By John J. Kavanagh & Weisiyu Jiang1
I. Background
Reviving a deregulatory agenda with a new antitrust twist, the Trump administration is using Executive Orders along with DOJ and FTC firepower to challenge entrenched regulatory regimes at both the federal and state levels. This "anti-Big Government" effort signals an aggressive use of federal government power to reshape the boundaries between state authority and national competition policy.
Shortly after taking office, President Trump issued two Executive Orders: EO 14192 in January 2025, directing federal agencies to "alleviate unnecessary regulatory burdens placed on the American people"2 and EO 14219 in February 2025, requiring agency heads to initiate a process to review all regulations "subject to their sole or joint jurisdiction for consistency with law and Administration policy." EO 14219 does not specifically cite anticompetitive regulations as a target, but directs the agency heads to identify regulations that "harm the national interest by significantly and unjustifiably impeding technological innovation, infrastructure development, disaster response, inflation reduction, research and development, economic development, energy production, land use, and foreign policy objectives" and "impose undue burdens on small business and impede private enterprise and entrepreneurship."3
Building on those orders, the DOJ launched the Anticompetitive Regulations Task Force on March 27, 2025, to advocate for the elimination of anticompetitive state and federal laws and regulations that undermine free market competition and harm consumers, workers, and businesses. The Antitrust Division solicited comments from the public to identify unnecessary laws and regulations that raise the highest barriers to competition. In particular, the Division sought information about laws and regulations that make it more difficult for businesses to compete effectively, especially in the housing, transportation, food and agriculture, healthcare, and energy sectors. The deadline for comments was May 27, 2025. The Task Force will now review the comments with staff from the Antitrust Division, along with interagency partners, to identify state and federal laws and regulations that unnecessarily restrict competition and then take action to assist agencies in revising or eliminating those anticompetitive laws and regulations.4
Soon after the DOJ Antitrust Division's announcement of the Task Force, President Trump signed on April 9, 2025, a Presidential Memorandum titled "Directing the Repeal of Unlawful Regulations,"5 ordering agencies to take additional steps to "immediately repeal" unlawful federal regulations following the identification of those regulations pursuant to EO 14219. The Memorandum instructs the federal agencies to proceed "without notice and comment" pursuant to the statutory "good cause" exception in the Administrative Procedure Act ("APA"), along with a brief statement of the reasons that the exception applies.
Also on April 9, the President issued Executive Order No. 14267 – "Reducing Anti-Competitive Regulatory Barriers" – directing the heads of all executive agencies to provide to the DOJ and FTC a list of all their regulations that impose anticompetitive restraints or distortions. 6 In addition, within 90 days of receiving the lists, the FTC Chairman, in consultation with the Attorney General, the Assistant to the President for Economic Policy, and relevant agency heads, must provide the Office of Management and Budget with a consolidated list of regulations that warrant rescission or modification, along with recommended changes. In what appears to be an overlap with the similar request for comments from the DOJ, the order directed FTC Chairman to issue a request for information seeking public comment on the identification of anticompetitive regulations. Chairman Ferguson issued the request on April 13, and comments were also due on May 27, 2025.
And again, on April 9, President Trump issued an Executive Order titled "Zero-Based Regulatory Budgeting to Unleash American Energy."7 This order requires ten agencies and subagencies to embed a sunset provision into existing energy regulations. Any rule not affirmatively renewed before its expiration will automatically be rescinded, with all such regulations set to expire no later than September 30, 2026.
As the administration implements this broad and fast-moving initiative, it may encounter legal challenges, particularly around the efforts to bypass the APA and the limits of federal authority versus state regulatory autonomy under the state action doctrine.
II. Public Comments from Key Stakeholders
The public comment period, which ended on May 27, 2025, yielded a range of responses from think tanks, industry groups, corporations, and trade associations, many of which offered detailed critiques of regulations believed to hinder competition. These 569 comments provide insight into how various sectors view the competitive effects of the current regulatory environment and which rules are now most vulnerable to challenge or repeal.8 Below we review some of the comments from several key industry groups.
