PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

COMMISSIONERS: Joseph J. Simons, Chairman 

 Noah Joshua Phillips 

 Rohit Chopra 

 Rebecca Kelly Slaughter 

 Christine S. Wilson 

In the Matter of 

RAG-stiftung, 

a public-private foundation; 

Evonik Industries AG, 

a public company; 

Evonik Corporation, 

a public company; 

Evonik International Holding B.V., 

a public company; 

One Equity Partners Secondary Fund, 

L.P., 

a private company; 

One Equity Partners V, L.P., 

a private company; 

Lexington Capital Partners VII (AIV I), 

L.P., 

a private company; 

PeroxyChem Holding Company LLC, 

a private company; 

PeroxyChem Holdings, L.P., 

a private company; 

PeroxyChem Holdings LLC, 

a private company; 

PeroxyChem LLC 

 a private company; 

 

Docket No. 9384 

08 20 2019 

595704 
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and 

PeroxyChem Cooperatief U.A. 

a private company. 

ANSWER AND DEFENSES OF RESPONDENTS RAG-STIFTUNG, EVONIK 

INDUSTRIES AG, EVONIK CORPORATION, AND EVONIK INTERNATIONAL 

HOLDING B.V. 

 Pursuant to Rule 3.12 of the Federal Trade Commission’s (Commission) Rules of 

Practice for Adjudicative Proceedings, Respondents RAG-Stiftung, Evonik Industries AG, 

Evonik Corporation, and Evonik International Holding B.V. (together, Evonik), by and through 

its attorneys, hereby answers the Administrative Complaint (the Complaint) filed by the 

Commission in relation to Evonik’s proposed acquisition of PeroxyChem LLC (the Acquisition) 

as follows: 

Except to the extent specifically admitted herein, Evonik denies each and every allegation 

contained in the Complaint, including all allegations contained in headings or otherwise not 

contained in one of the Complaint’s 57 numbered paragraphs. 

RESPONSE TO THE SPECIFIC ALLEGATIONS OF THE COMPLAINT 

The preamble to the Complaint characterizes this action and asserts legal conclusions to 

which no response is required; to the extent that a response is deemed necessary, Evonik denies 

the allegations in the preamble to the Complaint. 

Evonik responds to the numbered paragraphs of the Complaint as follows: 

1. Evonik denies the allegations in the first sentence of Paragraph 1. As to the 

second sentence of Paragraph 1, Evonik admits that hydrogen peroxide is used, among other 

things, for oxidation, sterilization, and bleaching, and in all other respects denies the allegations 

in the second sentence of Paragraph 1. Evonik admits the allegations in the third sentence of 
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Paragraph 1. As to the fourth sentence of Paragraph 1, Evonik admits that the pulp and paper 

industry uses most of the standard-grade hydrogen peroxide produced in North America, but in 

all other respects denies the allegations in the fourth sentence of Paragraph 1. As to the fifth 

sentence of Paragraph 1, Evonik admits that the Commission has excluded electronics-grade 

hydrogen peroxide from its alleged product market definition, that electronics-grade hydrogen 

peroxide requires additional purification as compared to standard-grade hydrogen peroxide, and 

that electronics-grade hydrogen peroxide is not a substitute for other grades of hydrogen 

peroxide and vice versa; in all other respects, Evonik denies the allegations in the fifth sentence 

of Paragraph 1, and specifically denies that the Commission’s alleged hydrogen peroxide market, 

excluding electronics-grade hydrogen peroxide, constitutes a properly-defined relevant product 

market. 

2. Evonik denies the allegations in the first sentence of Paragraph 2 except to admit 

that Evonik and the other North American producers of hydrogen peroxide “compete vigorously 

for customers.” The remainder of Paragraph 2 contains legal conclusions to which no response 

is required. To the extent a response is deemed necessary, Evonik denies the remaining 

allegations in Paragraph 2, and specifically denies that the Commission’s artificial “Pacific 

Northwest” and “Southern and Central United States” markets on which the allegations in 

Paragraph 2 are based constitute properly defined relevant geographic markets and that the 

Commission’s alleged hydrogen peroxide market, excluding electronics-grade hydrogen 

peroxide, constitutes a properly defined relevant product market. 

