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

Filing 19

NOTICE of Defendant Simon & Schuster Inc.'s Description and Certification of Written or Oral Communications Concerning the Proposed Final Judgment in this Action. Document filed by Simon & Schuster, Inc.. (Attachments: # 1 Certificate of Service)(Scullion, Jennifer)

UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NKW YORK

UNITED STATES OF AMERICA,
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), INC. , and
SIMON X SCHUSTER, INC. ,
Defendants.

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Civil No. I:12-CV-2826 (DLC)

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DEFENDANT SIMON A SCHUSTER INC. 'S DESCRIPTION AND
CERTIFICATION OF WRITTEN OR ORAL COMMUNICATIONS
CONCERNING THE PROPOSED FINAL JUDGMENT IN THIS ACTION
Pursuant to Section 2(g)

of the

Antitrust Procedures and Penalties Act, 15 U. S.C.

)16(g), Defendant Simon k, Schuster Inc. ("Defendant" ), by its attorneys,
following description and certification

of all

submits the

written and oral communications

by, or on

behalf of, Defendant with any officer or employee of the United States concerning or
relevant to the Proposed Final Judgment filed in this action on April 11, 2012. In

accordance with Section 2(g), the description excludes any communications
counsel

of record alone

Justice alone. "

with the Attorney General or the employees

"made by

of the Department of

I.

Description
Defendant has no oral or written communications

to report, except to note that

of the Proposed Final

from roughly March 1, 2012 through the filing

Judgment,

counsel

of record for Simon & Schuster and HarperCollins Publishers L.L.C had several
meetings and teleconferences

with officers or employees

of the United States Department

of Justice. Counsel of record for Hachette Book Group, Inc. , as well as employees of the
Attorneys General for Texas and Connecticut and
attended certain

II.

of the European Commission may have

of these meetings or teleconferences.

Certification
Defendant certifies that the requirements

with, and that the description above

known to Defendant, or

of Section 2(g) have been complied

of communications

by or on behalf

of Defendant,

of which Defendant reasonably should have known,

and which

are required to be reported under Section 2(g), is true and complete.

Respectfully submitted,
qy'Z

Helene D. Jaffe
Jennifer R. Scullion
Proskauer Rose LLP
11 Times Square
New York, NY 10036

212.969.3000
Martha E. Gifford
Law Office of Martha E. Gifford
137 Montague Street 4220
Brooklyn, NY 11201

718.858.7571
James Quinn
Yehudah Buchweitz
Weil, Gotshal &. Manges LLP
767 Fifth Avenue
New York, NY 10153

212.310.8000