Blanket Authorities Initiatives

Simply stated, "blanket authority" is the process through which an ABA section or division seeks approval from other ABA entities to present its own view, rather than an official ABA position, to a governmental body. In general, this procedure is employed when the subject matter of the position is extremely technical and when a time-sensitive need exists and it is not possible to have either the ABA House of Delegates or ABA Board of Governors go through the regular process for adopting Association policy.

Below is a list of current blanket authority initiatives of the Section. Please be advised that members must follow the policy procedure and usage guidelines outlined in the American Bar Association's Constitution and Bylaws, Rules of Procedure of the House of Delegates. The handbook on blanket authority can be found here:
Blanket Authority Handbook

Comments on the European Commission’s Vertical Block Exemption Regulation Consultation Document

Comments on the UK Competition and Markets Authority Consultation Paper on “Algorithms: How They Can Reduce Competition and Harm Consumers”

Comments on New Zealand Commerce Commission’s Revised Cartel Leniency and Immunity Policy under the Commerce Act

Comments on Nigeria’s Federal Competition and Consumer Protection Act Merger Review Regulations 2020

Comments on the United Kingdom Competition and Markets Authority Merger Review Guidelines

Comments to the European Data Protection Board on Measures that Supplement Transfer Tools to Ensure Compliance with the Level of Protection of Personal Data

Comments to China's State Administration for Market Regulation on Draft Antitrust Guidelines for Platform Economy

Comments to the Namibian Competition Commission on the Draft Competition Amendment Bill

Comments on Indecopi’s Draft Guidelines on Actions for Damages on Behalf of Consumers as a Consequence of Anticompetitive Conduct

Comments on the World Bank's International Centre for the Settlement of Investment Disputes (ICSID) and the United Nations Commission on International Trade Law (UNCITRAL) Working Group III Draft Code of Conduct for Adjudicators in Investor-State Dispute Settlement

Comments on the European Commission’s Consultation on Review of the Market Definition Notice

Comments of the American Bar Association's Antitrust Law and International Law Sections on Draft Anti-Monopoly Guidelines in the Field of Platform Economy
Comments

Comments of the Antitrust Law Section and the International Law Section of the American Bar Association on the Australian Competition and Consumer Commission's Proposed News Media Bargaining Code
Comments

Joint Comments of the Section of Intellectual Property Law, and
International Law Section of the American Bar Association on the Second Reading Draft of China’s Patent Law Amendments
Comments

Comments on Draft Report of the Department of State Commission on Unalienable Rights
Comments

IP Law Section and International Law Section comments to the U.S. Patent & Trademark Office regarding China's Supreme People's Court's 6 draft documents regarding intellectual property and trade secrets disputes
Comments

Comments on JFTC Attorney Client Privilege and Surcharge Reduction Rules
Comments

Letter to the U.S. Patent and Trademark Office on China’s Draft Guidelines Regarding the Enforcement of IP Judgments
Comments

Comments regarding India’s Personal Data Protection Bill, 2019
Cover Letter | Comments

Comments on China's draft amendments to its Anti-Monopoly Law
Cover Letter | Comments

Comments on the European Commission’s Competition Rules on Horizontal Agreements Between Companies
Cover Letter | Comments

Comments on China’s State Administration for Market Regulation’s Draft Anti-Monopoly Compliance Guidelines for Undertakings
Cover Letter | Comments

Comments regarding the Peruvian Competition Authority’s Request for Public Comments regarding its Draft Guidelines on Antitrust Compliance Programs
Cover Letter | Comments

Comments on the revised Guidelines to Application of the Antimonopoly Act Concerning Review of Business Combination and the revised Policies Concerning Procedures of Review of Business Combination
Cover Letter and Comments (English)
Cover Letter and Comments (Japanese)

Comments on the Japan Fair Trade Commission Regarding Draft Guidelines Concerning Abuse of a Superior Bargaining Position in Transactions Between Digital Platform Operators and Consumers that Provide Personal Information, etc.
Cover Letter | Comments

Joint Comments Regarding Canadian Competition Bureau Draft Model Timing Agreement for Merger Reviews Where Merging Parties Raise Efficiencies Claims
Cover Letter | Comments

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
Comments

Comments to the Organisation for Economic Co-operation and Development (“OECD”) Working Group on Bribery (“WGB”) on proposed updates to the 9 December 2009 Recommendation of the Council for Further Combating Bribery of Foreign Public Officials in International Business Transactions
Cover Letter | Comments

