On 15 April 2011, the Japan Fair Trade Commission (‘JFTC’) found that 30 companies associated with the engineering works in Enzan district, and 21 companies associated with the engineering works in Isawa district, respectively, were in violation of Article 3 (Prohibition of unreasonable restraint of trade) of the Antimonopoly Act. The companies agreed to decide, between themselves, the successful bidder (called the ‘designated successful bidder’) for various construction projects. Other companies would then support the designated successful bidder by filing bids that were not competitive and unlikely to get selected, a classic approach to bid-rigging. The JFTC conducted a ‘spot investigation’ and issued cease and desist orders for this bid-rigging exercise. The JFTC also imposed a surcharge payment of 756.82 million Yen on the bid-rigging entities in total.