Merger Control

2017
Sixth Edition

Editors:
Nigel Parr & Ross Mackenzie

CONTENTS
Preface

Nigel Parr & Ross Mackenzie, Ashurst LLP

General chapter The economics of UK merger control: retrospect and prospect
Ben Forbes & Mat Hughes, AlixPartners UK LLPCountry chapters
Albania
Anisa Rrumbullaku, CR PARTNERS
Australia
Sharon Henrick & Wayne Leach, King & Wood Mallesons
Austria
Dr. Lukas Flener, Fellner Wratzfeld & Partner Rechtsanwälte GmbH
BrazilLeonardo Rocha e Silva & José Rubens Battazza Iasbech,
Pinheiro Neto Advogados
CanadaRandall J. Hofley, Micah Wood & Kevin H. MacDonald,
Blake, Cassels & Graydon LLP
Chile
Ignacio Larraín Jiménez, Álvaro Espinosa Vásquez &Pascale Fouillioux Puentes, Philippi Prietocarrizosa Ferrero DU & Uría
China
Ding Liang, DeHeng Law Offices
CyprusGeorge Middleton & Constantina Mitsingas, Chryssafinis and Polyviou LLC
European Union Peter Broadhurst, Koen Platteau & Tony Woodgate,
Simmons & Simmons LLP
Finland
Katri Joenpolvi, Leena Lindberg & Jarno Käkelä, Krogerus Attorneys Ltd
FrancePierre Zelenko & Rahel Wendebourg, Linklaters LLP
GermanyPeter Stauber & Rea Diamantatou, Noerr LLP
Hong Kong
Neil Carabine & James Wilkinson, King & Wood Mallesons
India
G.R. Bhatia, Abdullah Hussain & Kanika Chaudhary Nayar,
Luthra & Luthra Law Offices
IsraelDr. David E. Tadmor & Shai Bakal,
Tadmor & Co. Yuval Levy & Co., Attorneys-at-Law
Italy
Luciano Vasques, DDPV Studio Legale
Japan
Masahiro Nakatsukasa, Chuo Sogo Law Office, P.C.
Macedonia
Jasmina I. Jovanovik & Dragan Dameski,
Debarliev, Dameski & Kelesoska, Attorneys at Law
Malta
Ron Galea Cavallazzi & Lisa Abela, Camilleri Preziosi Advocates
Netherlands
Fanny-Marie Brisdet & Else Marije Meinders, BRISDETRomania
Silviu Stoica & Mihaela Ion, Popovici Nițu Stoica & Asociații
Singapore
Daren Shiau & Elsa Chen, Allen & Gledhill LLP
South Africa
Marianne Wagener and Candice Upfold,
Norton Rose Fulbright South Africa Inc.
SwedenPeter Forsberg & Haris Catovic, Hannes Snellman Attorneys Ltd
Switzerland
Franz Hoffet & Marcel Dietrich, Homburger
TurkeyGönenç Gürkaynak & Öznur İnanılır, ELIG, Attorneys-at-Law
UkraineIgor Svechkar, Alexey Pustovit & Oleksandr Voznyuk, Asters
United Kingdom Alan Davis & Angelique Bret, Pinsent Masons LLP,
Bojana Ignjatovic, RBB Economics
USA
Christopher A. Williams, Roisin E. Comerford & Paul S. Jin,
Wilson Sonsini Goodrich & Rosati PC

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JapanMasahiro Nakatsukasa
Chuo Sogo Law Office, P.C.
Overview of merger control activity during the last 12 months
The implementation of policies related to merger control falls under the jurisdiction of theJapan Fair Trade Commission (the “JFTC”), which was established pursuant to the 1947
Japanese Antimonopoly Act (the “AMA”), and consists of a chairperson, four commissioners,
and a staff of around 800. The AMA also introduced Japan’s first anti-competition rules,
including merger control provisions. The JFTC is an autonomous administrative body withbroad enforcement powers.
