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Antitrust Case Filings

United States
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 & Schuster, Inc.

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Appeal Materials

Final Brief for Plaintiffs-Appellees United States and Plaintiff-States (September 18, 2014)

Final Form Joint Brief for Plaintiffs-Appellees United States and Plaintiff-States (July 15, 2014)

Opposition of Plaintiffs-Appellees to Apple's Emergency Motion for a Stay Pending Appeal (January 24, 2014)

Remedy Documents

Second Report of the Extenal Compliance Monitor (Non-Confidential) (October 15, 2014)

Report of the External Compliance Monitor (April 14, 2014)

Declaration of Michael R. Bromwich (with Exhibits) (December 30, 2013)

Plaintiff's Memorandum of Law in Opposition to Apple Inc.'s Motion to Show Cause for a Stay of the Injunction Pending Appeal (December 30, 2013)

Final Judgment (September 5, 2013)

Memorandum in Support of Plaintiffs' Revised Proposed Injunction (August 23, 2013)

Letter Brief Regarding Publisher Defendants' Remedy Submission (August 8, 2013)

Plaintiffs' Memorandum of Law in Support of Proposed Injunction (August 2, 2013)

Trial Materials

Opinion & Order (July 10, 2013)

Trial Exhibits

Direct Testimony

United States Closing Argument Presentation (June 20, 2013)

United States Opening Statement Presentation (June 3, 2013)

Pretrial Submissions

Plaintiffs' Reply Memorandum in Support of Their Motion in Limine to Preclude Dr. Michelle Burtis from Offering at Trial Any Opinion on Competitive Effects (Submitted: May 8, 2013 | Filed: May 14, 2013)

Plaintiffs' Reply Memorandum in Support of Their Motion in Limine to Preclude Dr. Kevin Murphy from Offering at Trial Testimony on His Opinions #1-#3 (Submitted: May 8, 2013 | Filed: May 14, 2013)

United States' Opposition to Apple Inc.'s Motion in Limine to Exclude Certain Expert Testimony of Professor Richard Gilbert (Submitted: May 3, 2013 | Filed: May 14, 2013)

Plaintiffs' Opposition to Defendants' Motion in Limine to Exclude Certain Anticipated Testimony Regarding the "Appropriateness" of Communications (Submitted: May 3, 2013 | Filed: May 14, 2013)

Plaintiffs' Response to Apple's Pretrial Memorandum of Law (Submitted: May 3, 2013 | Filed: May 14, 2013)

Plaintiffs' Motion in Limine to Preclude Dr. Michelle Burtis from Offering at Trial Any Opinion on Competitive Effects (Submitted: April 26, 2013 | Filed: May 14, 2013)

Plaintiffs' Motion in Limine to Preclude Dr. Kevin Murphy from Offering at Trial Testimony on His Opinions #1-#3 (Submitted: April 26, 2013 | Filed: May 14, 2013)

Plaintiffs' Proposed Findings of Fact and Conclusions of Law (Cover Sheet)

Plaintiffs' Pretrial Memorandum of Law (Submitted: April 26, 2013 | Filed: May 14, 2013)

[Proposed] Joint Pretrial Order (Submitted: April 26, 2013 | Filed: May 14, 2013)


Macmillan Settlement Documents

Final Judgment (August 12, 2013)

Order (August 12, 2013)

Memorandum in Support of Motion by the United States for Entry of the Proposed Macmillan Final Judgment (June 12, 2013)

Notice of Motion by the United States for Entry of the Proposed Macmillan Final Judgment (June 12, 2013)

Response by Plaintiff United States to Public Comments on the Proposed Final Judgment as to the Macmillian Defendants (May 24, 2013)

Public Comments on the Proposed Final Judgment as to the Macmillian Defendants (May 24, 2013)

Competitive Impact Statement (February 8, 2013)

Stipulation (February 8, 2013)


Penguin Settlement Documents

Final Judgment As To Defendants The Penguin Group, A Division Of Pearson PLC, And Penguin Group (USA), Inc. (May 17, 2013)

