AAI submitted comments in response to the Federal Trade Commission’s request for public comments for Hearing #5 On Competition and Consumer Protection in the 21st Century. The FTC sought feedback on several questions pertaining to vertical merger enforcement.
AAI’s comments discuss updating the 1984 Non-Horizontal Merger Guidelines to address appropriate structural presumptions, burdens of proof, the evaluation of efficiencies claims, and the role of behavioral and structural remedies. Among other things, the comments collect, organize, and excerpt AAI’s recent work on these topics.
