ORIGINAL 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRAE COMMISSION 

In the Matter of ) Docket No. 9327 

) 

) 

Polypore International, Inc. 

a corporation 

) 

) 

) PUBLICI 

) 

RESPONDENT'S THIRD MOTION FOR IN CAMERA TREATMENT 

OF CERTAIN TRIAL EXHIBITS 

By Order on May 13, 2009 (the "Order"), Administrative Law Judge Chappell granted, in 

part, Respondent's Second Motion for In Camera Treatment. As to the remaining exhibits for 

which Respondent had sought in camera treatment, the Order denied Respondent's Second 

Motion for In Camera Treatment without prejudice. As to these exhibits, Respondent has 

conducted a complete and thorough review in order to reduce the total number of exhibits for 

which Respondent seeks in camera protection. In the instant motion, Polypore International, Inc. 

("Polypore") seeks in camera treatment for the remaining exhibits it contends warrant in camera 

treatment. Additionally, Respondent seeks in camera treatment for a handful of exhibits which 

were introduced for the first time at the trial of this proceeding and which had not been 

previously included by Respondent in a motion for in camera treatment. 

The exhibits identified in the instant motion are highly sensitive and proprietary in nature. 

Public disclosure of such information would divulge Polypore's most sensitive and confidential 

information to competitors and/or customers, and would cause irreparable harm and serious 

i This motion refers to and contains information subject to Respondent's Third Motion for In Camera Treatment of 

Certain Trial Exhibits pursuant to Rule 3.45(b) of 
 the FTC's Rules of Practice. Such information has been redacted and labeled 

"(Redacted - Subject to Pending Motion for In Camera Treatment)" in the public version of this motion. 

PPAB 1574240vl 
injur to Polypore. Accordingly, Polypore respectfully requests an order granting in camera
 

status to these exhibits. 

The specific pages and exhibits which have been identified by Polypore fall within the 

Commission's strict standards for in camera treatment as set forth in Judge Chappell's April 27, 

2009 Order and the opinions of 
 this Commission.2 Each exhibit identified by Polypore contains 

sensitive information that is "suffciently secret and sufficiently material to (Polypore's) business 

that disclosure would result in serious competitive injury" and, even when balanced against the 

"importance of the information in explaining the rationale of Commission decisions" warrants in 

camera treatment. General Foods Corp., 95 FTC 352 (1980). The exhibits at issue in this Third 

Motion are listed in the index attached hereto as Exhibit A. For ease of reference, Polypore has 

grouped the exhibits identified in Exhibit A into the following categories: 

1. Category 1 - Business Plans & Strategies 

2. Category 2 - Contract Negotiations & Customer Contracts 

3. Category 3 - Intellectual Property & Proprietary Information 

4. Category 4 - Market Analysis Documents 

5. Category 5 - Pricing Strategy Documents 

6. Category 6 - Customer-Specific Documents 

7. Category 7 - Costing Data
 

8. Category 8 - Sales & Financial Information
 

9. Category 9 - Multiple Category Documents 

2 See In re Dura Lube Corp., 1999 FTC LEXIS 255 (Dec. 23 1999); In re Hoechst Marion Roussel, Inc., 2000 FTC 

LEXIS 157 (Nov. 22,2000) and 2000 FTC LEXIS 138 (Sept. 19,2000); and In re Basic Research, Inc., 2006 FTC LEXIS 14 

(Jan. 25, 2006) 

2 

PPAB 1574240vl 
The grounds for this Third Motion are set forth herein, and this Third Motion is fully 

supported by the sworn Third Declaration of Michael Shor ("Shor Decl. ") attached hereto as 

Exhibit B and which individually analyzes each item listed on Exhibit A. 

Introduction 

As Respondent wil demonstrate herein and in the supporting Third Declaration of 

Michael Shor, the public disclosure of the exhibits identified in Exhibit A hereto, wil likely 

result in a clearly defined, serious injury to Respondent, thus justifying in camera treatment 

under the standard articulated by the Commission in In re Dura Lube Corp., 1999 FTC LEXIS 

255 (Dec. 23 1999); In re Hoechst Marion Roussel, Inc., 2000 FTC LEXIS 157 (Nov. 22,2000) 

and 2000 FTC LEXIS 138 (Sept. 19,2000); and In re Basic Research, Inc., 2006 FTC LEXIS 14 

(Jan. 25, 2006). 

