In the Matter of Victrex plc, et al.; File No. 141 0042 #00002

Submission Number:
00002
Commenter:
John Thich
State:
Colorado
Initiative Name:
In the Matter of Victrex plc, et al.; File No. 141 0042
I set up and ran the PEEK plant for Evonik Industries from 2005-2010 and subsequently managed the Americas sales and marketing of PEEK for both industrial and medical applications. I retired from Evonik in December 2013. The complaint issued by the FTC and settled by Invibio is correct in all aspects from my experience. Potential Evonik PEEK customers big and small who were doing business with Invibio were all severely restricted by contract from even evaluating alternative supplies for the duration of their exclusive contracts under penalty of loss of supply. Given the time it takes to get approval of medical devices, this made it even more difficult to enter into the market despite very attractive pricing, supply conditions, and performance differences that had significant positive impact on the performance of medical devices made with Evonik PEEK. This complaint and resolution was long overdue. In my opinion, Invibio did a great disservice to the advancement of the use of PEEK in the medical field by the manner in which it conducted its business over the last decade or longer. These are my personal comments and were not submitted to Evonik for prior review.