Broadcom Limited and Brocade Communications Systems, Inc.; Analysis To Aid Public Comment, 32186-32188 [2017-14536]
Download as PDF
32186
Federal Register / Vol. 82, No. 132 / Wednesday, July 12, 2017 / Notices
banks and nonbanking companies
owned by the bank holding company,
including the companies listed below.
The applications listed below, as well
as other related filings required by the
Board, are available for immediate
inspection at the Federal Reserve Bank
indicated. The applications will also be
available for inspection at the offices of
the Board of Governors. Interested
persons may express their views in
writing on the standards enumerated in
the BHC Act (12 U.S.C. 1842(c)). If the
proposal also involves the acquisition of
a nonbanking company, the review also
includes whether the acquisition of the
nonbanking company complies with the
standards in section 4 of the BHC Act
(12 U.S.C. 1843). Unless otherwise
noted, nonbanking activities will be
conducted throughout the United States.
Unless otherwise noted, comments
regarding each of these applications
must be received at the Reserve Bank
indicated or the offices of the Board of
Governors not later than August 7, 2017.
A. Federal Reserve Bank of Boston
(Prabal Chakrabarti, Senior Vice
President) 600 Atlantic Avenue, Boston,
Massachusetts 02210–2204. Comments
can also be sent electronically to
BOS.SRC.Applications.Comments@
bos.frb.org:
1. Berkshire Hills Bancorp, Inc.,
Pittsfield, Massachusetts; to acquire 100
percent of the shares of Commerce
Bancshares Corporation and thereby
acquire, Commerce Bank and Trust
Company, both of Worcester,
Massachusetts.
B. Federal Reserve Bank of Dallas
(Robert L. Triplett III, Senior Vice
President) 2200 North Pearl Street,
Dallas, Texas 75201–2272:
1. Maple Financial Holdings, Inc.,
Dallas, Texas; to become a bank holding
company by acquiring The First
National Bank of Edgewood, Edgewood,
Texas.
Board of Governors of the Federal Reserve
System, July 7, 2017.
Michele T. Fennell,
Assistant Secretary of the Board.
[FR Doc. 2017–14587 Filed 7–11–17; 8:45 am]
BILLING CODE 6210–01–P
FEDERAL TRADE COMMISSION
asabaliauskas on DSKBBXCHB2PROD with NOTICES
[File No. 171 0027]
Broadcom Limited and Brocade
Communications Systems, Inc.;
Analysis To Aid Public Comment
Federal Trade Commission.
Proposed consent agreement.
AGENCY:
ACTION:
The consent agreement in this
matter settles alleged violations of
SUMMARY:
VerDate Sep<11>2014
17:54 Jul 11, 2017
Jkt 241001
federal law prohibiting unfair methods
of competition. The attached Analysis to
Aid Public Comment describes both the
allegations in the complaint and the
terms of the consent order—embodied
in the consent agreement—that would
settle these allegations.
DATES: Comments must be received on
or before August 2, 2017.
ADDRESSES: Interested parties may file a
comment at https://
ftcpublic.commentworks.com/ftc/
broadcombrocadeconsent/ online or on
paper, by following the instructions in
the Request for Comment part of the
SUPPLEMENTARY INFORMATION section
below. Write ‘‘In the Matter of
Broadcom Limited and Brocade
Communications Systems, Inc., File No.
171 0027’’ on your comment and file
your comment online at https://
ftcpublic.commentworks.com/ftc/
broadcombrocadeconsent/ by following
the instructions on the web-based form.