The exhibits identified in Exhibit A contain confidential information that is paramount to 

Polypore's business, competitiveness, and profitabilty. Indeed, revealing such information
 

would, among other things: (1) allow Polypore's competitors to gain a commercial advantage 

through knowledge of Polypore's pricing strategies, production capacities, technical know-how, 

and manufacturing processes; (2) give Polypore's customers a tactical advantage in future 

negotiations with Polypore; and (3) enable suppliers to peg the prices they charge Polypore. At 

the very least, disclosure of the information Polypore seeks to protect would deprive Polypore of 

its current bargaining position with customers and suppliers; at worst, competitors would be 

allowed unfettered access to Respondent's confidential and sensitive documents which wil 

inevitably create a less competitive marketplace and harm competition. Continued 

confidentiality of these documents is key to maintaining Polypore's abilty to develop, market, 

and sell its products in this competitive market dominated by powerful buyers. 

3 

PPAB 1574240vl 
Argument 

Pursuant to Commission Rule 3.45(b), the Administrative Law Judge may order material, 

or portions thereof, offered into evidence. . . to be placed in camera on a finding that their public 

disclosure wil 
 likely result "in a clearly defined, serious injury to the . . corporation requesting 

in camera treatment." 16 C.F.R. § 3.45(b)(emphasis added). Establishing that a serious injur 

would ensue with disclosure requires a demonstration that serious and irreparable harm wil 

result from the Cotirt's publication of the confidential documents. Meeting such a standard 

requires Respondent to make a clear showing that the information concerned is "sufficiently 

secret and sufficiently material to (Respondent's) business that disclosure would result in serious 

competitive injur." See Bristol-Myers Co., 90 FTC 455 (1977), General Foods Corp., 95 FTC 

352 (1980). 

In Bristol-Myers, 90 FTC 455 (1977), the Commission outlined six factors to be weighed 

when determining materiality and secrecy: (1) the extent to which the information is known 

outside of the applicant's business; (2) the extent to which the information is known by 

employees and others involved in the applicant's business; (3) the extent of measures taken by 

the applicant to guard the secrecy of the information; (4) the value of the information to the
 

applicant and its competitors; (5) the amount of effort or money expended by the applicant in 

developing the information; and (6) the ease or diffculty with which the information could be 

properly acquired or duplicated by others. Additionally, the Commission has expounded on the 

definition of "serious injury," stating "(t)he likely loss of 
 business advantages is a good example 

ofa clearly defined, serious injur." Hoechst Marion Roussel, Inc., 2000 FTC LEXIS 138 (Sept. 

19,2000). 

As set forth below and in the Third Declaration of Michael Shor, the documents list in 

Exhibit A, and grouped by the previously identified nine categories, contain information 

4 

PPAB 1574240vl 
sufficiently secret, and suffciently material to Polypore's business, that disclosure constitutes a 

serious competitive injury under the Bristol-Myers factors and prevailng Commission law. 

I. IN CAMERA TREATMENT IS WARTED FOR THE FOLLOWING
 

POLYPORE DOCUMENTS 

A. Category One - Business Plans & Strategies
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

B. Category Two - Contract Negotiations & Customer Contracts
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

C. Category Three - Intellectual Property & Proprietary Information
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

D. Category Four - Market Analysis Documents
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

E. Category Five - Pricing Strategy Documents
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

F. Category Six - Customer-Specific Documents
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

G. Category Seven - Costing Data
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

H. Category Eight - Sales and Financial Information
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

I. Category Nine - Multiple-Category Documents
 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

5 

PPAB 1574240vl 
Conclusion 

(Redacted - Subject to Pending Motion for In Camera Treatment). For the foregoing 

reasons and those articulated in the Third Declaration of Michael Shor, Polypore respectfully 

requests that this Cour grant in camera protection to all the documents identified on Exhibit A. 

6 

PPAB 1574240vl 
Dated: June 11, 2009
 Respectfly submittd, ~ WifL í2ú ~ 

Wiliam L. Rikard, Jr. (
 

Eric D. Welsh 

PARKR POE ADAMS & BERNSTEIN, LLP 

Three Wachovia Center 

401 South Tryon Street, Suite 3000 

Charlotte, NC 28202 

Telephone: (704) 372-9000 

Facsimile: (704) 335-9689 

willamrikard~parkerpoe.com 

ericwelsh~parkerpoe.com 

John F. Graybeal 

PARKER 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 1574240vl 
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRAE COMMISSION 

In the Matter of ) 

) Docket No. 9327 

) Polypore International, Inc. ) a corporation ) PUBLIC DOCUMENT 

) 

PROPOSED ORDER 

Upon consideration of Respondent's Third Motion for In Camera Treatment of Certain 

Trial Exhibits, any opposition thereto, any hearing thereon, and the entire record in this 

proceeding, 

IT is HEREBY ORDERED, that Respondent's Motion is GRANTED. 

