the Federal Trade Commission (“FTC”) in connection with their Request for Information on Merger Enforcement (“Merger RFI …”). This comment addresses the questions contained in Section 5 of the RFI related to the use of presumptions in merger … enforcement. Our view is that an important objective of the agency’s horizontal merger enforcement guidelines is to ensure that …

the Federal Trade Commission (“FTC”) in connection with their Request for Information on Merger Enforcement (“Merger RFI …”). The GAI welcomes the opportunity to provide input on the proposed changes to the Horizontal Merger Guidelines (“HMGs … Section 14 of the Merger RFI, in which the Agencies pose two questions that go to the heart of the treatment of efficiencies …

the Federal Trade Commission (“FTC”) in response to their Request for Information on Merger Enforcement. This Comment … addresses the questions related to Purpose, Harms and Scope. Our view is that the essential and defining purpose of merger … fundamental change in the character of merger analysis would require strong reasons for a profound departure from the present …

the Federal Trade Commission (“FTC”) in connection with their Request for Information on Merger Enforcement (“Merger RFI … important goal of both antitrust law and merger policy.Based on the existing evidence, an empirically supported basis for the … use of differential analyses for labor or for presumptions in labor markets does not clearly exist at this time. Merger …

Commission's January 18, 2022, Request for Information on Merger Enforcement. Despite information and uncertainty problems with … exercise involved in potential/nascent competition cases should differ from a standard merger review. Third, analysis of …

comment concludes by encouraging ex-post empirical analysis of merger remedies …