Comments in response to the European Commission’s consultation on the Current Regime for the Assessment of Vertical Agreements
Cover Letter | Comments

Comments on the Proposed Revisions to the Chilean Merger Notification Regulations
Cover Letter | Comments

Comments on the Draft Guide for Merger Notification Proposed by Argentina’s National Commission
Cover Letter | Comments

Comments concerning the Rohingya Refugee Crisis
Cover Letter | Comments

Sections of Antitrust Law and International Law joint comments on the Regulation on the Prohibition of Abuse of Dominant Market Position (Draft for Comments)
Cover Letter | Comments

Sections of Antitrust Law and International Law comments on the FNE Fining Guidelines
Cover Letter | Comments

Sections of Antitrust Law and International Law comments on INDECOPI’s Draft Guide to Trade Associations and Free Competition
Cover Letter | Comments

Joint Comments on China Patent Law
Cover Letter | Comments

Sections of International Law and Antitrust Law comments to China’s State Administration for Market Regulation on its Interim Measures for Administrative Penalty Hearings in Market Regulation (Draft for Public Comment) and its Interim Provisions on Administrative Penalty Procedures in Market Regulation (Draft for Public Comment)
Cover Letter | Comments

Joint Comments regarding Draft Bills on Reduction of Leniency Benefits
Cover Letter | Comments

Comments to the Organization of American States (OAS) on OAS’s Second Draft of the Guide on the Law Applicable to International Commercial Contracts in the Americas
Cover Letter | Comments

Comments on the advance notice of proposed rulemaking published by the U.S. Department of Commerce, Bureau of Industry and Security
Comments

Comments to China’s State Administration for Market Regulation on its Interim Measures for Administrative Penalty Hearings in Market Regulation (Draft for Public Comment) and its Interim Provisions on Administrative Penalty Procedures in Market Regulation (Draft for Public Comment)
Cover Letter | Comments

Comments on EU Consultation on the Digital Economy
Cover Letter | Comments

Comments on Proposed Amendments and Revisions to India’s Competition Act and Related Rules and Regulations
Cover Letter | Comments

Joint Comments to Switzerland on International Price Discrimination
Cover Letter | Comments

Comments on the EU Proposed Guidelines on Cartel Overcharges
Cover Letter | Comments

Joint comments on Argentina’s Draft Guidelines for the Analysis of Cases of Abuse of Dominance
Cover Letter | Comments

Comments of ABA Sections of Antitrust and International Law on the proposed amendments to the Monopoly Regulation and Fair Trade Law
Cover Letter | Comments (English) | Comments (Korean)

Comments by the American Bar Association Sections of Antitrust Law and International Law on the French Merger Control Consultation
Cover Letter | Comments

Comments on India’s Personal Data Protection Bill
Cover Letter | Comments

Joint comments on the Israel Antitrust Authority Consultation on Competition Issues in the Digital Economy.
Cover Letter | Comments

Comments in response to the Argentinian National Commission for the Defense of Competition’s Draft Regulation for the Implementation of the Leniency Program
Cover Letter | Comments

Comments on the Italian Competition Authority’s request for public comments regarding its Draft Guidelines on Compliance Programs
Cover Letter | Comments

Joint Comments on the Abuse of Dominance Enforcement Guidelines for the Canadian Competition Bureau
Cover Letter | Comments

Comments on Chile's Internal Guidelines for the Submission of Criminal Claims for Cartel Offences
Cover Letter | Comments

Comments on India White Paper on Data Protection Framework
Cover Letter | Comments

Comments on South Africa Competition Amendment Bill, 2017
Cover Letter | Comments

Comments on Revisions to Canada Competition Bureau Immunity Program
Cover Letter | Comments

Comments on Draft European Commission's Public Inception Impact Assessment Fairness in Platform-to-Business Relations
Cover Letter | Comments

Final Comments on Proposed Reform to Israeli Antitrust Law
Cover Letter | Comments

Joint Comments on Amended Rules on the KFTC Committee Operation and Case Handling Procedure
Cover Letter | Comments

Revised Draft for Comment of Measures for the Review of Undertaking Concentrations under the Anti-Monopoly Law
Cover Letter | Comments

French Competition Authority's Consultation on Modernizing and Simplifying the French Merger Control Law
Cover Letter | Comments

Comments to the National Commission for the Defense of Competition on the Draft Version of the New Argentine Merger Control Guidelines
Cover Letter | Comments

