Abstract
I respond to concerns raised by James Cooper, Luke Froeb, Dan O'Brien, and Michael Vita regarding the analysis of vertical and conglomerate mergers contained in my report to the European Commission. I address their arguments that the raising rivals' costs literature does not support an aggressive stance on vertical mergers; that market power is a necessary, but not a sufficient, condition for a non-horizontal merger to raise antitrust concerns; and that efficiencies intrinsic to a non-horizontal merger should be treated in the second step of the proposed structured rule of reason framework.
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