The SEC stated that: "[It] filed two settled enforcement proceedings against Avery Dennison Corporation ("Avery"), a Pasadena, California-based multinational corporation, alleging violations of the Foreign Corrupt Practices Act ("FCPA") in connection with improper payments and promises of improper payments to foreign officials by Avery's Chinese subsidiary and several entities Avery acquired."

The Court stated: "The Securities and Exchange Commission (the "Commission") having filed a Complaint ("Complaint") and Defendant Avery Dennison Corporation ("Avery") having entered a general appearance; consented to the Court's jurisdiction over Avery and the subject matter of this action; consented to entry of this Final Judgment without admitting or denying the allegations of the Complaint (except as to jurisdiction), in the Consent of Defendant Avery Dennison Corporation to Entry of Final Judgment Ordering Penalty ("Consent"); waived findings of fact and conclusions of law; and waived any right to appeal from this Final Judgment"