ORIGINAL
 

UNITED STATES OF AMERICA 

BEFORE THE FEDERA TRADE COMMISSION 

In the Matter of ) 

) Docket No. 9327 

Polypore International, Inc. 

a corporation 

) 

) 

) PUBLIC DOCUMENT 

) 

MOTION TO RESCHEDULE HEARING DATE 

Pursuant to Rule 4.3(b) of the Rules of Practice of the Federal Trade Commission, 16 

C.F.R. § 4.3 
 (b), Polypore International, Inc. ("Polypore") moves that the hearng on the 

Complaint fied in this matter be rescheduled to begi on May 18, 2009. The Complaint states 

that the heanng on the Complaint wil begin on "December 9, 2008, or such other. date as 

determined by the ALl" Beging a hearing in this matter on December 9, 2008, only 
 eightyfour (84) days after service of the Complaint, is manfestly unai and unjust, would matenally 

prejudice Polypore and depnve Polypore of a reasonable opportity to prepare its defense to 

this complex matter. For the reasons set forth below, Polypore requests that the hearng on this 

matter be set to commence on May 18, 2009: 

A. Matters Preceding the Issuance of the Complaint
 

1. The matter grows out of Polyp ore's purchase of the stock of Micro porous Holding

Corporation ("Microporous") in a transaction that closed on Februar 29,2008. FTC staff first 

contacted Polypore regarding this matter in March 2008. 

2. Throughout the investigative penod and the responses to the civil investigative 

demand (CID), Polypore has worked cooperatively with FTC staf to provide requested 

inormation, includig the followig: 

. Polypore provided over one milion pages of documents to the FTC.
 
. Polypore provided answers and supporting exhbits to interrogatories propounded
 

by the FTC. 

. Polypore produced five witnesses for investigational hearings, with some hearngs
 

tang multiple days to complete.
 

. Durng the course. of the investigation, Polypore executives traveled to Washigton no less than five (5) times for varous meetings with FTC staff and 

with Commissioners. 

. Polypore answered numerous inquiries though correspondence and exchanges
 

with FTC staff. 

3. Durng the course of its six and one-half month investigatlon, FTC staf 

conducted other investigational heargs and inquiries of thrd pares about which Polypore has 

no information at all: neither the transcripts of any hearings, copies of any documents or 

affdavìts, nor information about the inquiries made. Polypore believes FTC staf has obtaied 

i Complait
 affidavits and documents from third paries about which it has no information. 


Counsel has indicated that they may identify ten (10) witnesses in their disclosures. At the 

earliest, disclosures will not be made unti mid-October, less than sixty (60) days before the 

December 9, 2008 hearng, providing insuffcient time for Polypore to review the disclosed 

materials or pursue independent discovery from the entities who provided materials to the FTC. 

B. The Issuance of 
 the Complaint

4. On September 9, 2008, the Commission issued the Complaint against Polypore.
 

The Complait was served on Polypore on September 15,.2008. The Complait, purorting to 

assert thee claims against Poiypore under Section 7 of the Clayton Act and Section 5 of the FTC 

Act, is striking for its lack of clarty, its vagueness and absence of necessar allegatiòns. Such 

infirmties will cause Polypore signficant work 
 and time to be able to respond to the Complaint,

IIn Complaint Counsel's Response to Respondent's Motion to Extend Respondent's Time to Respond to Complaint
 

(the "Respnse to Motion to Extend"), Complaint Counsel has stted its opposition to any delay in the hearing, arguing, in par 

that "the case is not complex." Having had the advantage of over six months of investigation in this matter, and craing its 

complaint to ignore, among other things, the global nature of the separator market, it is disingenuous, at best, for Complaint 

Counsel to object to Polyp ore being provided suffcient opportnity to gather evidence to assert its defense. 

2 
assert its defenses, conduct discovery and otherse prepare to defend itself at the Hearg in this 

matter. Due to many serious deficiencies in the Complaint, Polypore moved the Cour on 

September 25, 2008 for a more definite statement or clarification of the allegations in Counts II 

and II of the Cnmplaint. Complaint Counsel has opposed that motion, yet failed to address in 

any meaningful way in its opposition the points raised by Polypore in its motion for more 

definite statement or clarfication. See Complaint Counsel's Response to Respondent's Motion 

for a More Definite Statement ("Response to Motion for More Definite Statement"). Among 

other things, Complait Counsel fails to address at all the serious issue raised by Polypore in its 

motion with respect to the pleading standard Complaint Counsel asserts it must meet for its 

