UNITED STATES DISTRICT COURT
The United States of America, acting through its attorneys, charges:
DESCRIPTION OF THE OFFENSE
1. CHANG SUK CHUNG ("defendant") is made a defendant on the charge stated below.
2. From on or about September 21, 2001, until on or about June 1, 2006, the defendant's corporate employer, LG Display Co., Ltd. (formerly LG.Philips LCD Co., Ltd.) ("LG"), and coconspirators entered into and engaged in a combination and conspiracy in the United States and elsewhere to suppress and eliminate competition by fixing the prices of thin-film transistor liquid crystal display panels ("TFT-LCD"). The combination and conspiracy engaged in by the defendant's corporate employer and coconspirators was an unreasonable restraint of interstate and foreign trade and commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1). The defendant knowingly joined and participated in the charged conspiracy from on or about September 21, 2001, until on or about June 1, 2006.
3. The charged combination and conspiracy consisted of a continuing agreement, understanding, and concert of action among the defendant, his corporate employer, and coconspirators, the substantial terms of which were to agree to fix the prices of TFT-LCD.
4. For the purpose of forming and carrying out the charged combination and conspiracy, the defendant, his corporate employer, and coconspirators did those things that they combined and conspired to do, including, among other things:
DEFENDANT AND COCONSPIRATORS
5. LG, the defendant's corporate employer, is a corporation organized and existing under the laws of the Republic of Korea ("Korea"). During the period covered by the Information, LG.Philips LCD Co., Ltd. a joint venture between LG Electronics and Phillips Electronics, and a corporation organized and existing under the laws of Korea, engaged in the business of producing and selling TFT-LCD to customers in the United States and elsewhere. Effective March 4, 2008, LG Phillips LCD Co., Ltd., changed its name to LG Display Co., Ltd.
6. CHANG SUK CHUNG held various sales and marketing positions, including Vice President of Monitor Sales for LG during the period covered by the Information.
7. Various corporations and individuals, not made defendants in this Information, participated as coconspirators in the offense charged in this Information and performed acts and made statements in furtherance of it.
8. Whenever in this Information reference is made to any act, deed, or transaction of any corporation, the allegation means that the corporation engaged in the act, deed, or transaction by or through its officers, directors, employees, agents, or other representatives while they were actively engaged in the management, direction, control, or transaction of its business or affairs.
9. TFT-LCD are glass panels composed of an array of tiny pixels that are electronically manipulated in order to display images. TFT-LCD are manufactured in a broad range of sizes and specifications for use in televisions, notebook computers, desktop monitors, mobile devices, and other applications.
10. During the period covered by this Information, the defendant, his corporate employer, and coconspirators sold and distributed TFT-LCD in a continuous and uninterrupted flow of interstate and foreign trade and commerce to customers located in states or countries other than the states or countries in which the defendant, his corporate employer, and coconspirators produced TFT-LCD.
11. The business activities of the defendant, his corporate employer, and coconspirators that are the subject of this Information were within the flow of, and substantially affected, interstate and foreign trade and commerce.
JURISDICTION AND VENUE
12. The combination and conspiracy charged in this Information was carried out, in part, in the Northern District of California, within the five years preceding the filing of this Information.
ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.