UNITED STATES OF AMERICA,                                     v. MITSUBISHI CORPORATION,                                      Defendant.

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Criminal No. 00-033 Judge Marvin Katz Violations: 15 U.S.C. § 1 and 18 U.S.C. § 2(a) Filed: 05/16/00

Without admitting that the defendant has any legal right to any particulars other than those set forth in the Indictment and fully reserving all rights it may have to oppose or object to any request contained in the defendant's letter of February 11, 2000, requesting a Bill of Particulars, and further reserving the right to file further and amended particulars prior to trial, the United States of America, by its attorneys, voluntarily files this bill based on present knowledge, information and belief.

1.  The unindicted corporate and individual co-conspirators described in the Indictment that are presently known to the United States are listed below. The individual co-conspirators were employed by their respective co-conspirator corporations during all or part of the charged conspiracy.

1. Nippon Carbon Co. Ltd., Tokyo, Japan

   Shinichi Mori
   Yutaka Okada
   Yasuo Sakai
   Toshiko Takami
   Hirofumi Takado
   Yoshitake Yamagucchi
   

2. Pechiney Balzac S.A., Coarbevoie, France

   Claude Calvez
   Phillipe D'Argenlieu
   

3. Primary Industries, Inc., Tokyo, Japan

   Gen Hibi

4. The Carbide/Graphite Group, Inc., Pittsburgh, PA

   James G. Baldwin
   Walter Fowler
   David Higginbotham
   Nicholas Kaiser
   Donald Masyada
   Thomas L. Parks
   

5. SEC Corporation, Hyogo, Japan

   Takao Okabe
   Shigeki Takahara
   

6. SGL Carbon AG, Wiesbaden, Germany

   Rolf Ahele
   Robert J. Koehler
   H. Manfred Schuecker
   

7. Showa Denko KK, Tokyo, Japan and its U.S. subsidiary,
   Showa Denko Carbon, Inc., Ridgeville, SC

   Employed only by Showa Denko KK:
   

   Yoshiaki Furihata
   Makato Murata
   Hitoshi Tanaka
   

   Employed during various periods of the conspiracy by Showa Denko
   KK or Showa Denko Carbon, Inc.:
   
   

   Keiji Ishi
   
   Koh Matsushita
   
   Koji Tanaka
   
   Yoshi Watanabe
   
   Kazue Yamato
   

   Employed only by Showa Denko Carbon, Inc.:
   
   Robert C. Whitten

   Tokai Carbon Co. Ltd., Tokyo, Japan

   Yosiyuki Atsuji
   Yoshio Hirata
   Masahisa Sanmonji
   Yukio Tomita
   Naoshi Takahashi
   Hiroshi Yamazaki
   

   (i) UCAR Carbon Company and UCAR International, Inc., Danbury CT

   Frederick G. Bailine
   Thomas W. Burkett
   Robert J. Hart
   James Howell
   Robert P. Krass
   Maurice Marcellin
   Raymond Pelletier
   Georges Schwegler
   

   VAW Carbon GmbH, Germany

   Manfred Mueller

2. The conspiracy affected all countries in the free world where the conspirators marketed graphite electrodes. Home market leaders, as described in the Indictment, included UCAR in North America; UCAR and SGL in designated countries in Western Europe; and the Japanese co-conspirators collectively in Japan and the Far East. Market shares for the co-conspirators were discussed both on the basis of geographic regions and specific countries.

3. On or about the time that the defendant began negotiations to purchase 50% of the stock of UCAR, it formulated plans to foster the creation of a price-fixing conspiracy among certain of the world's producers of graphite electrodes. On February 25, 1991, defendant, in fact, did acquire 50% ownership interest in UCAR. Both prior to and subsequent to that date, defendant counseled, induced and encouraged UCAR and other industry participants to coordinate their prices. By March 1992, UCAR and competitors began to conspire to fix prices. Thereafter, and until at least June 1997, the defendant made statements and took actions, including those set forth in the Indictment, to aid and abet such a conspiracy. Those officers, employees, and agents of the defendant, presently known to the Government, who participated in such scheme are:

1. Corporations

   M.C. Carbon Co., Ltd., Tokyo, Japan
   Mitsubishi International Corporation, New York, NY
   Carbonex Corporation, Stamford, CT
   

2. Individuals

   Ichiro Fukushima
   Tetsuro Imai
   Tadashi Komatsu
   Seiji Kato
   Hiroshi Kawamura
   Yorizo Kimura
   Kenichi Koyanagi
   Y. Nakane
   Masao Nakayama
   Shiro Shinozaki
   Eisuke Shiozaki
   Ikusaburo Wakae
   Yutaka Yamamoto
   

4. The combination and conspiracy charged in the Indictment was carried out, in part, within the Eastern District of Pennsylvania within the five years preceding the filing of the Indictment through statements made and acts performed pursuant to the conspiracy, by certain conspirators, including sales of graphite electrodes to steel companies located within this District.

Dated:

Respectfully submitted,

________________________ ROBERT E. CONNOLLY JOSEPH MUOIO WENDY BOSTWICK NORMAN ROGER L. CURRIER Attorney, Philadelphia Office Antitrust Division U.S. Department of Justice The Curtis Center, Suite 650W 170 S. Independence Mall West Philadelphia, PA 19106 Tel. No.: (215) 597-7405

UNITED STATES OF AMERICA,                                     v. MITSUBISHI CORPORATION,                                      Defendant.

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Criminal No. 00-033 Judge Marvin Katz Violations: 15 U.S.C. § 1 and 18 U.S.C. § 2(a) Filed: 05/16/00

This is to certify that on the 16^th day of May 2000, a copy of the Government's Voluntary Bill of Particulars, has been mailed to counsel of record for the defendant as follows:

Theodore V. Wells, Jr., Esquire
Paul Weiss Rifkind Wharton & Garrison
1285 Avenue of the Americas
New York, NY 10019-6064

________________________ ROBERT E. CONNOLLY Attorney, Philadelphia Office Antitrust Division U.S. Department of Justice The Curtis Center, Suite 650W 170 S. Independence Mall West Philadelphia, PA 19106 Tel. No.: (215) 597-7405