Stipulated Notice of Related Case in a Criminal Action

Pursuant to Crim. L. R. 8-1, the United States and Akzo Nobel Chemicals International B.V. ("Akzo Nobel") jointly file this Stipulated Notice of Related Case in a Criminal Action, and request that the criminal case, United States v. Akzo Nobel Chemicals International B.V., CR 06-0160 JSW, assigned to Judge Jeffrey S. White, be related to United States v. Solvay S.A., CR 06-0159 MMC, a previously filed criminal case assigned to Judge Maxine M. Chesney.

On March 14, 2006, the United States filed an Information in United States v. Solvay S.A., charging Solvay with participating in price-fixing conspiracies in both the hydrogen peroxide and sodium perborates industries. Also on March 14, 2006, the United States filed an Information in United States v. Akzo Nobel Chemicals International B.V., charging Akzo Nobel with participating in the same hydrogen peroxide price-fixing conspiracy charged in United States v. Solvay S.A., CR 06-0159 MMC. Both criminal antitrust cases involve the same defendants and allege the same events and occurrences with respect to the hydrogen peroxide industry. The assignment of Case CR 06-0160 JSW to Judge Chesney (to whom Case CR 06-0159 MMC has already been assigned) is likely to conserve judicial resources and promote an efficient determination of the action.