Mr. Lipson was an author of the memorandum to Blackstone's Investment Committee and he knew the memorandum contained detailed information concerning competition in the funeral homes and cemeteries markets. Mr. Lipson had a copy of the memorandum in his own files, and he knew of its importance to the decision-making at Blackstone. Further, the explanations he provided to the FTC's staff about the failure to submit the Investment Committee Memorandum with Blackstone's filing were inconsistent. Accordingly, it is appropriate that Mr. Lipson pay a penalty for what was at a minimum his reckless disregard for his obligations under the HSR Act. A stipulated Final Judgment and Order is for settlement purposes only and does not constitute an admission by the defendant of a law violation.
Consent judgments have the force of law when signed by the judge.