Horizontal Merger Guidelines Review Project: Proposed New Horizontal Merger Guidelines #548050-00002

Submission Number:
548050-00002
Commenter:
Richard Higgins
State:
DC
Initiative Name:
Horizontal Merger Guidelines Review Project: Proposed New Horizontal Merger Guidelines

Please consider expanding or dropping the discussion regarding markets that are especially vulnerable to coordinated conduct in the last paragraph on p. 25 and the second full paragraph on p. 26, in section 7.2. A reasonable interpretation of these statements is that the more competitive a market is, the more vulnerable it is to monopolization through tacit collusion. If the present guidance is retained, I suggest that it be stated more directly along the lines of the my interpretation.