Horizontal Merger Guidelines Review Project: Proposed New Horizontal Merger Guidelines #548050-00007

Submission Number:
548050-00007
Commenter:
Michael Carrier
Organization:
Rutgers Law School
State:
NJ
Initiative Name:
Horizontal Merger Guidelines Review Project: Proposed New Horizontal Merger Guidelines

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."