Section 5 FTC Act claims and fails to state whether it proposes to present its monopolization and 

attempt to monopolize claims under Section 5 of the FTC Act without satisfying the standards 

required by Section 2 of the Sherman Act. Complait Counsel also glosses over the deficiencies 

of its pleadng related to its failure to allege monopolies in the supposed UPS, automotive and 

PE separator markets by simply characterizing the allegations of the Complaint, which do not 

say what Complaint Counsel suggests (compare Polypre's Motion, pp. 4-5 with the Response to 

Motion for More Definite Statement, p. 1), and by even referrg to some unpecified 

conversations with Polypore's prior counsel (Id. at 2). Polypore's motion for more definite 

statement or clarification is pending with the Cour. 

S. The Complaint, and its multiple vague and deficient allegations, manfest that the 

case the FTC intends to bring against Polypore is complex. It is evident that the FTC's 

allegations have broadened substatially beyond the merger concerns which were the heavy and 

exclusive focus of the discussions between Polypore and the Commissioners leading up to the 

filing of the Complaint. Indeed, the Complaint stands as an unexpected depare from the 

Commission's prior approach to this matter. 

3 
6. Dung the multiple meetings between Polypore and the FTC, there were 

numerous and repeated indications that FTC staff was limting its inqui and investigation. On
 

the day the Complaint was voted out, Polypore's CEO was again in Washigton to meet with 

two different Commssioners to answer questions and fuer explain why this small merger
 

(which does not even trgger pre-merger notification requirements under the Hart-Scott-Rodino 

Antitrst Improvements Act of 1976) neither violates Section 7 of the Clayton Act nor hars any 

consumers. Not once during the meetings on September 9 was anything said to indicate that a 

complaint would be voted out that very afernoon by the FTC, let alone, that the complaint would 

include vague allegations purortedly grounded in Section 5 of the FTC Act and set a hearng 

date only ninety (90) days later. Accordingly, the abrupt change in the Commission's approach 

to ths matter, by itself, requires an extension of time. This case canot be ready for an effcient, 

effective hearing on December 9,2008. 

C. Polypore's Preparation of its Defens 

7. On September 10,2008, the undersigned and his firm (collectively "Parker Poe") 

were retaed as tral counsel to represent Polypore with respect to the Complaint in these Par 3 

proceedings. To ths point, Parker Poe has had only very limited 
 involvement in responding to 

the FTC investigation. While Parker Poe is workig dilgently to gain command of the facts and 

circumstances that the FTC has worked on for six months, it wil obviously tae it some tie to
 

reach this level, let alone move 
 beyond that to conduct adequate discovery and prepare for the

hearng. In its Response to Motion to Extend, Complaint Counsel has seriously overstated
 

Parker Poe's prior involvement in this matter. In the investigative process, Hogan & Harson 

was primary counsel. Parker Poe acted only in narowly defined roles to provide very limited 

assistance to Polypore and Hogan & Harson. ParkerPoe was not involved in the development 

.. 

of positions in response to the FTC inquiry, or in the strategy and tactics of responding to FTC 

4
 
sta. It was not involved in any investigational heargs and its narow involvement ended in
 

early June. Parker Poe did not collect. review or produce Polypore's documents. It only 

forwarded to Hogan & Harson cerain plead,ings, trancripts and exhbits and from a preexisting unelated arbitration. Complait Counsel in his Response to Motion to Extend is in 

error in asserting otherwse. A redacted copy of the May 1, 2008, letter referenced by Complaint 

Counsel is attched as Exhibit A to confi Parker Poe's limited role and to ilustrate the extent 

of Complaint Counsel's misrepresentation. Parker Poe also assisted Polypore and Hogan & 

Harson in responding to eight interrogatories dealing with sales, product-specific information, 

development and changes, and certain information concernng Microporous, by gathering basic 

factu information for those interrogatories. 

8. Polypore would like to bring ths matter to hearg as soon as practical. Given the
 

seriousness of the allegations in the Complaint, however, Polypore does not believe that it can 

present its defenses fairly and effectively without the requested extension. As evidence of 

Polypre's intent to tr to move this matter forward expeditiously, Parker Poe initiated, and came 

to Washington for, an introductory, informal meeting with Complaint Counsel on September 16, 

2008. Furher, Polypore has moved the Cour to schedule the initial scheduling conference in 

this matter for October 22 or 23, 2008 irrespective of the Cour's decision on the motion for 

more definite statement. Polypore's counsel has also reviewed, revised and on September 25, 

provided to Complaint Counsel a proposed Protective Order which would govern the use of 

confdential information from the paries and thrd pares in ths matter. Complaint Counsel has 

not yet provided any comment on polypore's revised draf of the Protective Order. 

