Commission européenne, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229 -91111. Fax: +32 229 -64301. E -mail: COMP -MERGER -REGISTRY@ec.europa.eu . 
  EUROPEAN COMMISSION  
Brussels,  08.01.2019  
C(2019 ) 104 final  
 
 
 
 
 
 To the notifying party:  
 
 
Subject : Case M. 9191 – SOFTWAREONE / COMPAREX   
Commission decision pursuant to Article 6(1)(b) of Council Regulation (EC) 
No 139/20041 and Article 57 of the Agreement on the European Economic Area2  
Dear Sir or Madam,  
1. On 4 December 2018 , the European Commission received notification of a proposed 
concentration pursuant to Article 4 of the Merger  Regulation by which  the undertaking 
Softwa reONE (Switzerland) acquires  within the meaning of Article 3(1)(b) of the Merger 
Regulation  sole control of the whole of  the undertaking Comparex AG (Germany ) by way 
of a purchase of shares .3 
2. The business activities of the undertakings concerned are:  
 for SoftwareONE4: distribution of information technology (“IT”) products and the 
provision of IT services. It helps customers optimise their software sourcing (process 
and commercial terms) and the technical setup of their software architecture. It 
manages all  aspects of its customers’ software portfolios . 
                                                 
1 OJ L 24, 29.1.2004, p. 1 ( the 'Merger Regulation '). With effect from 1 December 2009,  the Treaty on the 
Functioning of the European Union ( 'TFEU ') has introduced certain changes, such as the replacement of 
'Communi ty' by 'Union ' and 'common market ' by 'internal market '. The terminology of the TFEU will be used 
throughout this decision.  
2  OJ L 1, 3.1.1994, p.  3 (the 'EEA Agreement '). 
3  Publication in the Official Journal of the European Union No C 446, 11.12.2018 , p. 14. 
4  Investment funds advised or managed by affiliates of KKR & Co. Inc. (together with its affiliates, “KKR”) 
acquired indirect negative sole control over SoftwareONE in 2015.  KKR is a global investment firm, which 
offers a broad range of alternative  asset funds and other investment products to investors and provides capital 
markets solutions for the firm, its portfolio companies and other clients. KKR’s affiliated private equity funds 
invest in companies in a variety of sectors. Each KKR -affiliated p ortfolio company has its own board of 
directors, which generally includes one or more KKR representatives, and is operated and financed 
independently from other KKR -affiliated portfolio companies . 
PUBLIC VERSION  
2  for Comparex : provision of IT services and the distribution of IT products. It serves 
corporate customers spanning from small businesses to large international 
corporations as well as public institutions. Com parex’s portfolio of services 
encompasses license management, software procurement and cloud services, and 
software asset management.  
3. After examination of the notification, the European Commission has concluded that the 
notified operation falls within the scope of the Merger  Regulation  and of paragraph 5(c) of 
the Commission Notice on a simplified procedure for treatment of certain concentrations 
under Council Regulation (EC) No 139/2004 .5 
4. For the reasons set out in the Notice on a simplified procedure, the European Commission 
has decided not to oppose the notified operation and to declare it compatible with the 
internal market and with the EEA Agreement. This decision is adopted in applicat ion of 
Article 6(1)(b) of the Merger  Regulation  and Article 57 of the EEA Agreement . 
For the Commission  
(signed)  
Johannes LAITENBERGER  
Director -General  
 
                                                 
5  OJ C 366, 14.12.2013, p. 5 .