Abstract
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 are insufficient to guide decisions regarding the likely competitive effects of mergers; and (3) that simplistic inferences of competitive effects based on theoretical or econometric evidence from other industries are inappropriate and unpersuasive.
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