IN THE UNITED STATES DISTRICT COURTFOR THE DISTRICT OF COLUMBIAU.S. SECURITIES AND EXCHANGE COMMISSION,100 F Street, NEWashington, DC 20549,
,-v-PFIZER INC.,235 East 42nd StreetNew York, NY 10017,
Plaintiff, U.S. Securities and Exchange Commission (the “Commission”), alleges:
This action arises from violations of the books and records and internal controlsprovisions of the Foreign Corrupt Practices Act of 1977 (“the FCPA”) by Defendant Pfizer Inc.(“Pfizer”), relating to improper payments made to foreign officials in numerous countries by theemployees and agents of Pfizer’s subsidiaries in order to assist Pfizer in obtaining or retainingbusiness.2.
At various times from at least 2001 through 2007, employees and agents of subsidiaries of Pfizer, conducting business in Bulgaria, China, Croatia, Czech Republic, Italy,Kazakhstan, Russia, and Serbia, engaged in transactions for the purpose of improperlyinfluencing foreign officials, including doctors and other healthcare professionals employed by