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UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

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In the Matter of 

Ardagh Group S.A., 

a public limited liability company, and 

Compagnie de Saint-Gobain, 

a corporation, and 

Saint-Gobain Containers, Inc., 

a corporation. 

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PUBLIC 

DOCKET NO. 9356 

UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE 

MOTIONS FOR IN CAMERA TREATMENT

 Respondents Ardagh Group S.A., Compagnie de Saint-Gobain, and Saint-Gobain 

Containers, Inc. respectfully move pursuant to FTC Rule of Practice 3.21(c)(2) to extend the 

deadline for Respondents and third parties to file motions for in camera treatment of confidential 

information and expert related exhibits. In support of the motion, Respondents state as follows: 

1. On November 19, 2013, Respondents received notice from Complaint 

Counsel of its intent to introduce at the hearing confidential material produced by Respondents in 

the above-captioned matter, the related federal action (FTC v. Ardagh Group S.A., et al., 13-CV1021 (BJR) (D.D.C.)), and the Federal Trade Commission’s investigation of Ardagh’s proposed 

acquisition of Saint-Gobain Containers, Inc. 

2. That same day, Respondents and Complaint Counsel notified numerous 

third parties of their intent to introduce confidential material that has been produced by the third 

parties as evidence at the hearing scheduled to begin in this matter on December 19, 2013. 

11 20 2013
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3. Pursuant to the Revised Scheduling Order entered on October 18, 2013, 

the deadline for Respondents and third parties to file motions for in camera treatment of 

confidential information is currently November 26, 2013, with responses due on December 4. 

The deadline for the parties to file motions for in camera treatment of proposed expert related 

exhibits is December 5, 2013, with responses due on December 12. 

4. In light of ongoing settlement negotiations between the parties, extending 

the deadline to file motions for in camera treatment may avoid an unnecessary burden on both 

the parties and third parties who would seek to protect their confidential information from public 

disclosure at the hearing, and it will also allow the parties to focus on settlement negotiations. 

5. This is Respondents’ first request for an extension of time to file motions 

for in camera treatment of confidential material and in camera treatment of expert related 

exhibits. 

6. Complaint Counsel has consented to the relief requested herein. 

7. Should the Court grant this motion, Respondents and Complaint Counsel 

will promptly notify third parties that the deadline for filing a motion for in camera treatment of 

confidential material has been extended. 

WHEREFORE, Respondents respectfully request that the Court extend the deadline to 

file motions for in camera treatment of confidential information and motions for in camera 

treatment of expert related exhibits until December 9, 2013, and extend the deadline to file 

responses to in camera motions until December 13, 2013. 

Dated: November 20, 2013 Respectfully submitted, 

SHEARMAN & STERLING LLP 

By: /s/ Richard F. Schwed 

Richard F. Schwed 
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Alan S. Goudiss 

Wayne Dale Collins 

Lisl Joanne Dunlop 

SHEARMAN & STERLING LLP 

599 Lexington Avenue 

New York, NY 10022 

Telephone: (212) 848 4000 

Facsimile: (212) 848 4173 

agoudiss@shearman.com 

rschwed@shearman.com 

wcollins@shearman.com 

ldunlop@shearman.com 

Heather L. Kafele 

SHEARMAN & STERLING LLP 

801 Pennsylvania Avenue N.W. 

Washington, DC 20004 

Telephone: (202) 508 8000 

Facsimile: (202) 508 8100 

hkafele@shearman.com 

Counsel for Respondent Ardagh Group 

S.A. 

CRAVATH, SWAINE & MOORE LLP, 

 by 

 /s/ Christine A Varney 

 Christine A. Varney 

Sandra C. Goldstein (pro hac vice) 

Yonatan Even (pro hac vice) 

 Members of the Firm 

 

 Attorney for Defendants 

Worldwide Plaza 

825 Eighth Avenue 

New York, NY 10019 

(212) 474-1000 

cvarney@cravath.com 

Counsel for Respondent Compagnie 

de Saint-Gobain and Saint-Gobain 

Containers, Inc. 
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CERTIFICATE OF SERVICE

I, Jason M. Swergold, an associate at Shearman & Sterling LLP, hereby certify that on 

November 20, 2013, I caused the foregoing document to be filed using the FTC’s E-Filing 

System, which will send notifications of such filing to: 

Donald S. Clark 

Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-113 

Washington, DC 20580 

I also certify that I delivered via electronic mail and hand delivery a copy of the foregoing 

document to: 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm. H-110 

Washington, DC 20580 

I further certify that I delivered via electronic mail a copy of the foregoing document to: 

Edward D. Hassi 

Catharine M. Moscatelli 

Brendan J. McNamara 

Sebastian Lorigo 

Victoria Lippincott 

Meredith Robinson 

Devon Kelly 

James Abell 

Teresa Martin 

Amanda Hamilton 

U.S. Federal Trade Commission 

600 Pennsylvania Avenue, NW 

Washington, DC 20580 

ehassi@ftc.gov 

cmoscatelli@ftc.gov 

bmcnamara@ftc.gov 

slorgio@ftc.gov 

vlippincott@ftc.gov 

mrobinson@ftc.gov 

dkelly2@ftc.gov 

jabell@ftc.gov 

tmartin@ftc.gov 

ahamilton1@ftc.gov 
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Complaint Counsel 

November 20, 2013 By: /s/ Jason M. Swergold

 Jason M. Swergold 

CERTIFICATE FOR ELECTRONIC FILING 

I certify that the electronic copy sent to the Secretary of the Commission is a true and correct 

copy of the paper original and that I possess a paper original of the signed document that is 

available for review by the parties and the adjudicator. 

November 20, 2013 By: /s/ Jason M. Swergold

 Jason M. Swergold