If you prefer to file your comment on
paper, write ‘‘In the Matter of Broadcom
Limited and Brocade Communications
Systems, Inc., File No. 171 0027’’ on
your comment and on the envelope, and
mail your comment to the following
address: Federal Trade Commission,
Office of the Secretary, 600
Pennsylvania Avenue NW., Suite CC–
5610 (Annex D), Washington, DC 20580,
or deliver your comment to the
following address: Federal Trade
Commission, Office of the Secretary,
Constitution Center, 400 7th Street SW.,
5th Floor, Suite 5610 (Annex D),
Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT:
Stephen Antonio (202–326–2536),
Bureau of Competition, Mergers II
Division, 600 Pennsylvania Avenue
NW., Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant
to Section 6(f) of the Federal Trade
Commission Act, 15 U.S.C. 46(f), and
FTC Rule 2.34, 16 CFR 2.34, notice is
hereby given that the above-captioned
consent agreement containing consent
order to cease and desist, having been
filed with and accepted, subject to final
approval, by the Commission, has been
placed on the public record for a period
of thirty (30) days. The following
Analysis to Aid Public Comment
describes the terms of the consent
agreement, and the allegations in the
complaint. An electronic copy of the
full text of the consent agreement
package can be obtained from the FTC
Home Page (for July 3, 2017), on the
World Wide Web, at https://www.ftc.gov/
news-events/commission-actions.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
PO 00000
Frm 00027
Fmt 4703
Sfmt 4703
before August 2, 2017. Write ‘‘In the
Matter of Broadcom Limited and
Brocade Communications Systems, Inc.,
File No. 171 0027’’ on your comment.
Your comment—including your name
and your state—will be placed on the
public record of this proceeding,
including, to the extent practicable, on
the public Commission Web site, at
https://www.ftc.gov/policy/publiccomments.
Postal mail addressed to the
Commission is subject to delay due to
heightened security screening. As a
result, we encourage you to submit your
comments online. To make sure that the
Commission considers your online
comment, you must file it at https://
ftcpublic.commentworks.com/ftc/
broadcombrocadeconsent/ by following
the instructions on the web-based form.
If this Notice appears at https://
www.regulations.gov/#!home, you also
may file a comment through that Web
site.
If you prefer to file your comment on
paper, write ‘‘In the Matter of Broadcom
Limited and Brocade Communications
Systems, Inc., File No. 171 0027’’ on
your comment and on the envelope, and
mail it to the following address: Federal
Trade Commission, Office of the
Secretary, 600 Pennsylvania Avenue
NW., Suite CC–5610 (Annex D),
Washington, DC 20580, or deliver your
comment to the following address:
Federal Trade Commission, Office of the
Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610
(Annex D), Washington, DC. If possible,
submit your paper comment to the
Commission by courier or overnight
service.
Because your comment will be placed
on the publicly accessible FTC Web site
at www.ftc.gov, you are solely
responsible for making sure that your
comment does not include any sensitive
or confidential information In
particular, your comment should not
include any sensitive personal
information, such as your or anyone
else’s Social Security number; date of
birth; driver’s license number or other
state identification number, or foreign
country equivalent; passport number;
financial account number; or credit or
debit card number. You are also solely
responsible for making sure that your
comment does not include any sensitive
health information, such as medical
records or other individually
identifiable health information. In
addition, your comment should not
include any ‘‘trade secret or any
commercial or financial information
which . . . is privileged or
confidential’’—as provided by Section
6(f) of the FTC Act, 15 U.S.C. 46(f), and
E:\FR\FM\12JYN1.SGM
12JYN1
Federal Register / Vol. 82, No. 132 / Wednesday, July 12, 2017 / Notices
FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2)—
including in particular competitively
sensitive information such as costs,
sales statistics, inventories, formulas,
patterns, devices, manufacturing
processes, or customer names.
Comments containing material for
which confidential treatment is
requested must be filed in paper form,
must be clearly labeled ‘‘Confidential,’’
and must comply with FTC Rule 4.9(c).
In particular, the written request for
confidential treatment that accompanies
the comment must include the factual
and legal basis for the request, and must
identify the specific portions of the
comment to be withheld from the public
record. See FTC Rule 4.9(c). Your
comment will be kept confidential only
if the General Counsel grants your
request in accordance with the law and
the public interest. Once your comment
has been posted on the public FTC Web
site—as legally required by FTC Rule
4.9(b)—we cannot redact or remove
your comment from the FTC Web site,
unless you submit a confidentiality
request that meets the requirements for
such treatment under FTC Rule 4.9(c),
and the General Counsel grants that
request.
Visit the Commission Web site at
https://www.ftc.gov to read this Notice
and the news release describing it. The
FTC Act and other laws that the
Commission administers permit the
collection of public comments to
consider and use in this proceeding as
appropriate. The Commission will
consider all timely and responsive
public comments that it receives on or
before August 2, 2017. You can find
more information, including routine
uses permitted by the Privacy Act, in
the Commission’s privacy policy, at
https://www.ftc.gov/site-information/
privacy-policy.