9. Without the requested additional time to prepare its defenses and to conduct vita 

discovery, Polypore will not be aforded the fudamental right of any litigant: to develop its 

defenses fairly and fully and to present those defenses effectively and efficiently at a hearng. 

5 
The work will take some time, but is critical and wil take considerable effort even with the 

proposed extension. At present, the tasks to prepare for tral include, but may not be limited to: 

(a) Identification of the necessar witnesses for tral. At this time, Polypore has
 

its offcers and employees who may have relevant information and are 

likely witnesses. Five of them already have been the subject of investigational heargs. 

Substantial work will need to be accomplished to determine the actual witnesses and the scope of 

identified fourteen (14) of 


their testimony. Assuredly, several of them will have to be defended at depositions taen by 

Complaint Counsel. 

(b) Documents have to be reviewed. At ths point, 1.1 milion documents have been 

turned over to the FTC. These documents have not been reviewed by Parker Poe and must be 

thoroughy reviewed. Complait Counsel has indicated that the FTC may seek more discovery 

from Polypore. Polypore believes that the FTC has obtained additional documents from thrd 

paries which presumably will be tued over to Polypore in discovery. The quantity of these 

documents is not known, yet they, too, wil have to be reviewed in order to prepare effectively 

for trial. 

( c) Discovery must occur of thid pares (customers mid competitors). At ths time,
 

Polypore does not know whether the customers and competitors will cooperate or whether 

compulsory process will be necessar to obtain the discovery. 

(i) With respect to customers, Polypore has identified at this time twelve (12) 

domestic customers who may have relevant information. Those customers and their 

representatives which Polypore may call upon for deposition are located in nine 
 (9) states across 

the country. The logistics of obtaining documents, scheduling and tang depositions will be 

substatial and take a considerable amount of time. Polypore canot predict the amount of 

6
 
document discovery that will be necessar. There are also foreign customers that Polypore likely 

will need to obtain discovery from in this matter. 

(ii) Polypore has identified at this time eight (8) competitors who may have
 

relevant information. All are foreign enterprises whose main offces are in the countres of the 

United Kigdom, Japan, China, Thailand and India. Only two of those have substantial 

presences in the United States. Cooperation will probably not be fortcoming and some form of 

compulsory process will likely be required. Polyp 
 ore fully expects that it may have to utilze the 

Hague Convention to obtain discovery from certain of these international competitors. 

Compliance with the Hague Convention wil take significant time. Depositions under the Hague 

Convention may be necessar and wil likewise add complexity and time. 

(d) When disclosures are made by the FTC in mid-October, Polypore will have to 

determine what discovery it must do with respect to such disclosures. Complaint Counsel has 

indicated ten (10) witnesses may be identified. The scheduling and tag of those depositions 

alone will take significant time. Follow-up document requests will likewise take time. Under 

the curent hearng schedule, both of these discovery efforts will have to be done in 

approximately fort-five (45) days to meet a December 9, 2008 hearng date, an impossible task. 

(e) Polypore intends to employ an economist to testify as an expert in ths matter.
 

Complaint Counsel has not indicated whether the FTC wil use testifying experts. Even if the 

FTC does not use an expert, it will take signficant time for Polypore to work with the expert, for 

the expert to develop his theories, data and report, and presumably, be deposed by Complaint 

Counsel. If Complaint Counsel chooses to use an expert, then Polyp 
 ore will also have to engage 

in discovery concerning such experts' bases for opinions, theories, data and reports, and depose 

such expert. 

7 
I 

10. Polypre wants this matter to be resolved in an orderly and expeditious maner, 

but as set forth above, that canot be done without a fair and ful opportunty for Polypore to 

protect its own interests. At ths point, the. FTC sta has had a six and one-half month 

opportty to gather its information, collate, review and analyze it. The Complaint was only
 

served on September 15, 2008, laying out the claims that the FTC will make in this proceeding. 

Extending the date for the hearng will not har consumers who in ths case are sophisticated 

purchasers. Polypore is entitled to ful due process in responding to these claims. 

