Northrop Grumman Corporation and Orbital ATK, Inc.; Analysis To Aid Public Comment, 27776-27778 [2018-12750]
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27776
Federal Register / Vol. 83, No. 115 / Thursday, June 14, 2018 / Notices
FEDERAL TRADE COMMISSION
[File No. 181 0005]
Northrop Grumman Corporation and
Orbital ATK, Inc.; Analysis To Aid
Public Comment
Federal Trade Commission.
Proposed consent agreement.
AGENCY:
ACTION:
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 July 5, 2018.
ADDRESSES: Interested parties may file a
comment 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 Northrop
Grumman Corporation and Orbital ATK,
Inc., File No. 181 0005’’ on your
comment, and file your comment online
at https://ftcpublic.commentworks.com/
ftc/northropgrumman by following the
instructions on the web-based form. If
you prefer to file your comment on
paper, write ‘‘In the Matter of Northrop
Grumman Corporation and Orbital ATK,
Inc., File No. 181 0005’’ 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:
James Southworth (202–326–2822),
Bureau of Competition, 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 a 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
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SUMMARY:
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full text of the consent agreement
package can be obtained from the FTC
Home Page (for June 5, 2018), on the
World Wide Web, at https://
www.ftc.gov/news-events/commissionactions.
You can file a comment online or on
paper. For the Commission to consider
your comment, we must receive it on or
before July 5, 2018. Write ‘‘In the Matter
of Northrop Grumman Corporation and
Orbital ATK, Inc., File No. 181 0005’’ 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
website, 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/
northropgrumman 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
website.
If you prefer to file your comment on
paper, write ‘‘In the Matter of Northrop
Grumman Corporation and Orbital ATK,
Inc., File No. 181 0005’’ 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. 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 website
at https://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
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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
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
website—as legally required by FTC
Rule 4.9(b)—we cannot redact or
remove your comment from the FTC
website, 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 FTC website 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 July 5, 2018. For
information on the Commission’s
privacy policy, including routine uses
permitted by the Privacy Act, see
https://www.ftc.gov/site-information/
privacy-policy.
Analysis of Agreement Containing
Consent Order To Aid Public Comment
I. Introduction
The Federal Trade Commission
(‘‘Commission’’) has accepted an
Agreement Containing Consent Order
(‘‘Consent Agreement’’) designed to
remedy the anticompetitive effects
resulting from Northrop Grumman
Corporation’s (‘‘Northrop’’) proposed
acquisition of Orbital ATK, Inc.
(‘‘Orbital ATK’’). Under the terms of the
Consent Agreement, Northrop would be
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Federal Register / Vol. 83, No. 115 / Thursday, June 14, 2018 / Notices
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required to (1) continue to act as a nondiscriminatory merchant supplier of
Orbital ATK’s solid rocket motors
(‘‘SRMs’’) rather than favor its nowvertically integrated missile system
business, and (2) protect SRM and
missile system competitors’
competitively sensitive information
from improper use or disclosure.
The Consent Agreement has been
placed on the public record for thirty
days for receipt of comments by
interested persons. Given that the
acquisition could impact a current
ongoing missile system competition, the
Commission issued the accompanying
Decision and Order (‘‘Order’’) as final
prior to seeking public comment, as
provided in Section 2.34(c) of the
Commission’s Rules. This will allow the
Commission to enforce the Order if
there are any violations of its provisions
during the public comment period.
Comments received during this period
will become part of the public record.
After thirty days, the Commission will
again review the proposed Consent
Agreement and the comments received,
and will decide whether it should
withdraw from the Consent Agreement
or modify the accompanying Order.
Pursuant to an Agreement and Plan of
Merger dated September 17, 2017,
Northrop agreed to acquire 100 percent
of the issued and outstanding voting
securities of Orbital ATK for
approximately $7.8 billion (the
‘‘Acquisition’’). The Commission’s
Complaint alleges that the Acquisition
is in violation of Section 5 of the FTC
Act, as amended, 15 U.S.C. 45, and that
the 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 lessening the competition in the
United States market for missile
systems. The Acquisition would provide
Northrop with the ability and incentive
to withhold its SRMs from competing
missile system prime contractors, or
only offer its SRMs at disadvantageous
terms, thereby raising rivals’ costs or
otherwise undermining their ability to
compete on future missile system bids.
The Consent Agreement will remedy the
alleged violations by prohibiting
Northrop from discriminating against
competing missile prime customers in
supplying SRMs.