Analysis of Agreement Containing
Consent Order To Aid Public Comment
asabaliauskas on DSKBBXCHB2PROD with NOTICES
Introduction
The Federal Trade Commission
(‘‘Commission’’) has accepted, subject to
final approval, an Agreement
Containing Consent Order (‘‘Consent
Agreement’’) from Broadcom Limited
(‘‘Broadcom’’) and Brocade
Communications Systems, Inc.
(‘‘Brocade’’), designed to remedy the
anticompetitive effects resulting from
Broadcom’s proposed acquisition of
Brocade.
Pursuant to an Agreement and Plan of
Merger dated November 1, 2016, the
parties agreed that Broadcom would
acquire Brocade for $5.9 billion,
including assuming $400 million in
debt (‘‘the Acquisition’’). The
VerDate Sep<11>2014
17:54 Jul 11, 2017
Jkt 241001
Commission’s Complaint alleges that
the proposed Acquisition, if
consummated, would violate Section 7
of the Clayton Act, as amended, 15
U.S.C. 18, and Section 5 of the FTC Act,
as amended, 15 U.S.C. 45, by
substantially lessening competition in
the worldwide market for fibre channel
switches. The Complaint alleges that
Broadcom’s access to Cisco’s
competitively sensitive confidential
information, provided in furtherance of
its ongoing supply relationship for
application specific integrated circuits
(‘‘ASICs’’) with Broadcom, may
substantially lessen competition by
increasing the likelihood that Broadcom
may unilaterally exercise market power
or by increasing the likelihood of
coordinated interaction between the two
competitors in the fibre channel switch
market.
Under the terms of the proposed
Decision and Order (‘‘Order’’) contained
in the Consent Agreement, Broadcom is
required to implement firewalls
preventing the flow of Cisco’s
confidential business information
outside of an identified group of
relevant Broadcom employees, and
requires a monitor to oversee
compliance with the firewall provisions.
The proposed remedy effectively
addresses the potential for competitive
harm resulting from Broadcom misusing
Cisco’s competitively sensitive
confidential information.
The Consent Agreement has been
placed on the public record for 30 days
to solicit comments from interested
persons. Comments received during this
period will become part of the public
record. After 30 days, the Commission
will again review the Consent
Agreement and the comments received,
and decide whether it should withdraw
from the Consent Agreement, modify it,
or make it final.
The Parties
Headquartered in both Singapore and
San Jose, California, Broadcom is a
publically traded global developer and
supplier of semiconductor products.
Broadcom’s enterprise storage group
specializes in designing, producing, and
selling a broad array of integrated
circuits used in fibre channel and
Ethernet network environments,
including ASICs for fibre channel
switches.
Headquartered in San Jose, California,
Brocade is a data storage and
networking company. Brocade is the
leading manufacturer of fibre channel
switches, and also sells wireless
networking equipment, Ethernet
switches, and software solutions for
networks.
PO 00000
Frm 00028
Fmt 4703
Sfmt 4703
32187
The Relevant Market and Market
Structure
The relevant line of commerce in
which to analyze the effects of the
Acquisition is fibre channel switches.
The fibre channel switch is part of a
fibre channel storage area network,
which employs the fibre channel
interconnect protocol to enable stable,
high-throughput data transfers between
servers and storage arrays in data
centers. Fibre channel switches provide
quick and secure access to large
amounts of data and are often used for
mission-critical applications.
Fibre channel switch customers
would not turn to alternative switching
technologies in response to a small but
significant price increase because doing
so would involve significant business
risk and expense.
Each fibre channel switch contains an
ASIC, which is an integrated circuit that
is custom-tailored to carry out the
functions of the fibre channel switch. It
is the most costly and technically
complex component of the switch. The
ASIC is designed through a
collaboration between the switch
manufacturer and an ASIC provider.
Switch manufacturers typically develop
proprietary intellectual property, and
ASIC providers, add intellectual
property libraries, design oversight
capabilities, and oversee the production
of the ASICs at a third-party foundry in
order to create a commercial ASIC for a
switch manufacturer.