IT is FURTHER ORDERED, that pursuant to Rule 3.45(b) of the Federal Trade 

Commission Rules of Practice, 16 C.F.R.§ 3.45(b), the documents identified in the index 

attached as Exhibit A to the Motion, and any related trial testimony, shall be subject to the 

requested in camera treatment and wil be kept confidential and not placed on the public record 

of this proceeding. 

D. Michael Chappell 

Administrative Law Judge 

Date: 

PPAB 1574240vl 
CERTIFICATE OF SERVICE
 

I hereby certify that on June 11, 2009, I caused to be filed via hand delivery and 

electronic mail delivery an original and two copies of the foregoing Respondent's Third Motion 

for In Camera Treatment of Certain Trial Exhibits ¡PUBLIC), and that the electronic copy is a

true and correct copy of the paper original and that a paper copy with an original signature is 

being fied with:
 

Donald S. Clark, Secretary 

Offce of 
 the Secretary 

Federal Trade Commission 

600 Pennsylvania Avenue, NW, Rm. H-135 

Washington, DC 20580 

secretary~ftc.gov 

'f' 

I hereby certify that on June 11,2009, I caused to be served one copy via electronic mail 

delivery and two copies via hand delivery of the foregoing Respondent's Third Motion for In 

Camera Treatment of Certain Trial Exhibits ¡PUBLIC) upon: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

oali ~ftc. gov 

I hereby certify that on June 11, 2009, I caused to be served via hand delivery and 

electronic mail delivery a copy of the foregoing Respondent's Third Motion for In Camera 

Treatment of Certain Trial Exhibits ¡PUBLIC) upon: 

J. Robert Robertson, Esq. Steven Dahm, Esq. 

Federal Trade Commission Federal Trade Commission 

600 Pennsylvania Avenue, NW 600 Pennsylvania Avenue, NW 

Washington, DC 20580 Washington, DC 20580 

rrobertson~ftc.gov sdahm~ftc.gOV 

Bri~~wey~ft

Parker Poe Adams & Bernstein LLP 

Three Wachovia Center 

401 South Tryon Street, Suite 3000 

Charlotte, NC 28202 

Telephone: (704) 335-9534 

Facsimile: (704) 335-9776 

PPAB 1574240vl 
--

Polypore International, Inc., Docket 9327 I £.h:bit A 

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Polyp ore International, Inc., Docket 9327 

Provisional In Camera Documents Requiring In Camera Treatment 

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Polypore International, Inc., Docket 9327
 

Provisional In Camera Documents Requiring In Camera Treatment
 

06/10/2009
 

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Polypore International, Inc., Docket 9327
 

Provisional In Camera Documents Requiring In Camera Treatment
 

06/10/2009
 

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Polyp ore International, Inc., Docket 9327 

Provisional In Camera Documents Requiring In Camera Treatment 

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Polypore International, Inc., Docket 9327
 

Provisional In Camera Documents Requiring In Camera Treatment 

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Polypore International, Inc., Docket 9327
 

Provisional In Camera Documents Requiring In Camera Treatment
 

06/10/2009
 

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Polypore International, Inc., Docket 9327
 

Provisional In Camera Documents Requiring In Camera Treatment
 

06/10/2009
 

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---

Polyp ore International, Inc., Docket 9327 

Provisional In Camera Documents Requiring In Camera Treatment 

06/10/2009 

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Polyp ore International, Inc., Docket 9327 

Provisional In Camera Documents Requiring In Camera Treatment 

06/10/2009 

6 

i 

Redacted -i i i i ¡ I -i__~ 

- 10­
UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRAE COMMISSION 

In the Matter of ) Docket No. 9327 

) 

) 

Polypore International, Inc. 

a corporation 

) 

) 

) PUBLIC DOCUMENTI 

) 

THIRD DE 
 CLAR TION OF MICHAEL SHOR 

I, Michael Shor, being duly sworn and based upon my personal knowledge, declare and 

state as follows: 

1. I am Special Counsel of Respondent Polypore International, Inc. ("Polypore").
 

2. I am familar with the documents of Polypore and the level of confdentiality associated
 

with the subject matter therein. 

