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.
2022 Comments, Reports, & Briefs
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Comments
- New Zealand | Joint Comments on the New Zealand Draft Misuse of Market Power Guidelines | Dec. 1, 2022 | Cover Letter & Comments PDF
- Peru | Joint comments on the Guidelines Draft to Identify Suspicious Joint Bids in Public Procurement Under the Peruvian Competition Act | Oct 31, 2022 | Cover Letter & Comments PDF
- Chile | Joint Comments on the Chilean Competition Authority Consultation for the Update of its “Competition Law Compliance Programs” Guidelines | Oct 28, 2022 | Cover Letter & Comments PDF
- European Commission | Joint Comments on the European Commission’s Consultation on Antitrust Procedural Rules | Oct 5, 2022 | Cover Letter & Comments PDF
- Ireland | Joint Comments on the Draft Guidelines on Access to the File Published by the Irish CCPC | Sept. 14, 2022 | Cover Letter & Comments PDF
- Ireland | Comments on the Draft Addendum to the Leniency Policy | Sept 14, 2022 | Cover Letter & Comments PDF
- Switzerland | Joint Comments in response to WEKO call for inputs in relation to the proposed SWISS regime for vertical restraints (VERTBEK) | August 30, 2022 | Combined Cover Letter & Comments PDF
- China | Joint Comments on Five Draft Provisions Implementing the Anti-Monopoly Law of China | Aug. 18, 2022 | Cover Letter & Comments PDF
- Peru | Joint Comments on the Peruvian Merger Control Guidelines on the Definition and Analysis of Merger Transactions | July 15, 2022 | Cover Letter & Comments PDF
- Brazil | Joint Comments to the ANPD on the Regulation of International Transfers of Personal Data under Brazil’s General Data Protection Law (LGPD) | June 30, 2022 | Cover Letter & Comments PDF
- Argentina | Joint Comments Regarding Argentina’s Draft Regulations for the Notification of Economic Concentrations | June 29, 2022 | Combined Cover Letter & Comments
- European Union | Joint Comments to the European Commission in response to the Commission’s Consultation on Certain Procedural Aspects of EU Merger Control | June 10, 2022 | Cover Letter & Comments PDF
- Uruguay | Joint Comments to the Commission for the Promotion and Defense of Competition in response to the Consultation on Merger Control Guidelines | June 7, 2022 | Cover Letter & Comments PDF
- Ireland | Joint Comments on the Draft Guidelines on the Determination
of Administrative Financial Sanctions and Periodic Penalty Payments Published by the Irish CCPC | May 26, 2022 | Cover Letter & Comments PDF
- Malaysia | Comments on the Malaysian Competition Commission Consultation Paper on the Proposed Amendments to the Competition Act 2010 | May 26, 2022 | Combined Cover Letter & Comments
- Netherlands | Comments on the ACM Guidelines on the Protection of the Online Consumer | May 23, 2022 | Combined Cover Letter & Comments
- European Commission | Comments on the European Commission's Consultation Document on the Revision of the EU Competition Rules | April 26, 2022 | Combined Cover Letter & Comments
- United States | Comments on the American Innovation and Choice Online Act | April 27, 2022 | Combined Cover Letter & Comments
- United States | Comments on the DOJ/FTC Merger Guidelines Request for Information | April 14, 2022 | Combined Cover Letter & Comments
- Ireland | Joint Comments on the Initial Set of Draft Guidelines Published by the Irish Competition and Consumer Protection Commission | March 11, 2022 | Combined Cover Letter & Comments
- Switzerland | Joint Section Comments on Swiss Competition Act Amendments | March 11, 2022 | Combined Cover Letter & Comments
- United States | Comments on Bank Merger Competitive Analysis | February 15, 2022 | Combined Cover Letter & Comments