Unites States of America v. Apple, Inc. et al

Filing 26

NOTICE of Certification of Defendant Hachette Book Group Pursuant to 15 U.S.C. Section 16(g). Document filed by Hachette Book Group, Inc.. (Stuart, Walter)

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IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF NEW YORK ) ) ) Plaintiff, ) ) v. ) ) APPLE, INC., ) HACHETTE BOOK GROUP, INC., ) HARPERCOLLINS PUBLISHERS L.L.C., ) VERLAGSGRUPPE GEORG VON ) HOLTZBRINCK GMBH, ) HOLTZBRINCK PUBLISHERS, LLC ) d/b/a MACMILLAN ) THE PENGUIN GROUP, ) A DIVISION OF PEARSON PLC, ) PENGUIN GROUP (USA) PLC, and ) SIMON & SCHUSTER, INC. ) ) Defendants. ) ) UNITED STATES OF AMERICA, Case No.: 12-CV-2826 Judge: Denise L. Cote CERTIFICATION OF DEFENDANT HACHETTE BOOK GROUP, INC. PURSUANT TO 15 U.S.C. §16(g) Pursuant to 15 U.S.C. § 16(g), defendant Hachette Book Group, Inc. (“Hachette”) states that no written or oral communications occurred by, or on behalf of, Hachette with an officer or employee of the United States concerning, or relevant to, the Proposed Final Judgment, other than communications made by counsel of record alone with employees of the Department of Justice, except as follows. From roughly March 1, 2012 through the filing of the Proposed Final Judgment, counsel of record for Hachette engaged in numerous communications with officers or employees of the United States Department of Justice. Some of those communications between counsel of record and the United States Department of Justice also included counsel of record for HarperCollins Publishers LLC and/or Simon and Schuster, Inc. -1- Defendant certifies that, with this submission, it has complied with the requirements of 15 U.S.C. §16(g), and that this submission is a true and complete description of communications known to defendant or that defendant reasonably should have known that are required to be reported pursuant to that provision. April 20, 2012 Respectfully submitted, /s/ Walter B. Stuart Walter B. Stuart Samuel J. Rubin FRESHFIELDS BRUCKHAUS DERINGER US LLP 601 Lexington Avenue New York, New York 10022 Telephone: (212) 277-4000 Facsimile: (212) 277-4001 walter.stuart@freshfields.com samuel.rubin@freshfields.com Attorneys for Defendants Hachette Book Group, Inc. -2-