FOR THE TERRITORY OF GUAM
The United States of America, acting through its attorneys, charges:
1. YOUNG SOO YOON is made a defendant on the charge stated below.
2. Beginning as early as December 17, 1997 and continuing at least until
May 26, 1998, the exact dates being unknown to the United States, the defendant and others entered into and engaged in a combination and conspiracy, and the defendant knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused conspirators to enter into and engage in such combination and conspiracy, to suppress and restrain competition for contracts with the Territorial Government of Guam's Department of Parks and Recreation ("DPR") to repair facilities located on Guam damaged by Typhoon Paka ("Typhoon Damage Repair Contracts"), in unreasonable restraint of territorial trade and commerce, in violation of the Sherman Act, Title 15, United States Code, Section 3 and Title 18, United States Code, Section 2.
DEFENDANT AIDED AND ABETTED
3. During the period covered by this Information, YOUNG SOO YOON was a resident of the Territory of Guam and a citizen of the United States of America.
4. In committing the offense charged in this Information, the defendant also acted through various individuals and corporations, not made defendants in this Information, with whom the defendant conspired and whom the defendant knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused to perform acts and make statements in furtherance of the conspiracy charged in this Information.
5. Various individuals and corporations, not made defendants in this Information, participated as co-conspirators in the conspiracy charged and performed acts and made statements in furtherance of it.
6. The charged combination and conspiracy consisted of an agreement, understanding, and concert of action among the conspirators, knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused by the defendant, the substantial terms of which were to rig price quotations offered for, and to allocate, Typhoon Damage Repair Contracts.
7. For the common purpose of forming and carrying out the charged combination and conspiracy, the defendant conspired to, and knowingly and intentionally aided, abetted, counseled, commanded, induced, procured, and caused his co-conspirators to, among other things:
8. During the period covered by this Information, the activity that was the object of the conspiracy was within the flow of, and substantially affected, commerce in the Territory of Guam, between the Territory of Guam and the State of California, and between the Territory of Guam and the Country of Australia.
8. The combination and conspiracy charged in this Information was formed and carried out, in part, within the District of Guam, within five years preceding the filing of this Information.
ALL IN VIOLATION OF TITLE 15, UNITED STATES CODE, SECTION 3, AND TITLE 18, UNITED STATES CODE, SECTION 2.