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.


  • India’s Personal Data Protection Bill, 2019 (February 27, 2020) | Combined Cover Letter & Comments
  • Comments on the Draft Vertical Merger Guidelines Issued by the Department of Justice and the Federal Trade Commission Comments (February 24, 2020) | Combined Cover Letter & Comment
  • Comments to China’s State Administration for Market Regulation (SAMR) on the Draft of Amendments to China’s Anti-Monopoly Law (February 14, 2020) | Combined Cover Letter & Comment
  • Joint Comments on European Commission’s Competition Rules on Horizontal Agreements Between Companies – Evaluation (February 11, 2020) | Combined Cover Letter & Comment
  • Guidance for Regulation of Artificial Intelligence Applications (March 11, 2020) | Combined Cover Letter & Report
  • ion International Comments: The Value of Retrospective Analysis (January 30, 2020) | Report