Comments:

Ladies and Gentlemen, I am pleased to submit my comments in the above-referenced proceeding on Single-Firm Conduct and Antitrust Law. I have attached my statement Two-Sided Platforms and Analysis of Single-Firm Conduct. My conclusion is that there is no general reason, at least at this point in the literature, to believe that two-sided platforms are more or less likely than other businesses to engage in anticompetitive practices. When two-sided platforms are the subject of antitrust analysis, proper analysis should consider the implications of two-sidedness for evaluating market definition, assessing market power, considering efficiencies, and assessing anticompetitive effects. Part of this submission are two papers that I have previously (co-)written on this topic. As it is not possible to attach more than one document to this online submission form, I will send these papers to section2hearings2@ftc.gov. Please confirm receipt and let me know if you have any questions about my statement. Thank you very much. Regards, David S. Evans Chairman, eSapience, Ltd., Cambridge, MA Executive Director, Jevons Institute for Competition Law and Economics and Visiting Professor, University College London, London, U.K.