Beginning in part at least as early as January 1990 and continuing in part until February 1999, the exact dates being unknown to the United States, the defendant and co-conspirators entered into and participated in a combination and conspiracy to suppress and eliminate competition by fixing the price and allocating the volume of certain vitamins manufactured and sold in the United States and elsewhere, and to allocate customers for vitamin premixes sold in the United States. Vitamins are organic compounds required in the diet of humans and animals for normal growth and maintenance of life. Vitamins are essential sources of certain coenzymes necessary for metabolism, the biochemical processes that support life. All known vitamins have been synthesized chemically, and various such synthesized vitamins are manufactured and sold by the defendant and its corporate co-conspirators.
Vitamins are necessary for the normal and healthy growth and development of both humans and animals.
A and E, vitamin B2, vitamin B5, vitamin C, and beta carotene are sold to customers in the human food, pharmaceutical and animal feed industries. Vitamin premixes are a blend of several vitamins and other products in either dry or spray-on applications. Formulated and sold as additives, these vitamin premix applications are used to enrich human food and animal feed products. During the period covered by this Information, the defendant was a corporation organized and existing under the laws of Germany, with its principal place of business in Lugwigshafen, Germany. The defendant is engaged in the manufacture and sale of vitamins and vitamin premixes in the United States and elsewhere.