days after the date of entry of this
final judgment, certifying to the plaintiff whether it has designated
an Antitrust Compliance officer and has distributed the final judgment
in accordance with Sections VI (A) and (B) above;
D. Within thirty (30) days after each such person becomes an
officer, director, employee or agent of the kind described in Section
VI (B), furnishing to him or her a copy of this final judgment together
with the advice specified in Section VI (B);
E. Annually distributing the final judgment to each person
described in Sections VI (B) and (D);
F. Annually briefing each person described in Sections VI (B) and
(D) as to the defendant's policy regarding compliance with the Sherman
Act and with this final judgment, including the advice that such
defendant will make legal advice available to such persons regarding
any compliance questions or problems;
G. Annually obtaining (and maintaining) from each person described
in Sections VI (B) and (D) a certification that he or she:
(1) Has read, understands, and agrees to abide by the terms of this
final judgment;
(2) Has been advised of and understands the company's policy with
respect to compliance with the Sherman Act and the final judgment;
(3) Has been advised and understands that his or her non-compliance
with the final judgment may result in conviction for criminal contempt
of court and imprisonment, a fine, or both; and
(4) Is not aware of any violation of the final judgment that has
not been reported to the Antitrust Compliance Officer; and
H. On or about each anniversary date of the entry of the final
judgment, submitting to the plaintiff an annual declaration as to the
fact and manner of its compliance with this final judgment, including
any reports responsive to Section V of this final judgment.
VII
Inspection and Compliance
For the purpose of determining or securing compliance with this
final judgment and subject to any legally recognized privilege, from
time to time:
A. Duly authorized representatives of the Department of Justice
shall, upon written request of the Attorney General or of the Assistant
Attorney General in charge of the Antitrust Division, and on reasonable
notice to a defendant made to its principal office, be permitted:
(1) Access, during office hours of such defendant, to inspect and
copy all books, ledgers, accounts, correspondence, memoranda and other
records and documents in the possession or under the control of such
defendant, which may have counsel present, relating to any matters
contained in this final judgment; and
(2) Subject to the reasonable convenience of such defendant and
without restraint or interference from it, to interview officers,
employees and agents of such defendant, who may have counsel present,
regarding any such matters;
B. Upon the written request of the Attorney General or of the
Assistant Attorney General in charge of the Antitrust Division made to
a defendant's principal office, such defendant shall submit such
written reports, under oath if requested, with respect to any of the
matters contained in this final judgment, as may be requested;
C. No information or documents obtained by the means provided in
this Section VII of the final judgment shall be divulged by any
representative of the Department of Justice to any person other than a
duly authorized representative of the Executive Branch of the United
States, except in the course of legal proceedings to which the United
States is a party, or for the purpose of securing compliance with this
final judgment, or as otherwise required by law;
[[Page 52462]]
D. If at the time information or documents are furnished by a
defendant to plaintiff, such defendant represents and identifies in
writing the material in any such information or documents to which a
claim of protection may be asserted under Rule 26(c)(7) of the Federal
Rules of Civil Procedure, and such defendant marks each pertinent page
of such material, ``Subject to claim of protection under Rule 26(c)(7)
of the Federal Rules of Civil Procedure,'' then ten (10) days notice
shall be given by plaintiff to such defendant prior to divulging such
material in any legal proceeding (other than a grand jury proceeding)
to which such defendant is not a party; and
E. Nothing set forth in this final judgment shall prevent the
Antitrust Division from utilizing other investigative alternatives,
such as Civil Investigative Demand process provided by 15 U.S.C.
Secs. 1311-1314 or a federal grand jury, to determine if the defendant
has complied with this final judgment.
VIII
Retention of Jurisdiction
Jurisdiction is retained by this Court for the purpose of: (1)
enabling any of the parties to this final judgment to apply to this
Court at any time for such further orders or directions as may be
necessary or appropriate for the construction or carrying out of this
final judgment, for the modification of any of the provisions hereof,
for the enforcement of compliance herewith, and for the punishment of
violations hereof; and (2) adjudicating the legality of any merger or
acquisition of assets or securities described in Section IV (K) above.
IX
Ten Year Expiration
This final judgment will expire on the tenth anniversary of its
date of entry.