The relevant geographic market in
which to analyze the effects of the
Acquisition on the fibre channel switch
market is worldwide. Fibre channel
switches are produced in facilities
worldwide. The size and weight of fibre
channel switches generally allow for
economical shipping to downstream
customers located throughout the world.
The worldwide market for fibre
channel switches is highly
concentrated, consisting of a duopoly
between Brocade and Cisco. The fibre
channel market has been flat to slowly
declining over the past several years.
Effects of the Acquisition
The Complaint alleges that as a result
of its ongoing ASIC supply relationship
with Cisco, Broadcom will continue to
have extensive access to Cisco’s
competitively sensitive confidential
information. Without proper safeguards,
Broadcom could misuse that
information, leading to anticompetitive
conduct that could make Cisco a less
effective competitor, or increase the
likelihood of coordinated interaction
between the two remaining fibre
channel switch competitors, in turn
E:\FR\FM\12JYN1.SGM
12JYN1
32188
Federal Register / Vol. 82, No. 132 / Wednesday, July 12, 2017 / Notices
increasing the probability that
customers would pay higher prices for
fibre channel switches and that
innovation would be lessened.
asabaliauskas on DSKBBXCHB2PROD with NOTICES
Entry
Entry into the worldwide fibre
channel switch market is not likely to
occur in a timely, likely, or sufficient
magnitude, character and scope to deter
or counteract any anticompetitive
effects created by the proposed
Acquisition. Entry is unlikely in light of
slowly declining demand for fibre
channel switches in a mature market,
customers that tend to stay with one
fibre channel switch manufacturer for
extended periods of time, and the
significant capital costs required for
entry.
The Consent Agreement
To remedy the alleged competitive
concern stemming from Broadcom’s
access to Cisco’s competitively sensitive
confidential information, the consent
decree prevents the Cisco information
from being shared among Broadcom
employees who could use such
information to raise prices or lessen
innovation.
Pursuant to the proposed Order, only
authorized individuals will have access
to Cisco’s competitively sensitive
confidential information that is given to
the firewalled entity, which is defined
as Broadcom’s business group
responsible for the development,
production, sale, and marketing of fibre
channel ASICs for Cisco. The firewalled
entity will have separate facilities and a
separate information technology system
with security protocols assuring access
only to the authorized individuals.
Furthermore, Broadcom shall require all
authorized individuals to sign a nondisclosure agreement, requiring
compliance with the terms of the
proposed Order. Additionally, the
proposed Order provides for a cooling
off period whereby any authorized
individual who leaves his or her
position at the firewalled entity will not
work in the development, production,
sale, or marketing of fibre channel
ASICs for Brocade’s business unit or in
the development, production, sales, and
marketing of fibre channel switches for
twelve months.
The proposed Order also requires
Broadcom to use Cisco’s competitively
sensitive confidential information only
in furtherance of the design,
manufacturing, and sale of fibre channel
ASICs for Cisco. Moreover, Broadcom
will be required to take all actions
necessary to prevent access to, or the
disclosure or use of Cisco’s
competitively sensitive confidential
VerDate Sep<11>2014
17:54 Jul 11, 2017
Jkt 241001
information by or to anyone who is not
an authorized individual. The proposed
Order also incorporates by reference
non-disclosure provisions contained in
four prior private Confidentiality
Agreements that Broadcom, or its
predecessor, signed with Cisco.
To ensure compliance with the
proposed Order, the Commission will
appoint a Monitor to oversee
Broadcom’s and Brocade’s performance
of their obligations pursuant to the
Consent Agreement. The Monitor will
be appointed to a five-year term, but the
Commission may extend or modify the
term as appropriate up to a ten-year
period. Further, the Consent Agreement
contains appropriate reporting
requirements.
Opportunity for Public Comment
The purpose of this analysis is to
facilitate public comment on the
proposed Consent Agreement to aid the
Commission in determining whether it
should make the proposed Consent
Agreement final. This analysis is not an
official interpretation of the proposed
Consent Agreement and does not
modify its terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2017–14536 Filed 7–11–17; 8:45 am]
BILLING CODE 6750–01–P
management activities, for both the
Centers for Disease Control and
Prevention and the Agency for Toxic
Substances and Disease Registry.
