UNITED STATES DISTRICT COURT
The United States of America, acting through its attorneys, charges:
1. Mark Morrow Stamps, Inc. and Mark Morrow are hereby made defendants on the charge stated below.
I. DESCRIPTION OF THE OFFENSE
2. Beginning at least in the early 1980s and continuing until at least June 1997, the exact dates being unknown to the United States, the defendants and co-conspirators engaged in a combination and conspiracy in unreasonable restraint of interstate and foreign trade and commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1).
3. The aforesaid combination and conspiracy consisted of a continuing agreement, understanding, and concert of action among the defendants and co-conspirators, the substantial terms of which were to rig bids for the purchase of stamps at auctions in the United States and elsewhere.
4. For the purpose of forming and effectuating the aforesaid combination and conspiracy, the defendants and co-conspirators did those things which they combined and conspired to do, including, among other things:
II. DEFENDANTS AND CO-CONSPIRATORS
5. Mark Morrow Stamps, Inc. is incorporated and is located in Denver, Colorado. During the period covered by this Information, Mark Morrow Stamps, Inc. was engaged in the purchase of stamps for resale.
6. During the period covered by this Information, Mark Morrow was President of Mark Morrow Stamps, Inc., and was responsible for determining the price to be bid for stamps purchased at auction by Mark Morrow Stamps, Inc.
7. Whenever in this Information reference is made to any act, deed, or transaction of any corporation, such allegation shall be deemed to mean that the corporation engaged in such act, deed, or transaction by or through its officers, directors, agents, employees, or representatives while they were actively engaged in the management, direction, control, or transaction of its business or affairs.
8. Various persons and companies, not made defendants herein, participated as co-conspirators in the offense charged herein and performed acts and made statements in furtherance thereof.
III. INTERSTATE AND FOREIGN TRADE AND COMMERCE
9. Stamps are often sold at auctions at which the highest bid price determines who will purchase the stamps. Stamp auctions take place periodically throughout the year at various locations in the United States, including in New York City, and elsewhere.
10. During the period covered by this Information, stamps of substantial value were bid for at public auctions at which the defendants and co-conspirators rigged the prices bid.
11. During the period covered by this Information, the activities of the defendant and co-conspirators with respect to the sale of stamps at public auctions were within the flow of, and substantially affected, interstate and foreign trade and commerce.
IV. JURISDICTION AND VENUE
12. The aforesaid combination and conspiracy was carried out, in part, within the Southern District of New York within the five years preceding the filing of this Information.
IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.