| Comment Number: | 548050-00007 |
| Received: | 5/23/2010 |
| Organization: | Rutgers Law School |
| Commenter: | Michael Carrier |
| State: | NJ |
| Agency: | Federal Trade Commission |
| Rule: | Horizontal Merger Guidelines Review Project: Proposed New Horizontal Merger Guidelines |
| Attachments: | 548050-00007.pdf Download Adobe Reader |
Comments:
In section 6.4 (Innovation and Product Variety), the agencies may wish to make clear that the characteristics of innovation competition vary by industry. One application occurs in innovation markets in the pharmaceutical industry. For a suggested approach that considers not only the number of firms in R&D but also the stage (both preclinical and clinical) of FDA review, you may wish to consider the framework I suggest in my attached article, "Two Puzzles Resolved: Of the Schumpeter-Arrow Stalemate and Pharmaceutical Innovation Markets."