2018 Comments, Reports, & Briefs

These Section comments were submitted and cleared in accordance with ABA Blanket Authority Policy.  Please note that Blanket Authority is effective for two years from the date of submission, unless granted under “Expedited” procedure, in which case it is effective for 90 days from the date of submission.

Comments

• European Union - Comments Of The American Bar Association’s Section Of Antitrust Law On The European Commission’s Request For Input On The Evolution Of Competition Policy In Light Of The Digitization Of The Economy - December 18, 2018 | Cover Letter | Comments
• India - Comments Of The American Bar Association Sections Of Antitrust And International Law On Proposed Amendments And Revisions To India’s Competition Act And Related Rules And Regulations | December 6, 2018 | Cover Letter | Comments
• Peru - Comments Of The American Bar Association Sections Of Antitrust And International Law To Indecopi On Draft Bill 1579/2016-Cr (Congressman Gonzales Ardiles) And Draft Bill 1853/2017-Cr (Congressman Lescano Ancieta) December 5, 2018 | Cover Letter | Comments
• China - The American Bar Association's Antitrust Law Department and the International Law Department on China's National Market Supervision and Management The Interim Measures for the Administration of Administrative Supervision and Punishment for Market Supervision and Management (Consultation Draft) and the Municipality Joint Opinions on the Interim Provisions on the Administrative Punishment Procedures for the Supervision and Administration of the Field (Draft for Comment) | December 4, 2018 | Cover Letter | Comments
• Switzerland -  Comments Of The American Bar Association Sections Of Antitrust Law And International Law On The Swiss Federal Council’s Indirect Counterproposal For Rules Against Price Discrimination (November 21, 2018) | Cover Letter | Comments
• Argentina – Comments of the American Bar Association Sections of Antitrust and International Law on the Draft Guidelines for the Analysis of Cases of Abuse of Dominance Issued by the Argentinian Comision Nacional de Defensa de la Competencia
  (November 2, 2018)
  Cover Letter | Comments
• Israel - Joint Comments Of The American Bar Association Section Of Antitrust Law And Section Of International Law On The Israel Antitrust Authority Consultation On Competition Issues In The Digital Economy ( October 31, 2018) Cover Letter | Comments
• Australia - Comments Of The American Bar Association Section Of Antitrust Law In Response To The Australian Competition And Consumer Commission’s Request For Public Comments Regarding Its Draft Guidelines On Immunity And Cooperation Policy For Cartel Conduct 
  (Octpber 22, 2018) Cover Letter | Comments
• Korea - Comments Of The American Bar Association Sections Of Antitrust And International Law On The Korea Fair Trade Commission’s Proposed Amendments To The Monopoly Regulation And Fair Trade Law (October 3, 2018) Cover Letter | Comments
• Malta - Comments Of The American Bar Association Section Of Antitrust Law In Response To The Republic Of Malta Ministry For Justice, Culture And Local Government, Malta Competition And Consumer Affairs Authority Consultation On An Act To Amend The Competition Act, Cap. 379 And The Consumer Affairs Act Cap. 378 And Other Laws, To Extend The Competence Of The Civil Court (Commercial Section) And To Make Ancillary And Consequential Provisions Thereto (September 28, 2018) Cover Letter | Comments

• France - Comments Of The American Bar Association’s Sections Of Antitrust Law And International Law Regarding The French Competition Authority’s Consultation On Modernizing And Simplifying The French Merger Control Law (September 28, 2018) Cover Letter | Comments

• India - Comments Of The American Bar Association Sections Of Antitrust Law And International Law On The Personal Data Protection Bill, 2018 (September 27, 2018) Cover Letter | Comments

• South Africa - Comments Of The American Bar Association Section Of Antitrust Law On The Competition Amendment Bill, 2018 (September 7, 2018) Combined Cover Letter & Comments
• United States - Comments Of The Section Of Antitrust Law Of The American Bar Association In Advance Of The Federal Trade Commission Hearings On Competition And Consumer Protection In The 21st Century (August 20, 2018) Cover Letter | Comments
• United Kingdom - Comments Of The American Bar Association Section Of Antitrust Law And Section Of International Law On The Draft Guidance Document On The Cma’s Investigation Procedures In Competition Act 1998 Cases (Consultation Document) (July 30, 2018) Cover Letter | Comments
  
• Peru - Joint Comments Of The American Bar Association’s Section Of Antitrust Law And Section Of International Law On Indecopi’s Legislative Recommendations To Promote Competition In Public Procurement (July 30, 2018) Cover Letter | Comments
• Canada - Comments Of The American Bar Association Sections Of Antitrust Law And International Law In Response To The Canadian Competition Bureau Request For Public Comments Regarding Its Draft Immunity And Leniency Program Under The Competition Act    (July 9, 2018) Cover Letter | Comments 
• European Union - Comments Of The American Bar Association’s Sections Of Antitrust Law And International Law On The European Commission’s Proposal For A Regulation Promoting Fairness And Transparency For Business Users Of Online Intermediation Services (June 25, 2018) Cover Letter | Comments
  
• Germany - Joint Comments Of The American Bar Association Section Of Antitrust Law And Section Of International Law On The Draft Guidance On Transaction Value Thresholds For Mandatory Pre-Merger Notification (Section 35 (1a) Gwb And Section 9 (4) Kartg    (June 15, 2018) Cover Letter | Comments 
• Canada - Comments of American Bar Association Sections of Antitrust Law and International Law on the Canadian Competition Bureau Abuse of Dominance Enforcement Guidelines
  (May 14, 2018)
  Cover Letter & Comments
  
• United Kingdom - Comments of American bar Association Sections of Antitrust Law and International Law on the U.K. Competition and Markets Authority Public Consultation on Information Requests in Merger Control (May 2, 2018)
  Cover Letter & Comments
  
• Chile - Comments of American Bar Association Sections of Antitrust Law and International Law on Chile's Internal Guidelines for the Submission of Criminal Claims for Cartel Offences.
  (April 12, 2018) 
  Cover Letter & Comments
  
• India - Comments of the American Bar Association Sections of Antitrust Law and International Law on the White Paper on a Data Protection Framework For India
  (January 31, 2018)
  Cover Letter & Comments
  
• South Africa - Comments of the American Bar Association Sections of Antitrust Law and International Law on the Competition Amendment Bill, 2017
  (January 30, 2018)
  Cover Letter & Comments
  
• Korea - Comments of the American Bar Association Sections of Antitrust Law and International Law on the Amended Rules on the Korea Fair Trade Commission’s Committee Operation and Case Handling Procedure
  (January 26, 2018)
  Cover Letter & Comments
• Belgium - Comments of the American Bar Association's Sections of Antitrust Law and International Law on the European Commission's Public Inception Impact Assessment on Fairness in Platform-to-Business Relations
• (January 9, 2018)
  Cover Letter & Comments