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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
The United States of America, acting through its attorneys, charges:I
DESCRIPTION OF THE OFFENSE
1. Dead Sea Bromine Company, Ltd. ("Dead Sea"), a corporation organized and existing under the laws of the State of Israel, is made a defendant on the charge stated below.
2. Beginning in July, 1995 and continuing until April, 1998, the exact dates being unknown to the United States, the defendant and co-conspirators entered into and participated in a combination and conspiracy to suppress and eliminate competition by allocating customers and fixing the price for TBBA, DECA and 100% methyl bromide sold in the United States. The combination and conspiracy engaged in by the defendant and co-conspirators was in unreasonable restraint of interstate commerce in violation of Section 1 of the Sherman Act (15 U.S.C. § 1).
3. The charged combination and conspiracy:
4. For the purpose of forming and carrying out the charged combination and conspiracy, the defendant and co-conspirators did those things that they combined and conspired to do including, among other things:
5. As used in this Information, the term:
DEFENDANT AND CO-CONSPIRATORS
6. During the relevant period, Dead Sea was a corporation organized and existing under the laws of the State of Israel, with its principal place of business in Beer Sheva, Israel. Dead Sea manufactures TBBA, DECA and 100% methyl bromide in Israel and is engaged in the sale of TBBA, DECA and 100% methyl bromide throughout the United States.
7. Various corporations and individuals not made defendants herein participated as co-conspirators in the offense charged herein and performed acts and made statements in furtherance thereof.
8. Wherever in this Information reference is made to any act, deed, or transaction of a corporation, the allegation means that the corporation engaged in the 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.IV
TRADE AND COMMERCE
9. During the period covered by this Information, the defendant and co-conspirators sold and distributed substantial quantities of TBBA, DECA and 100% methyl bromide in a continuous and uninterrupted flow of interstate commerce.
10. During the period covered by this Information, the activities of the defendant and co-conspirators that are the subject of this Information were within the flow of, and substantially affected, interstate commerce.V
JURISDICTION AND VENUE
11. The combination and conspiracy charged in this Information was carried out, in part, within the Northern District of Texas within the five years preceding the filing of this Information.
ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.