Memorandum in Support of Motion by the United States for Entry of the Proposed Penguin Final Judgment (April 18, 2013)

Notice of Motion by the United States for Entry of the Proposed Penguin Final Judgment (April 18, 2013)

Response by Plaintiff United States to Public Comments on the Proposed Final Judgment as to the Penguin Defendants (April 5, 2013)

Public Comments on the Proposed Final Judgment as to the Penguin Defendants (April 5, 2013)

Letter to J. Cote Requesting Leave for Electronic Publication of Tunney Comments (April 1, 2013)

Competitive Impact Statement (December 18, 2012)

[Proposed] Final Judgment as to Defendants the Penguin Group, a Division of Pearson PLC, and Penguin Group (USA), Inc. (December 18, 2012)

Stipulation (December 18, 2012)


Hachette, HarperCollins, and Simon & Schuster Settlement Documents

Reply of the United States in Support of Motion to Dismiss Appeal (December 3, 2012)

Motion of the United States to Dismiss Appeal (November 13, 2012)

Opposition of the United States to Motion by Bob Kohn for Leave to Intervene (September 17, 2012)

Final Judgment as to Defendants Hachette, HarperCollins, and Simon & Schuster (September 6, 2012)

Opinion and Order (September 6, 2012)

Supplemental Reply Memorandum in Support of the United States' Motion for Entry of Final Judgment (September 5, 2012)

Declaration of Karry Lu in Support of the United States' Motion for Entry of Final Judgment (August 22, 2012)

Reply Memorandum in Support of the United States' Motion for Entry of Final Judgment (August 22, 2012)

Memorandum in Support of the United States' Motion for Entry of Final Judgment (August 3, 2012)

Declaration of Stephanie A. Fleming in Support of Motion for Entry of Final Judgment (August 3, 2012)

Certificate of Compliance with Provisions of the Antitrust Procedures and Penalties Act (August 3, 2012)

[Proposed] Final Judgment as to Defendants Hachette, Harpercollins, and Simon & Schuster (August 3, 2012)

Plaintiff United States of America's Notice of Motion for Entry of Final Judgment (August 3, 2012)

Response of Plaintiff United States to Public Comments on the Proposed Final Judgment (July 23, 2012)

Public Comments on the Proposed Final Judgment (July 23, 2012)

Tunney Act Comments Electronic Posting (June 11, 2012)

Competitive Impact Statement (April 11, 2012)

[Proposed] Final Judgment as to Defendants Hachette, HarperCollins, and Simon & Schuster (April 11, 2012)

Stipulation (April 11, 2012)

Plaintiff United States' Explanation of Consent Decree Procedures (April 11, 2012)


Discovery and Case Management Documents

United States' Letter Regarding Illinois Brick (October 16, 2012)

Order Denying Apple's Motion to Compel (September 14, 2012)

United States' Letter in Opposition to Apple's Discovery Request (September 14, 2012)

Joint Initial Report - Revised July 6, 2012 (July 6, 2012)

Stipulated Protective Order (May 9, 2012)

Complaint (April 11, 2012)


NOTICE: In the matter of U.S. v. Apple, Inc., et al., the U.S. Department of Justice invited public comment regarding settlement of defendants Hachette Book Group, Inc., HarperCollins Publishers L.L.C., and Simon & Schuster, Inc. (see Federal Register notice at http://www.gpo.gov/fdsys/pkg/FR-2012-04-24/pdf/2012-9831.pdf), defendants the Penguin Group, a Division of Pearson PLC, Penguin Group (USA), Inc. (see Federal Register notice at http://www.gpo.gov/fdsys/pkg/FR-2012-12-31/pdf/2012-31339.pdf), and defendants Verlagsgruppe Georg Von Holtzbrink GmbH and Holtzbrink Publishers, LLC d/b/a Macmillan (see Federal Register notice at http://www.gpo.gov/fdsys/pkg/FR-2013-02-25/pdf/2013-04234.pdf.) Pursuant to 15 U.S.C. § 16, comments and responses thereto will be filed with the court and may be published in the Federal Register and/or on the U.S. Department of Justice Internet website.

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