Merger Control Trends

Miranda Cole

Overview
I.

Some Statistics

II.

General Trends

III.

Technology

IV.

Pharmaceuticals and Medical Devices

V.

Chemicals

VI.

Exchanges and Payment Systems

VII.

Consumer Products

VIII.

Cross-border Content

IX.

Heavy Industry

X.

Upcoming Jurisdictional Changes

I. Some Statistics

Proceedings in Phase I and Phase II (2013-Sep.2016)

350
300
250

297

280
252

239

200
150
100
50
0

11 6

12 8

2013

Phase I compatible

2014
Phase I commitments

Phase II initiated

13 11

2015
Phase II compatible

12 6

Sep-16
Phase II commitments
4

Number of Referrals (2013 Sep.2016)

18

16

16

14

Number of Referrals

14
12
10

11

13

12

11

6
4
2
0

2013

2014

Referral Requests (Form RS)

2015

Sep-16

Referrals to Member States

5

In Short

Overall, lowest number of deals notified since 2013

Related to timing of recent political events: Brexit, US elections?

While number of Phase II cases decreased, number of Phase II

conditional clearances represented higher proportion of Phase II
cases higher than in previous years:

2013: 6 Phase II cases initiated, 2 cleared conditionally

2014: 8 Phase II cases initiated, 5 cleared conditionally
2015: 11 Phase II cases initiated, 7 cleared conditionally
End of Sep. 2016: 6 Phase II cases initiated, 5 cleared conditionally

II. General Trends

General Trends

Technology and life sciences (pharma and devices) remain particularly

active, with approaches on key issues continuing to develop

Approaches to market definition potential tensions

Defining markets by reference to therapeutic use while increasingly looking

at early stage development/ entire development programmes

Defining inputs with specificity

Continued emphasis on preserving innovation

Next generation products across broad swathe of industries

Broader view of what is required (entire development programs)

Challenge to not constrain future development through overly narrow

identification of uses made of inputs

Data important across all sectors but the Commission has not yet had
a case that turns on unique data that would support an exclusionary
theory of harm
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III. Technology

A. Data

Recent Trends

Use of data growing rapidly - used as an input in many industries (not

only GAFA and other online advertising players where used to target
ads)
Use of data not new phenomenon
But volume of data generated and analysed is new, as are some
uses
Commissioner Having large amounts of data not anti-competitive
Nature of the data at issue is important is it unique
[] it's true that we shouldn't be suspicious of every company which holds a
valuable set of data. But we do need to keep a close eye on whether companies
control unique data, which no one else can get hold of, and can use it to shut their
rivals out of the market. - Vestager, Data as Power, Copenhagen, 9 September 2016

Data as an input (parallels to IP inputs to technology markets)

Does data confer ability to exclude (Bronner framework)

Replicability (or uniqueness)

Exclusivity
Degree to which data is important to compete in downstream/related market
11

Amadeus/Navitaire
Acquisition initially notified to FCO - referred by CMA to EC
Acquisition of PSS provider by provider of GDSs and PSSs; PSSs
supplied to airlines, GDSs to airlines and travel agents
Despite market evolution, EC concluded distinct segments for
PSSs
limited overlap

Navitaires customers do not use GDSs

Acquisition approved unconditionally on 19 January 2016: EC
concluded the companies IT solutions target different types of
airlines and are complementary

12

Sanofi/Verily Life Science

JV for management and treatment of diabetes, including data
collection and processing, and data analysis
Markets defined for

Services for management and treatment of diabetes using integrated

digital e-medicine platform (incl using e-medicine platforms to collect,
display, store, analyse and transmit data)
Data analytics services

Segmentation of market by reference to data analysed are algorithms tools different to

those used with other types of data? Market test mixed
predictive algorithmic models are data agnostic and not industry-specific
healthcare data analytics more diverse and complex, requiring more sophisticated
algorithms and analytical tools than other types of data
complexity and regulatory nature of healthcare analytics creates significant complexity
in data this complexity and depth of domain expertise to apply and interpret analytics
differentiates healthcare analytics

Commission considered data portability and potential for lock-in to platform

(and impact of GDPR)
Significant competition in analytics for healthcare
13

B. Mobile Telecommunications

Recent Trends
Additional four-to-three and multi-play transactions
Is four the magic number? In particular in the mobile sector, it
seems more likely that EC will accept merger if still four MNOs
post-merger, e.g.,

