December 31, 2016

2016

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 of the American Bar Association Sections of Antitrust Law and International Law on the Preliminary Bills for the Protection of Personal Data for the Republic of Brazil
    (December 2, 2016)
    Cover LettersComments (English)Comments (Portuguese)


  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law on the Bundeskartellamt's Public Consultation Version of Guidance on Remedies in Merger Control
    (December 2, 2016)
    Cover LetterComments


  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law on the Proposed Update to the U.S. Department of Justice and Federal Trade Commission Antitrust Guidelines for International Enforcement and Cooperation
    (December 1, 2016)
    Cover LetterComments


  • Best Practices for Antitrust Procedure: Report of the ABA Section of Antitrust Law International Task Force
    Comments (May 22, 2015)Cover Letter (November 7, 2016)


  • Joint Comments of the American Bar Association's Sections Of Antitrust Law and International Law on the Exposure Draft of the Competition and Consumer Amendment (Competition Policy Review) Bill 2016
    (October 27, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on the Draft "Framework For Concerted Practices Guidelines" of the Australian Competition and Consumer Commission
    (October 27, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association’s Sections of Antitrust Law and International Law on the Draft "Framework For Misuse Of Market Power Guidelines" of the Australian Competition and Consumer Commission
    (October 21, 2016) Cover LetterComments


  • Comments of the American Bar Association Sections of Antitrust Law and International Law to the National Commission for the Defense of Competition on the Draft Legislative Proposal to Update the Rules and Institutions for the Defense of Competition in the Argentine Republic
    (October 14, 2016) Cover LetterComments


  • Comments of the ABA Sections of Antitrust Law and Intellectual Property Law to Proposed Update to Federal Trade Commission and U.S. Justice Department Antitrust Guidelines for the Licensing of Intellectual Property
    (September 26, 2016) Cover Letter • Comments


  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law to the Japan Fair Trade Commission on the Summary of Issues Concerning The Modality of the Administrative Surcharge System of the Study Group on the Antimonopoly Act
    (August 31, 2016) Cover Letter and Comments [Japanese, English]Cover Letter [Japanese]

  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law on the First Draft Bill of the German Ministry of Economics and Energy for the 9th Amendment of the Act Against Restraints of Competition
    (August 15, 2016) Cover LetterComments


  • Comments of the American Bar Association Sections of Antitrust Law and International Law on the Draft Guidelines of the Anti-Monopoly Commission of the State Council on Determining the Illegal Gains Generated From Monopoly Conduct and on Setting Fines
    (July 21, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on CADE's Public Consultation N. 02/2016, dated May 5, 2016
    (July 6, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law on the Draft Guidelines on General Conditions and Procedures for the Exemption of Monopoly Agreements of the Antimonopoly Commission of the State Council of the People's Republic of China
    (June 29, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association's Sections of Antitrust Law and International Law on INDECOPI's Draft Leniency Program Guidelines
    (June 20, 2016) Cover LetterComments


  • Joint Comments of the American Bar Association Sections of Antitrust Law, Intellectual Property Law, International Law, And Science & Technology Law on the Government of India's Discussion Paper on Standard Essential Patents and Their Availability on FRAND Terms
    (April 21, 2016) Cover LetterComments


  • Comments of the American Bar Association Sections of Antitrust Law and International Law on the Draft Anti-Unfair Competition Law of the People's Republic of China
    (March 24, 2016) Cover LetterComments (Chinese, English)


  • Comments of the American Bar Association’s Sections of Antitrust Law and International Law Regarding the National Development and Reform Commission’s (“NDRC”) February 3, 2016 Draft Guidelines for Applying Leniency Program to Horizontal Monopoly Agreements
    (March 15, 2016) Cover Letter • Comments (ChineseEnglish) • Appendix A


  • Joint Comments of the American Bar Association Section of Antitrust Law and Section of International Law On guidelines On Undertakings’ Commitments in Anti-Monopoly Cases (Draft for Comment)
    (March 14, 2016) Cover LetterComments (in Chinese, then English)


  • Joint Comments of the American Bar Association Sections of Antitrust Law and International Law on New Zealand's Targeted Review of the Commerce Act 1986 (February 17, 2016) Cover LetterComments


  • Comments of the ABA Sections of Antitrust Law and International Law on the European Commission's Public Consultation on Empowering the National Competition Authorities to Be More Effective Enforcers
    (February 12, 2016)
    Cover LetterComments


  • Joint Comments of the American Bar Association's Sections of Antitrust Law, Intellectual Property Law, and International Law on the Anti-Monopoly Guideline on Intellectual Property Abuse (Draft for Comments)
    (February 4, 2016)
    Cover LetterComments


  • Comments of the ABA Sections of Antitrust Law and International Law on the Administrative Council for Economic Defense's Draft Guidelines for Its Antitrust Leniency Program
    (February 1, 2016)
    Cover LetterComments