III. The Information Technology & Innovation Foundation ("ITIF")
The ITIF, a global think tank specializing in science and technology policy, submitted comprehensive comments in response to the DOJ's request. ITIF expressed strong support for the Department's initiative and urged a systematic, competition-oriented review of federal, state, and local regulations that, while often well-intentioned, end up stifling innovation and protecting entrenched incumbents. ITIF's comments were structured in three key parts: (1) a survey of problematic federal regulations; (2) an analysis of harmful state and local policies, and (3) a set of overarching recommendations for the DOJ's approach to regulatory reform.9
First, at the federal level, ITIF highlighted, among others, how aircraft weight-based landing fees regulated by the Federal Aviation Administration (FAA) enable airlines to reserve valuable airport slots at peak times using under-filled aircraft. As landing fees are assessed based on aircraft weight rather than congestion or marginal cost, "the fee a carrier pays is virtually the same at 7 a.m. as at 2 p.m."10 Moreover, because "a 50-seat regional jet is charged far less than a 150-seat narrow-body, incumbents can protect their market share by blanketing the most valuable peak hours with numerous lightly loaded flights."11 ITIF argued that these pricing structures contribute to airport delays and limit market access for new entrants, estimating that replacing this system with a congestion-based pricing model could yield up to $6 billion in annual consumer benefits.12
Second, at the state and local levels, ITIF identified policies that restrict competition and innovation. For instance, it criticized the "three-tier" alcohol distribution mandates, which require all alcoholic beverages to pass through wholesalers before reaching retailers. ITIF argued that this structure undermines small producers and inhibits the growth of direct-to-consumer and online sales, estimating potential consumer savings of up to 21 percent if such constraints were lifted.13 ITIF also singled out state auto-dealer franchise laws preventing automakers from selling new vehicles directly to consumers. ITIF noted that these laws are especially detrimental in the context of electric vehicles and online sales, as they can increase new vehicle prices by as much as 30 percent.14
In addition, ITIF noted that at many airports, ground transportation policies disadvantage rideshare services like Uber through higher fees or restricted access, reinforcing the position of incumbent taxi companies and limiting consumer choice.15
ITIF further warned that state-by-state medical licensure requirements create serious barriers to the expansion of telehealth. Under current rules, healthcare providers generally cannot treat patients across state lines without obtaining a license in each state, a restriction that ITIF argued makes little sense in an era where technology enables safe, high-quality virtual care. These rules particularly hurt patients in rural and underserved areas.16
ITIF called on the DOJ to adopt a regulatory framework that prioritizes competition and consumer welfare so that regulations are maintained only when they correct demonstrable market failures. Wherever possible, antitrust enforcement and consumer protection laws should serve as the primary tools for addressing harm, with prescriptive regulation used sparingly. ITIF emphasized that any rule should be justified on its real-world effects and ability to improve outcomes for consumers and the economy, rather than entrenching existing business models or protecting incumbent firms.17
III. The Electricity Transmission Competition Coalition ("ETCC")
In the energy sector, the ETCC submitted extensive comments to the DOJ Task Force, urging decisive action to address what it characterized as widespread anti-competitive conduct and regulatory failure in the U.S. electric transmission sector.18
ETCC, representing a coalition of 95 industrial consumers, non-incumbent transmission developers, and public interest organizations, argued that state right-of-first-refusal ("ROFR") laws (or "Preference Laws") and certain policies of Federal Energy Regulatory Commission ("FERC") unjustifiably insulate incumbent utilities from competition, leading to excessive costs, entrenched monopolies, and diminished innovation in the development of new transmission infrastructure. ETCC's central concern was that state ROFR laws allow incumbent utilities to receive automatic assignments of new transmission projects within their territories without competitive solicitation. ETCC argued that these laws are inherently protectionist, shielding in-state monopolies at the expense of cost savings and efficiency.19
ETCC highlighted that despite FERC's 2011 Order No. 1000, which aimed to eliminate federal ROFRs for certain transmission projects, Order No. 1000 has failed to produce meaningful competition in practice, as many transmission providers have relied on the loopholes in Order No. 1000 to bypass the competition requirement. For instance, ETCC noted that FERC has allowed an emergency exception to competition for projects that are needed "immediately."20 As a result, projects deemed necessary on a near-term basis are routinely exempted from competition. In addition, FERC included in Order No. 1000 another exemption from competition for projects that are "upgrades" to existing transmission facilities, so long as the upgrade is not an entirely new facility.21 On this basis, FERC has permitted regional transmission organizations ("RTOs") such as Midcontinent Independent System Operator ("MISO") and the New York Independent System Operator ("NYISO") to adopt expansive definitions of "upgrades" that now exempt entirely new transmission facilities from competition in certain circumstances.22
