These comments were submitted to the FTC as part of its hearings on “Competition and Consumer Protection in the 21st Century.” In these comments, we note three high level points: (1) Antitrust policy must avoid the simplistic inference of competitive effects from market structure; (2) HHIs...

Given the link between innovation and economic growth, the stakes of “getting it right” in high-tech antitrust are high. Caution and humility are warranted in light of both the historical hostility towards innovative business practices by competition policy as well as the large gaps of...

The Durbin Amendment to the Dodd-Frank financial reform legislation capped debit card interchange fees for banks with assets of $10 billion. Credit card and prepaid card interchange fees were not regulated. The cap, which took effect on October 11, 2011, cut the average interchange fee for...