16 CFR Part 240, Guides for Advertising Allowances and Other Merchandising Payments and Services, FTC File No. P123900 #563686-00005 

Submission Number:
563686-00005 
Commenter:
Theodore Voorhees, Jr.
Organization:
American Bar Association Section of Antitrust Law
State:
Illinois
Initiative Name:
16 CFR Part 240, Guides for Advertising Allowances and Other Merchandising Payments and Services, FTC File No. P123900

January 28, 2013 Via Online Delivery https://ftcpublic.commentworks.com/ftc/fredmeyerguides Federal Trade Commission Washington, DC 20580 Re: Comments of the ABA Section of Antitrust Law to the Federal Trade Commission Regarding its Guides for Advertising Allowances and Other Merchandising Payments and Services (the “Fred Meyer Guides”) On behalf of the American Bar Association Section of Antitrust Law, I am pleased to submit the attached comments to the Federal Trade Commission Regarding its Guides for Advertising Allowances and Other Merchandising Payments and Services (the “Fred Meyer Guides”). Please note that these views are being presented only on behalf of the Section of Antitrust Law. They have not been approved by the House of Delegates or the Board of Governors of the American Bar Association and should not be construed as representing the policy of the American Bar Association. If you have any questions after reviewing this report, I would be happy to provide further comments. Sincerely, Theodore Voorhees, Jr. Chair, Section of Antitrust Law