3. Paragraph 3 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 3, except to 

admit that Solvay, Arkema, and Nouryon all are active North American hydrogen peroxide 
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producers. Further, Evonik states that the parties proposed divestiture of PeroxyChem’s Prince 

George Plant in Western Canada to the Commission in May 2019, and that the parties have a 

signed divestiture agreement, contingent on closing the Acquisition; the proposed divestiture of 

the Prince George plant fully addresses any proffered or potential anticompetitive effects in the 

alleged Pacific Northwest geographic market. 

4. The first sentence of Paragraph 4 seeks to characterize the Commission’s Merger 

Guidelines, which speak for themselves. The remainder of Paragraph 4 contains legal 

conclusions to which no response is required; to the extent a response is deemed necessary, 

Evonik denies the allegations in Paragraph 4 and specifically denies that the Merger Guidelines 

are vested with the authority to determine the legality of any acquisition, presumptively or 

otherwise. 

5. The first, second, sixth, and seventh sentences of Paragraph 5 contain legal 

conclusions to which no response is required; to the extent a response is deemed necessary, 

Evonik denies the allegations in the first, second, sixth, and seventh sentences of Paragraph 5. 

Evonik denies the allegations in the third, fourth, and fifth sentences of Paragraph 5 except to 

admit that certain hydrogen peroxide suppliers admitted to illegally fixing prices nearly twenty 

years ago. 

6. Evonik denies the allegations in Paragraph 6, except to admit that Evonik and 

other North American hydrogen peroxide producers compete to serve customers throughout the 

United States. 

7. The first sentence of Paragraph 7 contains a legal conclusion to which no 

response is required; to the extent a response is deemed necessary, Evonik denies the allegations 
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in the first sentence of Paragraph 7. In all other respects, Evonik denies the allegations in 

Paragraph 7. 

8. Paragraph 8 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 8. 

9. Paragraph 9 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik admits that it is engaged in activities in or 

affecting interstate commerce. Evonik denies the remaining allegations in Paragraph 9. 

10. Paragraph 10 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 10. 

11. Evonik admits the allegations in Paragraph 11, except to deny that RAG-Stiftung 

acquired Degussa in 2006. Evonik states that RAG-Stiftung’s predecessor, RAG AG, acquired a 

majority share of Degussa in 2004 and the remainder of Degussa shares in 2006, and that RAGStiftung currently owns approximately 64.3 percent of the outstanding shares of Evonik 

Industries AG. 

12. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 12 and on that basis denies those allegations. 

13. Evonik denies the allegations in Paragraph 13, except to admit that pursuant to an 

Agreement and Plan of Merger dated November 7, 2018, Evonik proposes to acquire 100% of 

the non-corporate interests of PeroxyChem Holding Company LLC, 99% of the non-corporate 

interests of PeroxyChem Coöperatief U.A., and 100% of the non-corporate interests of 

PeroxyChem Holdings LLC for approximately $625 million. 

14. Paragraph 14 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 14. Evonik 
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specifically denies that the Commission’s artificial “Pacific Northwest” and “Southern and 

Central United States” markets constitute properly defined relevant geographic markets, and 

specifically denies that the Commission’s alleged hydrogen peroxide market, excluding 

electronics-grade hydrogen peroxide, constitutes a properly defined relevant product market. 

15. The first sentence of Paragraph 15 contains legal conclusions to which no 

response is required; to the extent a response is deemed necessary, Evonik denies the allegations 

in the first sentence of Paragraph 15. As to the second sentence of Paragraph 15, Evonik admits 

that hydrogen peroxide can be used as an oxidizing agent with diverse end uses, including 

various grades appropriate for end uses such as bleaching pulp, chemical synthesis, and 

sterilizing food packaging, among many others including electronics. As to the third sentence of 

Paragraph 15, Evonik admits that the primary use of standard-grade hydrogen peroxide in North 

America is for bleaching in the pulp and paper industry. In all other respects, Evonik denies the 

allegations in Paragraph 15. Evonik specifically denies that the Commission’s alleged hydrogen 

peroxide market, excluding electronics-grade hydrogen peroxide, constitutes a properly defined 

relevant product market. 

16. As to the first sentence of Paragraph 16, Evonik admits that the Commission has 

excluded electronics-grade hydrogen peroxide from its alleged product market definition, but 

specifically denies that the Commission’s alleged hydrogen peroxide market, excluding 

electronics-grade hydrogen peroxide, constitutes a properly defined relevant product market. 

Evonik admits the allegations in the second and third sentences of Paragraph 16. Evonik also 

states that certain other grades of hydrogen peroxide similarly require additional purification 

capabilities that vary by hydrogen peroxide producer, are not capable of being produced by all 
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hydrogen peroxide producers, and are not substitutable with other grades of hydrogen peroxide. 