X
Public Interest
Entry of this final judgment is in the public interest.
Dated:---------------------------------------------------------------
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United States District Judge
Competitive Impact Statement
Pursuant to Section 2 of the Antitrust Procedures and Penalties Act
(``APPA''), 15 U.S.C. Sec. 16(b), the United States files this
Competitive Impact Statement relating to the proposed final judgment as
to United States v. Ixtlera de Santa Catarina, S.A. de C.V. and MFC
Corporation, submitted for entry in this civil antitrust proceeding.
I
Nature and Purpose of the Proceedings
On September 26, 1996, the United States filed a civil antitrust
complaint alleging that under Section 4 of the Sherman Act, as amended,
15 U.S.C. Sec. 4, the above-named defendants combined and conspired
with others from at least as early as January 1990 to April 1995, to
lessen and eliminate competition in the sale of tampico fiber in the
United States, in violation of Section 1 of the Sherman Act, 15 U.S.C.
Sec. 1. A companion criminal information against Ixtlera de Santa
Catarina, S.A. de C.V. (``Ixtlera'') and MFC Corporation (``MFC'') was
filed on September 26, 1996. The civil complaint alleges that as part
of the conspiracy, the defendants and co-conspirators among other
things:
(a) Fixed the prices at which tampico fiber was imported into the
United States;
(b) Fixed the resale prices for tampico fiber charged by their
exclusive United States distributors; and
(c) Allocated sales between such distributors.
The complaint seeks a judgment by the Court declaring that the
defendants engaged in unlawful combinations and conspiracies in
restraint of trade in violation of the Sherman Act. It also seeks an
order by the Court to enjoin and restrain the defendants from any such
activities or other activities having a similar purpose or effect in
the future.
The United States and defendants have stipulated that the proposed
final judgment may be entered after compliance with the APPA, unless
the United States withdraws its consent.
The Court's entry of the proposed final judgment will terminate
this civil action against these defendants, except that the Court will
retain jurisdiction over the matter for possible further proceedings to
construe, modify or enforce the judgment, or to punish violations of
any of its provisions.
II
Description of the Practices Giving Rise to the Alleged Violations of
the Antitrust Laws
As defined in the complaint, tampico fiber is a natural vegetable
fiber produced by the lechuguilla plant and grown in the deserts of
northern Mexico. It is harvested by individual farmers, processed,
finished and exported worldwide, where it is used as brush filling
material for industrial and consumer brushes. It is available in
natural white, bleached white, black, gray and a wide variety of
mixtures.
The complaint further alleges that defendant MFC had United States
sales of tampico fiber of approximately $14,699,000 during the period
from January of 1990 through April of 1995. During this time, the
defendants sold and shipped substantial quantities of tampico fiber in
a continuous and uninterrupted flow of interstate commerce from the
processing facility of Ixtlera in Mexico through its exclusive United
States distributor, MFC, a company headquartered in Texas, to MFC's
customers throughout the United States, including those located in the
Eastern District of Pennsylvania. Similarly, the complaint alleges that
non-defendant co-conspirators sold and shipped additional substantial
quantities of tampico fiber in a continuous and uninterrupted flow of
interstate commerce from another processing facility in Mexico through
their exclusive United States distributor to customers throughout the
United States, including some located in the Eastern District of
Pennsylvania.
The complaint alleges that the defendants and co-conspirators
engaged in three forms of concerted action and states three causes of
action: (1) An agreement to fix import prices, (2) an agreement to fix
resale prices, and (3) an agreement to allocate sales. Essentially, the
complaint alleges that defendants and their co-conspirators fixed the
prices at which tampico fiber was sold to their two respective
exclusive United States distributors, agreed on the resale prices to be
charged by those two distributors and agreed to a percentage allocation
of sales volume between those distributors.
The defendants and their co-conspirators went far beyond suggesting
and adhering to suggested resale prices. Resale price sheets were
provided by Ixtlera and the co-conspirator processor to MFC and the co-
conspirator distributor. As a condition of becoming and remaining a
United States distributor of tampico fiber, the co-conspirator
distributor agreed by written contract with its supplier to sell at the
prices listed on the price sheet. From at least January 1990 on, both
MFC and the co-conspirator distributor had identical price sheets
supplied by Ixtlera and the co-conspirator processor, and the majority
of tampico fiber sales were made by those distributor at these list
prices or other agreed-upon prices. MFC made the sales with its two top
executives' knowledge of and participation in the collusive agreement
with their putative competitor.