II. The Parties
Northrop is a Delaware corporation
with its principal place of business in
Falls Church, Virginia. Northrop is a
global aerospace and defense company
that acts as a prime contractor or
preferred supplier on many highpriority programs for the United States
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Department of Defense (‘‘DOD’’) and
other United States Government
agencies. Northrop is one of only a few
companies capable of acting as a prime
contractor for tactical, missile defense,
and strategic missile systems for DOD
[the United States Government]. From
1997 to 2013, Northrop was the prime
contractor responsible for maintaining,
sustaining, and modernizing the
Minuteman III strategic missile system.
Northrop is currently competing to
develop the nation’s next
intercontinental ballistic missile system,
the Ground Based Strategic Deterrent.
Northrop has also successfully
competed for United States Government
research and development contracts for
tactical missiles and missile defense
interceptors.
Orbital ATK is a Delaware corporation
with its principal place of business in
Dulles, Virginia. The company is a
prime contractor and merchant supplier
of space, defense, and aviation-related
systems to customers around the world.
Orbital ATK is the nation’s leading
producer of SRMs for both defense and
commercial applications. For defense
programs, Orbital ATK produces
strategic-grade SRMs for the Trident II
D–5 and Minuteman III and the Missile
Defense Agency’s Ground-based
Midcourse Defense interceptor. In
addition, Orbital ATK is a leading
producer of SRMs for air-, sea- and landbased tactical missiles and missile
defense interceptors. Orbital ATK
supplies these SRMs to prime
contractors for use in their missile
systems.
III. The Products and Structure of the
Markets
Northrop is one of only four
companies capable of supplying missile
systems to the United States
Government. Missile systems provide
essential national defense capabilities
for the United States Government. The
United States Armed Forces employ
multiple types of missile systems,
including short-range tactical missiles,
longer-range strategic missiles, and
missile defense interceptors designed to
defeat ballistic missile threats. Each
type of missile system purchased by
DOD has unique capabilities and is
designed specifically to perform its
given mission(s).
Orbital ATK is one of only two viable
suppliers of SRMs for U.S. Government
missile systems and the dominant
supplier of large SRMs used for longrange strategic missiles. SRMs are used
to propel tactical, missile defense, and
strategic missiles to their intended
targets. SRMs are used for virtually all
missile systems purchased by the
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United States Government because they
offer numerous advantages over all
other existing propulsion technologies.
The relevant geographic market in
which to analyze the effects of the
proposed transaction is the United
States. The missile systems that are the
subject of the Complaint are solely
purchased by the United States
Government, which also typically funds
their development. National security
considerations and other factors limit
DOD’s ability to procure its missile
systems from foreign suppliers. Federal
law, national security, and other
considerations similarly drive missile
system prime contractors to procure
SRMs from domestic suppliers.
IV. Entry
Entry into the relevant markets would
not be timely, likely, or sufficient in
magnitude, character, and scope to deter
or counteract the anticompetitive effects
of the Acquisition. There are significant
barriers to entry into the development,
manufacture, and sale of both SRMs and
missile systems in the United States.
The relevant products are high
technology, defense-specific products
that require specialized expertise and
facilities to develop, test, and
manufacture. It would be extremely
difficult and costly for a new entrant to
establish the technological expertise and
specialized facilities necessary to
compete successfully in either of these
markets.
V. Effects of the Acquisition
Following the Acquisition, Northrop,
will be one of only two viable suppliers
of SRMs for U.S. Government missile
systems. The choice of SRM can have a
significant impact on the final
determination of a missile system prime
competition because the propulsion
system is a critical element of the
overall missile design. SRMs comprise a
large portion of the cost of the integrated
missile and their performance affects
the range, accuracy, and payload
capacity of the missile. Absent the
protections of the Consent Agreement,
Northrop would have the ability to
disadvantage competitors for future
missile prime contracts by denying or
limiting their access to Northrop’s SRM
products and technologies, which
would lessen the ability of Northrop’s
missile system competitors to compete
successfully for a given missile system
prime contract. The Acquisition would
also give Northrop access, through the
former Orbital ATK SRM business, to
the proprietary information that rival
missile prime contractors must share
with its SRM vendor. Similarly, the
Acquisition creates a risk that the
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Federal Register / Vol. 83, No. 115 / Thursday, June 14, 2018 / Notices
not intended to constitute an official
interpretation of the proposed Consent
Agreement or to modify its terms in any
way.
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proprietary, competitively sensitive
information of a rival SRM supplier
supporting Northrop’s missile system
business could be transferred to
Northrop’s vertically integrated SRM
business.
