Rethinking Antitrust

#3: Draft Merger Guidelines: The View of Two Practitioners

Episode Summary

The Merger Guidelines set forth the analytic framework the federal antitrust agencies used to evaluate the reasonably probable competitive effects of mergers, acquisitions and long-term joint ventures. There have been several versions since first released in 1968, all adopting then-current economic analysis of firm behavior as the framework for antitrust merger enforcement policy. Bill Blumenthal, a former General Counsel of the FTC, and Doug Melamed, a former DOJ Acting Assistant Attorney General for Antitrust, join the show to discuss whether the proposed revised Merger Guidelines are consistent with current economic learning and legal doctrine, and if the courts will adopt them as a sensible approach to interpreting Section 7 of the Clayton Act.

Episode Notes

Doug Melamed profile page

William Blumenthal profile page

Our comment for the 2023 proposed draft merger guidelines

Our comments for the 2022 RFI on merger enforcement guidelines

Doug Melamed: Property Rules, Liability Rules, and Inalienability: One View of the Cathedral 

1968 Merger Guidelines

1982 Merger Guidelines

1984 Merger Guidelines

1992 Horizontal Merger Guidelines

1997 Horizontal Merger Guidelines

2006 Commentary on Horizontal Merger Guidelines

2010 Horizontal Merger Guidelines

2020 Vertical Merger Guidelines

2020 Commentary on Vertical Merger Enforcement

2023 Proposed Merger Guidelines