F. Hoffmann-La Roche Ltd. (Roche) (defendant) and other vitamin manufacturers engaged in a sophisticated conspiracy to fix worldwide prices and sales volumes of vitamins. Each company involved in the conspiracy was allocated a percentage of the relevant global vitamin market. Within the United States, Roche and another co-conspirator met to divide customers between themselves. They reviewed bid requests and together determined the amount of each company’s bid. Roche played a pivotal role in the conspiracy, often initiating changes to its scope. Roche and the co-conspirator destroyed all documents after each meeting. In all, Roche sold over $3.2 billion in vitamins under the conspiracy. The United States charged Roche with violating § 1 of the Sherman Act. Dr. Kuno Sommer was the Roche executive primarily responsible for the company’s participation in the vitamin conspiracy. When the United States Department of Justice (DOJ) interviewed Sommer about the conspiracy, he lied to investigators. Eventually, Roche admitted to the collusion and began cooperating with the DOJ. Prior to this action, Roche reached a plea agreement with the DOJ in connection with an alleged violation of the Sherman Act related to Roche’s production and sale of citric acid.