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FREDERICK A. BLACK
United States Attorney
JOSEPH F. WILSON
Assistant U.S. Attorney
RICHARD B. COHEN
MATTHEW D. SEGAL
Trial Attorneys
Suite 500, Sirena Plaza
108 Hernan Cortez Ave.
Hagta, Guam 96910
TEL: (671) 472-7332
FAX: (671) 472-7334

Attorneys for the United States




Filed July 14, 2000
          Underseal

Made Public January 31, 2001

IN THE UNITED STATES DISTRICT COURT

FOR THE TERRITORY OF GUAM



UNITED STATES OF AMERICA  

                                    v.


YOUNG SOO YOON,  

                                    Defendant.

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CRIMINAL CASE NO. 00-00092

INFORMATION

CONSPIRACY TO RESTRAIN TRADE

[15 U.S.C. § 3][18 U.S.C. § 2]


INFORMATION

The United States of America, acting through its attorneys, charges:

DESCRIPTION OF THE OFFENSE

1. YOUNG SOO YOON is made a defendant on the charge stated below.

2. Beginning as early as December 17, 1997 and continuing at least until

May 26, 1998, the exact dates being unknown to the United States, the defendant and others entered into and engaged in a combination and conspiracy, and the defendant knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused conspirators to enter into and engage in such combination and conspiracy, to suppress and restrain competition for contracts with the Territorial Government of Guam's Department of Parks and Recreation ("DPR") to repair facilities located on Guam damaged by Typhoon Paka ("Typhoon Damage Repair Contracts"), in unreasonable restraint of territorial trade and commerce, in violation of the Sherman Act, Title 15, United States Code, Section 3 and Title 18, United States Code, Section 2.

DEFENDANT, CO-CONSPIRATORS, AND THOSE THE

DEFENDANT AIDED AND ABETTED

3. During the period covered by this Information, YOUNG SOO YOON was a resident of the Territory of Guam and a citizen of the United States of America.

4. In committing the offense charged in this Information, the defendant also acted through various individuals and corporations, not made defendants in this Information, with whom the defendant conspired and whom the defendant knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused to perform acts and make statements in furtherance of the conspiracy charged in this Information.

5. Various individuals and corporations, not made defendants in this Information, participated as co-conspirators in the conspiracy charged and performed acts and made statements in furtherance of it.

THE CONSPIRACY

6. The charged combination and conspiracy consisted of an agreement, understanding, and concert of action among the conspirators, knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused by the defendant, the substantial terms of which were to rig price quotations offered for, and to allocate, Typhoon Damage Repair Contracts.

7. For the common purpose of forming and carrying out the charged combination and conspiracy, the defendant conspired to, and knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused his co-conspirators to, among other things:

  1. discuss price quotations on upcoming Typhoon Damage Repair Contracts;
  2. agree on the price quotations they would submit on Typhoon Damage Repair Contracts;
  3. submit artificially high, non-competitive amounts in their price quotations offered for Typhoon Damage Repair Contracts; and
  4. perform work required by the Typhoon Damage Repair Contracts at artificially high, non-competitive prices and receive compensation therefor.

COMMERCE

8. During the period covered by this Information, the activity that was the object of the conspiracy was within the flow of, and substantially affected, commerce in the Territory of Guam, between the Territory of Guam and the State of California, and between the Territory of Guam and the Country of Australia.

JURISDICTION AND VENUE

8. The combination and conspiracy charged in this Information was formed and carried out, in part, within the District of Guam, within five years preceding the filing of this Information.

ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 3, AND TITLE 18, UNITED STATES CODE, SECTION 2.

Dated:

_______________"/s/"________________
Joel I. Klein
Assistant Attorney General

_______________"/s/"________________
James M. Griffin
Deputy Assistant Attorney General

_______________"/s/"________________
Scott D. Hammond
Director of Criminal Enforcement

Antitrust Division
U.S. Dpeartment of Justice






_______________"/s/"________________
Frederick A. Black
United States Attorney
District of Guam

_______________"/s/"________________
Christopher S Crook
Chief, San Francisco Field Office

_______________"/s/"________________
Richard B. Cohen
Trial Attorney

_______________"/s/"________________
Matthew D. Segal
Trial Attorney

Antitrust Division
U.S. Department of Justice
450 Golden Gate Avenue
Box 36046, Room 10-0101
San Francisco, California 94102
Telephone: (415) 436-6660