The Guidelines to Application of the Antimonopoly Act Concerning Review of Business
Combination (JFTC, May 31, 2004, updated most recently as of June 14, 2011) (the “Merger
Guidelines”) provide overall guidelines related to merger control. According to the latest
statistics published by the JFTC in June 2016, 295 notifications were made in FY 2015 (i.e.,
between April 1, 2015 and March 31, 2016) with a breakdown showing 222 notifications forshare acquisitions, 23 for mergers, 17 for company splits, six for joint share transfers, and 27
for business transfers. Of the 295 notifications, eight notifications were withdrawn before
the JFTC’s first-stage (Phase I) review was completed and 281 cases received clearance
in the first-stage review process (97.9% of all notifications). Six cases moved to the indepth second stage (Phase II) review. Four transactions were closed during the second-stage
review, including one in which merger clearance was conditioned on taking certain remedial
measures. No cease-and-desist order prohibiting a proposed transaction was issued. The
number of notifications was around 250 to 300 in these three years (2013 to 2015).
New developments in jurisdictional assessment or procedure
Abolition of former “Prior Consultation mechanism”
The JFTC announced that the Prior Consultation mechanism for M&A transactions would
be discontinued beginning July 2011. Prior to this announcement, M&A transactions
could be submitted to the JFTC on a voluntary consultation basis pursuant to the Prior
Consultation Guidelines, before submitting an official statutory filing of the contemplated
M&A transaction. As a general matter, the JFTC would render an “unofficial” opinion about
a contemplated transaction at this preliminary stage, which opinion could generally be relied
upon. In practice, the JFTC’s opinions in formal notification cases rarely deviated from its
early-stage opinions. As a result of this major shift in internal workings at the JFTC, the JFTC
would no longer make any determinations or provide guidance on substantive issues prior to
the filing of the official statutory notice. The official review would commence only after theofficial filing was made. The Prior Consultation mechanism was originally introduced so thatcompanies could learn the JFTC’s determination before the official proceedings would begin.
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However, in practice, the Prior Consultation was time-consuming, its procedures lengthy, andit was criticised for lack of transparency as the JFTC was not required to disclose its decisions.
Addressing these concerns, the JFTC abolished the Prior Consultation mechanism altogether.
Availability of “Consultations Prior to Notification” in regard to formalities
The JFTC is still open to voluntary “Consultations Prior to Notification” but only forinquiries on how to complete the notification form. For example, as the notification form
has a section in which the position of the notifying corporation in the domestic market must
be described, it can consult with the JFTC about its view of a particular field of trade before
submitting the notification.
In addition, the notifying company can submit with the JFTC, materials it believes necessary
for receiving appropriate explanations concerning the consultation prior to notification.
In this regard, the notifying company can also submit documents to demonstrate that theplanned transaction is not problematic under the AMA. In fact, the JFTC announced in its
second reviews that it had received opinion letters stating that the proposed transaction was
unlikely to significantly restrain competition and other documents related to the proposedtransaction from the notifying party before receiving the notification, and disclosed thatit had meetings with the notifying party before the notification was made. This indicatesthat the JFTC still thinks it is important to communicate with the notifying party before theofficial proceeding begins.
Although the former Prior Consultation mechanism was abolished, it is still very important
for a company in a complex case to provide sufficient information to the JFTC before filing
an official notification to facilitate the procedure and get a feeling for how the JFTC views
the transaction.
First stage review – Phase I (Primary Review)
The AMA provides for a 30-day waiting period after a party submits the notification form
to the JFTC (“waiting period”), during which the contemplated transaction may not be
consummated. During this time, the JFTC will normally either: (1) determine that thegiven business combination is not problematic in light of the AMA; or (2) determine that amore detailed review is necessary and request submission of necessary reports, informationor materials. This will move the case to the in-depth review of the second stage (Phase
II). The first stage review undertaken from the date of receipt of the notification until
the day preceding the date of either of the above-mentioned determinations is referred
to as the “primary review”. Normally, there is an ongoing discussion between the JFTC
and the notifying party, which tends to expedite the JFTC’s review and often results inearly clearance of the contemplated transaction, thereby avoiding requests for additional
information and extended review periods. This ongoing discussion can include briefings on
substantive issues by notifying parties or even interviews by the JFTC of interested parties,
such as customers and competitors. The Merger Guidelines permit the JFTC to shorten the
30-day waiting period in cases where it is clear that the contemplated transaction is unlikely
to significantly restrain competition in the relevant market. The notifying party may also
make a written request with the JFTC for an expedited disposition.
Second stage review – Phase II (Extended Review)
The second stage (Phase II) begins when the JFTC requests the notifying party to submit
necessary reports, information or materials (“request for reports”) and continues for a 90-day
period following receipt of all requested reports and information (or 120 days following thedate of receipt of the notification, whichever date is later). Once the second stage begins, the
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JFTC will make a public announcement to that effect and gather opinions from third parties
regarding the proposed transaction.