Liberty Global/BASE (acquisition by MVNO of MNO, and competing

MVNO created)
Vodafone/Liberty Global (JV by MNO and MVNO no MNO removal;
concern over fixed)
Hutchison/02 (concentration of 2 MNOs no new MNO - prohibited)
Hutchison/Vimpelcom (JV by 2 MNOs entry by new MNO Iliad
facilitated by remedy)

Structural remedies accepted

Continued focus on innovation

15

Liberty Global/BASE

Concerns raised that transaction would significantly reduce competition

Removal of important competitive force

Limited incentives to exert competitive pressure on Proximus and Mobistar

Reduced incentives for BASE to offer MVNOs access to its mobile network

Telenet able to bundle fixed line services for BASEs mobile customers

Approved on 4 February 2016 subject to remedies offered by Liberty

Global creating new MVNO

Sale of BASEs share in Mobile Vikings to Medialaan

Transfer of BASEs JIM Mobile customer base to Medialaan

Granting of access to BASE's mobile network to Medialaan on competitive terms

Coordination between EC and Belgian Competition Authority: BCA

approval required to implement EC remedies
"We have made sure that Liberty Global's merger with BASE will not reverse the
trend of declining mobile prices in Belgium in recent years. To maintain healthy
competition in the Belgian mobile market, Liberty Global and BASE will sell part of
their customer base to a new virtual mobile operator. Margrethe Vestager, Press
Release, 4 February 2016
16

Vodafone/Liberty Global/Dutch JV
Joint venture by MNO Vodafone and cable company Liberty Global
Concerns raised

Proposed transaction would eliminate benefits brought to the Dutch

telecoms market by Vodafone's recent entry
Absent the merger, Vodafone had potential to become a strong
competing provider of fixed line and fixed-mobile multiple play services

EU clearance on 3 August 2016 conditional upon Vodafone

divesting its retail customer fixed line business in the Netherlands

"The telecoms market is of strategic importance for our digital society. I am pleased
that we have been able to approve the creation of the joint venture between
Vodafone and Liberty Global in the Netherlands. The commitments offered by
Vodafone ensure that Dutch consumers will continue to enjoy competitive prices
and good choice., Margrethe Vestager, Press Release, 3 August 2016

17

Hutchison/O2 UK

Deal prohibited on 11 May 2016

Concerns voiced by EC

Elimination of competition between two strong MNOs in the UK mobile

market

Combined Three and O2 would have been the market leader with a share of more
than 40%

Future development of entire UK mobile network infrastructure would have

been hampered
Reduced number of MNOs willing to host other operators on their networks

Proposed remedies by Hutchison - measures aimed at strengthening

existing MVNOs or supporting market entry, including

Proposal to give access to a share of the merged entity's network capacity to

one or two MVNOs
Proposal to divest O2s stake in Tesco Mobile JV, and to offer a wholesale
agreement for network capacity to Tesco Mobile
Proposal to offer wholesale agreement network capacity to Virgin Media
Remedies inadequate - concerns about efficacy and monitoring
18

Hutchison 3G Italy/Wind/JV

Combination of Hutchisons subsidiary H3G and Vimpelcoms subsidiary

WIND, respectively the fourth and third largest operators in the Italian retail
mobile market
Structural remedies offered

Divestment of assets enabling fourth MNO to enter the market

Approved on 1 September 2016

Purchaser of assets: French operator Iliad (fix-it-first remedy)

Iliad has know-how and expertise to operate as MNO, invest and innovate in the
Italian market
Will replace competition lost and ensure that Italian mobile customers are not
harmed as a result of the transaction

This case shows that telecom companies in Europe can grow by consolidation
within the same country, provided effective competition is preserved. It also shows
they can grow by cross-border expansion, such as Iliad in this case. Margrethe
Vestager, Press Release, 1 September 2016

19

C. Other Technologies

Other Technologies/ Logistics

Satellites - Airbus Safran Launchers (ASL)/ Arianespace

Acquisition of French co Arianespace, offering satellite launch services, by

ASL, JV between Airbus and Safran (manufacturer of Ariane launcher)
Concerns that transaction would lead to flows of sensitive information
between the parties to the detriment of competitors
Clearance on 20 July 2016 conditional on the implementation of

firewalls between the companies to prevent information flows

measures restricting employees mobility between the companies and
creation of arbitration mechanism