In all other respects, Evonik denies the allegations in Paragraph 16. 

17. Evonik denies the allegations in the first sentence of Paragraph 17. As to the 

second sentence of Paragraph 17, Evonik admits that the primary raw materials used to 

manufacture the various grades of hydrogen peroxide are natural gas and hydrogen. As to the 

third sentence of Paragraph 17, Evonik admits that crude hydrogen peroxide is produced via a 

three-step process of hydrogenation, oxidation, and extraction. As to the fourth sentence of 

Paragraph 17, Evonik admits that various grades of hydrogen peroxide are made from crude 

hydrogen peroxide via dilution, filtration, and stabilization processes designed to meet end-use 

specific criteria. In all other respects, Evonik denies the allegations in the second, third, and 

fourth sentences of Paragraph 17. 

18. Evonik denies the allegations in the first, third, and fourth sentences of 

Paragraph 18. As to the second sentence of Paragraph 18, Evonik admits that pulp and paper 

customers purchase the majority of standard-grade hydrogen peroxide in North America. Evonik 

lacks knowledge or information sufficient to form a belief as to the truth of the allegations 

contained in the remainder of the second sentence of Paragraph 18 and on that basis denies those 

allegations. 

19. Paragraph 19 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 19 except to 

admit that Evonik and other producers of hydrogen peroxide compete to serve customers 

throughout the United States. 

20. Paragraph 20 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 20 and 
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specifically denies that the Commission’s artificial “Pacific Northwest” and “Southern and 

Central United States” markets constitute properly defined relevant geographic markets. 

21. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 21 as they relate to any customer or competitor other than Evonik, 

and on that basis denies those allegations. With that qualification: Evonik admits the allegations 

in the first sentence of Paragraph 21. As to the second sentence of Paragraph 21, Evonik admits 

that transportation costs associated with delivering standard-grade hydrogen peroxide may be 

high relative to the value of the product itself, and in all other respects denies the allegations of 

the second sentence of Paragraph 21. Evonik admits the allegations in the third sentence of 

Paragraph 21. Evonik denies the allegations in the fourth sentence of Paragraph 21, except to 

admit that Evonik uses terminals to deliver hydrogen peroxide further distances. 

22. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations regarding other hydrogen peroxide suppliers in Paragraph 22 and on that basis 

denies those allegations. In all other respects, Evonik denies the allegations in Paragraph 22, 

except to admit that Evonik analyzes the North American hydrogen peroxide industry in a 

number of different ways in its efforts to compete most effectively. 

23. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations regarding other hydrogen peroxide suppliers in Paragraph 23 and on that basis 

denies those allegations. In all other respects, Evonik denies the allegations in Paragraph 23 

except to admit that Evonik contracts individually with customers, primarily through customers’ 

formalized bid processes, and that prices vary by customer and customer-location, among a 

range of other factors. 
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24. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 24 and on that basis denies those allegations, but notes that 

customers of different grades of hydrogen peroxide can purchase and have purchased from 

producers outside of the artificial “Pacific Northwest” and “Southern and Central United States” 

markets alleged by the Commission. Evonik specifically denies that the Commission’s artificial 

“Pacific Northwest” and “Southern and Central United States” markets on which the allegations 

in Paragraph 24 are based constitute properly defined relevant geographic markets. 

25. Evonik denies the allegations in the first and second sentences of Paragraph 25, 

except to admit that Evonik and other hydrogen peroxide producers compete to serve customers 

across the United States. Evonik admits the allegations in the third sentence of Paragraph 25. 

26. Evonik denies the allegations in Paragraph 26 and specifically denies that the 

Commission’s artificial “Pacific Northwest” market on which the allegations in Paragraph 26 are 

based constitutes a properly defined relevant geographic market. 

27. Evonik denies the allegations in Paragraph 27 and specifically denies that the 

Commission’s artificial “Southern and Central United States” market on which the allegations in 

Paragraph 27 are based constitutes a properly defined relevant geographic market. 

