Eidemiller VS Arteva Specialties, LLC

continuing until present, upon information and belief, among the Defendants and their co-

conspirators with the purpose and effect of fixing prices, allocating market share, and committing

other unlawful practices designed to inflate the prices of polyester staple and products constituted

thereof sold indirectly to Plaintiff and other purchasers in California.

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Defendants’ conspiracy has involved illegal conduct by a cartel that has deliberately

targeted, and severely burdened, consumers in California. The conspiracy has existed at least during

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the period from 1993 to the present, and has affected millions of dollars of commerce for products

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10 commonly found in households and businesses in California. Upon information and belief, the

11 conspiracy has included communications and meetings in which Defendants agreed to eliminate

12 competition and fix the prices and allocate markets for polyester staple.

13 3. The charged combination, and conspiracy consisted, upon information and belief, of a

14 continuing agreement, understanding, and concert of action among Defendants and their co-

15 conspirators, the substantial terms of which were to fix, stabilize, and maintain prices, allocate

16 markets and customers, and to coordinate price increases for the sale of polyester staple in

17 California.

18 4. The acts in furtherance of the conspiracy by Defendants have included, upon

19 information and belief, the following wrongful conduct and horizontal agreements:

20 (a) participating in meetings and conversations in which Defendants and their co-

21 conspirators discussed and agreed to prices for polyester staple;

22 (b) __ participating in meetings and conversations in which Defendants and their co-

23 conspirators allocated markets and customers for polyester staple;

24 (c) participating in meetings and conversations in which defendants and their co-

25 conspirators discussed and agreed to refrain from engaging in competitive

26 bidding, or to submit complementary and non-competitive bids, for particular

27 contracts to supply polyester staple to various customers;