2019 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

• United States | Federal Trade Commission “16CFT parts 801 and 803: Amendments to the Premerger Notification Rules, Notice of Proposed Rulemaking, Matter No. P989316” (December 30, 2019) | Combined Cover Letter & Comments
  
• China | ABA Comments on SAMR Draft Compliance Guidelines (December 27, 2019) | Combined Cover Letter & Comments
  
• Peru | Comments in Response to the Peruvian Competition Authority’s Request for Public Comments Regarding its Draft Guidelines on Inspection Visits (Dawn Raids) (December 6, 2019) | Combined Cover Letter & Comments
  
• Mexico | Comments Regarding the Proposed Draft Regulatory Provisions for COFECE’s Leniency and Immunity Program (November 22, 2019) | Combined Cover Letter & Comments
  
• France | Comments Regarding France’s Competition Authority Draft of Revised Guidelines for the Competition Authority on the Control of Concentrations (“2019 Draft Merger Guidelines”) (November 21, 2019) | Combined Cover Letter & Comments
  
• Japan | Comments Regarding JFTC Merger Guideline and Policies (November 4, 2019) | Combined Cover Letter & Comments [English Version] [Japanese Version]
  
• Peru | Comments in Response to the Peruvian Competition Authority’s Request for Public Comments Regarding its Draft Guidelines on Antitrust Compliance Program | Combined Cover Letter & Comments
  
• European Union | Comments regarding Communication on the Protection of Confidential Information for the Private Enforcement of EU Competition Law by National Courts (October 18, 2019) | Combined Cover Letter & Comments
  
• Peru | Comments in Response to the Peruvian Competition Authority’s Request for Public Comments Regarding its Draft Guidelines on Antitrust Rewards Program (October 15, 2019) | Combined Cover Letter & Comments
• Canada | Joint Comments Regarding Canadian Competition Bureau Draft Model Timing Agreement for Merger Reviews Where Merging Parties Raise Efficiencies Claims (September 30, 2019) | Combined Cover Letter & Comments
• Japan | The American Bar Association Antitrust Legislation on the Antitrust Act (Draft) on the Abuse of Superior Position in Digital Platformers and Consumers who Provide Personal Information by the Fair Trade Commission and Opinion of International Law Committee (September 27, 2019) | Combined Cover Letter & Comments
  
• Australia | Joint Comments on the Australian Competition and Consumer Commission’s Draft Guidelines on the Repeal of Subsection 51(3) of the Competition and Consumer Act of 2010 (July 18, 2019) | Combined Cover Letter & Comments 
  
• Spain | Comments of the American Bar Association’s Antitrust Law Section Regarding the Cnmc’s Consultation on its Online Advertising Sector Inquiry (June 4, 2019) | Cover Letter & Comments
• European Union | Joint Comments on the European Commission’s Consultation on the Current Regime for the Assessment of Vertical Agreements | May 23, 2019 |Cover Letter & Comments
• United States | Comments Regarding the U.S. Justice Department Antitrust Division Roundtable Discussion of the Antitrust Criminal Penalty Enhancement & Reform Act (ACPERA) April 11, 2019 | Cover Letter & Comments
• Argentina | Joint Comments on the Draft Guide for Merger Notification Proposed by Argentina’s National Commission | March 29, 2019 | 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 Joint opinion issued by the Bureau on the Prohibition of Abuse of Market Dominant Status  (March 7, 2019) | Cover Letter & Comments
• Chile |  Joint Comments of the Antitrust Law and International Law Sections on the Proposed Revisions to the Chilean Merger Notification Regulations (May 6, 2019) | Cover Letter & Comment
• Chile |  Joint Comments of the Sections of Antitrust Law and International Law on the Draft Penalty Guidelines Issued by the Chilean Fiscalía Nacional Económica (February 28, 2019) | Cover Letter & Comments
• Peru | Comments of the American Bar Association Sections of Antitrust Law and International Law in Response to Indecopi’s Request for Public Comments Regarding its Draft Guide to Trade Associations and Free Competition (February 25, 2019) Cover Letter | Comments 
• Australia | Comments of the American Bar Association Section of Antitrust Law on the Australian Competition and Consumer Commission’s Preliminary Report on Digital Platforms (February 15, 2019) Cover Letter | Comments
• The Netherlands |  Comments of the American Bar Association Section of Antitrust on the Dutch Ministry of Economic and Climate Affairs Consultation on Online Platforms and Competition Law (February 5, 2019) Cover Letter | Comments
• China | Comments of the American Bar Association’s Sections of Antitrust Law and International Law to the National People’s Congress of the People’s Republic of China on the Draft Amendment of China’s Patent Law (February 5, 2019) Cover Letter | Comments
• EU | Comments of The American Bar Association Sections of Antitrust Law and International Law on the European Data Protection Board Guidelines 3/2018 on the Territorial Scope of the GDPR January 17, 2019) | Cover Letter & Comments