UNITED STATES OF AMERICA,                   Plaintiff,                   v. DENTSPLY INTERNATIONAL, INC.,                Defendant.

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Civil Action No. 99-005 (MMS)

Pursuant to Fed. R. Civ. P. 37(a) and D. Del. LR 7.1.1, the United States hereby moves for entry of the accompanying proposed Order compelling Defendant Dentsply International, Inc. to produce the requested information relating to its competitive position in foreign markets, as set forth in that Order and the United States' accompanying Brief. This Motion is made on the grounds that this information is directly relevant to the subject matter of this action, and therefore is within the scope of discovery under Fed. R. Civ. P. 26(b)(1), and that Defendant's refusal to comply is without justification, as set forth more fully in the accompanying Brief. Pursuant to D. Del. LR 7.1.1, the United States certifies that it has conferred in good faith with counsel for Defendant in an effort to resolve the dispute regarding this request for specific information.

Respectfully submitted,

COUNSEL FOR PLAINTIFF UNITED STATES OF AMERICA CARL SCHNEE UNITED STATES ATTORNEY _______________/s/________________ Judith M. Kinney (DSB #3643) Assistant United States Attorney 1201 Market Street, Suite 1100 Wilmington, DE 19801 (302) 573-6277 _______________/s/________________ Mark J. Botti William E. Berlin Jon B. Jacobs Sanford M. Adler Frederick S. Young Dionne C. Lomax Eliza T. Platts-Mills United States Department of Justice Antitrust Division 325 Seventh Street, N.W., Suite 400 Washington, DC 20530 (202) 616-5938

Dated: January  3 , 2000