VI. The Consent Agreement
The Consent Agreement remedies the
acquisition’s likely anticompetitive
effects by requiring, whenever Northrop
competes for a missile system prime
contract, that Northrop must make its
SRM products and related services
available on a non-discriminatory basis
to all other third-party competing prime
contractors that wish to purchase them.
The non-discrimination prohibitions of
the Consent Agreement are
comprehensive and apply to any
potential discriminatory conduct
affecting price, schedule, quality, data,
personnel, investment, technology,
innovation, design, or risk.
The Consent Agreement requires
Northrop to establish firewalls to ensure
that Northrop does not transfer or use
any proprietary information that it
receives from competing missile prime
contractors or SRM suppliers in a
manner that harms competition. These
firewall provisions require that
Northrop maintain separate firewalled
teams to support offers of SRMs to
different third-party missile prime
contractors and to maintain these
firewalled teams separate from the team
supporting Northrop’s missile prime
contractor activities. The firewall
provisions also prohibit Northrop’s
missile business from sharing
proprietary information it may receive
from third-party SRM suppliers with
Northrop’s SRM business.
The Consent Agreement also provides
that the DOD’s Under Secretary of
Defense for Acquisition and
Sustainment shall appoint a compliance
officer to oversee Northrop’s compliance
with the Order. The compliance officer
will have all the necessary investigative
powers to perform his or her duties,
including the right to interview
respondent’s personnel, inspect
respondent’s facilities, and require
respondents to provide documents,
data, and other information. The
compliance officer has the authority to
retain third-party advisors, at the
expense of Northrop, as appropriate to
perform his or her duties. Access to
these extensive resources will ensure
that the compliance officer is fully
capable of overseeing the
implementation of, and compliance
with, the Order.
The purpose of this analysis is to
facilitate public comment on the
proposed Consent Agreement, and it is
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By direction of the Commission.
Janice Frankle,
Acting Secretary.
[FR Doc. 2018–12750 Filed 6–13–18; 8:45 am]
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Government Accountability
Office (GAO).
AGENCY:
Request for letters of
nomination and resumes.
ACTION:
The Medicare Access and
CHIP Reauthorization Act of 2015
established the Physician-Focused
Payment Model Technical Advisory
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SUMMARY:
Letters of nomination and
resumes should be submitted no later
than July 20, 2018, to ensure adequate
opportunity for review and
consideration of nominees prior to
appointment. Appointments will be
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DATES:
Submit letters of
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contact GAO’s Office of Public Affairs,
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FOR FURTHER INFORMATION CONTACT:
Authority: Pub. L. 114–10, Sec. 101(e), 129
Stat. 87, 115 (2015).
Gene L. Dodaro,
Comptroller General of the United States.
[FR Doc. 2018–12736 Filed 6–13–18; 8:45 am]
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Agency for Healthcare Research
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ACTION: Notice.
Request for Nominations for the
Physician-Focused Payment Model
Technical Advisory Committee (PTAC)
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Agency for Healthcare Research and
Quality
AGENCY:
GOVERNMENT ACCOUNTABILITY
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This notice announces the
intention of the Agency for Healthcare
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that the Office of Management and
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‘‘Ambulatory Surgery Center Survey on
Patient Safety Culture Database.’’
This proposed information collection
was previously published in the Federal
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allowed 60 days for public comment.
AHRQ received no substantive
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The purpose of this notice is to allow an
additional 30 days for public comment.
DATES: Comments on this notice must be
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ADDRESSES: Written comments should
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omb.eop.gov (attention: AHRQ’s desk
officer).
SUMMARY:
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Doris Lefkowitz, AHRQ Reports
Clearance Officer, (301) 427–1477, or by
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SUPPLEMENTARY INFORMATION:
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In accordance with the Paperwork
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AHRQ invites the public to comment on
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are not expected to need to stay in a
surgical facility longer than 24 hours.
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Agencies
[Federal Register Volume 83, Number 115 (Thursday, June 14, 2018)]
[Notices]
[Pages 27776-27778]
From the Federal Register Online via the Government Publishing Office [www.gpo.gov]
[FR Doc No: 2018-12750]
[[Page 27776]]
=======================================================================
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FEDERAL TRADE COMMISSION
[File No. 181 0005]
Northrop Grumman Corporation and Orbital ATK, 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 July 5, 2018.
ADDRESSES: Interested parties may file a comment 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
Northrop Grumman Corporation and Orbital ATK, Inc., File No. 181 0005''
on your comment, and file your comment online at https://ftcpublic.commentworks.com/ftc/northropgrumman by following the
instructions on the web-based form. If you prefer to file your comment
on paper, write ``In the Matter of Northrop Grumman Corporation and
Orbital ATK, Inc., File No. 181 0005'' 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: James Southworth (202-326-2822),
Bureau of Competition, 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 a 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 June 5, 2018), 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 July 5, 2018.