Additionally, ETCC criticized FERC's tolerance of state legislative efforts to reintroduce ROFR-like protections through state laws, effectively nullifying Order No. 1000 in many regions. ETCC argued that FERC permitted state ROFR laws to be incorporated into the federally regulated tariffs of RTOs like MISO, Southwest Power Pool ("SPP"), and PJM Interconnection LLC ("PJM"), allowing these entities to exempt certain transmission projects from competitive bidding when such state Preference Laws apply. This practice, ETCC contended, effectively subordinates federal competition policy to state Preference Laws and places RTOs in the problematic role of interpreting and enforcing state law without adequate FERC oversight.23
In light of these allegations, ETCC urged DOJ to take aggressive actions. Specifically, ETCC requested the DOJ Antitrust Division and the Anticompetitive Regulations Task Force to engage FERC, investigate monopolist utilities, pursue preemption of state ROFR laws through litigation or Statements of Interest in ongoing cases, and otherwise take all actions with the Agency's power to protect consumers from the excess transmission rates that are the result of these incumbent preferences, whether in state law or federal regulations. ETCC also urged the DOJ to work with FERC to close regulatory loopholes, eliminate unjustified exemptions, and implement consistent enforcement of Order No. 1000's competition requirements across all FERC jurisdictions.24
Furthermore, ETCC pressed the Antitrust Division's Expert Analysis Group to remain active in providing an independent economic analysis of competitive transmission procurement. ETCC took aim at utility-sponsored studies that purport to show that competition is costly or ineffective, asserting that such studies use flawed methodologies and cherry-picked data.25 In contrast, ETCC highlighted empirical studies and case examples where competitively awarded projects resulted in dramatically lower costs and more innovative project designs than proposals from incumbent utilities.26
IV. Inari Agriculture
Inari Agriculture ("Inari"), a manufacturer of genetically modified crop seeds, submitted its comments to the FTC in support of efforts to identify and eliminate regulatory barriers that undermine competition. Inari focused on the genetically modified ("GM") seed industry, a sector it characterizes as heavily consolidated and anticompetitive. The comments noted that despite the expiration of foundational GM seed patents, regulatory and intellectual property structures continue to block generic entry and entrench a handful of incumbent seed developers.27
Inari noted that three companies control the intellectual property ("IP") for the majority of U.S. row crops: two firms hold approximately 80 percent of the IP in corn and 75 percent of the IP in soybeans, while the third firm controls 72 percent of the cotton seed market. These companies allegedly exploit a web of overlapping patents, plant variety protections, and redundant federal regulatory processes to suppress new entrants and preserve market dominance.28
A central theme of Inari's submission is the need for the FTC to work with the Environmental Protection Agency ("EPA") and U.S. Department of Agriculture ("USDA") to reform the regulatory regime for GM seeds, particularly for insect-resistant seeds classified as Plant-Incorporated Protectants ("PIPs"). Inari criticizes the current bifurcated approval system, which requires separate EPA and USDA reviews, as burdensome, duplicative, and costly. The company recommends consolidating regulatory responsibility in one agency (preferably USDA) to streamline the path to market.29
Inari also urged the FTC to work with the EPA to implement an expedited regulatory pathway for generic PIPs, consistent with requirements under the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA"). While FIFRA mandates streamlined approval for pesticide products that are "identical or substantially similar" to previously registered pesticides, EPA has never applied this provision to PIPs, forcing generic producers to endure costly and redundant reviews. Inari argued that this double standard protects incumbents and blocks generic competition in GM seeds.30
In addition, Inari targeted EPA's mandatory Insect Resistance Management ("IRM") program, a post-approval monitoring requirement applicable only to PIP developers. Inari asserted that this IRM program lacks statutory authority, imposes excessive costs, and disproportionately burdens new entrants. Inari also alleged that IRM requirements are heavily influenced by an industry consortium called the Agricultural Biotechnology Stewardship Technical Committee, which comprises dominant seed developers and operates with privileged access to EPA staff and data without transparency or farmer representation.31
Beyond regulatory reform, Inari proposed adapting elements of the Hatch-Waxman Act (which accelerated generic entry in the pharmaceutical sector) to the GM seed industry. It recommended a statutory framework that would permit generic developers to use expired seed patents for breeding, reduce redundant review obligations, and facilitate faster market entry.32