Most cases that move to the second stage have two common characteristics: (1) the notifying
party has participated in the “Consultations Prior to Notification”; and (2) it usually took
several months for the requested reports and information to be submitted by the notifying
party (thus the second-stage 90-day period did not start until after all those documents were
submitted to the JFTC). This would indicate that: the notifying parties involved in complex
transactions that moved to the second stage engaged in significant ongoing discussion with the
JFTC using the preliminary consultation mechanism – “Consultations Prior to Notification” –even though, technically speaking, this mechanism is for consultation in regard to formalitiesof the notification; furthermore, the notifying parties also used the period between the endof first stage and the official beginning of the second-stage review to adjust the timing ofsubmission of all the requested reports.
Outline of the review procedure
The outline of the JFT’s review procedure is as follows:

Source: abstracted from “Policies Concerning Procedures of Review of Business Combination”(Japan Fair Trade Commission June 14, 2011)

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Sanctions for improper or insufficient notices
Although rarely used, the AMA gives the JFTC the discretion to impose a criminal fineof up to two million Japanese yen for failure of a party to comply with legal requirements
for notice of a proposed merger. In practice, the JFTC will request the notifying party toprovide a letter explaining the reasons for deficiencies in the notice rather than imposing
the fine immediately.
Minority shareholders’ reporting requirements
Under the Merger Guidelines, only the transaction that will form a “joint relationship” will
be reviewed. Thus, potential lack of a “joint relationship” works as a safe harbour for thenecessity of merger review.
Under the Merger Guidelines, a joint relationship will be deemed established:(i) When the ratio of the total number of voting rights pertaining to shares held bycompanies that belong to the group of combined companies to which the shareholding
company belongs to all of the voting rights of the share issuing company exceeds50%.
(ii) When the ratio of the total number of voting rights pertaining to shares held bycompanies that belong to the group of combined companies to which the shareholding
company belongs to all of the voting rights of the share issuing company exceeds 20%
and the said ratio ranked as top by itself.
(iii) If the ratio of voting rights held (the ratio of the voting rights pertaining to shares heldby the shareholding company to all the voting rights of the share issuing company) is
more than 10% and the shareholding company is ranked among the top three holdersof voting rights, the following items will be taken into consideration to determine
whether a joint relationship is formed, maintained or strengthened:(a) the extent of the ratio of voting rights held;(b) the rank as a holder of voting rights, differences in and distribution of the ratios ofvoting rights held among the holders, and other relationships between holders;(c) cross-holding of voting rights (the share-issuing company concurrently holds
voting rights of the shareholding company) and other mutual relationships
between the companies involved;(d) whether officers or employees of one of the parties are officers of the other parties;(e) trading relationship between the parties (including financial relationship);(f) relationships between the parties based on business alliances, technical assistance,and other agreements; and(g) items (a) through (f), when including companies that already have joint
relationships with the parties.
In a case announced in 2015, in which Oji Holding’s purchase of Chuetsu Pulp & Paper
Co., Ltd.’s shares, which would have resulted in Oji Holding’s holding of 20.9% voting
rights in Chuetsu Pulp & Paper Co., the JFTC cleared the proposed transaction in thesecond-stage review on condition that, among other things, one party keep its business
operations independent of the other party. In that case, Oji Holding’s ratio of voting rights
ranked at the top.
That case indicates that the JFTC is certainly concerned about minority shareholdings even
if they slightly exceed 20% of voting rights.
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Public access to JFTC filings and challenge to mergers
As a general rule, the public does not have any right to access merger notification
filings. Pursuant to the Policy for Merger Review, the JFTC discloses brief summaries
of notification filings of proposed mergers only if the review moves to the second
stage (Phase II). Thus, third parties are not aware of proposed transactions until suchdisclosures. Otherwise, if a transaction received merger clearance in the first stage
review (Phase I), third parties could learn about it only from the notifying party’s
disclosure.
Once the case moves into the second stage, and the JFTC gathers information fromthird parties for opinions and comments in regard to the proposed transaction, third
parties may submit challenges to the merger with the JFTC by submitting opinions
that the proposed transaction would result in a significant restraint of competition ina particular field of trade. However, the AMA does not give third parties any express
right to intervene. Otherwise, anyone could notify the JFTC of possible violations of the
AMA with respect to the notifying party’s breach of notifying requirements.
