Abstract

One way of gaining insight into differences between legal systems and assessing their significance is to examine what they — i.e., their representatives — say about each other. The European Commission’s prohibition of the proposed merger between GE and Honeywell in the summer of 2001 led to US responses that reveal much about differences between the US and EU merger laws. They also have potentially important implications for the development of US-European cooperation in the area of competition law. Although there has been general discussion of these responses, there have been few serious attempts to analyze them and to explore their implications for legal development. In this article, I suggest some lines of analysis that may provide insights into the US responses and their potential importance.

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