The use of resale price maintenance by the defendants and co-
conspirators was designed to and had the effect of monitoring and
enforcing the horizontal
[[Page 52463]]
price-fixing and sales volume allocation agreements between the
defendants and co-conspirators. The defendants' conduct had the effect
of lessening or eliminating competition between the two United States
distributors of tampico fiber in order to maintain prices at
artificially high and non-competitive levels.
In furtherance of the conspiracy, the defendants and their co-
conspirators, among other things, periodically met, discussed and
agreed to new import and resale prices for tampico fiber, and met,
discussed and compared the annual sales volumes of their United States
distributors to ensure they were at or about the percentages the
defendants and co-conspirators had agreed upon for each.
III
Explanation of the Proposed Final Judgment
The United States and the defendants have stipulated that a final
judgment, in the form filed with the Court, may be entered by the Court
at any time after compliance with the APPA, 15 U.S.C. Sec. 16(b)-(h).
The proposed final judgment provides that the entry of the final
judgment does not constitute any evidence against or an admission by
any party with respect to any issue of fact or law. Under the
provisions of Section 2(e) of the APPA, entry of the proposed final
judgment is conditioned upon the Court finding that its entry will be
in the public interest.
The United States has filed a criminal information charging
Ixtlera, MFC and unnamed co-conspirators with a conspiracy to fix the
prices and allocate sales of tampico fiber imported into and sold in
the United States, in violation of the Sherman Act (15 U.S.C. Sec. 1).
The United States does not routinely file both civil and criminal
cases involving the same underlying conduct. It is appropriate to do so
in this case, however, because of the extent of the control of the
market by a small number of companies conspiring to eliminate price
competition in the sale of tampico fiber in the United States through a
comprehensive scheme of fixing the prices of imported tampico fiber,
allocating sales volumes between their exclusive distributors, and
agreeing upon the prices at which distributors would resell tampico
fiber within the United States.
The proposed final judgment contains three principal forms of
relief. First, the defendants are enjoined from repeating the conduct
they undertook in connection with the tampico fiber conspiracy and from
certain other conduct that could have similar anticompetitive effects.
Second, in light of their overwhelming shares of the tampico fiber
market in the United States and of evidence that they have previously
discussed consolidating operations, Ixtlera is prohibited from merging
with its co-conspirator processor, Fibras Saltillo, S.A. de C.V.,
without providing the Antitrust Division ninety (90) days notice. Such
a transaction, if consummated, would likely nullify the prophylactic
measures pertaining to horizontal conduct contained in both this
proposed final judgment and the final judgment entered by the Court
against Fibras Saltillo on August 20, 1996. Third, the proposed final
judgment places affirmative burdens on the defendants to pursue an
antitrust compliance program directed toward avoiding a repetition of
the tampico fiber conspiracy.
A. Prohibited Conduct
Section IV of the proposed final judgment broadly enjoins each
defendant from conspiring to fix prices, allocate sales, discourage or
eliminate new entrants, or otherwise restrict or eliminate the supply
of tampico fiber sold to any customer in the United States, (IV (A));
from communicating pricing, sales volume and customer information to
any processor, supplier or distributor of tampico fiber other than its
own (IV (B), (C) and (D)); from communicating regarding discouraging or
eliminating new entrants (IV (E)); from engaging in resale price
maintenance (IV (F)-(I)); and from joining any group whose aims or
activities are prohibited by Sections IV (A)-(I) of the proposed final
judgment (IV (J)). Finally, Ixtlera is enjoined from merging with,
acquiring the stock or assets of, or selling its stock or assets to
Fibras Saltillo, S.A. de C.V., a major processor of tampico fiber and a
co-conspirator, without providing the Antitrust Division ninety (90)
days notice.