Comments to the Japan Fair Trade Commission on the Study Group Report on Surcharges
Cover Letter | Comments

Comments of the American Bar Association on the draft Vietnamese Competition Law
Cover Letter | Comments

Joint comments on the Draft Guidelines for the Determination of Administrative Penalties for Failure to Notify a Merger and Implementation of Mergers Contrary to the Competition Act
Cover Letter | Comments

Comments to the National Reform & Development Commission on the Guidelines on Trade Association Pricing Activities
Cover Letter | Comments

Comments on the Japan Fair Trade Commission’s Draft Revisions to Guidelines re Distribution Systems and Business Practices under the Antimonopoly Act
Cover Letter | Comments (English) | Comments (Japanese)

Joint Comments on the European Commission’s Public Consultation on Building the European Data Economy
Cover Letter | Comments

Comments to the Anti-Monopoly Commission (“the AMC”) of the State Council of the People’s Republic of China on the Anti-Monopoly Guidelines on Abuse of Intellectual Property Rights
Cover Letter | Comments

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

Joint comments with the Section of Antitrust Law on the United Kingdom’s Competition Commission’s Draft "Guidelines for Market Investigations" for Public Consultation.
Cover Letter | Comments

Joint comments of the Sections of Antitrust Law and International Law to the Proposal for a Regulation of the European Parliament and of the Council on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of Such Data.
Cover Letter | Comments

Joint comments on the draft amendments of the Copyright Law of the People’s Republic of China.
Cover Letter | Comments

Joint comments in response to Brazil’s Administrative Council for Economic Defense (CADE) Proposed Regulations on Merger Control and on Calculation of Fines in Cartel Cases.
Cover Letter | Comments - English

Joint comments in response to the European Commission’s request for comments on its Green Paper – Towards an integrated European market for card, internet and mobile payments.
Cover Letter | Comments

Joint comment in response to the European Commission's request for comments on its Treaty on Categories of Technology Transfer Agreements and the Commission Notice on Guidelines on the Application to Technology Transfer Agreements.
Cover Letter | Comments

Joint comment in response to the United Kingdom Office of Fair Trading (OFT) regarding its draft detailed guidance on the principles and processes for applications for leniency and no-action in cartel cases.
Cover Letter | Comments

Joint comment in response to the United Kingdom Office of Fair Trading (OFT) regarding its draft revised guidance as to the appropriate amount of penalty.
Cover Letter | Comments

Comments to the European Commission on the European Approach in Collective Redress
Cover Letter | Comments

Joint comments to the PRC Proposed Trademark Law.
Cover Letter | Comments

Joint comment in response to the European Commission's request for comments on its Draft Guidance Paper on quantifying harm in antitrust damages actions.
Cover Letter | Comments

Joint comments to the Bundeskartellamt on its draft Guidance on Substantive Merger Control.
Cover Letter | Comments

Comments on the US Department of Commerce Bureau of Industry and Security's revisions to the Export Administration Regulations.
Comments

Joint comments on the Canadian Competition Bureau's Merger Enforcement Guidelines
Cover Letter | Comments

Joint comments United Kingdom's Department of Business Innovation & Skills "A Competition Regime for Growth: A Consultation on Options for Reform."
Cover Letter | Comments

Comments to the U.S. Department of Commerce, International Trade Administration, Foreign-Trade Zone Board regarding proposed revisions to the Regulations of the Foreign-Trade Zone Board.
Comments

Comments on the proposed rule issued by the U.S. Department of State's Directorate of Defense Trade (DDTC) concerning proposed amendments to the definition of "defense service" under the International Traffic in Arms Regulations (ITAR).
Comments

Joint comments on the Provision on Relevant Issues Concerning the Applications of Law in the Trial of Civil Monopoly Dispute Cases of China's Supreme People's Court.
Cover Letter | Comments

Joint comments regarding the Chinese Ministry of Industry and Information Technology's Draft Interim Measures for Supervision and Management of the Internet Information Service Market.
Cover Letter | Comments

Joint comments to the French Competition Commission regarding its Draft Notice on Fines.
Cover Letter | Comments

Joint comments on the draft Competition Commission of India (Procedure in Regard to the Transaction of Business Relating to Combination) Regulations.
Cover Letter | Comments

Joint comments regarding the USTR's Anti-Counterfeiting Trade Agreement.
Cover Letter | Comments