Key industry sectors reviewed and approach adopted to define market, barriers
to entry, nature of international competition, etc.
Key industry sectors reviewed
The JFTC does not officially target any particular industry sector for enforcement andcompliance. Indeed, the 10 publicly announced cases in 2016 involved businesses suchas manufacturers, web service providers, banks and insurance companies.
Revisions of Merger Guidelines in 2011
Under the amendment of the Merger Guidelines in July 2011, the JFTC also slightly
revised its standards of review by announcing that it would review transactions fromthe perspective of: (i) clearer market definition if the market’s geographical scopecrosses borders; (ii) competitive pressure when market demands are continuously andstructurally shrinking; and (iii) more flexible consideration of competitive pressure fromoverseas imports and entry.
Cross-border market definition
The Merger Guidelines state that if users of a certain product, both inside and outside
Japan, are conducting business without segregating domestic and foreign suppliers, even
if the prices have been raised in Japan, users in Japan will be able to substitute those
products with products from overseas suppliers, which may result in lowering of prices
in Japan. In such a case, the geographical scope has been determined across the border.
For example, in the cases announced in 2016 involving the merger of Intel Corporation
and Altera Corporation and the merger of Denali Holdings Inc. and EMC Corporation,
the JFTC defined the relevant market as being worldwide.
Competitive pressure under the Shrinking Market Condition
The Merger Guidelines state that the presence of competitive pressure from customers
deriving from the fact that the quantity of the product demanded is continuously andstructurally falling well under the quantity supplied as a result of a decrease in demand
for the product, may possibly work as a factor to prevent the company group fromfreely exerting an influence on the price of the product to some extent. Thus, the JFTC
may take into consideration the shrinking market condition as one of the factors which
prevents the transaction from restraining competition.
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Imports and entry from overseas
The Merger Guidelines state that in the presence of sufficient competitive pressure fromimports, the possibility that business combinations will substantially restrain competition
in a particular field of trade is usually small. If users can easily switch from a product of
the company group to an imported product and the switchover becomes more likely if thecompany group raises the price of the product, the company group would be unlikely toraise the price on the grounds of a potential loss of sales due to the imported goods. The
Merger Guidelines also point out that even if importation is currently not being conducted,
the JFTC may consider a potential increase in imports over a period of around two years. In
the past, competitive pressure from imports and entry from overseas were rarely considered
unless already present. The change in the JFTC’s perspective to consider future competitive
pressure from overseas is likely to result in more practical determination of competitive
pressures in the market.
In the case of a subsidiary of Mars, Inc.’s acquisition of P&G Japan’s pet foods business(announced in 2015), the JFTC considered future competitive pressure from overseas in thepet foods market.
Key economic appraisal techniques applied, e.g. as regards unilateral effects andcoordinated effects, and the assessment of vertical and conglomerate mergers
Consistent with the growing trend by the JFTC of aggressively using economic analyses
in review of merger transactions, the JFTC has increased the number of economists amongstaff who analyse economic data provided by notifying parties and third parties. The JFTC
may also initiate its own economic analysis in complex cases in the second-stage review.
In the case of acquisition of shares of C&H Co., Ltd. (“C&H”) by Daiken Corporation(“Daiken”) (announced in 2013), in order to define the product range, the JFTC used
questionnaire surveys with users and competitors, asking whether users would switch toother products if the product prices increased by around 10%. And the JFTC took thoseanswers into consideration. The use of economic appraisal techniques in retail business isalso quite likely as POS (point of sales) data would be comparatively available.
In the case of merger of UNY Holdings Corporation (“UNY”) and FamilyMart Corporation(“FamilyMart”) (announced in 2016), both of which are categorised as convenience
stores, the JFTC also used questionnaire surveys with the consumer public in which itquestioned how many times consumers use convenience stores depending on the numberof the competitive conveniences located within 500 metres or 1 kilometre. Then, the JFTC
used the GUPPI (Gross Upward Pricing Pressure Index) to determine whether the parties’
convenience stores would have incentives to raise prices.