Delivery/Postal Services - FedEx /TNT Express

Takeover by FedEx of TNT, two out of four 'integrators' currently operating

in the small package delivery sector in Europe
In-depth investigation by EC prompted by concerns that transaction would
substantially lessen competition in certain international, intra-EEA and
extra-EEA, delivery service markets for small packages
Unconditional clearance on 8 January 2016
21

IV. Pharmaceuticals and Medical Devices

Recent Trends
Several deals in pharma sector withdrawn and re-notified in 2016
EC continues to assess impact of concentrations on innovation and
future markets/products
Recent developments in ECs substantive assessment include

Approach to market definition

Market to pipeline and pipeline to pipeline competition and broader
focus on innovation

Several national sector inquiries into pharmaceutical/medical sector

ongoing
Pricing on the agenda in behavioural investigations

23

Looking Beyond ATC Categories for Market Definition

Both EC and NCAs are looking beyond ATC categories in defining

markets

EC goes to molecular level in cases involving generics and pipeline

products
In certain therapeutic areas (started with oncology, but expanded to
quite different indications, like COPD and asthma) not defining relevant
product markets by reference to ATC3 class where products indicated
for various types of cancer

Definition based on the mode of operation (e.g., cutting off blood supply or
interfering with enzyme coating on cells)

Upcoming issues likely following biosimilar launches

24

Treatment Protocols

EC and NCAs increasingly looking at treatment protocols

(guidelines) to define markets

Treatment of some illnesses based on stages of illness

E.g., For asthma, Global Initiative for Asthma (GINA) treatment guidelines
distinguish between mild, moderate and severe asthma and treatment is based
on 5 step-approach (GINA 1- GINA 5) with treatment adjusted at each step
E.g., For COPD, Patients divided into different groups depending on symptoms
and specific treatment for each group of patients (as set out in Global Initiative
of Chronic Obstructive Lung Disease (GOLD) guidelines)

At each treatment stage, different treatment options are available, some

of which are considered the primary treatment option and others that are
considered as possible alternatives for non-responding patients

Use of therapeutic prescription advice at each treatment stage to

identify competing products

25

Consumer Healthcare/Animal Health

Sanofi/Boehringer Ingelheim (BI) business swap

Consumer Healthcare: Acquisition of BIs consumer healthcare
business by Sanofi

Concerns raised that transaction may lead to higher prices for antispasmodics,
anti-constipation products, cough drugs and headache drugs
Clearance on 4 August 2016 conditional on parties divesting products - e.g.,
Sanofi's Suppositoria Glycerini in the Czech Republic and BI's Prontalgine in
France - with related MAs, customer information, brands and personnel

Animal Health: Buyout of Sanofis animal health business

(Merial) by BI

Deal withdrawn and re-notified in September 2016

Concerns related to markets for the supply of porcine and bovine vaccines, and
non-steroidal anti-inflammatory drugs for horses
Clearance on 9 November 2016 subject to divestment of a number of Merials
animal-health vaccines and pharmaceuticals
Agreement to sell Sanofi assets to Portuguese pharmaceutical company Ceva
Sant Animale
26

Other Pharma Deals

Teva/Allergan Generics

Acquisition of Allergans generics business by Teva

Concerns raised that there would be insufficient competition for certain
generic products in the UK, Ireland and Iceland
Focus on large number of generics marketed and in development, and
vertical relationships resulting from out-licensing
Clearance in March 2016 conditional on divestment of assets (both
marketed and development molecules), including majority of Allergan
Generics business in the UK and Ireland

Mylan/Meda

Concerns raised that the transaction would have reduced competition on

markets for several products, including treatments for abnormal heart
rhythms
Clearance in July 2016 conditional on divestment of a number of Mylan's
or Meda's businesses in Austria, Belgium, Estonia, France, Luxembourg,
Ireland, Italy, Norway, Portugal, Spain and the UK
27

Medical Devices

Dental Equipment - Dentsply / Sirona

Sirona was leading supplier of chairside CAD/CAM systems

Systems used by dentists to manufacture dental prosthetics such as crowns,

bridges, veneers and inlays out of the CAD/CAM blocks

Focus on CAD/CAM materials, small dental equipment, dental imaging

systems and dental implant systems
Parties agreed to ensure compatibility of Sirona's chairside CAD/CAM
systems with the CAD/CAM blocks of competitors
Clearance on 25 February 2016 conditional on inter alia extension of
licensing agreements with Sironas current suppliers of CAD/CAM blocks
used in its chairside CAD/CAM systems

