Abstract
This paper models the Federal Trade Commission’s (FTC) unilateral effects merger policy using a sample of 192 investigations undertaken between 1993 and 2010. Statistical analysis shows that the number of significant rivals represents a reasonable structural proxy for the FTC’s merger challenge decision, although other variables, such as impediments to entry, fringe share, clear evidence of head-to-head competition between the merging firms, competitive effects’ evidence, and efficiency-related proxies, also affect the decision to challenge a merger. Some of these variables suggest that the innovations in the 2010 Merger Guidelines had already been applied in FTC merger analysis.
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