Lastly, Inari called on the FTC to stop incumbent seed developers from misusing intellectual property laws to frustrate public access and research rights. Specifically, Inari noted that companies exploit the differences between the Patent Act and the Plant Variety Protection Act ("PVPA") to extend exclusivity (e.g. through "evergreening" and staggered IP filing strategy) and block researchers from accessing patented seed deposits despite public-access requirements. Inari argued that these practices undermine the public policy, locking competitors out of innovation pathways. To remedy this, Inari proposed that FTC should work with USDA and the UUSPTO to clarify that (1) patent depository access must remain open to the public post-issuance; (2) patent protections cannot override the PVPA's breeder's exemption, and (3) PVPA protections cannot be used to prolong exclusivity after a patent expires.33
V. International Center for Law & Economics ("ICLE")
The ICLE submitted its comments to both the DOJ and FTC, supporting the agencies' initiative to identify and eliminate anticompetitive regulatory barriers. ICLE argued that the regulatory landscape often entrenches monopoly power, not through private corporate abuse, but through government-granted privileges that restrict market entry and limit consumer choice. The organization called for a return to the "Anglo-American anti-monopoly tradition," which historically opposed government-sanctioned monopolies and urged the agencies to prioritize regulatory reform that enhances consumer welfare and economic efficiency.34
One of ICLE's central concerns is the persistence of Certificates of Convenience and Necessity ("CCNs"), which the organization characterized as structurally anticompetitive. These certificates, required in sectors like energy, telecommunications, transportation, and healthcare, effectively grant incumbent firms the power to block new entrants by requiring regulators to determine whether additional service providers are "necessary." ICLE argued that this process often becomes a "competitor's veto," enabling existing firms to suppress competition and innovation. ICLE recommended eliminating both federal and state CCN requirements, particularly those that apply to natural gas infrastructure, telecommunications, and healthcare facilities, as well as local transportation and electricity transmission.35
ICLE also criticized occupational licensing. While conceding that some licensing can be justified on public safety grounds, ICLE asserted that many licensing regimes create artificial barriers to entry, raise prices, and limit worker mobility without demonstrable benefits to consumers. The comments highlighted the economic burden imposed by unnecessary licensing requirements and the disproportionate harm to lower-income workers and small businesses. ICLE recommended scaling back or eliminating licensing laws that lack clear public safety justification and adopting more flexible and reciprocal licensing frameworks across states.36
ICLE also addressed the role of legal exemptions and immunities that allow anticompetitive practices to persist under the shield of state sovereignty. Citing doctrines like state-action immunity and the Noerr-Pennington doctrine, ICLE argued that antitrust enforcement is often hamstrung by legal doctrines that protect state-sanctioned anticompetitive behavior. They called for greater scrutiny of state-owned enterprises such as the Tennessee Valley Authority, which ICLE believed should be subject to antitrust law like private entities.37
Additionally, ICLE criticized prevailing wage laws and energy transmission regulations, such as FERC Order No. 1000. ICLE contended that prevailing wage mandates distort labor markets and raise public procurement costs, while Order No. 1000 entrenches central planning and investment distortions in energy infrastructure. ICLE also criticized the practice of cy-pres settlements in class actions which "permit[] funds from cash settlements in class actions to be directed to third parties – typically charitable organization with missions ostensibly related to the lawsuit's claims – rather than to class members themselves."38 ICLE emphasized that cy-pres awards function as non-market subsidies that bypass normal competitive processes, another example of market distortion through legal processes.39
ICLE recommended that the DOJ and FTC recommit to the consumer welfare standard in antitrust analysis and withdraw recent rulemakings, such as the FTC's ban on noncompete agreements that lack sufficient economic justification. ICLE also recommended revising merger guidelines, reforming the HSR premerger notification process, and adopting a clearer legal framework for data security enforcement under Section 5 of the FTC Act. Finally, ICLE called for a re-evaluation of the Children's Online Privacy Protection Act ("COPPA") due to the transaction cost involved in obtaining and giving verifiable parental consent and empirical evidence.40
Overall, ICLE's comments reflect the position that many regulatory frameworks – however well-intentioned – function primarily to protect incumbents, reduce competition, and limit consumer benefit. ICLE advocated for a robust competition policy agenda that dismantles such regulations and refocuses enforcement on removing government-created barriers to market entry.