11. Finally, it should be noted that the scheduling of ths Hearng for December 9,
 

2008, a mere thee months afer issuance of the Complaint, is significantly shorter than the 

period suggested by FTC in its recently released proposed rules. Under the FTC's proposed 

rules, the time for scheduling a hearing is 5 months afer issuace of the complaint for merger 

cases and 8 month afer issuance of a complait for non-merger cases. This is importt to note
 

in light of the fact that this rule change is being propose4 because "the Par 3 process has long 

been criticized as being too protracted." See FTC Seeks Comments on Proposed Amendments to 

its Rules of Practice Regarding Adjudicative Proceedings, September 25, 2008, a tre and 

correct copy of which is attached as Exhibit B. Here, in a case which appears to involve merger. 

and non-merger claims, the extension sougbt is equal to 8 months from issuance of the curent 

defective Co~plaint, a time equal to the period proposed by the FTC fòr non-merger cases. 

For the reasons stated, Polypore requests that the hearg be extended until May 18, 

2009, and that at the scheduling conference, the paries set fort and agree upon the appropriate 

discovery schedule that will faciltate and enable. the effcient and effective trying of this matter 

at that time. Polypore requests the opportity to discuss this motion with the Cour at any time 

it deems appropriate, or at the scheduling conference (which Polypore has requested be set for 

either October 22 or 23, 2008). 

8 
Dated: October I, 2008 Respectfully Submitted, 

l,/' i."~ v 0­

Willam L. Rikard, Jr. Eric D. Welsh \ .
 

PARR POE ADAMS & BERNSTEIN LLP 

Three Wachovia Center
 

401 South Tryon Street, Suite 3000
 

Charlotte, NC 28202
 

Telephone: (704) 372-9000 

Facsimile: (704) 334-4706
 

willamkard~parkerpoe.com
 

ericwelsh~parkerpoe.com
 

John F. Graybeal
 

PARR POE ADAMS & BERNSTEIN LLP
 

150 Fayettevile Street
 

Raleigh, NC 27602
 

Telephone: (919) 835-4599 

Facsimile: (919) 828-0564 

johngraybeal~parkerpoe.com 

Attorneys for Respondent 

PPAB l481350v3 
CERTIFICATE OF SERVICE
 

I hereby certify that on October I, 2008, I caused to be filed via hand delivery and 

electronic mail delivery an original and two copies of the foregoing Motion to Reschedule 

Hearing Date, and that the electronic copy is a tre and correct copy of the paper original and 

that a paper copy with an original signatue is being filed on the same day by other means with: 

Donald S. Clark, Secretary 

Office of the Secretar 

Federal Trade Commission 

600 Pennsylvania Avenue, NW, Rm. H-135 

Washington, DC 20580 

secretar~ftc. gov 

I hereby certify that on October I, 2008, I served via hand delivery and first-class mail 

delivery a copy of the foregoing Motion to Reschedule Hearing Date with: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvana Avenue, NW 

Washington, DC 20580 

I hereby certify that on October I, 2008, I served via first-class mail delivery and
 

electronic mail delivery a copy of 
 the foregoing Motion to Reschedule Hearing Date with: 

J. Robert Robertson, Esq. 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

rrobertson~ftc.gov 

Steven Dah, Esq. 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

sdah~ftc.gov 

~~ 

Adam C. Shearer 

Parker Poe Adams & Bernstein LLP 

Three Wachovia Center 

401 South Tryon Street, Suite 3000 

Charlotte, NC 28202 

Telephone: (704) 335-9050 

Facsimile: (704) 334-4706 

PPAB 1481350v3 
~TED STATES OF AMERICA
 

BEFORE THE FEDERAL TRAE COMMSSION 

) In the Matter of ) Docket No. 9327

)

Polypore International, Inc. )

a corporation. ) PUBLIC DOCUMENT 

) 

) 

ORDER 

Upon consideration of 
 Respondents Motion to Reschedule Hearng Date and Complaint 

Counsel's response thereto, and the Court being fully informed, it is this _ day of
 

, 2008, hereby 

ORDERED, that the Motion is GRANTED; and it is fuher 

ORDERED, that the hearing on the Complait will begin on May 18,2009. 

The Honorable D. Michael Chappell 

Chief Administrative Law Judge (Acting) 

Federal Trade Commission 
EXHfflT A
 
REDACTED Hogan & Hartson UP
 HOGAN & . Columbia Square
 

HARTSON 555 Thirteenth Stret. NW

Washington, DC 20004 

+ 1.02.637.5600 Tel 

+ l.202.637.5910 Fax
 

www.hhlaw.com 

May 1, 2008 Michaelyn R. Ware 

Associate 

202-637-8857 

mrare(hllaw.com 

BY HAND DELIVERY 

Steven A. Dahm, Esq. 

