"[Between 2004 through 2006] Saudi Distributor maintained a 'control account' from which a number of payments were made at THC Saudi Arabia's [an operational entity within Tyco Healthcare AG, a indirect wholly owned subsidiary of Tyco] direction to Saudi hospitals and doctors, some of whom were publicly employed HCPs. Several expenses from the control account were booked improperly as 'promotional expenses' and 'sales development' expenses. In connection with these improper transactions, THC Saudi earned approximately $1,960,000 in gross profit."