UNITED STATES OF AMERICA v. THOMSON CORPORATION et al

Filing 15

MOTION for Entry of Final Judgment by UNITED STATES OF AMERICA (Attachments: # 1 [proposed] Final Judgment, # 2 Certificate of Compliance with the Tunney Act)(Mahnke, Robert) Modified on 9/15/2008 (jeb, ).

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA UNITED STATES OF AMERICA, Plaintiff, v. THE THOMSON CORPORATION, and REUTERS GROUP PLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO.: 1:08-cv-00262 Assigned To: Hogan, Thomas F. Assign. Date: 02/19/2008 Description: Antitrust

CERTIFICATE OF COMPLIANCE WITH PROVISIONS OF THE ANTITRUST PROCEDURES AND PENALTIES ACT Plaintiff, United States of America, by its undersigned attorney, hereby certifies that, in compliance with the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16(b)-(h), the following procedures have been followed in preparation for the entry of the Final Judgment in the abovecaptioned matter: 1. Plaintiff and defendants, The Thomson Corporation ("Thomson") and Reuters

Group PLC ("Reuters") stipulated to the entry of the proposed Final Judgment in an Asset Preservation Stipulation and Order filed with the Court on February 19, 2008. 2. The proposed Final Judgment was filed with the Court on February 19, 2008.

(Two schedules to the proposed Final Judgment, originally filed under seal, have been revised to reflect current information. The revised version, filed under seal herewith, is otherwise identical to the version filed on February 19.) 3. The Competitive Impact Statement was filed with the Court on February 19,

2008. 4. Pursuant to 15 U.S.C. § 16(b), the proposed Final Judgment (with certain

information filed under seal redacted) and Competitive Impact Statement were published in the Federal Register on March 21, 2008. United States v. The Thomson Corporation, 73 Fed. Reg. 15196. A copy of the Federal Register notice is attached hereto as Exhibit 1. 5. Pursuant to 15 U.S.C. § 16(b), copies of the Asset Preservation Stipulation and

Order, proposed Final Judgment (with certain information filed under seal redacted), and Competitive Impact Statement were furnished to all persons requesting them and were made available on the Antitrust Division's Internet site. 6. Pursuant to 15 U.S.C. § 16(c), a summary of the terms of the proposed Final

Judgment was published in The Washington Post, a newspaper of general circulation in the District of Columbia, for seven days beginning March 28, 2008, and ending April 3, 2008. A copy of the Proof of Publication from The Washington Post is attached hereto as Exhibit 2. 7. The sixty-day comment period prescribed by 15 U.S.C. § 16(b) and (d) for the

receipt and consideration of written comments, during which the proposed Final Judgment could not be entered, ended on May 20, 2008. 8. 9. The United States did not receive any comments on the proposed Final Judgment. On May 27, 2008, Thomson and Reuters filed a description of written or oral

communications by or on behalf of the defendants, or any other person, with any officer or employee of the United States concerning the proposed Final Judgment, as required by 15 U.S.C. § 16(g). 10. The parties have satisfied all of the requirements of the Antitrust Procedures and

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Penalties Act, 15 U.S.C. § 16(b)-(h), as a condition for entering the proposed Final Judgment. Pursuant to the Asset Preservation Order and Stipulation entered by the Court on January 24, 2008, and 15 U.S.C. §16(e), this Court may enter the Final Judgment, if it determines that the entry of the Final Judgment is in the public interest. 11. Plaintiff's Motion for Entry of the Final Judgment and its Competitive Impact

Statement demonstrate that the proposed Final Judgement satisfies the public interest standard of 15 U.S.C. §16(e). 12. For these reasons, plaintiff requests that this Court enter the Final Judgment

without further proceeding.

Respectfully submitted, FOR PLAINTIFF UNITED STATES OF AMERICA:

/s/ Robert P. Mahnke Robert P. Mahnke United States Department of Justice Antitrust Division, Networks and Technology Enforcement Section 600 E. Street, NW, Suite 9500 Washington, D.C. 20530 [phone] Dated: May 29, 2008

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