Comments, Reports & Amicus Briefs for 2012

  • Report of the Task Force on Controlling Costs of Antitrust Enforcement and Litigation
    (December 20, 2012)


  • Joint Comments of the ABA Sections of Antitrust Law and International Law on the Proposed Regulation of the European Parliament and of the European Council on the Protection of Individuals with Regard to the Processing of Personal Data and on the Free Movement of Such Data
    Cover LetterComments
    (November 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law, Section of Intellectual Property Law, and Section of International Law on the SAIC Draft Guide on Anti-Monopoly Law Enforcement in the Field of Intellectual Property Rights
    Cover LetterComments
    (October 2012)

  • Comments of the Sections of Antitrust Law and International Law of the American Bar Association on the United Kingdom’s Competition Commission’s Draft "Guidelines for Market Investigations" for Public Consultation
    Cover LetterComments
    (September 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law to the Department for Business Innovation & Skills' Consultation on Options for Reform of Private Actions in Competition Law
    Cover LetterComments
    (July 2012)
  • Comments of the American Bar Association Section of Antitrust Law and Section of International Law on the Colombian Superintendent of Industry and Commerce's Draft Guidelines on the Application of Competition Law to Business Associations and Groups or Associations of Professionals
    Cover LetterComments
    (June 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law Regarding the Office of Fair Trading’s Review of the OFT's Investigation Procedures In Competition Cases
    Cover LetterComments
    (June 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law on the Malaysian Competition Commission’s Draft Enforcement Guidelines on the Abuse of Dominance Provisions (Chapter 2 of the Competition Act)
    Cover LetterComments
    (June 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law on the Canadian Competition Bureau’s Draft Updated Enforcement Guidelines on the Abuse of Dominance Provisions (Sections 78 and 79 of the Competition Act) (The Draft Guidelines)
    Cover Letter • Comments
    (May 2012)

  • Comments Of The ABA Sections of Antitrust Law and International Law to the Brazilian Administrative Council of Economic Defense Draft Merger Notification Regulations Dated March 19, 2012 and Draft Regulations on Calculations of Fines Dates March 22, 2012
    Cover Letter • Comments (in English and in Portuguese)
    (April 2012)

  • Comments of the ABA Sections of Antitrust Law and International Law to the European Commission's Green Paper: Towards an Integrated European Market for Card, Internet and Mobile Payments
    Cover LetterComments
    (March 2012)

  • Comments to Federal Trade Commission re: Parts 2 and 4 Rules of Practice Rulemaking (16 CFR Parts 2 and 4) (Project No. P112103)
    Cover Letter and Comments
    (March 2012)

  • Joint Comments of the American Bar Association's Section of Antitrust Law, Section of International Law and Section of Intellectual Property Law on Commission Regulation on the Application of Article 81(3) of the EC Treaty to Categories of Technology Transfer Agreements and Commission Notice on Guidelines on the Application of Article 81 to Technology Transfer Agreements
    Cover LetterComments
    (February 2012)

  • Comments of the ABA Section of Antitrust Law and Section of International Law in Response to the United Kingdom Office of Fair Trading's Request for Public Comment on the Draft Detailed Guidance on the Principles and Process for Applications for Leniency and No-Action in Cartel Cases
    Cover LetterComments
    (January 2012)

  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law on the Office of Fair Trading's Draft Revised Guidance as to the Appropriate Amount of a Penalty (OFT423con)
    Cover LetterComments
    (January 2012)

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