Proposed Horizontal Merger Guidelines: Economists’ Comment
We are a group of economists (listed at the end of this letter) with extensive experience working on antitrust issues, including horizontal mergers. We applaud the Federal Trade Commission and the Department of Justice for inviting comments from the public on the proposed Horizontal Merger Guidelines (HMGs). The proposed HMGs represent a substantial advance over the existing guidelines by better explaining the methodologies actually employed at the Department of Justice and Federal Trade Commission in their evaluations of mergers. We are writing to comment on one specific aspect of the proposed HMGs: the use of price/cost margins in merger analysis.