28

V. Chemicals

Dow/DuPont
Dow and Dupont are two of the worlds Big Six agrochemical
players
Proposed merger would create worlds largest integrated crop
protection and seeds company
Preliminary concerns identified in crop protection, seeds and
petrochemicals markets

Phase II investigation opened on 11 August 2016 despite

commitments submitted in Phase I

Since both parties fund R&D, deal could also raise concerns over loss of
innovation
In addition to innovation, ECs main focus on license agreements for technology
in seeds

Clock stopped for second time on 13 October 2016

Investigation restarted on 7 November 2016
New deadline for Phase II decision on 28 February 2017

Parties expect SO next month

30

Other Chemicals Deals

Solvay/Cytec

Focus on manufacture and supply of phosphor-based solvent extractants used in

mining and refining industry to separate cobalt from nickel

Concerns raised over elimination of significant competitive force in the market

Clearance on 2 December 2015 conditional on divestment of Solvays Ionquest

290 business and - at request of purchaser - of its octylphosphonic acid (OPA)
and triethylphosphonoacetate (TEPA) businesses

Italmatch Chemicals approved as purchaser on 7 September 2016

China National Chemical Corporation (ChemChina)/Syngenta

Plans by ChemChina to buy crop-protection and seeds company Syngenta

ChemChina controls Adama, Europes largest supplier of generic crop-protection

products

Preliminary concerns raised in some crop-protection and seeds markets - EC

investigating parties supply of key chemicals to other providers of crop protection

Proposed Phase I remedies (including sale of Adama assets) insufficient

In-depth Phase II investigation opened on 28 October 2016 - deadline now 29

March 2017
31

VI. Exchanges and Payment Systems

Exchanges

Deutsche Brse AG (DB)/ London Stock Exchange Group (LSE)

Combination of exchanges of Germany, the UK and Italy, as well as several of the largest
European clearing houses

Would create by far the largest European exchange operator

Concerns raised in several markets inter alia relating to clearing, derivatives, repurchasing
agreements (repos), German stocks and Exchange Traded Products (ETPs)

Deadline of Phase II investigation extended to 6 March 2017

Intercontinental Exchange (ICE)/Trayport

Acquisition by ICE (largest operator of exchanges and clearinghouses) of energy trading

software provider Trayport

Post-merger agreement signed between parties on new interface development and support
putting their relationship at arms length

Deal referred by CMA to phase II

CMA raised concerns that transaction would result in SLC as merged group was likely to
pursue a partial foreclosure strategy

Proposed package of behavioural remedies rejected by CMA - full divestiture of Trayport and
unwinding of the post-merger agreement ordered by CMA

ICE appealed to CAT requesting annulment of order and referral back to CMA for
reconsideration

33

Payment Systems (1)

Worldline / Equens / PaySquare

Combination of two large payment systems operators, active in both

payment processing and card processing services

Overlaps in a number of Member States including Belgium, Germany,

Luxembourg and the Netherlands

Concerns over merchant acquiring services in Belgium and in Germany

Clearance on 20 April 2016 conditional on divestment of PaySquare's
business in Belgium and grant of licenses for the Poseidon software on
FRAND terms for ten years

MasterCard/VocaLink

UK CMA currently reviewing MasterCards acquisition of VocaLink

VocaLink operates payments technology platforms on behalf of UK
payment schemes
Investigation launched on 17 October 2016, CMA extended Phase I to 4
January 2017

34

VII. Consumer Products

Beer Sector

AB InBev/SABMiller

Acquisition by world's largest brewer AB InBev of world's second largest

brewer SABMiller
Concern that transaction would lead to higher beer prices in Member
States where SABMiller is currently active

Deal would remove an important competitor and make tacit coordination

between the parties more likely

Clearance conditional on AB InBev selling large portion of SABMiller

beer business in Europe
"Today's decision will ensure that competition is not weakened in these markets
and that EU consumers are not worse off. Europeans buy around 125 billion
euros of beer every year, so even a relatively small price increase could cause
considerable harm to consumers. It was therefore very important to ensure that
AB InBev's takeover of SABMiller did not reduce competition on European beer
markets. Margrethe Vestager, Press Release, 24 May 2016