Claudette Grant,
Acting Director, Management Analysis and
Services Office, Centers for Disease Control
and Prevention.
[FR Doc. 2017–14745 Filed 7–10–17; 4:15 pm]
BILLING CODE 4163–18–P
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Food and Drug Administration
[Docket No. FDA–2017–N–0002]
New Animal Drugs; Withdrawal of
Approval of a New Animal Drug
Application
AGENCY:
Food and Drug Administration,
HHS.
ACTION:
Notice of withdrawal.
The Food and Drug
Administration (FDA) is withdrawing
approval of two new animal drug
applications (NADAs). This action is
being taken at the sponsor’s request
because these products are no longer
manufactured or marketed.
SUMMARY:
Withdrawal of approval is
effective July 24, 2017.
DATES:
DEPARTMENT OF HEALTH AND
HUMAN SERVICES
Centers for Disease Control and
Prevention
Sunshine Act Meeting: Board of
Scientific Counselors NCEH/ATSDR;
Cancelation
FEDERAL REGISTER CITATION OF PREVIOUS
ANNOUNCEMENT: The original Federal
Register Notice for this meeting was
published in the Federal Register on
May 22, 2017, Volume 82, Number
2017–10333, page/s/23250–23251.
PREVIOUSLY ANNOUNCED TIME AND DATE OF
THE MEETING: 9:00 a.m.–noon, EDT, June
23, 2017.
This meeting is
being canceled in its entirety.
CONTACT PERSON FOR MORE INFORMATION:
Amanda Malasky, BS, ORISE Fellow,
CDC, 4770 Buford Hwy., Atlanta, GA
30344, telephone 770–488–7699; yoo0@
cdc.gov.
The Director, Management Analysis
and Services Office, has been delegated
the authority to sign Federal Register
notices pertaining to announcements of
meetings and other committee
CHANGES IN THE MEETING:
PO 00000
Frm 00029
Fmt 4703
Sfmt 4703
FOR FURTHER INFORMATION CONTACT:
Sujaya Dessai, Center for Veterinary
Medicine (HFV–212), Food and Drug
Administration, 7519 Standish Pl.,
Rockville, MD 20855, 240–402–5761,
sujaya.dessai@fda.hhs.gov.
Zoetis,
Inc., 333 Portage St., Kalamazoo, MI
49007 has requested that FDA withdraw
approval of NADA 065–291 for bulk
dihydrostreptomycin sulfate and NADA
065–324 for bulk streptomycin sulfate
because the products are no longer
manufactured or marketed.
Therefore, under authority delegated
to the Commissioner of Food and Drugs,
and in accordance with § 514.116 Notice
of withdrawal of approval of application
(21 CFR 514.116), notice is given that
approval of NADA 065–291 and NADA
065–324, and all supplements and
amendments thereto, is hereby
withdrawn, effective July 24, 2017.
As neither of these NADAs was
codified, the animal drug regulations do
not require amendment to reflect the
voluntary withdrawal of approval of
these applications.
SUPPLEMENTARY INFORMATION:
E:\FR\FM\12JYN1.SGM
12JYN1
Agencies
[Federal Register Volume 82, Number 132 (Wednesday, July 12, 2017)]
[Notices]
[Pages 32186-32188]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2017-14536]
=======================================================================
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
[File No. 171 0027]
Broadcom Limited and Brocade Communications Systems, Inc.;
Analysis To Aid Public Comment
AGENCY: Federal Trade Commission.
ACTION: Proposed consent agreement.
-----------------------------------------------------------------------
SUMMARY: The consent agreement in this matter settles alleged
violations of federal law prohibiting unfair methods of competition.
The attached Analysis to Aid Public Comment describes both the
allegations in the complaint and the terms of the consent order--
embodied in the consent agreement--that would settle these allegations.
DATES: Comments must be received on or before August 2, 2017.
