These comments are respectfully submitted both as to the Horizontal Merger Guidelines ("HMG") generally, and also to questions 1-10., 12-15. They show that as a litigation matter the current HMG must be replaced because they are dependent on the PNB presumption, which will be overruled under the Supreme Court's GTE Sylvania and later presumption cases, and that new merger guidelines (and antitrust analysis generally) should be based on productivity and the Supreme Court's Cracking Oil opinion and recent cases. A productivity based antitrust analysis and productivity based economic theory developed by Harvard Business School Prof. Michael Porter is discussed, and attached: 1. MICHAEL PORTER, Competition and Antitrust: A Productivity-Based Approach, Chap 6, in MICHAEL PORTER, PETER STAUDHAMMER & CHARLES WELLER, UNIQUE VALUE (2005)(hereafter UNIQUE VALUE). 2. MICHAEL PORTER et al., Moving To A New Global Competitiveness Index, Chap. 1.2, WORLD ECONOMIC FORUM, THE GLOBAL COMPETITIVENESS REPORT 2008-2009 (2008).