, U.S. Dept. of Justice, Siemens AG and Three Subsidiaries Plead Guilty to Foreign Corrupt Practices Act Violations and Agree to Pay $450 Million in Combined Criminal Fines (Dec. 15, 2008), available at http://www. justice.gov/opa/pr/2008/December/08-crm- 1105. html. 7 See, CG, Complaint, SEC v. Biomet, supra note 221 (