In this article we offer a number of recommendations for updating the merger guidelines. Our comments address six distinct areas: (1) the guidelines’ structure, (2) guiding principles, (3) merger enforcement goals, (4) analysis of future competition, (5) innovation, and (6) efficiencies. The main theme of our comments is the importance of dynamic competition in merger analysis. Firms engage in dynamic competition by investing in innovation, product promotion, reputation, and producti
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