ADDRESSES: Interested parties may file a comment at https://ftcpublic.commentworks.com/ftc/broadcombrocadeconsent/ online or on
paper, by following the instructions in the Request for Comment part of
the SUPPLEMENTARY INFORMATION section below. Write ``In the Matter of
Broadcom Limited and Brocade Communications Systems, Inc., File No. 171
0027'' on your comment and file your comment online at https://ftcpublic.commentworks.com/ftc/broadcombrocadeconsent/ by following the
instructions on the web-based form. If you prefer to file your comment
on paper, write ``In the Matter of Broadcom Limited and Brocade
Communications Systems, Inc., File No. 171 0027'' on your comment and
on the envelope, and mail your comment to the following address:
Federal Trade Commission, Office of the Secretary, 600 Pennsylvania
Avenue NW., Suite CC-5610 (Annex D), Washington, DC 20580, or deliver
your comment to the following address: Federal Trade Commission, Office
of the Secretary, Constitution Center, 400 7th Street SW., 5th Floor,
Suite 5610 (Annex D), Washington, DC 20024.
FOR FURTHER INFORMATION CONTACT: Stephen Antonio (202-326-2536), Bureau
of Competition, Mergers II Division, 600 Pennsylvania Avenue NW.,
Washington, DC 20580.
SUPPLEMENTARY INFORMATION: Pursuant to Section 6(f) of the Federal
Trade Commission Act, 15 U.S.C. 46(f), and FTC Rule 2.34, 16 CFR 2.34,
notice is hereby given that the above-captioned consent agreement
containing consent order to cease and desist, having been filed with
and accepted, subject to final approval, by the Commission, has been
placed on the public record for a period of thirty (30) days. The
following Analysis to Aid Public Comment describes the terms of the
consent agreement, and the allegations in the complaint. An electronic
copy of the full text of the consent agreement package can be obtained
from the FTC Home Page (for July 3, 2017), on the World Wide Web, at
https://www.ftc.gov/news-events/commission-actions.
You can file a comment online or on paper. For the Commission to
consider your comment, we must receive it on or before August 2, 2017.
Write ``In the Matter of Broadcom Limited and Brocade Communications
Systems, Inc., File No. 171 0027'' on your comment. Your comment--
including your name and your state--will be placed on the public record
of this proceeding, including, to the extent practicable, on the public
Commission Web site, at https://www.ftc.gov/policy/public-comments.
Postal mail addressed to the Commission is subject to delay due to
heightened security screening. As a result, we encourage you to submit
your comments online. To make sure that the Commission considers your
online comment, you must file it at https://ftcpublic.commentworks.com/ftc/broadcombrocadeconsent/ by following the instructions on the web-
based form. If this Notice appears at https://www.regulations.gov/#!home, you also may file a comment through that Web site.
If you prefer to file your comment on paper, write ``In the Matter
of Broadcom Limited and Brocade Communications Systems, Inc., File No.
171 0027'' on your comment and on the envelope, and mail it to the
following address: Federal Trade Commission, Office of the Secretary,
600 Pennsylvania Avenue NW., Suite CC-5610 (Annex D), Washington, DC
20580, or deliver your comment to the following address: Federal Trade
Commission, Office of the Secretary, Constitution Center, 400 7th
Street SW., 5th Floor, Suite 5610 (Annex D), Washington, DC. If
possible, submit your paper comment to the Commission by courier or
overnight service.
Because your comment will be placed on the publicly accessible FTC
Web site at www.ftc.gov, you are solely responsible for making sure
that your comment does not include any sensitive or confidential
information In particular, your comment should not include any
sensitive personal information, such as your or anyone else's Social
Security number; date of birth; driver's license number or other state
identification number, or foreign country equivalent; passport number;
financial account number; or credit or debit card number. You are also
solely responsible for making sure that your comment does not include
any sensitive health information, such as medical records or other
individually identifiable health information. In addition, your comment
should not include any ``trade secret or any commercial or financial
information which . . . is privileged or confidential''--as provided by
Section 6(f) of the FTC Act, 15 U.S.C. 46(f), and
[[Page 32187]]
FTC Rule 4.10(a)(2), 16 CFR 4.10(a)(2)--including in particular
competitively sensitive information such as costs, sales statistics,
inventories, formulas, patterns, devices, manufacturing processes, or
customer names.