Approach to remedies (i) to avoid second stage investigation and (ii) following
second stage investigation
Timing of remedy proposal
In the first-stage (Phase I) review period, the notifying party generally has broad latitude
to offer its own remedies, which may be accepted by the JFTC as a means of avoiding an
extended second-stage review. After the commencement of a second stage, the notifying
party enjoys the same right to propose remedies. In the original notification file, thenotifying party will include a report of change and any remedies agreed to by the notifying
party and the JFTC.
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Early-stage acceptance of remedies offers the strategic advantage of avoiding a secondstage investigation. For transactions involving coordination of notification and review ofdeadlines in multiple jurisdictions, legal practitioners should bear in mind that the initial
review period and the second-stage review period may not be extended even if remedies arestill under discussion. The JFTC has no discretion to extend the deadlines. Accordingly, as
noted above, using the preliminary consultation and taking advantage of the period between
the end of the first stage and the submission of all the requested reports, ongoing discussion
with the JFTC is critical to avoid running-out-of-time situations.
Regulation of conduct
In addition to the final approvals that are subject to structural remedies, the JFTC also
has the latitude to condition a merger by imposing certain conduct between the partiesor requiring taking certain actions, including incorporating these obligations in a written
contract between the parties to the merger transaction. In the case of merger between
Zimmer, Inc. and Biomet, Inc. (announced in 2015), the JFTC approved the transaction
by accepting the condition proposed by the parties of: (i) transferring tangible assets andintellectual property rights of the leading brands in which they had 50% and 20% of themarket share in particular fields; (ii) reporting after executing the transfer agreements withthe third party and acquiring approval of the JFTC; and (iii) agreeing that an independent
third party transfers such assets and intellectual property rights referred to above to a third
party upon the JFTC’s approval in the event that the transfer agreements are not executed
within a certain period. The JFTC’s approval of ASML US Inc.’s acquisition of Cymer Inc.
(announced in 2013), is a case in point where ASML’s proposed remedy of imposing mutual
non-disclosure obligations on certain confidential information was adopted. These cases
illustrate one common remedy that regulates behaviour between the parties. The use of
independent monitoring tests to measure compliance with remedies is yet another exampleof the increasing acceptance of conduct-based remedies. In fact, the JFTC accepted thisvery concept, as proposed by the notifying party in the ASML/Cymer merger.
Warning on gun-jumping
The parties may be subject to the criminal penalty of fines and/or the JFTC’s cease-anddesist orders if the merger contemplated in the notification filing is closed during the 30-day
waiting period, or the 90-day period if it moves to the second stage. In most cases, thetiming of the contemplation of the transaction would be clear to see, but in some cases there
would be a grey zone regarding whether the transaction is contemplated or not.
The most noteworthy case in 2016 was the acquisition by Canon Inc. (“Canon”) of sharesof Toshiba Medical Systems Corporation (“TMSC”). In that case, before submitting thenotification to the JFTC, Canon acquired options in respect of common shares of TMSC
and, as consideration, Canon paid Toshiba Corporation (Toshiba) an amount equal to thevalue of the underlying common shares; furthermore, a third party other than Canon andToshiba came to own voting shares of TMSC prior to Canon’s exercise of the options. Even
though the JFTC cleared the proposed transaction, it stated that “[T]his series of actions
is likely to give rise to the formation of a certain joint relationship between Canon and
TMSC through the above-mentioned third party, comprising part of a structure premised on
Canon ultimately acquiring the voting shares of TMSC subject to approval being obtainedin the business combination review under the AMA. Given that this series of actions had
been undertaken before Canon made a notification to the JFTC, they are likely to lead toactivities that could violate the provisions of Article 10(2) of the AMA by undermining theintent behind the prior notification system.”
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Accordingly, the JFTC cautioned Canon not to conduct such actions in the future and also
urged Toshiba, who engaged in the implementation of the above structure, not to engage inthe future in activities that might be inconsistent with the purport of the prior notification
system.
The JFTC also warned prospective companies planning a business combination involving asimilar structure in the future to file a notification with the JFTC prior to implementing any
part of such a structure.
Therefore, in cases where a planned transaction consists of several phases that could beconstrued as implementation of the transaction, it would advisable to consult with the JFTC
using a preliminary consultation mechanism before actually taking the first step.
In addition, in the case of mergers between competitors, as the competition will continue
until the merger closes, the parties should be very careful about the exchange of information
while conducting due diligence. The parties should minimise the exchange of informationand limit persons who are aware of the information to non-sales and marketing divisions.
