UNITED STATES OF AMERICA
 

BEFORE THE FEDERAL TRADE COMMISSION
 

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In the Matter of ) Docket No. 9327 5l-q977 

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Polypore International, Inc. 

a corporation 

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DECLATION OF DOUGLAS GILLESPIE 

IN SUPPORT OF IN CAMERA TREATMENT 

Pursuant to 28 V.S.C. § 1746, I hereby make the following statement: 

1. My name is Douglas Gilespie. I am the Vice President for Global Procurement 

for Exide Technologies. On September 30, 2009, I signed the "Declaration Of Douglas 

Gillespie" ("Gilespie Declaration") which Complaint Counsel submitted with its 

Response To Respondent's Second Motion To Reopen The Hearing Record. I submit 

this declaration in support of Exide Technologies' (I) Motion For In Camera Treatment 

Of The Gilespie Declaration, and (II) Opposition To Respondent's Motion For A Court 

Order Allowing Respondent To Review The Declaration Of Douglas Gilespie. 

2. The Gilespie Declaration contained information that is highly confidentiaL. 

Public disclosure of that material would seriously har Exide's commercial and 

competitive interests. For that reason, Exide requests that the Gilespie Declaration be 

given in camera treatment until such time as disclosure wil not cause this harm. 

3. The Gilespie Declaration principally discusses Exide's ongoing negotiations with
 

Daramic for the supply of separators. The declaration discloses, among other things, 

Exide's analysis of 
 the available sources of supply for separators used to produce flooded 

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automotive (SLI) batteries in North America and separators used to produce flooded 

motive, deep cycle, and UPS batteries manufactured in North America. It also discloses 

highly confidential information concerning Exide's plans and expectations concerning 

potential contractual arangements with Daramic and others after the expiration of 

Exide's current contract with DaramIc at the end of2009. Disclosure ofthis information 

would cause serious harm to Exide's ability to negotiate new supply arangements. 

4. Disclosure of the Gilespie Declaration to DaramIc business executives, in
 

paricular, would har Exide's position in the ongoing negotiations. In my experience as
 

the executive in charge of negotiating Exide's procurement contracts, disclosure of 

information ofthis type may lead to a significant negotiating disadvantage. 

5. This information about Exide's negotiating plans and options is treated by the
 

company as highly confidentiaL. The information is distributed withi the company only 

to those who have a specific need for it. These individuals are typically bound by 

confidentiality obligations that would prohibit them from disclosing the information if 

they left the company. This information is not disclosed to others outside ofthe company 

and, in paricular, is not disclosed to Exide's competitors or suppliers. 

6. Whatever the result of current negotiations, Exide may find itself negotiating with 

DaramIc for a new agreement at any time in the foreseeable future. Disclosure of the 

Gilespie Declaration would prejudice Exide's negotiating position in such negotiations. 

For this reason, I believe that the information in the Gilespie Declaration should receive 

in camera treatment for a period of at least three years, and that any shorter period would 

risk substantial competitive and commercial har to Exide. 

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I declare under penalty of perjury under the laws of the United States of America that the 

foregoing is true and correct. 

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Douglas Gilespie Date 

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