Specifically, as regards tampico fiber sold in the United States,
Sections IV (A)-(E) of the proposed final judgment provide as follows:
Section IV (A) of the proposed final judgment enjoins each
defendant from agreeing with any other processor, supplier or
distributor of tampico fiber to (1) raise, fix, or maintain the prices
or other terms or conditions for the sale or supply of tampico fiber;
(2) allocate sales volumes, territories or customers for tampico fiber;
(3) discourage or eliminate any new entrant into the tampico fiber
market; or (4) restrict or eliminate the supply of tampico fiber to any
customer.
Section IV (B) of the proposed final judgment enjoins each
defendant from communicating with any processor, supplier or
distributor (other than its own processor, supplier or distributor) of
tampico fiber regarding any current or future price, price change,
discount, or other term or condition of sale charged or quoted or to be
charged or quoted to any customer or potential customer for tampico
fiber, whether communicated in the form of a specific price or in the
form of information from which such specific price may be computed.
Section IV (C) of the proposed final judgment enjoins each
defendant from distributing to any processor, supplier or distributor
(other than its own processor, supplier or distributor) of tampico
fiber price lists or other pricing material that is used, has been
used, or will be used in computing prices or terms or conditions of
sale charged or to be charged for tampico fiber.
Section IV (D) of the proposed final judgment enjoins each
defendant from communicating with any processor, supplier or
distributor (other than its own processor, supplier or distributor) of
tampico fiber regarding information pertaining to the volume of sales
of tampico fiber or the location or identity of customers.
Section IV (E) of the proposed final judgment enjoins each
defendant from communicating with any processor, supplier or
distributor regarding discouraging or eliminating any new entrant into
the tampico fiber market or restricting or eliminating the supply of
tampico fiber to any customer.
Section IV (F) of the proposed final judgment enjoins Ixtlera from
directly or indirectly entering into, adhering to, maintaining,
furthering, enforcing or claiming any right under any contract,
agreement, understanding, plan or program with any distributor to fix
or maintain the prices at which tampico fiber sold by Ixtlera may be
resold or offered for sale by any distributor.
Section IV (G) of the proposed final judgment enjoins Ixtlera from
directly or indirectly adopting, promulgating, suggesting, announcing
or establishing any resale pricing policy for tampico fiber.
Section IV (H) of the proposed final judgment enjoins Ixtlera from
threatening any distributor with termination or terminating any
distributor on the basis of that distributor's pricing; or discussing
with any present or potential distributor any decision regarding
termination of any other distributor for any reason directly or
indirectly related to the latter distributor's resale pricing,
provided, however, that nothing herein shall
[[Page 52464]]
prohibit Ixtlera from terminating a distributor for any reason other
than the distributor's resale pricing;
Section IV (I) of the proposed final judgment enjoins MFC from
directly or indirectly entering into, adhering to, maintaining,
furthering, enforcing or claiming any right under any contract,
agreement, understanding, plan or program with any supplier to fix or
maintain the prices at which tampico fiber may be resold or offered for
sale by MFC or any other distributor.
Section IV (J) of the proposed final judgment enjoins each
defendant from participating or engaging directly or indirectly through
any trade association, organization or other group in any activity
which is prohibited in IV (A)-(I).
Section IV (K) of the proposed final judgment enjoins Ixtlera from
merging with, acquiring all or part of the assets or securities of, or
selling all or part of its assets or securities to the Mexican tampico
fiber processor Fibras Saltillo, S.A. de C.V., or its owners, officers,
directors, agents, employees, subsidiaries, successors and assigns
without first providing plaintiff with at least ninety (90) days
written notice prior to closing the transaction. Such notification
shall include a complete description, in English, of the proposed
transaction and the reasons therefor. Ixtlera agrees to provide
promptly all information, with English translations, reasonably
requested by plaintiff in connection with its investigation of the
proposed transaction, consents to the jurisdiction of the Court to
adjudicate the legality of the proposed or consummated transaction
under the antitrust laws of the United States, and waives any
objections to venue. Nothing in this paragraph shall prohibit Miguel
Schwarz Marx, principal of Ixtlera, from divesting to any person,
without notice, the 27.5 percent interest in Fibras Saltillo, S.A. de
C.V. which he currently holds.
B. Permitted Conduct
Four exceptions to the broad prohibitions of Section IV of the
proposed final judgment are contained in Section V.