VI. U.S. Chamber of Commerce
The U.S. Chamber of Commerce's comments to the DOJ and FTC urged the agencies to promote competition by targeting excessive or protectionist state and federal regulations, particularly those that hinder entry, stifle innovation, and disadvantage smaller firms. The Chamber supported the agencies' goal of reducing regulatory barriers but urged caution when intervening in heavily regulated industries where existing policy choices, such as in healthcare, energy, and transportation, may reflect deliberate tradeoffs that should not be hastily overturned.41
The Chamber criticized several Biden-era rules, especially in agriculture, for "micromanaging" markets. For instance, the USDA rules on poultry grower payments (e.g. AMS-FTPP-22-0046 and AMS-FTPP-21-0045) are said to fix prices and discourage efficiency. The Chamber also warned about inconsistent state-level regulations, including ingredient labeling laws and "Extended Producer Responsibility" packaging rules, which act as entry barriers and hurt smaller businesses.42
In the entertainment and online services sectors, the Chamber called for federal preemption of state standards – such as auto-renewal laws, sweepstakes and contest regulations, and name-image-and likeness rules – that raise compliance costs. It also recommended modernizing outdated media regulations that no longer reflect the competitive streaming landscape.43
In the healthcare sector, the Chamber highlighted costly federal proposals like the HIPAA Security Rule update (90 Fed. Reg. 898) and restrictive state-level rules on telehealth, scope of practice, and corporation practice of medicine laws. The Chamber asserted that these laws reduce access, limit innovation, and prevent non-physician providers from practicing to the full extent of their training, particularly harming rural and underserved areas.44
In the transportation sector, the Chamber suggested reforming federal rules like DOT's airline fee disclosure and refund mandates, which, according to the Chamber, stifle business model differentiation. It also criticized monopolies enjoyed by USPS (e.g. the "mailbox monopoly") and called for U.S. advocacy at the Universal Postal Union to counter unfair advantages enjoyed by state-backed foreign postal carriers.45
At the state level, the Chamber critiqued inconsistent regulations on ridesharing, including disproportionate insurance requirements and misapplication of worker classification laws like California's AB5. It called for rolling back pandemic-era commission caps on delivery services and urged federal leadership to promote uniformity and innovation.46
The Chamber also flagged issues in financial regulation, advocating for GDP-indexed thresholds under the Tailoring Rule to remove growth penalties for mid-sized banks. The Tailoring Rule, issued by the Federal Reserve in 2019, created categories for supervising institutions based on asset thresholds, which the Chamber claimed have become barriers to organic growth and opportunity. The Chamber advocated that these thresholds should be indexed for GDP to reflect the current market environment and ensure that regulations are tailored with growth in mind. In addition, the Chamber suggested that any heightened regulatory requirements that accompany growing from one category to the next should also be phased in over time to eliminate "cliff effects" that disincentivize growth.47
The Chamber also decried the distortionary effects of tariffs – especially on small businesses – and called for trade policy review. It warned against a patchwork of state privacy and AI laws, such as California Consumer Privacy Agency Board's cyber audit rules and the Colorado's AI Act, arguing these impose undue costs and uncertainty. It also urged restraint in issuing new antitrust rules that duplicate or contradict federal law, especially in algorithmic pricing and merger enforcement.48
Throughout, the Chamber reiterated its core position that competition is best promoted by removing government-imposed barriers, not by expanding federal regulatory power. It encouraged DOJ and the FTC to focus their efforts on rolling back outdated or excessive rules, promoting uniform national standards, and resisting ideologically driven interventions that stifle entry and innovation.
VII. Conclusion
The administration's deregulation initiative has moved from promise to action. With the comment period complete, the DOJ and FTC possess a roadmap of stakeholder-identified barriers to competition they can consider for elimination or modification. In the next phase, companies in regulated industries should prepare for potentially significant changes. Those that benefit from existing regulatory protections should evaluate and mitigate risks to their business models, while others may find new opportunities to enter or expand in markets previously restricted by outdated or protectionist rules. Businesses should monitor agency actions closely and be prepared to participate in further proceedings or litigation as the competition-driven deregulation campaign evolves.
