Case 1:16-cv-00755 Document 1-2 Filed 04/25/16 Page 1 of 3

IN THE UNITED STATES DISTRICT COURT 

FOR THE DISTRICT OF COLUMBIA 

FEDERAL TRADE COMMISSION 

Plaintiff, 

v. 

Star Pipe Products, Ltd., 

Defendant. 

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CIVIL ACTION NO. 

STIPULATION 

It is stipulated by and between the undersigned parties, by their respective attorneys, that: 

(I) the parties consent that the Court may file and enter a Final Judgment in the form 

attached to the Stipulation, on the Court's own motion or on the motion of any pa1iy 

at any time, and without fu1iher notice to any party or other proceedings, if Plaintiff 

has not withdrawn its consent, which it may do at any time before the entry of' the 

Final Judgment by serving notice of its withdrawal on Defendant Star Pipe Products, 

Ltd. (Star Pipe), and filing that notice with the Court; 

(2) the parties have entered into the Stipulation to settle in full all claims related to Star 

Pipe' alleged failure to comply with Plaintiff's Decision and Order ("Plaintiffs 

Order") issued on May 8, 20 12, against Star Pipe in Jn the Maller of Mc Wane, Inc., 

and Star Pipe Products, Ltd., FTC Docket No. 935 I, _FTC_ (2012). 

(3) This Stipulation is for settlement purposes only and does not constitute an admission 

by Star Pipe that Plaintiffs Order has been violated as alleged in the Complaint, or 

that any of the facts alleged, other than jurisdictional facts, are true. 
Case 1:16-cv-00755 Document 1-2 Filed 04/25/16 Page 2 of 3

(4) Defendant Star Pipe waives any objection to venue or jurisdiction for purposes of the 

Final Judgment and authorizes Bernard A. Nigro, Jr., Esq., of Fried, Frank, Harris, 

Shriver & Jacobson LLP, and Gregory Huffman, Esq., of Thompson & Knight, LLP 

to accept service of all process in this matter on its behalf; 

(5) Defendant Star Pipe shall abide by and comply with the provisions of the proposed 

Final Judgment upon entry of the Final .Judgment by the Couti; 

(6) This Stipulation shall apply with equal force and effect to any amended proposed 

Final Judgment agreed upon in writing by the pa1iies and submitted to the Court; 

(7) In the event Plaintiff withdraws its consent or, if the proposed Final Judgment is not 

entered pursuant to this Stipulation, this Stipulation shall be of no effect whatever and 

the making of this Stipulation shall be without prejudice to any party in this or any 

other proceeding; and 

(8) Plaintiff considers entry of the Final Judgment to be in the Public Interest. 

Dated: I ·· 7 , 2016 -------

FOR THE FEDERAL TRADE COMMISSION 

By: 

Deborah L. Feinstein 

D.C. Bar No. 4!2109 

Marian R. Bruno 

D.C. Bar No. 414126 

Deputy Director, Bureau of Competition 

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Case 1:16-cv-00755 Document 1-2 Filed 04/25/16 Page 3 of 3

.\J: -~~ (72'1,t; ~ # , I~, . .~Q - // / t1·~- ~~A -~-~~c .--/ 

Daniel P. Ducore, Esq. • 

D.C. Bar No. 933721 

Assistant Director, Bureau of Competition 

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ln~~R~ s~hrir, E:~~"·'' L"/":1-----

D.c. Bar No. 185462 o· 

Thomas H. Brock 

D.C. Bar No. 939207 

Attorneys, Bureau of Competition 

Federal Trade Commission 

Washington, D.C. 20580 

(202) 326-2526 

FOR STAR PIPE PRODUCTS, LTD. 

A Texas limited partnership 

By: 

Thompson & Knight LLP 

Dated: __ I _··_1-_-_1 _b __ _ 

Dated:_-'-/--_,_f __ /_b __ 

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