Section V (A) permits any necessary negotiations or communications
with any processor, supplier or distributor of tampico fiber or with
any agent, broker or representative of such processor, supplier or
distributor in connection with bona fide proposed or actual purchases
of tampico fiber from, or sale of tampico fiber to, that processor,
supplier or distributor.
Section V (B) makes it clear that nothing contained in the proposed
final judgment would prohibit MFC from unilaterally deciding to resell
tampico fiber at prices suggested by its supplier. However, any
instance of this must be reported and the reports must be retained in
MFC's files.
Section V (C) makes it clear that although Miguel Schwarz Marx, an
owner and officer of Ixtlera, is otherwise prohibited from discussing
with or obtaining information from Fibras Saltillo regarding Fibras
Saltillo's prices, volume, customers or marketing plans for tampico
fiber (IV (A)-(E)), as a 27.5 percent owner of Fibras Saltillo, he can
have limited access to historical pricing information of Fibras
Saltillo to A&L Mayer Associates, Inc. (Associates) or Associates
successor that serves as a conduit between Fibras Saltillo and its
United States distributor (currently Brush Fibers, Inc.), provided such
information is at least six months old and is used solely to protect
the value of Schwarz's investment in Fibras Saltillo under Mexican law.
Section V (D) makes it clear that nothing contained in the final
judgment would prevent (1) MFC from continuing to act as Ixtlera's
exclusive distributor for tampico fiber in the United States; (2) MFC
and Ixtlera from conducting negotiations regarding such an exclusive
distributorship; or (3) Ixtlera from deciding to appoint another
company as its exclusive distributor in the United States.
C. Defendants' Affirmative Obligations
Section VI requires that within thirty (30) days of entry of the
final judgment, the defendants adopt or pursue an affirmative
compliance program directed toward ensuring that their employees comply
with the antitrust laws. More specifically, the program must include
the designation of an Antitrust Compliance Officer responsible for
compliance with the final judgment and reporting any violations of its
terms. It further requires that each defendant furnish a copy of the
final judgment to each of its officers and directors and each of its
employees who is engaged in or has responsibility for or authority over
pricing of tampico fiber within sixty (60) days of the date of entry,
and to certify that it has distributed those copies and designated an
Antitrust Compliance Officer within seventy-five (75) days. Copies of
the final judgment also must be distributed to anyone who becomes such
an officer, director or employee within thirty (30) days of holding
that position and to all such individuals annually.
Furthermore, Section VI requires each defendant to brief each
officer, director and employee engaged in or having responsibility over
pricing of tampico fiber as to the defendant's policy regarding
compliance with the Sherman Act and with the final judgment, including
the advice that his or her violation of the final judgment could result
in a conviction for contempt of court and imprisonment, a fine or both
and that the defendant will make legal advice available to such persons
regarding compliance questions or problems. The defendants annually
must obtain (and maintain) certifications from each such person that
the aforementioned briefing, advice and a copy of the final judgment
were received and understood and that he or she is not aware of any
violation of the final judgment that has not been reported to the
Antitrust Compliance Officer. Finally, each defendant must submit to
the plaintiff an annual declaration as to the fact and manner of its
compliance with the final judgment.
Under Section VII of the final judgment, the Justice Department
will have access, upon reasonable notice, to the defendants' records
and personnel in order to determine defendants' compliance with the
judgment.
D. Scope of the Proposed Judgment
(1) Persons Bound by the Decree
The proposed judgment expressly provides in Section III that its
provisions apply to each of the defendants and each of their owners,
officers, directors, agents and employees, subsidiaries, successors and
assigns and to all other persons who receive actual notice of the terms
of judgment.
In addition, Section III of the judgment prohibits each of the
defendants from selling or transferring all or substantially all of its
stock or assets used in its tampico fiber business unless the acquiring
party files with the Court its consent to be bound by the provisions of
the judgment.
(2) Duration of the Judgment
Section IX provides that the judgment will expire on the tenth
anniversary of its entry.