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Footnotes
1. John J. Kavanagh is a partner at Steptoe in Washington, D.C. and part of the firm's Antitrust team. Weisiyu Jiang is an associate at Steptoe in Washington, D.C. and part of the firm's Antitrust team.
2. EO 14192, Unleashing Prosperity Through Deregulation, (Jan 31, 2025), available at: https://www.federalregister.gov/documents/2025/02/06/2025-02345/unleashing-prosperity-through-deregulation.
3. EO 14219, Ensuring Lawful Governance and Implementing the President's "Department of Government Efficiency" Deregulatory Initiative, (Feb. 25, 2025), available at: https://www.federalregister.gov/documents/2025/02/25/2025-03138/ensuring-lawful-governance-and-implementing-the-presidents-department-of-government-efficiency.
4. Department of Justice, Press Release, Justice Department Launches Anticompetitive Regulations Task Force, (Mar. 27, 2025), available at: https://www.justice.gov/opa/pr/justice-department-launches-anticompetitive-regulations-task-force.
5. Presidential Memoranda, Directing the Repeal of Unlawful Regulations, (Apr. 9, 2025), available at: https://www.whitehouse.gov/presidential-actions/2025/04/directing-the-repeal-of-unlawful-regulations/#:~:text=Promoting%20economic%20growth%20and%20American,American%20consumers%20and%20American%20businesses.
6. Executive Order, Reducing Anti-Competitive Regulatory Barriers, (Apr. 9, 2025), available at: https://www.whitehouse.gov/presidential-actions/2025/04/reducing-anti-competitive-regulatory-barriers/.
7. Executive Order, Zero-Based Regulatory Budgeting to Unleash American Energy, (Apr. 9, 2025), available at: https://www.whitehouse.gov/presidential-actions/2025/04/zero-based-regulatory-budgeting-to-unleash-american-energy/.
8. FTC, Request for Public Comment Regarding Anti-Competitive Regulatory Barriers, FTC-2025-0028, (Number of Comments Posted to Docket: 173), available at: https://www.regulations.gov/docket/FTC-2025-0028/comments: DOJ Antitrust Division, Anticompetitive Regulations Task Force, ATR-2025-0001, (Number of Comments Posted to Docket: 396), available at: https://www.regulations.gov/docket/ATR-2025-0001.
9. ITIF, Comments of ITIF to the U.S. Justice Department, Antitrust Division, In the Matter of : Anticompetitive Regulations Task Force, Docket No. ATR-2025-0001-0002, (May 27, 2025), available at: https://www2.itif.org/2025-doj-anticompetitive-regulations.pdf.
10. Id at 3.
11. Id.
12. Id.
13. Id at 5.
14. Id.
15. Id at 6.
16. Id at 7.
17. Id at 9-10.
18. ETCC, Comments to the Anticompetitive Regulations Task Force of the U.S. Department of Justice Antitrust Division, Docket No. ATR-2025-0001 (May 27, 2025).
19. Id.
20. Id at 7.
21. Id at 12.
22. Id.
23. Id.
24. Id at 16.
25. Id at 7.
26. Id at 13-14.
27. Inari Agriculture, Inc., Inari Agriculture, Inc.'s Comments for the Federal Trade Commission Regarding Reducing Anti-Competitive Regulatory Barriers, (May 27, 2025).
28. Id at 2.
29. Id at 5.
30. Id at 6-7.
31. Id at 7-8.
32. Id at 9.
33. Id at 13.
34. International Center for Law & Economics, RE: Department of Justice Anticompetitive Regulations Task Force, Docket No. ATR2025-0001; Federal Trade Commission Request for Public Comment Regarding Reducing Anti-Competitive Regulatory Barriers, (May 27, 2025).
35. Id at 16.
36. Id at 20.
37. Id at 31.
38. Id at 43.
39. Id.
40. Id at 55.
41. U.S. Chamber of Commerce, Re: Public Inquiries Regarding Anticompetitive Regulations (Docket Nos. ATR-2025-0001, FTC-2025-0028-0001), p. 2.
42. Id at 4.
43. Id at 6.
44. Id at 7.
45. Id at 10.
46. Id at 11.
47. Id at 12.
48. Id at 14.
Originally Published by Competition Policy International (CPI)
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