A common approach to merger simulations used in antitrust cases is to calibrate demand from market shares and a few … additional parameters. When the products involved in the merger case are differentiated along several dimensions, the resulting … diversion ratios may be very different from those based upon market shares. This again may affect the predicted post-merger …

principles informing merger policy such as the presumed profitability of mergers for the merging firms and the merger … concentration indices for screening out unproblematic from potentially harmful mergers. The incremental effect of a merger taking …Common ownership fundamentally upsets the well-settled merger enforcement ecosystem. Not only it challenges basic …

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 …

enormous variety of mergers subject to review. Flawed or vague agency standards are likely to discourage procompetitive … 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 …