FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 1 of 23 * PUBLIC *; 

 

 

 

PUBLIC 

UNITED STATES OF AMERICA 

BEFORE THE FEDERAL TRADE COMMISSION 

OFFICE OF ADMINISTRATIVE LAW JUDGES 

In the Matter of 

Microsoft Corp., 

a corporation, Docket No. 9412 

and 

Activision Blizzard, Inc., 

a corporation. 

RESPONDENTS’ OPPOSITION TO COMPLAINT COUNSEL’S 

MOTION TO COMPEL PRODUCTION 

The parties had a deal. Microsoft Corp. (“Microsoft”) would use technology assisted review 

(“TAR”) to respond to a massive Second Request, and later to refresh (and supplement) that 

production through the date of the Complaint. Activision Blizzard, Inc. (“Activision”) would do the 

same using search terms. Complaint Counsel would issue targeted requests for production, not to 

exceed 50. 

After receiving 17 million pages from that bargain, Complaint Counsel have now served 81 

wide-ranging RFPs that are not reasonably calculated to yield useful information. Complaint Counsel 

essentially make two demands: (1) that Respondents re-review millions of documents previously 

deemed least relevant, the burden of which is unjustifiable; and (2) that Respondents conduct a 

similarly burdensome review of post-Complaint documents, which is unlikely to yield non-privileged 

information and for which Complaint Counsel cite no precedent. Respondents have made clear that 

they will provide appropriate and targeted discovery of post-Complaint events, and have been doing 

so on an expedited basis. That is all the law requires. Complaint Counsel’s Motion should be denied. 

1
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 2 of 23 * PUBLIC *; 

 

 

 

 

 

 

PUBLIC 

BACKGROUND 

Complaint Counsel’s Motion omits key background context fatal to its request.1 This is not a 

dispute about Respondents’ unwillingness to produce relevant documents, but rather a dispute about 

Respondents’ unwillingness to pore through millions of documents previously agreed to be irrelevant 

because Complaint Counsel now hope to find needles in a haystack. 

Respondents’ Massive 2R Productions. The scope of the Second Request was immense. Staff 

defined the relevant product and service so broadly as to touch every aspect of Respondents’ gaming 

businesses and the proposed transaction. See Ex. A (Second Request to Microsoft); Ex. B (Second 

Request to Activision). Microsoft therefore determined that TAR was the best way to respond. TAR 

has become an industry-standard option to approach electronic discovery. Keeling Decl. ¶¶15-19; see 

also Rio Tinto PLC v. Vale S.A., 306 F.R.D. 125, 127, 129 (S.D.N.Y. 2015) (“[I]t is now black letter 

law that where the producing party wants to utilize TAR for document review, courts will permit it.” 

(collecting cases)). TAR learns to identify potentially responsive documents based on a statistical 

sample of the document universe coded by human reviewers. Keeling Decl. ¶¶16-18. The algorithm 

then assigns every document a numerical score for responsiveness, and non-privileged documents 

above a certain cutoff score are produced.2 Id. ¶18. 

Microsoft and Staff collaborated on the implementation of TAR during the investigation. The 

parties agreed on a list of 64 custodians and a TAR protocol, including a “recall rate” of 70. Id. ¶¶26-

27. This agreement meant that at least 70% of all responsive documents would be produced—or, put 

differently, Staff agreed that up to 30% of all responsive documents would not be produced. This 

recall rate is common in Second Requests because low-scoring documents are unlikely to be useful. 

1 The full context is set forth in detail in the declarations of Robert Keeling (“Keeling Decl.”) and 

Bradley Pierson (“Pierson Decl.”), attached hereto as Exs. C and J, respectively. 

2

 Human reviewers must still review responsive documents for privilege. 

2
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 3 of 23 * PUBLIC *; 

 

 

 

 

PUBLIC 

Id. ¶28. Using the agreed-upon TAR protocol, Microsoft produced more than 2.1 million documents 

totaling more than 9.5 million pages. Id. ¶31. 

Staff also audited the TAR process, confirming that the “null set” contained no meaningfully 

responsive documents. Id. ¶¶29-30. Microsoft thereafter certified substantial compliance, and Staff 

did not challenge certification. Id. ¶¶29-31. Afterward, between August and October 2022, Microsoft 

voluntarily “refreshed” its production, using the same TAR model, to include documents being 

produced to foreign antitrust regulators. Id. ¶31. At Staff’s request, Microsoft also added two 

additional custodians to this “refresh.” Id. 

