Ladies and Gentlemen: Please find enclosed an article I recently published in the October 2009 Antitrust Source on the subject of the Horizontal Merger Guidelines Review Project. The article addresses the issues raised by Initial Questions for Public Comment nos. 1, 2, 3, 7, 9, 10, 11, 12, 13, 14, and 15. The article also proposes three revisions not identified in the Initial Questions. This transmittal and the enclosed article reflect my personal views and do not necessarily represent the views of the Commission or any individual Commissioner.