Skip to main content

Exhibit 6

This document is available in two formats: this web page (for browsing content) and PDF (comparable to original document formatting). To view the PDF you will need Acrobat Reader, which may be downloaded from the Adobe site. For an official signed copy, please contact the Antitrust Documents Group.

Exhibit 6











U.S. Department of Justice Seal
U.S. DEPARTMENT OF JUSTICE

Antitrust Division

   City Center Building
1401 H Street, NW
Washington, DC 20530

May 5,2003



Mr. Neil F. Keehn
2603 Third Street
Santa Monica, CA 90405
Re:     Comment on Proposed Final Judgment in United States v. Northrop Grumman
Corporation and TRW Inc., No. 1:02CV02432, filed December 11, 2002

Dear Mr. Keehn:

This letter responds to your January 7, 2003 letter, commenting on the proposed Final Judgment submitted for entry in the captioned case. The government's Complaint in the case charged that the proposed acquisition of TRW Inc. ("TRW") by Northrop Grumman Corp. ("Northrop") would combine one of the only two suppliers of radar and EO/IR payloads for reconnaissance satellite systems sold to the U.S. Government (Northrop) with one of the few companies able to act as prime contractor on U.S. reconnaissance satellite programs that use these payloads (TRW). The Complaint alleges that as a result of this combination, Northrop would have the incentive and ability to lessen competition by favoring its own payload and/or prime contractor capabilities to the detriment or foreclosure of competitors, and would harm the U.S. Government by posing an immediate danger to competition in two current or future programs, the Space-Based Radar and Space Based InfraRed System-Low programs (the latter program is now called the Space Tracking and Surveillance System).

Your letter relates exclusively to matters that are not in any way directly related to either the acquisition of TRW by Northrop or the proposed relief. Specifically, you claim that there have been unfair allegations that you were involved in illegal activities during a past employment by TRW. Your letter includes proposed modifications to the Final Judgment, which also relate specifically to your personal claims and not to the subject acquisition or efforts to remedy any competitive problems that it may cause.

The purpose of the proposed Final Judgment, and the Complaint on which it is based, is to address the potential lessening of competition that may result from the acquisition of TRW by Northrop. The Final Judgment cannot serve as a vehicle for addressing totally unrelated issues. For this reason, the United States cannot adopt the proposed modifications you have requested.

Pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C. § 16(d), a copy of your comment and this response will be published in the Federal Register and filed with the Court. However, we will not publish or file the extensive materials that you included with your comment, which do not relate to the issues of this lawsuit.

Sincerely yours,

_______________/s/________________
J. Robert Kramer II
Chief
Litigation II Section


NEIL F. KEEHN
2603 THIRD STREET n SANTA MONICA, CA 90405
(310) 396-0622  n neilkeehn@yahoo.com

January 7,2003

J. Robert Kramer II
Antitrust Division
1401 H Street, NW. Suite 3000
Washington, D.C. 20530
 
RE:     Proposed Addenda to Northrop
Grumman Consent Decree

Dear Mr. Kramer,

This correspondence is for the purpose of submitting proposed addenda, which are included as Exhibit A, to the above referenced consent decree.

In July 2002, I sent a package to Secretary of Defense Rumsfeld as well as to Attorney General Ashcroft. The package sent to Attorney General Ashcroft, received by DoJ on 7/18 via certified mail, is included herein as Exhibit B, and addresses allegations that the former TRW illegally sold a satellite reconnaissance system to the People's Republic of China in which I was allegedly the program manager. The Department of Defense addressed this issue in a competent and professional manner. As a part of its response, DoD informed me that I was perfectly correct in bring this issue to the attention of the Department of Justice. However, I have never received a response of any kind from the DoJ, and several attempts to speak to someone at DoJ about the status of my inquiry resulted in my calls being transferred to the mailroom. Finally, I asked to speak with Attorney General Ashcroft's correspondence secretary. I twice left her a detailed message as per her voice mail instruction. Said voice mail promised to return my call, but I never received any call from anyone at the DoJ.

As a result of my on-going efforts to clear my name as well as to learn as much as possible about the alleged use of my name in what people high in the intelligence community have labeled as treason, I wish to submit the addenda in Exhibit A. If the consent decree's Compliance Officer finds evidence of the aforereferenced sale to the PRC and my name is found in any documentation associated with that sale, I want to be so informed. I also understand that the names of several other people who had nothing to do with this alleged transaction were also included in the program's documentation. Further information is included in my sworn declaration in Exhibit B.

I hope that you will take seriously my proposed addenda to the consent decree, and that, as a result, I might begin to find justice in a system that to date has proven to be anything but just.

Respectfully submitted,

Neil F. Keehn


PROPOSED ADDENDA TO THE FINAL JUDGMENT

IV.J.Northrop shall not in any way have contact with any government (other than the U.S. Government), company, organization, individual nor any other type of entity for the purpose of selling reconnaissance satellite systems, in whole or in part, without the explicit, written permission of the Secretary of Defense.
V.G.If, in the course of his duties, the Compliance Officer finds evidence that the former TRW sold, provided, donated or in any manner was involved in the transfer of reconnaissance satellite systems, in whole or in part, at any time in its history, to any government (other than the U S. Government), company, organization or individual, he shall provide notice of such evidence to the Secretary of Defense within ten (10) business days.
(1)If the Secretary of Defense finds that such a program was likely to have been the result of an illegal transfer, the Compliance Officer shall:
(a)prepare a list of all names found to be associated with any such sale;
(b)notify all individuals whose names appear on this list that their names have been found associated with a program that may have been illegal;
(c)provide these individuals the opportunity to review the nature of their alleged involvement in the program(s) in which their names were found in program documentation, memos, etc. that are associated with the program.
V.H.If, in the course of his duties, the Compliance Officer finds evidence that any documentation of any kind of any transactions by the former TRW that conforms to the types of transactions identified in Section V.G., has been destroyed, he shall notify the Secretary of Defense of said discovery within ten (10) business days.
Updated August 14, 2015