Write ``In the Matter of Northrop Grumman Corporation and Orbital ATK,
Inc., File No. 181 0005'' 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 website, 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/northropgrumman 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 website.
If you prefer to file your comment on paper, write ``In the Matter
of Northrop Grumman Corporation and Orbital ATK, Inc., File No. 181
0005'' 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. 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
website at https://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 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 website--as legally required by FTC Rule
4.9(b)--we cannot redact or remove your comment from the FTC website,
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 FTC website 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 July 5, 2018. For information on the Commission's
privacy policy, including routine uses permitted by the Privacy Act,
see https://www.ftc.gov/site-information/privacy-policy.
Analysis of Agreement Containing Consent Order To Aid Public Comment
I. Introduction
The Federal Trade Commission (``Commission'') has accepted an
Agreement Containing Consent Order (``Consent Agreement'') designed to
remedy the anticompetitive effects resulting from Northrop Grumman
Corporation's (``Northrop'') proposed acquisition of Orbital ATK, Inc.
(``Orbital ATK''). Under the terms of the Consent Agreement, Northrop
would be
[[Page 27777]]
required to (1) continue to act as a non-discriminatory merchant
supplier of Orbital ATK's solid rocket motors (``SRMs'') rather than
favor its now-vertically integrated missile system business, and (2)
protect SRM and missile system competitors' competitively sensitive
information from improper use or disclosure.
The Consent Agreement has been placed on the public record for
thirty days for receipt of comments by interested persons. Given that
the acquisition could impact a current ongoing missile system
competition, the Commission issued the accompanying Decision and Order
(``Order'') as final prior to seeking public comment, as provided in
Section 2.34(c) of the Commission's Rules. This will allow the
Commission to enforce the Order if there are any violations of its
provisions during the public comment period. Comments received during
this period will become part of the public record. After thirty days,
the Commission will again review the proposed Consent Agreement and the
comments received, and will decide whether it should withdraw from the
Consent Agreement or modify the accompanying Order.
Pursuant to an Agreement and Plan of Merger dated September 17,
2017, Northrop agreed to acquire 100 percent of the issued and
outstanding voting securities of Orbital ATK for approximately $7.8
billion (the ``Acquisition''). The Commission's Complaint alleges that
the Acquisition is in violation of Section 5 of the FTC Act, as
amended, 15 U.S.C. 45, and that the 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 lessening the
competition in the United States market for missile systems. The
Acquisition would provide Northrop with the ability and incentive to
withhold its SRMs from competing missile system prime contractors, or
only offer its SRMs at disadvantageous terms, thereby raising rivals'
costs or otherwise undermining their ability to compete on future
missile system bids. The Consent Agreement will remedy the alleged
violations by prohibiting Northrop from discriminating against
competing missile prime customers in supplying SRMs.
II. The Parties
Northrop is a Delaware corporation with its principal place of
business in Falls Church, Virginia. Northrop is a global aerospace and
defense company that acts as a prime contractor or preferred supplier
on many high-priority programs for the United States Department of
Defense (``DOD'') and other United States Government agencies. Northrop
is one of only a few companies capable of acting as a prime contractor
for tactical, missile defense, and strategic missile systems for DOD
[the United States Government]. From 1997 to 2013, Northrop was the
prime contractor responsible for maintaining, sustaining, and
modernizing the Minuteman III strategic missile system. Northrop is
currently competing to develop the nation's next intercontinental
ballistic missile system, the Ground Based Strategic Deterrent.
Northrop has also successfully competed for United States Government
research and development contracts for tactical missiles and missile
defense interceptors.
Orbital ATK is a Delaware corporation with its principal place of
business in Dulles, Virginia. The company is a prime contractor and
merchant supplier of space, defense, and aviation-related systems to
customers around the world. Orbital ATK is the nation's leading
producer of SRMs for both defense and commercial applications. For
defense programs, Orbital ATK produces strategic-grade SRMs for the
Trident II D-5 and Minuteman III and the Missile Defense Agency's
Ground-based Midcourse Defense interceptor. In addition, Orbital ATK is
a leading producer of SRMs for air-, sea- and land-based tactical
missiles and missile defense interceptors. Orbital ATK supplies these
SRMs to prime contractors for use in their missile systems.