28. Paragraph 28 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 28. 

29. Evonik denies the allegations in Paragraph 29 and specifically denies that the 

Commission’s artificial “Pacific Northwest” market on which the allegations in Paragraph 29 are 

based constitutes a properly defined relevant geographic market. Evonik also specifically denies 

the allegations in the second sentence of Paragraph 29 on the grounds that, following the 

proposed divestiture of the Prince George plant, Evonik’s market share will remain unchanged. 
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30. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 30 and on that basis denies those allegations, except to admit that 

Evonik and other hydrogen peroxide producers compete vigorously to serve customers 

throughout the United States. Evonik specifically denies that the Commission’s artificial 

“Southern and Central United States” market on which the allegations in Paragraph 30 are based 

constitutes a properly defined relevant geographic market. 

31. Paragraph 31 contains characterizations of the Merger Guidelines and court 

opinions, which speak for themselves and to which no response is required; to the extent a 

response is deemed necessary, Evonik denies the allegations in Paragraph 31 and specifically 

denies that the Merger Guidelines are vested with the authority to determine the legality of any 

acquisition, presumptively or otherwise. 

32. Evonik denies the allegations in Paragraph 32. 

33. Evonik denies the allegations in Paragraph 33. Evonik further denies the 

allegations in Paragraph 33 on the grounds that concentration in the alleged Pacific Northwest 

market will remain unchanged following the divestiture of the Prince George plant. 

34. Evonik denies the allegations in Paragraph 34. 

35. Evonik denies the allegations in Paragraph 35. 

36. Evonik denies the allegations in Paragraph 36. 

37. Evonik denies the allegations in Paragraph 37. 

38. Evonik denies the allegations in the first sentence of Paragraph 38. As to the 

second sentence of Paragraph 38, Evonik admits that Degussa, Evonik’s predecessor, entered 

into an antitrust leniency agreement with the U.S. Department of Justice for its cooperation with 

a criminal antitrust investigation involving hydrogen peroxide in relation to conduct that ceased 
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in 2001—nearly twenty years ago; in all other respects, Evonik denies the allegations in the 

second sentence of Paragraph 38. The third sentence of Paragraph 38 purports to quote a plea 

agreement associated with conduct that ceased in 2001, to which Evonik refers the Court for a 

complete and accurate statement of its contents; to the extent a further response is deemed 

necessary, Evonik admits, on information and belief, that certain hydrogen peroxide producers 

entered plea agreements in relation to that same decades-old conduct. 

39. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 39 concerning other “North American hydrogen peroxide 

producers,” and on that basis denies those allegations. Evonik denies the remaining allegations 

in Paragraph 39 except to admit that Evonik seeks to gather public information or information 

from customers regarding the competitive conditions in the market(s) in which it competes. 

40. Evonik lacks knowledge or information sufficient to form a belief as to the 

allegations in Paragraph 40 as they relate to competitors and customers other than Evonik, and 

on that basis denies those allegations. With that qualification, Evonik admits that the major costs 

to produce hydrogen peroxide include natural gas and electricity and that it seeks to gather public 

information or information from customers regarding the competitive conditions in the market(s) 

in which it competes; in all other respects, Evonik denies the allegations in Paragraph 40. 

41. Evonik denies the allegations in Paragraph 41. 

42. Evonik denies the allegations in Paragraph 42. 

43. Evonik denies the allegations in Paragraph 43 except to admit that customers 

benefit substantially from competition among multiple North American producers. 

44. Evonik denies the allegations in the first sentence of Paragraph 44 except to admit 

that Evonik and other producers of hydrogen peroxide compete to serve customers throughout 
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the United States. Evonik lacks knowledge or information sufficient to form a belief as to the 

truth of the allegations regarding PeroxyChem in the second sentence of Paragraph 44 and on 

that basis denies those allegations; Evonik in all other respects denies the allegations in the 

second sentence of Paragraph 44 except to admit that Evonik seeks to gather public information 

regarding the competitive conditions in the market(s) in which it competes, which allows Evonik 

to respond to competition by offering better prices. As to the third sentence of Paragraph 44, 

Evonik admits that competition among multiple North American producers enables customers to 

pit producers against each other in negotiations to obtain lower prices and increased discounts. 

Evonik denies the remaining allegations in Paragraph 44. 

45. Evonik denies the allegations in Paragraph 45. 

46. Evonik denies the allegations in the first sentence of Paragraph 46. Evonik 

specifically denies the allegations in the first sentence of Paragraph 46 on the grounds that the 

divestiture of the Prince George plant will fully replace any alleged lost competition. Evonik 

lacks knowledge or information sufficient to form a belief as to the truth of the allegations in the 

second and third sentences of Paragraph 46 and on that basis denies those allegations. 