Although employing human review, Activision likewise fully cooperated with Staff during the 

Second Request, resulting in the pre-Complaint production of over 850,000 documents from 49 

custodians. Pierson Decl. ¶6. At multiple points during the Second Request, Staff proposed additional 

custodians and search terms, nearly all of which Activision accepted. Id. ¶3. Unsurprisingly, 

therefore, Staff did not challenge Activision’s substantial compliance with the Second Request. Id. 

¶4. 

Respondents’ Voluntary Post-Complaint Productions. Shortly after the Complaint was filed, 

Respondents offered to refresh their Second Request productions up to the date of the Complaint in 

an effort to expedite party discovery. Keeling Decl. ¶33. During subsequent meet-and-confers, 

Microsoft informed Complaint Counsel that it would use TAR for the refresh. Complaint Counsel 

voiced no objections. Id. ¶¶33-34. Complaint Counsel built upon Microsoft’s approach by asking 

Microsoft to produce documents from 10 new custodians, with the understanding that Microsoft 

would continue to use the same TAR model. Id. ¶33. Microsoft agreed, relying on Complaint 

Counsel’s representation that they had no interest in reinventing the wheel through RFPs or in 

receiving yet more documents there would not be time to review. Id. ¶35. 

3
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 4 of 23 * PUBLIC *; 

 

 

 

 

 

 

PUBLIC 

Microsoft thereafter used TAR to produce an additional 270,000 documents created between 

substantial compliance and the date of the Complaint, plus 166,000 documents from the 10 new 

custodians. Id. ¶34. Thus, without receiving any formal discovery request, Microsoft produced more 

than 445,000 documents, totaling 3 million pages, after this litigation commenced. Id. Activision 

produced over 122,000 documents in the same vein. Pierson Decl. ¶6. 

Complaint Counsel Issued Improper and Overbroad RFPs. Notwithstanding this extensive 

course of dealing between the parties, and Respondents’ good-faith understanding of Complaint 

Counsel’s representations, Complaint Counsel served a set of wide-ranging RFPs shortly after the 

Complaint was filed. Two aspects of the RFPs are notable. 

First, Complaint Counsel violated the Court-ordered limit of 50 RFPs per party,

3 ultimately 

issuing 44 discrete requests to Microsoft and 37 to Activision. Complaint Counsel arrived at this 

approach by subdividing its numeric requests into subparts and by using run-on sentences to cram 

multiple requests into a “single” request. But that does not comply with FTC rules. A subpart counts 

separately if it can “stand alone and be answered irrespective of the answers to the others.” In re 

McWane, Inc. F.T.C. Dkt. No. 9351 (Apr. 16, 2012). Many of Complaint Counsel’s RFPs contain 

subparts that are logically and factually independent of each other; others count as more than one 

because they seek documents related to topics that could be answered without regard to the other. See 

Exs. E, K. 

Second, Complaint Counsel’s proposed approach essentially seeks to undo the parties’ 

understanding, requiring Respondents to re-review the “discard pile” and use new search terms for 

evidence they claim must be missing but cannot describe; and to review and produce post-Complaint 

3

 Exhibits E and K break the RFPs into their 81 separate subparts. 

4
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 5 of 23 * PUBLIC *; 

 

 

 

 

 

PUBLIC 

documents for more than 100 custodians, notwithstanding the fact that many of these documents are 

privileged. 

ARGUMENT 

I. Complaint Counsel’s Requests to Microsoft Are Duplicative and Unduly Burdensome. 

Complaint Counsel seek sweeping new searches of more than 14 million documents that 

simply duplicate what Staff requested and received in the Second Request. This would impose 

significant additional burden for no appreciable benefit. See In re Intuit, Inc., F.T.C. No. 9408 (Oct. 

31, 2022) (“Discovery shall be limited if the Administrative Law Judge determines that it is 

‘unreasonably cumulative or duplicative,’ or the ‘burden and expense of the proposed discovery ... 

outweigh its likely benefit.’” (quoting 16 C.F.R. §3.31(c)(2)(i), (iii))). 

Documents relevant to all the RFPs have already been produced. For example, Microsoft has 

produced more than 621,000 documents hitting on Complaint Counsel’s proposed search terms 

(including families). Keeling Decl. ¶¶22-23. These are the documents most likely to be responsive to 

Complaint Counsel’s RFPs, not Complaint Counsel’s proposed searches of the null set. Microsoft 

sampled the documents that would result from Complaint Counsel’s approach and identified virtually 

no responsive documents, finding instead nearly 98% false positives. Id. ¶¶45-47. Indeed, sampling 

found zero responsive documents for RFPs 3 and 11. Id. This is not surprising, since Staff also 

identified no responsive documents in their review of the null set validation sample. Id. ¶¶29-30. At 

the same time, undertaking this review would impose massive costs. Id. ¶¶41-44. 