36

Office Supplies

Staples/Office Depot

EC investigation focused on effects of transaction on international and

national contract sales channels in the Netherlands and Sweden

International contract sales

Staples, Office Depot and Lyreco capable of entering into international supply contracts
for large business customers in Europe
Customers benefit from lower prices and savings in administrative costs
High entry barriers
Limited competition

Online companies such as Amazon not at this stage competitors in contract business market in Europe

National contract sales and wholesale

Transaction would reduce competition in concentrated markets for (i) national contracts
with large business customers in Netherlands and Sweden and (ii) wholesale supply of
office products in Sweden

Phase II clearance on 10 February 2016 conditional on divestment of

Office Depot's contract distribution business in the EEA and Switzerland

Office Depot's entire business operations in Sweden
37

VIII. Cross-border Content

PRSfM/STIM/GEMA - Joint Venture for Online Music Licensing

Three collective rights management organisations (CMOs) from the UK,

Sweden and Germany
CMOs usually manage rights of artists in a country
CMOs license repertoire on country-by-country basis

EC identified two relevant markets:

JV will offer multi-repertoire multi-territorial

licenses for online platforms

Copyright administration services provided to CMOs and option 3 publishers in

relation to MTMR licences
Online licensing (market for licencing of online rights in musical works)

Cleared June 2015

November 2015 launch of first integrated licensing and processing hub under
ICE brand with different services:

ICE Operations: providing state of the art online matching and processing services,
together with authoritative multi-territorial copyright services
ICE Services: providing business enhancing middle-office services including invoicing,
legal support and business intelligence analysis to both ICE Licensing customers and
those offering bespoke services, such as Solar, Aresa and PEDL
ICE Licensing: providing consolidated licensing of PRS for Music, GEMA and STIMs
multi-territorial online rights and options for other rights holders to join the same core
licence
39

IX. Heavy Industry

Heating Products

Honeywell/Elster

Acquisition of Elster by Honeywell

Concerns over several upstream/midstream gas metering markets

EEA-wide markets for turbine gas meters for fiscal applications (i.e. meters
used for billing purposes)
Flow computers and gas chromatographs that operate by the so-called DSFG
protocol

Phase I clearance on 21 December 2015 conditional on Honeywell

divesting German gas meters manufacturing plant

Energas Turbines B.V. approved as purchaser on 7 September 2016

41

Cement

HeidelbergCement and Schwenk/ Cemex Croatia

Construction material producers HeidelbergCement and Schwenk to

acquire, via joint subsidiary DDC, Cemex assets in Croatia and Hungary
Concerns raised in Phase I over reduced competition for grey cement in
Croatia

Combine largest producer in the area (Cemex) and largest importer (DDC)
Remove significant competitor from already concentrated regional market only limited post-merger competitive pressure

Deadline for phase II investigation is on 23 February 2017

"The Construction sector, like any other sector needs competition. As

cement is an essential part of the sector we need to make sure that
consolidation does not lead to higher prices for construction companies
and ultimately consumers in Croatia. Margrethe Vestager, Press Release,
10 October 2016

42

Crane and Container Handling

Konecranes/Terex

Concerns raised over

Significant overlaps in activities in supply of electric chain hoists and wire rope
hoists and standard cranes and container handling equipment
Risk of significant reduction of effective competition in markets for electric chain
hoists and wire rope hoists in the EEA (particularly Germany and France)

Phase I clearance on 8 August 2016 conditional on

Divestment of Konecranes Stahl subsidiary, supplier of industrial cranes, crane

components and spare parts (including its German production facility)
Removal of overlap in Germany and more than half of the overlap in France
for both electric chain hoists and wire rope hoists
At EEA level removal of overlap in wire rope hoists and half overlap for
electric chain hoists

43

Railway Equipment

Wabtec / Faiveley

Concerns that transaction would reduce competition in aftermarket for

sintered train friction brake materials, purchased by train operators for
existing train fleets
Merger would eliminate one of only three strong suppliers remaining
competitor would be insufficient to maintain adequate competition
Phase II clearance on 4 October 2016 conditional on sale of Faiveleys
operations in manufacturing of sintered friction materials for train brakes
Removal of all overlap between Faiveley and Wabtec in sintered train
friction brake materials