3. I submit this declaration in support of 
 Polyp ore's Third Motion for In Camera Treatment 

of Certain Trial Exhibits, requesting in camera treatment of certain documents, identified 

by Complaint Counsel and/or Polypore as potential trial exhibits at the hearing of this 

matter. 

4. I am personally informed of the content of the individual documents and groups of
 

documents that were reviewed, and the specific basis upon which Polypore is moving for 

in camera treatment of such documents. 

i This Declaration refers to and contains information subject to Respondent's Third Motion for In Camera Treatment of 

Certain Trial Exhibits pursuant to Rule 3.45(b) of the FTC's Rules of 
 Practice. Such information has been redacted and labeled 

"(Redacted - Subject to Pending Motion for In Camera Treatment)" in the public version of this Declaration. 

PPAB 1574366vl 
5. Each of the documents identified in Exhibit A of 
 Polyp ore's Third Motion for In Camera

Treatment of Certain Trial Exhibits, and individually described herein, contain sensitive 

and confidential material and/or information that would result in competitive injur to
 

Polypore should it be made public. 

6. Each document identified by Polypore as requiring in camera treatment has been 

maintained internally by Polypore in a confidential manner, only being shared with those 

individuals requiring the knowledge contained within the documents. Additionally, each 

such document has, upon production in this case, been designated "Confidential 

Material" pursuant to the Protective Order entered on October 23,2008. 

7. Exhibit A to Polypore's Third Motion for In Camera Treatment of 	 Certain Trial Exhibits 

is an index which lists each document for which Polypore seeks in camera treatment. 

This index contains the exhibit designation (i.e., "RX" or "PX"), the exhibit number, a 

description of the exhibit, the date of the exhibit, the individual pages (if applicable)
 

requiring in camera treatment, the categorical reason for seeking in camera treatment,
 

and the length of time for which in camera treatment is sought. 

8. These exhibits
 

(Redacted - Subject to Pending Motion for In Camera Treatment) The public 

disclosure of any of this critically sensitive information would be highly detrimental to 

Polypore 

(Redacted - Subject to Pending Motion for In Camera Treatment) 

Each document is individually reviewed in 

tu below, and for convenience's sake, organized by the following categories:
 

PPAB 1574366vl 
(a) Category 1 - Business Plans & Strategies
 

(b) Category 2 - Contract Negotiations & Customer Contracts
 

(c) Category 3 - Intellectual Property & Proprietary Information
 

(d) Category 4 - Market Analysis Documents
 

(e) Category 5 - Pricing Strategy Documents
 

(f) Category 6 - Customer-Specific Documents
 

(g) Category 7 - Costing Data
 

(h) Category 8 - Sales & Financial Information
 

(i) Category 9 - Multiple Category Documents
 

9. Also for convenience sake, the subject documents are also summarized in the index
 

attached as Exhibit A to Respondent's Third Motion. 

CATEGORY ONE - BUSINESS PLANS & STRATEGIES 

10. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY TWO - CONTRACT NEGOTIATIONS & CUSTOMER CONTRACTS 

11. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY THREE - INTELLECTUAL PROPERTY & PROPRIETARY 

INFORMATION 

12. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY FOUR - MART ANALYSIS DOCUMENTS 

13. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY FIVE - PRICING STRATEGY DOCUMENTS 

14. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

PPAB 1574366vl 
CATEGORY six - CUSTOMER-SPECIFIC DOCUMENTS 

15. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY SEVEN - COSTING DATA 

16. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY EIGHT - SALES & FINANCIAL INFORMATION 

17. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

CATEGORY NINE - MULTIPLE-CATEGORY DOCUMENTS 

18. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

19. Prior to this administrative proceeding, the information contained in the exhibits
 

identified by Polypore for in camera treatment has been revealed only to appropriate 

Polypore personnel and any contracting parties to the particular documents. General 

Polypore employees do not have access to the documents containing in camera materiaL. 

Such information is not in the public domain and canot be obtained through other 

means. 

20. (Redacted - Subject to Pending Motion for In Camera Treatment).
 

21. (Redacted - Subject to Pending Motion for In Camera Treatment)..
 

PPAB 1574366vl 
I declare, under penalty of 
 perjury, that the above statements are true and correct. 

This 11 th day of June, 2009. 

Charlotte, North Carolina 

NOTARIZED: ~~!D
 

Marilyn Owendoff 

Notary Public, District of Columbia 

My Commission Expires 02-28-10 

PPAB 1574366vl