47. Evonik denies the allegations in Paragraph 47 and specifically denies that the 

Commission’s artificial “Pacific Northwest” and “Southern and Central United States” markets 

on which the allegations in Paragraph 47 are based constitute properly defined relevant 

geographic markets and that the Commission’s alleged hydrogen peroxide market, excluding 

electronics-grade hydrogen peroxide, constitutes a properly-defined relevant product market. 

48. Evonik denies the allegations in Paragraph 48. 

49. Evonik denies the allegations in Paragraph 49. 
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50. Evonik denies the allegations in the first sentence of Paragraph 50. Evonik denies 

the allegations in the second and third sentences of Paragraph 50 except to admit that, on 

information and belief, Solvay expanded capacity at its Longview, Washington plant in 2016. In 

all other respects, Evonik denies the allegations in Paragraph 50. 

51. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations as to “other industrial chemical producers” in Paragraph 51, and on that basis 

denies those allegations. 

52. Evonik lacks knowledge or information sufficient to form a belief as to the truth 

of the allegations in Paragraph 52 as they relate to other competitors or customers, and on that 

basis denies those allegations. In all other respects, Evonik denies the remaining allegations in 

Paragraph 52 except to admit that Evonik has not observed significant imports of hydrogen 

peroxide into North America. 

53. Evonik denies the allegations in Paragraph 53. 

54. Paragraph 54 incorporates by reference the allegations in Paragraphs 1 through 53 

of the Complaint; Evonik’s response to Paragraph 54 likewise incorporates Evonik’s responses 

to the allegations contained in Paragraphs 1 through 53. 

55. Paragraph 55 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 55. 

56. Paragraph 56 incorporates by reference the allegations in Paragraphs 1 through 53 

of the Complaint; Evonik’s response to Paragraph 56 likewise incorporates Evonik’s responses 

to the allegations contained in Paragraphs 1 through 53. 

57. Paragraph 57 contains legal conclusions to which no response is required; to the 

extent a response is deemed necessary, Evonik denies the allegations in Paragraph 57. 
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AFFIRMATIVE DEFENSES 

 The inclusion of any defense within this section does not constitute an admission that 

Evonik bears the burden of proof on each or any of the issues, nor does it excuse Plaintiff’s 

counsel from establishing each element of its purported claims. 

First Defense 

 The Complaint fails to state a claim on which relief can be granted. 

Second Defense 

 The relief sought in the Complaint is not in the public interest and the equities favor 

consummation of the Acquisition 

Third Defense

The Complaint fails to allege a plausible relevant product market. 

Fourth Defense 

 The Complaint fails to allege a plausible relevant geographic market. 

Fifth Defense 

 The Complaint fails to allege any plausible harm to competition. 

Sixth Defense 

 The benefits of the Acquisition significantly outweigh any alleged anticompetitive 

effects. 

Seventh Defense 

The proposed divestiture of the Prince George plant fully addresses any proffered 

anticompetitive effects in the alleged Pacific Northwest geographic market and ensures that there 

will be no harm to competition or consumers. 
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Additional Defenses 

Evonik reserves the right to assert any other available defenses. 

WHEREFORE, having fully answered the Complaint, Evonik respectfully requests that 

the Commission (i) deny the Complaint’s contemplated relief; (ii) dismiss the Complaint in its 

entirety with prejudice; (iii) award to Evonik its costs of suit, including expert fees and 

reasonable attorney fees, as may be allowed by law; and (iv) award to Evonik such other and 

further relief as the Commission deems just and appropriate. 

Date: August 20, 2019 

s/ Eric J. Mahr 

Eric J. Mahr 

Andrew J. Ewalt 

Justin Stewart-Teitelbaum 

Laura C. Onken 

Freshfields Bruckhaus Deringer US LLP 

700 13th Street NW, 10th Floor 

Washington, DC 20005 

Tel: 202-777-4545 

Email: eric.mahr@freshfields.com 

Counsel for Respondents RAG-Stiftung, Evonik 

Industries AG, Evonik Corporation, and Evonik 

International Holding, B.V. 
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CERTIFICATE OF SERVICE

I hereby certify that on August 20, 2019, I filed the foregoing documents using the FTC’s 

E-Filing System, which will send notification of such filing to: 

Office of the Secretary 

Federal Trade Commission 

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

Washington, DC 20580 

The Honorable D. Michael Chappell 

Chief Administrative Law Judge 

Federal Trade Commission, 

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

Washington, DC 20580 

 I also hereby certify that I caused a true and correct copy of the foregoing documents to 

be served upon the following via email: 