Comments containing material for which confidential treatment is
requested must be filed in paper form, must be clearly labeled
``Confidential,'' and must comply with FTC Rule 4.9(c). In particular,
the written request for confidential treatment that accompanies the
comment must include the factual and legal basis for the request, and
must identify the specific portions of the comment to be withheld from
the public record. See FTC Rule 4.9(c). Your comment will be kept
confidential only if the General Counsel grants your request in
accordance with the law and the public interest. Once your comment has
been posted on the public FTC Web site--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from the FTC Web site,
unless you submit a confidentiality request that meets the requirements
for such treatment under FTC Rule 4.9(c), and the General Counsel
grants that request.
Visit the Commission Web site at https://www.ftc.gov to read this
Notice and the news release describing it. The FTC Act and other laws
that the Commission administers permit the collection of public
comments to consider and use in this proceeding as appropriate. The
Commission will consider all timely and responsive public comments that
it receives on or before August 2, 2017. You can find more information,
including routine uses permitted by the Privacy Act, in the
Commission's privacy policy, at https://www.ftc.gov/site-information/privacy-policy.
Analysis of Agreement Containing Consent Order To Aid Public Comment
Introduction
The Federal Trade Commission (``Commission'') has accepted, subject
to final approval, an Agreement Containing Consent Order (``Consent
Agreement'') from Broadcom Limited (``Broadcom'') and Brocade
Communications Systems, Inc. (``Brocade''), designed to remedy the
anticompetitive effects resulting from Broadcom's proposed acquisition
of Brocade.
Pursuant to an Agreement and Plan of Merger dated November 1, 2016,
the parties agreed that Broadcom would acquire Brocade for $5.9
billion, including assuming $400 million in debt (``the Acquisition'').
The Commission's Complaint alleges that the proposed Acquisition, if
consummated, would violate Section 7 of the Clayton Act, as amended, 15
U.S.C. 18, and Section 5 of the FTC Act, as amended, 15 U.S.C. 45, by
substantially lessening competition in the worldwide market for fibre
channel switches. The Complaint alleges that Broadcom's access to
Cisco's competitively sensitive confidential information, provided in
furtherance of its ongoing supply relationship for application specific
integrated circuits (``ASICs'') with Broadcom, may substantially lessen
competition by increasing the likelihood that Broadcom may unilaterally
exercise market power or by increasing the likelihood of coordinated
interaction between the two competitors in the fibre channel switch
market.
Under the terms of the proposed Decision and Order (``Order'')
contained in the Consent Agreement, Broadcom is required to implement
firewalls preventing the flow of Cisco's confidential business
information outside of an identified group of relevant Broadcom
employees, and requires a monitor to oversee compliance with the
firewall provisions. The proposed remedy effectively addresses the
potential for competitive harm resulting from Broadcom misusing Cisco's
competitively sensitive confidential information.
The Consent Agreement has been placed on the public record for 30
days to solicit comments from interested persons. Comments received
during this period will become part of the public record. After 30
days, the Commission will again review the Consent Agreement and the
comments received, and decide whether it should withdraw from the
Consent Agreement, modify it, or make it final.
The Parties
Headquartered in both Singapore and San Jose, California, Broadcom
is a publically traded global developer and supplier of semiconductor
products. Broadcom's enterprise storage group specializes in designing,
producing, and selling a broad array of integrated circuits used in
fibre channel and Ethernet network environments, including ASICs for
fibre channel switches.
Headquartered in San Jose, California, Brocade is a data storage
and networking company. Brocade is the leading manufacturer of fibre
channel switches, and also sells wireless networking equipment,
Ethernet switches, and software solutions for networks.
The Relevant Market and Market Structure
The relevant line of commerce in which to analyze the effects of
the Acquisition is fibre channel switches. The fibre channel switch is
part of a fibre channel storage area network, which employs the fibre
channel interconnect protocol to enable stable, high-throughput data
transfers between servers and storage arrays in data centers. Fibre
channel switches provide quick and secure access to large amounts of
data and are often used for mission-critical applications.
Fibre channel switch customers would not turn to alternative
switching technologies in response to a small but significant price
increase because doing so would involve significant business risk and
expense.