Attorney, Mergers II 

Bureau of Competition 

Federal Trade Commission 

Room 6017 

601 New Jersey Avenue, NW 

Washington, DC 20001 

Re: Supplemental Production for Polypore International, Inc.'sFirst Response to the 

Subpoena Duces 
 Tecum, FTC File No. 0810131 

Dear Steve: 

.' 

. v, .¡.'l.,


-- ~- .~------~ - - -..-...­
St~ven A. Dahm 

May 1,2008 . 

Page 2 

Finally, as I discussed with Benjamin Oris on April 30,2008, we have produced aii~fthe 

documents related to the arbitration in PDF files in an effort to provide them to you as quickly as 

possible. These documents were scaned into PDF fies from the hard copy fies ofPolypore's 

local counsel, Parker Poe Adams & Bertsein LLP. 

I 

i 

Sincerely, 

;'. ( 

v 

Michaelynn R. Ware 

Enclosures 

cc: Philip Bryson, Esq. 

Benjam Oris, Esq. 

Ada Shearer, Esq.
 .1

Michael Shor, Esq.
 
EXHIBIT B
 
FTC Seeks Comments on Proposed Amendments to its Rules of 
 Practice Regarding Adju... Page 1 of 3 

'v 

. Federal Trade Commission
 

. .. .. Protecting America's Consumers 

For Release: September 25,2008 

FTC Seeks Comments on Proposed Amendments to its Rules of Practice 

Regarding Adjudicative Proceedings 

Changes Proposed to Ensure the High Quality of Commission Decision-making 

The Federal Trade Commission today issued a Notice of Proposed Rulemaking (NPRM) seeking public comment on proposed 

rule revisions that would amend Parts 3 and 4 of the agency's Rules of Practice, with the goal of further expediting its 

adjudicative proceedings, improving the quality of adjudicative decision-making, and clarifying the respective roles of the 

Administrative Law Judge (ALJ) and the Commission hi Part 3 proceedings. The FTC currently is seeking public comment on 

the proposed amendments as part of the rulemaking process. 

, The Administrative Process 

Part 3 and sections of Part 4 of the Commission's Rules of Practice concern the process of administrative adjudication at the 

agency. While some Commission law enforcement actions are brought in federal district court, others are brought through the 

administrative process - commonly referred to as Part 3. In such cases, the FTC's action typically is tried before an ALJ, who 

then Issues an initial decision and order in the matter. This decision can be appealed to the full Commission. The Commission 

then issues its decision and order, which can be appealed to the U.S. Court of Appeals (and subsequently the U.S. Supreme 

Court) by the respondents. If the Commission rules against complaint counsel - the FTC staff who prosecuted the matter - the 

case is over and cannot be appealed outside the agency. 

The Part 3 process has long been criticized as being too protracted, leading to at least three undesirable consequences. First, 

in merger cases, drawn-out proceedings may result in parties abandoning transactions before their merits can be adjudicated. 

Second, protracted Part 3 proceedings may lead to substantially increased litigation costs, both for the Commission and for 

private parties. Third, protracted proceedings do not necessarily leadtodecisions that are m.ore just or fair. 

The goal of the rulemaking is to address these concerns by making appropriate changes to streamline and otherwise improve 

the Part 3 process, while balancing three factors: 1) the public interest in a high-quality decision-making process; 2) the 

interests of justice in an expeditious review of litigated matters; and 3) the very real interest of the parties in litigating matters 

economically without unnecessary expense. 

The Proposed Amendments 

Each of the proposed rule revisions is detailed In the NPRM, and considered together they are designed to ensure an 

administrative process that brings the Commission's expertise into play earlier and more often during Part 3 proceedings. The 

revisions include: 1) setting tighter time limits on the adjudicative process; 2) making the discovery and motion practice more 

effcient; 3) expediting and streamlining evidentiary hearings; and 4) making changes to the process for Issuing initial decisions 

by the ALJ and subsequent Commission review. 

First, the NPRM would allow the ALJ or the Commission to impose tighter time periOds during the adjudicative process. .It 

would allow the ALJ or the Commission to shOrten any time periods set in the rules, provided that the change does not unfairly 

prejudice any party. It also would require that the date of the evidentiary hearing be set in a notice accömpanying issuance of 

the complaint. This hearing would be held five months from the date of the complaint in merger cases and eight months from 

this date in non-merger cases, unless theComn:issibn decides that a different date would be appropriate. Respondents would 

be required to file answers to the complaint within 14 days of service, instead of the current 20, and deadlines would be 

imposed on pre-hearing procedures, such as the initial meet and confer session and the scheduling conference. The rule also 

would be amended to eliminate the unilateral authority of the ALJto extend the one-year deadline for filing the initial decision, 

requiring instead Commission approval for extensions. 