Amy Dobrzynski 

Cecelia Waldeck 

Daniel Matheson 

Dominic Vote 

Frances Anne Johnson 

Rames Rhillinger 

Michael Blevins 

Michael Lovinger 

Sean Hughto 

Stephen Santulli 

Steven Dahm 

Federal Trade Commission 

600 Pennsylvania Ave., NW 

Washington, DC 20580 

Complaint Counsel 

Mike G. Cowie 

James A. Fishkin 

Shari Ross Lahlou 

Brian E. Rafkin 

Anna Aryankalayil 

Blair Kuykendall 

Dechert LLP 

1900 K Street, NW 

Washington, DC 20006 

Counsel for Respondents One Equity Partners 

Secondary Fund, L.P., One Equity Partners 

V, L.P., Lexington Capital Partners VIII (AIV 

I), L.P., PeroxyChem Holding Company LLC, 

PeroxyChem Holdings, L.P., PeroxyChem 

Holdings LLC, PeroxyChem LLC, and 

PeroxyChem Cooperatief U.A. 

Dated: August 20, 2019 By: s/ Laura C. Onken 

 Laura C. Onken
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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. 

Dated: August 20, 2019 By: s/ Laura C. Onken 

 Laura C. Onken
Notice of Electronic Service 

I hereby certify that on August 20, 2019, I filed an electronic copy of the foregoing Respondent Evonik's 

Answer and Defenses to Complaint, with: 

D. Michael Chappell 

Chief Administrative Law Judge 

600 Pennsylvania Ave., NW 

Suite 110 

Washington, DC, 20580 

Donald Clark 

600 Pennsylvania Ave., NW 

Suite 172 

Washington, DC, 20580 

I hereby certify that on August 20, 2019, I served via E-Service an electronic copy of the foregoing 

Respondent Evonik's Answer and Defenses to Complaint, upon: 

Amy Dobrzynski 

Attorney 

Federal Trade Commission 

adobrzynski@ftc.gov 

Complaint 

Cecelia Waldeck 

Attorney 

Federal Trade Commission 

cwaldeck@ftc.gov 

Complaint 

Daniel Matheson 

Attorney 

Federal Trade Commission 

dmatheson@ftc.gov 

Complaint 

Dominic Vote 

Attorney 

Federal Trade Commission 

dvote@ftc.gov 

Complaint 

Frances Anne Johnson 

Attorney 

Federal Trade Commission 

fjohnson@ftc.gov 

Complaint 

James Rhilinger 

Attorney 

Federal Trade Commission 

jrhilinger@ftc.gov 

Complaint 

Michael Blevins 

Attorney 

Federal Trade Commission 

mblevins@ftc.gov 

Complaint 

Michael Lovinger 

Attorney 
Federal Trade Commission 

mlovinger@ftc.gov 

Complaint 

Sean Hughto 

Attorney 

Federal Trade Commission 

shughto@ftc.gov 

Complaint 

Stephen Santulli 

Attorney 

Federal Trade Commission 

ssantulli@ftc.gov 

Complaint 

Steven Dahm 

Attorney 

Federal Trade Commission 

sdahm@ftc.gov 

Complaint 

Eric Mahr 

Partner 

Freshfields Bruckhaus Deringer US LLP 

eric.mahr@freshfields.com 

Respondent 

Andrew Ewalt 

Partner 

Freshfields Bruckhaus Deringer US LLP 

andrew.ewalt@freshfields.com 

Respondent 

Justin Stewart-Teitelbaum 

Counsel 

Freshfields Bruckhaus Deringer US LLP 

justin.s-t@freshfields.com 

Respondent 

Mike Cowie 

Dechert LLP 

mike.cowie@dechert.com 

Respondent 

James Fishkin 

Partner 

Dechert LLP 

James.Fishkin@dechert.com 

Respondent 

Shari Ross Lahlou 

Dechert LLP 

shari.lahlou@dechert.com 

Respondent 

Brian Rafkin 

Dechert LLP 

brian.rafkin@dechert.com 

Respondent 

Anna Aryankalayil 

Dechert LLP 

anna.aryankalayil@dechert.com 
Respondent 

Blair Kuykendall 

Dechert LLP 

blair.kuykendall@dechert.com 

Respondent 

Laura Onken 

Senior Associate 

Freshfields Bruckhaus Deringer US LLP 

laura.onken@freshfields.com 

Respondent 

Laura Onken 

Attorney