Indeed, it is hard to imagine what additional documents Complaint Counsel are hoping to find 

given what has been produced to date on the specific RFPs identified in their Motion: 

RFP 1 asks for documents of the Searching across 

Microsoft’s productions to date reveals that approximately 194,000 documents hitting on Complaint 

Counsel’s terms (including their family members) have already been produced. Nevertheless, 

5
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 6 of 23 * PUBLIC *; 

 

PUBLIC 

Microsoft conducted additional diligence in response to Complaint Counsel’s concerns and produced 

all responsive documents identified, including audio or video recordings and files from three 

central repositories.4 Id. ¶23. 

RFP 3 asks for documents related to cross-play. Again, searching across Microsoft’s 

productions to date using Complaint Counsel’s search terms reveals that more than 127,000 

documents, including their family members, have already been produced. Id. ¶23. 

RFP 6 asks for documents related to A search of Microsoft’s 

productions to date reveals that more than 124,000 documents hitting on Complaint Counsel’s search 

terms, including their family members, have already been produced. In addition, Microsoft has 

identified video recordings related to which were produced on March 13. Id. 

¶¶23, 37. 

RFP 11 asks for documents related to exclusivity decision-making. Complaint Counsel’s 

exclusivity search terms hit on more than 205,000 documents Microsoft has already produced. 

Microsoft has also produced which Complaint Counsel did not request before 

filing the motion, see Mot. 7, and which does not even contain any of Complaint Counsel’s proposed 

RFP 11 search terms. Keeling Decl. ¶¶23, 50. 

Finally, in response to RFP 16, Microsoft has produced all existing third-party agreements to 

distribute Activision content, often on an expedited basis, together with external communications 

about those agreements. Id. ¶38. If Microsoft reaches additional third-party agreements to distribute 

Activision content, it will produce those agreements and any related external communications. Id. 

4 As Microsoft has repeatedly explained to Complaint Counsel, 

mailboxes. Responsive, nonprivileged documents for nine members of this distribution list have 

already been produced. 

is not a 

mailbox that contains emails, but a distribution list that routes emails to individual team members’ 

6
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 7 of 23 * PUBLIC *; 

 

 

 

 

PUBLIC 

Complaint Counsel’s demand for internal communications regarding these agreements is 

unreasonable because virtually all of those communications are likely privileged. Id. 

Against that backdrop, it is telling to look at what Complaint Counsel have identified as the 

gaps in the production. Despite asking for a re-review of 14 million documents, they have identified 

only three documents they claim are relevant but were not produced. Mot. 6, 7. Even if marginally 

relevant documents in the TAR null set were an appropriate consideration here, Complaint Counsel 

are wrong on the facts. Two of these documents were produced, and the third would not have been 

produced by Complaint Counsel’s requested approach. Notably, however, Microsoft promptly located 

and produced that document this week—as Microsoft has been doing with every other specific 

document Complaint Counsel have requested. Keeling Decl. ¶¶49-50. 

In short, Complaint Counsel have provided nothing close to the strong showing required to 

justify backtracking on an agreed approach that has already generated a massive amount of evidence. 

See PRCM Advisers LLC v. Two Harbors Invst. Corp., 2022 WL 18027565, at *6 (S.D.N.Y. Dec. 30, 

2022) (“Courts enforce discovery deals not only because lawyers should abide by their agreements, 

but also because if the parties could not rely on courts to enforce discovery agreements, there would 

be little incentive for parties to make them.” (citations and internal quotation marks omitted)). No 

court has ever ordered a party using TAR pursuant to an agreed protocol to further review documents 

in the null set that hit on broad search terms. See Keeling Decl. ¶¶55-57. Complaint Counsel cannot 

show that this case should be the first. 

II. Complaint Counsel’s Requests to Activision Should Also Be Denied. 

Likewise, the RFPs to Activision that Complaint Counsel move to compel are subsumed 

within—and unreasonably duplicative of—Second Request specifications. Requiring that Activision 

engage in the additional, duplicative discovery that Complaint Counsel demand would impose a 

burden and expense that outweigh any imagined benefit. 

