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)

IN THE UNITED STATES DISTRICT COURT
FOR THE SOUTHERN DISTRICT OF NEW YORK
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)
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Plaintiff,
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v.
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APPLE, INC.,
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HACHETTE BOOK GROUP, INC.,
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HARPERCOLLINS PUBLISHERS L.L.C.,
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VERLAGSGRUPPE GEORG VON
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HOLTZBRINCK GMBH,
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HOLTZBRINCK PUBLISHERS, LLC
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d/b/a MACMILLAN
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THE PENGUIN GROUP,
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A DIVISION OF PEARSON PLC, )
PENGUIN GROUP (USA) PLC, and
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SIMON & SCHUSTER, INC.
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Defendants.
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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.

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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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants Hachette Book
Group, Inc.

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