Penguin LTD = Penguin UK. Simon & Schuster UK also have some books on Kobo that are not agency. Even though they stated they were participating in agency pricing last year I am wondering if the EU investigation has caused them to pull back on this. Random House UK already stated that they would wait until the end of the investigation before they would go to agency model. I don't see their books at Kobo.
Simon & Schuster UK