Next, the amendments would provide the Commission with the authority to décide in the first Instance all dispositive prehearing motions, including motions for summary decision, unless it refers the motion to the ALJ. The amendments also would 

expressly provide authority for the Commission or an individual Commissioner to preside over discovery and other pre-hearing 

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FTC Seeks Comments on Proposed Amendments to its Rules of Practice Regarding Adju... Page 2 of3
 

proceedings before the matter is transferred to the ALJ. 

Other proposed rule changes would impose word-count limits on all motions; would limit the scope of the search for
 

discoverable materials for complaint counsel, respondents and third parties to minimize the burden of search costs; would
 

expressly limit waivers resultng from the inadvertent disclosure of privileged materials; and would require the ALJ to issue a 

standard protective order designed to limit delays and ensure that privileged or confidential information is treated consistently 

in all Part 3 cases. A new rule governing expert discovery would impose deadlines to identify expert witnesses and to submit 

expert reports and would limit the number of expert witnesses. Deadlines would be imposed on the discovery process and 

procedures would be specified concerning the exchange of relevant "electronically stored information." 

To expedite and streamline evidentiary hearings. the length of hearings would be limited to 210 hours, the equivalent of 30 

seven-hour trial days, and each side would be limited to one half of the trial time. Hearsay evidence at the hearings ~ including 

prior testimony.. would be expressly permitted if deemed suffciently reliable. The amendments would require that witness 

testimony be video recorded and made part of the offcial record, and deadlines would be imposed for the simultaneous fiing 

of proposed findings, conclusions, and supporting briefs after the hearing. 

Finally. the one-year initial decision filing deadline would be maintained, but with the requirement that the decision be issued
 

within 70 days of the last proposed findings. The lengths of principal briefs on appeal to the Commission would be limited to
 

14,000 words, and reply briefs to 7,000 words, unlèS$ otherwise allowed by the Commission. AdditOnal propòsed rule 

amendments are detailed in the notice. .
 

To expedite proposed reforms to the adjudicative process, the notice states the Commission's intention to establish an internal 

Standing Rules Committee to address potential rule changes that may be needed in the future. The Commission would review 

the Committee's recommendations annually to determine whether additional rule changes are appropriate. The Commission 

also announces that it wil make best efforts to expedite its review of initial decisions on appeaL. 

Opportunity for Public Comment 

The FTC is seeking public comment on the proposed rule revisions. Comments must be received within 30 days after 

publication in the Federal Register. Instructions for submitting comments are found in the Addresses section of the NPRM. 

The Commission vote to issue the NPRM was 3-0, with Commissioner J. Thomas Rosch not participating. The notice wil be 

on the FTC's Web site and likely wil be pUblished in the Federal Register next week. 

Copies of the Notice of Proposed Rulemaking are available from the FTC's Website at hltp://w.ftc.gov and from the FTC's
 

Consumer Response Center, Room 130,600 Pennsylvania Avenue, N.W., Washington, D.C. 20580. 

. MEDIA CONTACT: 

Mitchell J. Katz, 

Offce of Public Affairs 

202-326-2180 

STAFF CONTACTS: 

Lisa M. Harrison,
 

Offce of General Counsel
 

202-326-3204
 

Michael D. Bergman,
 

Offce of General Counsel
 

202-326-3184
 

(FTC File No. P072104) 

(Part 3 NPR final.wpd) 

E-mail this News Release
 

If you send.thls link to someone else, the FTC wil not collect any personal information about you or the recipient.
 

r Related Items: 1_.._..._........_......_... ..._............_....................... ......_____..........__...___.,........... ..". ..........._"..................._...._...... .................................1
 

http://ww.ftc.gov/opa/2008/09/nprmpt3 .shtm
 9/26/2008
FTC Seeks Comments on Proposed Amendments to its Rules of Practice Regarding Adju... Page 3 of 3 

116 CFR Part 3 and 4: Rules of Practice Regarding Adjudicative Proceedings 

I . Text of the Federal Register Notice
 

, 

L._____ J

Last Modified: Friday, 26-Sep-2008 11 :54;00 EDT 

http://ww.ftc.gov /opa/2008/09/nprmpt3 .shtm
 9/26/2008