Penalties for failure to implement remedies
The AMA does not expressly authorise the JFTC to monitor compliance by the notifying
party with the agreed remedies; nor does the AMA grant the JFTC the right to proactively
provide instructions or guidance to the notifying party on how to implement approved
remedies. The only real leverage that the JFTC has is the right to penalise the parties forbreaches of the accepted remedies contained in the original notification, if the failure causes
a substantial restraint of competition in any of the relevant markets.
Key policy developments
Cooperation between the JFTC and foreign competition authorities
Cooperation between the JFTC and antitrust agencies in other countries has been on the risein recent years, reflecting not only the increasing harmonisation of antitrust schemes but
also Japan’s integral role in international markets. In 2016 alone, the JFTC became a party
to bilateral cooperation agreements with antitrust agencies in Canada, the United States andthe European Union. Japan also signed a memorandum of understanding with the Chinese
Ministry of Commerce in April 2016 concerning antitrust cooperation. These protocols
provide a general framework for information exchanges and ongoing discussion between
the participating parties. In addition to these bilateral agreements, the AMA also provides
a legal basis for the JFTC to exchange information with authorities in other jurisdictions,subject to certain conditions, and where applicable, waivers by notifying parties.
As JFTC’s coordination of merger control work with foreign authorities is becoming
more frequent and detailed, coordination of work among Japanese and foreign attorneys
representing notifying parties is gaining importance. Moreover, to support the JFTC’s
coordination of work with foreign competition authorities, discussions between attorneys
should be encouraged. Recent examples where the JFTC launched a joint investigation andengaged in information exchanges with foreign antitrust authorities (such as the US FTCand the European Commission) include the following cases announced in 2016: Intel/Altera
case; NXP Semiconductors/Freescale Semiconductor case; and Denali Holdings Inc./EMC
Corporation case.
Regulation on foreign-to-foreign mergers
The January 2010 AMA amendment requiring notification to the JFTC with respect toforeign-to-foreign mergers (i.e., mergers between two or more entities with no corporate
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presence in Japan) that meet the substantial domestic turnover requirement is evidence of
the JFTC’s continuing aggressive stance vis-à-vis international mergers with a potential
anti-competitive effect on the Japanese domestic market.
Recent reform
The AMA amendment bill passed in December 2013 and, effective as from April 2015,
basically aims to abolish the former administrative hearing procedure exercised by the
JFTC and replace it with a judicial appeal process. The outline of the bill is as follows:
1. Abolition of the JFTC’s hearing procedure for administrative appeals.
2. Introduction of a system in which any appeals pertaining to cease-and-desist orders are
subject to the exclusive jurisdiction of the Tokyo District Court, and a panel comprising
three or five judges of the Tokyo District Court will hear the cases, with a view toensuring expertise of the court.
3. With a view to ensuring due process, development of procedures for a hearing prior toissuing a cease-and-desist order:• providing the expected recipient of the order with an explanation of the content of
the order;• providing an opportunity for the expected recipient to present opinions and/or
submit evidence; and• stipulating the inspection of and/or opportunity to copy evidence relied on by theJFTC.

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Masahiro Nakatsukasa
Tel: +81 6 6365 8111/ Email: nakatsukasa_m@clo.gr.jp
Masahiro Nakatsukasa is a bilingual international attorney admitted in Japan
and New York, with more than 24 years’ experience representing Japaneseand foreign clients in a wide variety of transactions and litigations. He is
well-known as one of the leading counsels in the areas of cross-border M&A
and financial transactions in the Kansai area in Japan (comprised of Osaka,
Kobe, and Kyoto). Mr. Nakatsukasa was selected for inclusion in the 5th to 8theditions of Best Lawyers in Japan in Banking and Finance Law (2014, 2015,2016, and 2017) and Insolvency and Reorganization Law (2017). He served
as a Vice-President of the Osaka Bar Association from 2015 to 2016. Mr.
Nakatsukasa received an LL.B. from Kyoto University in 1994 and an LL.M.
from the Northwestern University School of Law in 2005.

Chuo Sogo Law Office, P.C.
Kohda Bldg. 11th Floor, 2-10-2 Nishi-Tenma, Kita-ku, Osaka 530-0047, Japan
Telephone: +81 6 6365 8111 / Fax: +81 6 6365 8289 / URL: www.clo.jp
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