44

Laser Manufacturing

Coherent/Rofin-Sinar Technologies

Acquisition of Rofin-Sinar by Coherent

Preliminary investigation indicated proposed transaction would combine
two largest suppliers of low power CO2 lasers

Market share above 50%

Phase I clearance conditional on sale of Rofin-Sinar's Hull (UK) business

manufacturing low power CO2 lasers

45

Bumpers

Plastic Omnium/ Faurecia

Acquisition by Plastic Omnium of Faurecias automotive component

business
Concerns over reduced competition and insufficient post-merger
competitive pressure in:

Market for production and supply of plastic bumpers in France, Belgium and
Spain
Market for production and supply of front-end carriers, plastic
hatchbacks/tailgates and front-end modules at EEA level

Phase I clearance conditional on divesting a number of Faurecias

production facilities in France, Spain and Germany

46

Container Liner Shipping

CMA GCM/Neptune Oriental Lines

Acquisition of Neptune Oriental Lines of Singapore by CMA GCM,

French shipping company operating globally
Concerns that new links would have anti-competitive effects on two
trade routes

Between Northern Europe and North America

Between Northern Europe and the Middle East

Clearance on 29 April 2016 conditional on Neptune Oriental Lines

leaving G6 Line Shipping Alliance
"Container liner shipping plays a central role in global trade, so competition in
this sector is essential for businesses and consumers in the EU. Today's
decision ensures that the takeover will not lead to price increases for the many
EU companies using these container shipping services. Margrethe Vestager,
Press Release, 29 April 2016

47

Fuel

Statoil Fuel & Retail/Royal Dutch Shell

Acquisition of Shells Danish retail and wholesale fuel business, Dansk

Fuels, by Alimentation Couche-Tard of Canada, operating in Denmark
under Statoil brand
Concerns that merger could lead to higher prices for fuel, diesel,
gasoline and light heating oil customers in Denmark
Phase I clearance on 23 March 2016 conditional on extensive
commitments package including divestment of over 200 petrol stations
and Shells commercial fuels business

48

X. Upcoming Jurisdictional Changes

German Size of Transaction Threshold

New size of transaction threshold proposed in 21 July draft

Amendment

Modified threshold adopted in September:

Mergers to be notified where the value of the consideration for the transaction is
more than 400 million

Value for consideration includes all assets and services of a monetary value that the seller
receives from the acquirer in connection with the concentration, including financial liabilities

Target company must have significant activities in Germany

Effects element stricter than the test originally proposed in July - active or expected to become
active in Germany

Significant activities assessed on criteria and factors relevant to the particular industry (e.g.,
significant turnover for traditional industries, number of users for internet services)

De minimis exception not apply if size of transaction criterion is met

Submitted to Federal Parliament for discussion and scheduled to be

submitted to German Federal Council for vote (although unlikely to be
in force before February 2017)
50

At EU Level

Evaluation of procedural and jurisdictional aspects of EU merger

control
Consultation launched on 7 October 2016, closes on 13 January 2017
Focus on:

Simplification of procedures for cases generally not raising competition

concerns by

Broadening category of cases exempt from notification

Reducing information requirements on notifying parties
Introducing self assessment system for certain cases
Simplicity of treatment of extra-EEA joint ventures

Effectiveness of purely turnover-based notification thresholds

Focus specifically on digital economy and pharmaceutical industry

Questioning adequacy of case referral system

Proposing value of the transaction jurisdictional threshold

Referral mechanisms between NCAs and EC

Focus on increasing business-friendly nature of referral system by simplifying procedure and

simplifying process for accepting referral request
51

Commissioner Vestager

The issue seems to be that its not always turnover that makes a company
an attractive merger partner. Sometimes, what matters are its assets. That
could be a customer base or even a set of data. In the pharmaceutical
sector, it might be a new drug that's been developed but not yet approved
for sale. Or a company might be valuable simply because of its ability to
innovate.
[]Whatever we decide in the end, it has to meet one fundamental
principle: there should be no doubt whether you need to notify a particular
merger. So whatever test we choose has to be easy to apply, and has to
give a definitive answer.
Margrethe Vestager, Speech at Studienvereinigung
Kartellrecht, Brussels, 10 March 2016

52