E. Effect of the Proposed Judgment on Competition
The prohibition terms of Section IV of the final judgment are
designed to ensure that each defendant will act independently in
determining the prices, and terms and conditions at which it will sell
or offer to sell tampico fiber, and that there will be no
anticompetitive restraints (horizontal or vertical) in the tampico
fiber market. The affirmative obligations of Sections
[[Page 52465]]
VI and VII are designed to ensure that each corporate defendant's
employees are aware of their obligations under the decree in order to
avoid a repetition of the conspiracies in the tampico fiber industry
that led to this case and the companion criminal proceeding. Compliance
with the proposed judgment will deter price collusion, allocation of
sales, markets and customers, concerted activities in restricting new
entrants and customers, and resale price restraints by each of the
defendants with each other and with other tampico fiber processors and/
or distributors.
IV
Remedies Available to Potential Private Plaintiffs
After entry of the proposed final judgment, any potential private
plaintiff who might have been damaged by the alleged violation will
retain the same right to sue for monetary damages and any other legal
and equitable remedies which he or she may have had if the proposed
judgment had not been entered. The proposed judgment may not be used,
however, as prima facie evidence in private litigation, pursuant to
Section 5(a) of the Clayton Act, as amended, 15 U.S.C. Sec. 16(a).
V
Procedures Available for Modification of the Proposed Consent Judgment
The proposed final judgment is subject to a stipulation between the
government and the defendants which provides that the government may
withdraw its consent to the proposed judgment any time before the Court
has found that entry of the proposed judgment is in the public
interest. By its terms, the proposed judgment provides for the Court's
retention of jurisdiction of this action in order to permit any of the
parties to apply to the Court for such orders as may be necessary or
appropriate for the modification of the final judgment.
As provided by the APPA (15 U.S.C. Sec. 16), any person wishing to
comment upon the proposed judgment may, for a sixty-day (60) period
subsequent to the publishing of this document in the Federal Register,
submit written comments to the United States Department of Justice,
Antitrust Division, Attention: Robert E. Connolly, Chief, Middle
Atlantic Office, Suite 650 West, 7th and Walnut Streets, Philadelphia,
Pennsylvania 19106. Such comments and the government's response to them
will be filed with the Court and published in the Federal Register. The
government will evaluate all such comments to determine whether there
is any reason for it to withdraw its consent to the proposed judgment.
VI
Alternative to the Proposed Final Judgment
The alternative to the proposed final judgment considered by the
Antitrust Division was a full trial of the issues on the merits and on
relief. The Division considers the substantive language of the proposed
judgment to be of sufficient scope and effectiveness to make litigation
on the issues unnecessary, as the judgment provides appropriate and
fully effective relief against the violations alleged in the complaint.
VII
Determinative Materials and Documents
No materials or documents were considered determinative by the
United States in formulating the proposed Final Judgment. Therefore,
none are being filed pursuant to the APPA, 15 U.S.C. Sec. 16(b).
Dated:---------------------------------------------------------------
Joel I. Klein,
Acting Assistant Attorney General.
Rebecca P. Dick,
Deputy Director of Operations.
Robert E. Connolly,
Chief, Middle Atlantic Office.
Respectfully submitted,
Edward S. Panek,
Michelle A. Pionkowski,
Roger L. Currier,
Joseph Muoio,
Attorneys, Antitrust Division, U.S. Department of Justice, Middle
Atlantic Office, The Curtis Center, Suite 650W, 7th and Walnut Streets,
Philadelphia, PA 19106, Tel.: (215) 597-7401.
Certificate of Service
I, Edward S. Panek, an attorney with the United States Department
of Justice, Antitrust Division, hereby certify that on September 26,
1996, copies of the Complaint, Stipulation, Proposed Final Judgment and
Competitive Impact Statement were served, by mail, on counsel of record
as follows.
Counsel for Ixtlera de Santa Catarina, S.A. de C.V.:
Gordon B. Spivack, Esquire, Coudert Brothers, 1114 Avenue of the
Americas, New York, NY 10036-7703
Counsel for MFC Corporation:
Roxann E. Henry, Esquire, Howrey & Simon, 1299 Pennsylvania Avenue,
NW., Washington, DC 20004-2402
Edward S. Panek,
Attorney, Antitrust Division, U.S. Department of Justice, Middle
Atlantic Office, The Curtis Center, Suite 650W, 7th and Walnut Streets,
Philadelphia, PA 19106, Tel.: (215) 597-7401.
[FR Doc. 96-25336 Filed 10-4-96; 8:45 am]
BILLING CODE 4410-01-M