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IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA

UNITED STATES OF AMERICA,                                     v. ACE SCHIFFLI EMBROIDERY CO., INC.,                         Defendant.

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Criminal No.: 95-00540 Filed: [9/27/95] 15 U.S.C. § 1 Judge Newcomer

   
                        INFORMATION
     The United States of America, acting through its attorneys,
charges:
                                I
               DEFENDANT AND CO-CONSPIRATORS
     1.   ACTION EMBROIDERY CORPORATION (ACTION) is hereby made a
defendant on the charge stated below.  ACTION is a corporation
organized and existing under the laws of the State of California,
with its principal place of business in Ontario, California. 
During the period covered by this information, ACTION
manufactured embroidered insignia which it sold to the Army Air
Force Exchange Service (AAFES) for resale to United States
military personnel.
     2.   Various individuals and companies, not made defendants
herein, participated as co-conspirators in the offense charged
herein and performed acts and made statements in furtherance
thereof.
     3.   Wherever in this information reference is made to any
act, deed or transaction of a corporation, the allegation means
                                                   Page 2

that the corporation engaged in the act, deed or transaction by
or through its officers, directors, agents, employees or
representatives while they were actively engaged in the
management, direction, control or transaction of its business or
affairs.
                                II
                       BACKGROUND
     4.   AAFES operates over 3,000 retail facilities and
clothing stores on military installations worldwide at which
embroidered military insignia are offered for sale to military
personnel.  Military insignia are accessories attached to a
soldier's uniform to designate branch of service, unit, rank, and
also identify the wearer's years of service, campaigns served,
training completed and meritorious and heroic conduct performed. 
Embroidered insignia are manufactured and sold to AAFES by the
defendant and co-conspirator companies.
     5.   AAFES procures embroidered insignia through
competitively bid individual bulk contracts with awards made to
the qualified bidder offering the lowest price.  During the
period covered by this information, ACTION and its co-conspirator
companies supplied AAFES with embroidered insignia under
competitively bid individual bulk contracts.  
                               III
                 OFFENSE CHARGED       
     6.   Beginning at least as early as January 1990 and
continuing at least until December 1993, the exact dates being
                                                   Page 3

unknown to the United States, the defendant and co-conspirators
entered into and participated in a combination and conspiracy to
suppress and eliminate competition in unreasonable restraint of
interstate and foreign trade and commerce.
     7.   The charged conspiracy consisted of a continuing 
agreement, understanding and concert of action among the
defendant and co-conspirators, the substantial terms of which
were to submit collusive, noncompetitive and rigged bids for
certain bulk embroidered insignia contracts with AAFES.
     8.   For the purpose of forming and carrying out the charged
conspiracy, the defendant and co-conspirators did those things
which they combined and conspired to do, including, among other
things:
          (a)  discussing among themselves the submission of
               prospective bids on individual bulk embroidered
               insignia contracts;
          (b)  agreeing among themselves which company would be
               the low bidder for the aforementioned contracts;
               and
          (c)  submitting collusive, noncompetitive and rigged
               bids for the aforementioned contracts.
                                IV
                   TRADE AND COMMERCE
     9.   During the period covered by this information, a
substantial quantity of the embroidered insignia items
manufactured by the defendant and co-conspirators were shipped
across state lines and overseas to military facilities throughout
the United States and abroad.
                                                   Page 4

    10.   During the period covered by this information, the
activities of the defendant and co-conspirators, which are the
subject of this information, were within the flow of, and
substantially affected, interstate and foreign trade and
commerce.
                                V.
                                 
               JURISDICTION AND VENUE

     11.  The combination and conspiracy charged in this
information was formed and carried out, in part, within the
Eastern District of Pennsylvania, within the five years preceding
the filing of this Information.

     
     ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 1.

Dated:

_______________"/s/"________________ JOEL I. KLEIN Acting Assistant Attorney General _______________"/s/"________________ GARY R. SPRATLING Deputy Assistant Attorney General _______________"/s/"________________ ROBERT E. CONNOLLY Attorneys, Antitrust Division U.S. Department of Justice _______________"/s/"________________ MICHAEL R. STILES United States Attorney Eastern District of Pennsylvania

_______________"/s/"________________ WILLARD S. SMITH _______________"/s/"________________ BRADFORD L. GEYER Attorneys, Antitrust Division U.S. Department of Justice Middle Atlantic Office The Curtis Center, Suite 650W 7th and Walnut Streets Philadelphia, Pennsylvania 19106 Tel.: (215) 597-7401