Each fibre channel switch contains an ASIC, which is an integrated
circuit that is custom-tailored to carry out the functions of the fibre
channel switch. It is the most costly and technically complex component
of the switch. The ASIC is designed through a collaboration between the
switch manufacturer and an ASIC provider. Switch manufacturers
typically develop proprietary intellectual property, and ASIC
providers, add intellectual property libraries, design oversight
capabilities, and oversee the production of the ASICs at a third-party
foundry in order to create a commercial ASIC for a switch manufacturer.
The relevant geographic market in which to analyze the effects of
the Acquisition on the fibre channel switch market is worldwide. Fibre
channel switches are produced in facilities worldwide. The size and
weight of fibre channel switches generally allow for economical
shipping to downstream customers located throughout the world.
The worldwide market for fibre channel switches is highly
concentrated, consisting of a duopoly between Brocade and Cisco. The
fibre channel market has been flat to slowly declining over the past
several years.
Effects of the Acquisition
The Complaint alleges that as a result of its ongoing ASIC supply
relationship with Cisco, Broadcom will continue to have extensive
access to Cisco's competitively sensitive confidential information.
Without proper safeguards, Broadcom could misuse that information,
leading to anticompetitive conduct that could make Cisco a less
effective competitor, or increase the likelihood of coordinated
interaction between the two remaining fibre channel switch competitors,
in turn
[[Page 32188]]
increasing the probability that customers would pay higher prices for
fibre channel switches and that innovation would be lessened.
Entry
Entry into the worldwide fibre channel switch market is not likely
to occur in a timely, likely, or sufficient magnitude, character and
scope to deter or counteract any anticompetitive effects created by the
proposed Acquisition. Entry is unlikely in light of slowly declining
demand for fibre channel switches in a mature market, customers that
tend to stay with one fibre channel switch manufacturer for extended
periods of time, and the significant capital costs required for entry.
The Consent Agreement
To remedy the alleged competitive concern stemming from Broadcom's
access to Cisco's competitively sensitive confidential information, the
consent decree prevents the Cisco information from being shared among
Broadcom employees who could use such information to raise prices or
lessen innovation.
Pursuant to the proposed Order, only authorized individuals will
have access to Cisco's competitively sensitive confidential information
that is given to the firewalled entity, which is defined as Broadcom's
business group responsible for the development, production, sale, and
marketing of fibre channel ASICs for Cisco. The firewalled entity will
have separate facilities and a separate information technology system
with security protocols assuring access only to the authorized
individuals. Furthermore, Broadcom shall require all authorized
individuals to sign a non-disclosure agreement, requiring compliance
with the terms of the proposed Order. Additionally, the proposed Order
provides for a cooling off period whereby any authorized individual who
leaves his or her position at the firewalled entity will not work in
the development, production, sale, or marketing of fibre channel ASICs
for Brocade's business unit or in the development, production, sales,
and marketing of fibre channel switches for twelve months.
The proposed Order also requires Broadcom to use Cisco's
competitively sensitive confidential information only in furtherance of
the design, manufacturing, and sale of fibre channel ASICs for Cisco.
Moreover, Broadcom will be required to take all actions necessary to
prevent access to, or the disclosure or use of Cisco's competitively
sensitive confidential information by or to anyone who is not an
authorized individual. The proposed Order also incorporates by
reference non-disclosure provisions contained in four prior private
Confidentiality Agreements that Broadcom, or its predecessor, signed
with Cisco.
To ensure compliance with the proposed Order, the Commission will
appoint a Monitor to oversee Broadcom's and Brocade's performance of
their obligations pursuant to the Consent Agreement. The Monitor will
be appointed to a five-year term, but the Commission may extend or
modify the term as appropriate up to a ten-year period. Further, the
Consent Agreement contains appropriate reporting requirements.
Opportunity for Public Comment
The purpose of this analysis is to facilitate public comment on the
proposed Consent Agreement to aid the Commission in determining whether
it should make the proposed Consent Agreement final. This analysis is
not an official interpretation of the proposed Consent Agreement and
does not modify its terms in any way.
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2017-14536 Filed 7-11-17; 8:45 am]
BILLING CODE 6750-01-P