7
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 8 of 23 * PUBLIC *; 

 

 

PUBLIC 

RFP 1 is subsumed within Specifications 7, 8, 9, and 10 of the Second Request, pursuant to 

which Activision produced over 423,000 documents, including 57,473 documents from the three 

custodians referenced in Complaint Counsel’s proposed order. Pierson Decl. ¶7. While the Motion 

demands that Activision produce studies from its marketing department, Activision’s Second Request 

production already contained hundreds of such studies. Id. ¶7. Even under Complaint Counsel’s 

purported compromise, Activision would have to review approximately 507,292 documents for 

responsiveness to RFP 1, which would cost approximately Id. ¶7. RFP 1 is thus both 

unreasonably duplicative and burdensome. 

RFP 2 is similarly duplicative of Specifications 7, 8, and 16 of the Second Request, pursuant 

to which Activision produced more than 457,000 documents. Id. ¶8. Complaint Counsel contend that 

Activision did not search the term “cross-play” during the Second Request, but “cross-play” (and 

iterations thereof) appears in more than 185,000 documents in Activision’s productions. Id. ¶8. Given 

the low responsiveness rate (0.06%) of a random sample of these documents and the large volume of 

documents already produced, Complaint Counsel’s demands regarding RFP 2 are unreasonably 

duplicative and burdensome. Id. ¶8.5 

III. Complaint Counsel’s Demand for Post-Complaint Documents Imposes Substantial and 

Unjustified Burden. 

In addition to its demand for a discovery do-over, Complaint Counsel also clamor for 

extensive post-Complaint discovery “through February 28, 2023.” Mot. 3. This should also be denied. 

Respondents are unaware of any precedents requiring production of documents generated 

after the date of the Complaint, and Complaint Counsel have identified none. See SPS Techs., LLC v. 

Boeing Co., 2019 WL 2409601, at *8 (N.D. Ill. June 7, 2019) (“Ordering review and production of 

5

 Although RFPs 5, 7, and 8 are also unreasonably duplicative of prior productions, Activision will 

agree to Complaint Counsel’s proposals related to those requests because the additional review 

required is not unduly burdensome. 

8
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 9 of 23 * PUBLIC *; 

 

 

PUBLIC 

communications post-Complaint runs the risk of including too many irrelevant documents being 

swept into the review.”). And for good reason—to keep discovery open to the date the Motion was 

filed would result in an untenable burden on Respondents, who have already been producing 

documents related to real-time events on an expedited basis. 

Since the Complaint was filed, many of Respondents’ custodians have been involved in 

defending this proceeding and regulatory proceedings in Europe and the United Kingdom, 

significantly increasing the proportion of their documents that are privileged or protected. Keeling 

Decl. ¶¶52-53. To produce post-Complaint documents, Respondents would therefore have to review 

hundreds of thousands of documents from these custodians, in addition to navigating a cumbersome 

clawback process should any privileged documents slip through. Id. ¶¶51-54. 

Respondents have made clear that they will produce appropriate relevant post-Complaint 

discovery, and have been actively doing so on a priority basis; for example, directly emailing to 

Complaint Counsel post-Complaint agreements reached with third parties that may impact Complaint 

Counsel’s theories of harm, and expediting the production of external communications related to 

those deals. But there is no warrant for the broad-ranging additional and burdensome discovery that 

Complaint Counsel demand. 

CONCLUSION 

For the foregoing reasons, the Motion to Compel should be denied. 

9
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 10 of 23 * PUBLIC *; 

 

 

 

PUBLIC 

Dated: March 15, 2023 

By: /s/ Steven C. Sunshine 

Steven C. Sunshine 

Julia K. York 

Jessica R. Watters 

Skadden, Arps, Slate, Meagher & Flom LLP 

1440 New York Avenue, N.W. 

Washington, DC 20005 

Telephone: (202) 371-7860 

Fax: (202) 661-9126 

steve.sunshine@skadden.com 

julia.york@skadden.com 

jessica.watters@skadden.com 

Maria A. Raptis 

Michael J. Sheerin 

Matthew M. Martino 

Evan R. Kreiner 

Andrew D. Kabbes 

Bradley J. Pierson 

Skadden, Arps, Slate, Meagher & Flom LLP 

One Manhattan West 

New York, NY 10001 

Telephone: (212) 735-2425 

Fax: (917) 777-2425 

maria.raptis@skadden.com 

michael.sheerin@skadden.com 

matthew.martino@skadden.com 

evan.kreiner@skadden.com 

andrew.kabbes@skadden.com 

bradley.pierson@skadden.com 

Counsel for Activision Blizzard, Inc. 

