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Defendants Deutsche Telekom, Softbank, T-Mobile, and Sprint (“Defendants”) from violating
Section 7 of the Clayton Act, as amended, 15 U.S.C. § 18.
26. The Plaintiff States bring this action under Section 16 of the Clayton Act, 15
U.S.C. § 26, to prevent and restrain the Defendants from violating Section 7 of the Clayton Act,
15 U.S.C. § 18. The Plaintiff States, by and through their respective Attorneys General, bring
this action as parens patriae on behalf of and to protect the health and welfare of their citizens
and the general economy of each of their states.
27. T-Mobile and Sprint are engaged in, and their activities substantially affect,
interstate commerce. T-Mobile and Sprint sell mobile wireless service throughout the United
States. As parties to the Business Combination Agreement, which will have effects throughout
the United States, Deutsche Telekom and Softbank have submitted to the jurisdiction of the
United States. All four of the Defendants have consented to venue and personal jurisdiction in
this District.
28. Venue is proper under Section 12 of the Clayton Act, 15 U.S.C. § 22, and 28
U.S.C. § 1391(b) and (c)(2), for Defendants T-Mobile and Sprint, and venue is proper for
Defendants Deutsche Telekom, a German corporation, and SoftBank, a Japanese corporation,
under 28 U.S.C. § 1391(c)(3).
VII. VIOLATION ALLEGED
29. The merger of T-Mobile and Sprint likely would lessen competition substantially
in interstate trade and commerce in the relevant geographic market for retail mobile wireless
service, in violation of Section 7 of the Clayton Act, 15 U.S.C. § 18.
30. Unless enjoined, the transaction likely would have the following effects in the
national retail mobile wireless market described above:
Case 1:19-cv-02232 Document 1 Filed 07/26/19 Page 9 of 13