Although criticized for its alleged lax enforcement of anti-trust laws, the Bush Administration set a record for price-fixing fines. Violators have paid $3.5 billion in the last eight years in criminal price-fixing fines. The fines included a fine against Samsung Electronics of $300 million for price fixing in dynamic random access memory (DRAM) chips and against Mitsubishi Corporation of $134 million for price fixing of graphite electrodes. One factor encouraging these heavy fines was an amnesty program that was more lenient to the first company to confess involvement in a price-fixing cartel and more severe for later confessed violators. Of course, the Obama Administration is not expected to soften the enforcement policy. In addition, in the face of falling prices, competitors may be tempted more than ever towards illegal price-fixing. So a tougher enforcement policy may uncover more actual violations. (As an aside, this report was described in The National Law Journal of January 30, 2009. However, a search of the Department of Justice website did not show the report. It is unclear if this is due to the searcher's lack of skill or due to the report being taken off the DOJ website by the incoming Obama Administration.)