Respectfully submitted, 

By: /s/ Beth Wilkinson 

Beth Wilkinson 

Rakesh N. Kilaru 

Kieran Gostin 

Grace L. Hill 

Anastasia M. Pastan 

Sarah E. Neuman 

Wilkinson Stekloff LLP 

2001 M Street NW, 10th Floor 

Washington, DC 20036 

Telephone: (202) 847-4000 

Fax: (202) 847-4005 

bwilkinson@wilkinsonstekloff.com 

rkilaru@wilkinsonstekloff.com 

kgostin@wilkinsonstekloff.com 

ghill@wilkinsonstekloff.com 

apastan@wilkinsonstekloff.com 

sneuman@wilkinsonstekloff.com 

Michael Moiseyev 

Megan A. Granger 

Weil Gotshal & Manges LLP 

2001 M Street NW 

Suite 600 

Washington, DC 20036 

(202) 682-7026 

michael.moiseyev@weil.com 

megan.granger@weil.com

 Counsel for Microsoft Corp. 

10
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 11 of 23 * PUBLIC *; PUBLIC

Exhibit A 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

11
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 12 of 23 * PUBLIC *; PUBLIC

Exhibit B 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

12
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 13 of 23 * PUBLIC *; PUBLIC

Exhibit C 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

13
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 14 of 23 * PUBLIC *; PUBLIC

Exhibit D 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

14
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 15 of 23 * PUBLIC *; PUBLIC

Exhibit E 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

15
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 16 of 23 * PUBLIC *; PUBLIC

Exhibit F 

[CONFIDENTIAL - REDACTED IN ENTIRETY]

16
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 17 of 23 * PUBLIC *; PUBLIC

Exhibit G 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

17
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 18 of 23 * PUBLIC *; PUBLIC

Exhibit H 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

18
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 19 of 23 * PUBLIC *; PUBLIC

Exhibit I 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

19
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 20 of 23 * PUBLIC *; PUBLIC

Exhibit J 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

20
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 21 of 23 * PUBLIC *; PUBLIC

Exhibit K 

[CONFIDENTIAL - REDACTED IN ENTIRETY] 

21
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 22 of 23 * PUBLIC *; 

 

 

 

 

 

 

 

 

PUBLIC 

CERTIFICATE OF SERVICE 

I hereby certify that on March 15, 2023, I caused a true and correct copy of the 

foregoing to be filed electronically using the FTC’s E-Filing System and served the following 

via email: 

April Tabor 

Secretary 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm H-113 

Washington, DC 20580 

ElectronicFilings@ftc.gov 

The Honorable D. Michael Chappell 

Administrative Law Judge 

Federal Trade Commission 

600 Pennsylvania Ave., NW, Rm H-110 

Washington, DC 20580 

I also certify that I caused the forgoing document to be served via email to: 

James H. Weingarten (jweingarten@ftc.gov) 

James Abell (jabell@ftc.gov) 

Cem Akleman (cakleman@ftc.gov) 

Taylor Alexander (talexander@ftc.gov) 

J. Alexander Ansaldo (jansaldo@ftc.gov) 

Peggy Bayer Femenella (pbayerfemenella@ftc.gov) 

Michael T. Blevins (mblevins@ftc.gov) 

Amanda L. Butler (abutler2@ftc.gov) 

Nicole Callan (ncallan@ftc.gov) 

Maria Cirincione (mcirincione@ftc.gov) 

Kassandra DiPietro (kdipietro@ftc.gov) 

Jennifer Fleury (jfleury@ftc.gov) 

Michael A. Franchak (mfranchak@ftc.gov) 

James Gossmann (jgossmann@ftc.gov) 

Ethan Gurwitz (egurwitz@ftc.gov) 

Meredith Levert (mlevert@ftc.gov) 

David E. Morris (dmorris1@ftc.gov) 

Merrick Pastore (mpastore@ftc.gov) 

Stephen Santulli (ssantulli@ftc.gov) 

Edmund Saw (esaw@ftc.gov) 

U.S. Federal Trade Commission 

600 Pennsylvania Ave., N.W. 

Washington, DC 20580 

Telephone: (202) 326-3570 

22
FEDERAL TRADE COMMISSION | OFFICE OF THE SECRETARY | FILED 3/15/2023 | Document No. 607223 | PAGE Page 23 of 23 * PUBLIC *; 

PUBLIC 

Counsel Supporting the Complaint 

/s/ Beth Wilkinson 

Beth Wilkinson 

Counsel for Microsoft Corp. 

23