III. The Products and Structure of the Markets
Northrop is one of only four companies capable of supplying missile
systems to the United States Government. Missile systems provide
essential national defense capabilities for the United States
Government. The United States Armed Forces employ multiple types of
missile systems, including short-range tactical missiles, longer-range
strategic missiles, and missile defense interceptors designed to defeat
ballistic missile threats. Each type of missile system purchased by DOD
has unique capabilities and is designed specifically to perform its
given mission(s).
Orbital ATK is one of only two viable suppliers of SRMs for U.S.
Government missile systems and the dominant supplier of large SRMs used
for long-range strategic missiles. SRMs are used to propel tactical,
missile defense, and strategic missiles to their intended targets. SRMs
are used for virtually all missile systems purchased by the United
States Government because they offer numerous advantages over all other
existing propulsion technologies.
The relevant geographic market in which to analyze the effects of
the proposed transaction is the United States. The missile systems that
are the subject of the Complaint are solely purchased by the United
States Government, which also typically funds their development.
National security considerations and other factors limit DOD's ability
to procure its missile systems from foreign suppliers. Federal law,
national security, and other considerations similarly drive missile
system prime contractors to procure SRMs from domestic suppliers.
IV. Entry
Entry into the relevant markets would not be timely, likely, or
sufficient in magnitude, character, and scope to deter or counteract
the anticompetitive effects of the Acquisition. There are significant
barriers to entry into the development, manufacture, and sale of both
SRMs and missile systems in the United States. The relevant products
are high technology, defense-specific products that require specialized
expertise and facilities to develop, test, and manufacture. It would be
extremely difficult and costly for a new entrant to establish the
technological expertise and specialized facilities necessary to compete
successfully in either of these markets.
V. Effects of the Acquisition
Following the Acquisition, Northrop, will be one of only two viable
suppliers of SRMs for U.S. Government missile systems. The choice of
SRM can have a significant impact on the final determination of a
missile system prime competition because the propulsion system is a
critical element of the overall missile design. SRMs comprise a large
portion of the cost of the integrated missile and their performance
affects the range, accuracy, and payload capacity of the missile.
Absent the protections of the Consent Agreement, Northrop would have
the ability to disadvantage competitors for future missile prime
contracts by denying or limiting their access to Northrop's SRM
products and technologies, which would lessen the ability of Northrop's
missile system competitors to compete successfully for a given missile
system prime contract. The Acquisition would also give Northrop access,
through the former Orbital ATK SRM business, to the proprietary
information that rival missile prime contractors must share with its
SRM vendor. Similarly, the Acquisition creates a risk that the
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proprietary, competitively sensitive information of a rival SRM
supplier supporting Northrop's missile system business could be
transferred to Northrop's vertically integrated SRM business.
VI. The Consent Agreement
The Consent Agreement remedies the acquisition's likely
anticompetitive effects by requiring, whenever Northrop competes for a
missile system prime contract, that Northrop must make its SRM products
and related services available on a non-discriminatory basis to all
other third-party competing prime contractors that wish to purchase
them. The non-discrimination prohibitions of the Consent Agreement are
comprehensive and apply to any potential discriminatory conduct
affecting price, schedule, quality, data, personnel, investment,
technology, innovation, design, or risk.
The Consent Agreement requires Northrop to establish firewalls to
ensure that Northrop does not transfer or use any proprietary
information that it receives from competing missile prime contractors
or SRM suppliers in a manner that harms competition. These firewall
provisions require that Northrop maintain separate firewalled teams to
support offers of SRMs to different third-party missile prime
contractors and to maintain these firewalled teams separate from the
team supporting Northrop's missile prime contractor activities. The
firewall provisions also prohibit Northrop's missile business from
sharing proprietary information it may receive from third-party SRM
suppliers with Northrop's SRM business.
The Consent Agreement also provides that the DOD's Under Secretary
of Defense for Acquisition and Sustainment shall appoint a compliance
officer to oversee Northrop's compliance with the Order. The compliance
officer will have all the necessary investigative powers to perform his
or her duties, including the right to interview respondent's personnel,
inspect respondent's facilities, and require respondents to provide
documents, data, and other information. The compliance officer has the
authority to retain third-party advisors, at the expense of Northrop,
as appropriate to perform his or her duties. Access to these extensive
resources will ensure that the compliance officer is fully capable of
overseeing the implementation of, and compliance with, the Order.
The purpose of this analysis is to facilitate public comment on the
proposed Consent Agreement, and it is not intended to constitute an
official interpretation of the proposed Consent Agreement or to modify
its terms in any way.
By direction of the Commission.
Janice Frankle,
Acting Secretary.
[FR Doc. 2018-12750 Filed 6-13-18; 8:45 am]
BILLING CODE 6750-01-P