Indian Leniency Regime in Competition Law

ASIA-PACIFIC
ANTITRUST REVIEW 2020
© Law Business Research 2020

ASIA-PACIFIC
ANTITRUST REVIEW 2020
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Contents
Overview
Merger Control�� 1
Andrew L Foster and Kexin Li
Skadden, Arps, Slate, Meagher & Flom LLP
Australia
Competition and Consumer Commission�� 24

Rod Sims
Chair
Overview�� 31
Liza Carver and Patrick Gay
Herbert Smith Freehills
China
Overview�� 45
Stephanie Wu
East & Concord Partners
Abuse of Dominance�� 56
John Yong Ren, Wesley Wang and Schiffer Shi
T&D Associates
Vertical Agreements�� 67
Yingling Wei and Xuefei Bai
JunHe LLP
iii
Contents
Hong Kong
Competition Commission�� 76
Brent Snyder
Chief Executive Officer
Cartels�� 81
Alastair Mordaunt and Nicholas Quah
Freshfields Bruckhaus Deringer
India
Cartels�� 92
Samir R Gandhi, Arunima Chatterjee and Shreya Singh
AZB & Partners
Leniency�� 105
Ram Kumar Poornachandran and Ankita Gulati
Talwar Thakore & Associates

Avaantika Kakkar and Anshuman Sakle
Cyril Amarchand Mangaldas
Japan
Cartels�� 129
Hideto Ishida and Atsushi Yamada
Anderson Mōri & Tomotsune
E-Commerce�� 141
Yusuke Takamiya
Mori Hamada & Matsumoto

Hideto Ishida and Takeshi Suzuki
Anderson Mōri & Tomotsune
iv
Contents
Malaysia
Overview�� 167
Shanthi Kandiah
SK Chambers
Singapore
Competition and Consumer Commission�� 180

Aik Kor Sia
Chief Executive
South Korea
Fair Trade Commission�� 185

Joh Sung-wook
Chairperson

Namwoo Kim, Wonseok Choi and Gunsup Shim
Trinity Legal
Vietnam

Nguyen Anh Tuan and Tran Hai Thinh
LNT & Partners
v
Preface
Global Competition Review is a leading source of news and insight on national and cross-border
competition law and practice, with a readership that includes top international lawyers, corporate
counsel, academics, economists and government agencies. GCR delivers daily news, surveys and
features for its subscribers, enabling them to stay apprised of the most important developments
in competition law worldwide.
GCR’s coverage of Asia continues to expand, with a senior reporter now stationed in Hong
Kong and more plans for growth following Law Business Research’s merger with Globe Business
Media Group.
Complementing our news coverage, Asia-Pacific Antitrust Review 2020 provides an in-depth
and exclusive look at the region. Preeminent practitioners have written about antitrust issues
in nine jurisdictions, as well as one regional overview for merger control. The edition includes
updates to 16 chapters and adds three new ones: two chapters on merger control in India and
Vietnam, and another on leniency in India. The authors are unquestionably among the experts
in their field within these jurisdictions and the region.
The volume includes contributions from the chairs of the Australian Competition and
Consumer Commission and Korea’s Fair Trade Commission, as well as the chief executives of Hong
Kong’s Competition Commission and Singapore’s Competition and Consumer Commission. Other
experts look at a range of subjects, including abuse of dominance and vertical agreements in China
and e-commerce in Japan.
This annual review expands each year, especially as the Asia-Pacific region gains even more
importance in the global antitrust landscape. It has some of the world’s most developed enforcers
– in Australia, Korea and Japan, for example – but it also has some of the world’s newest competi-
tion regimes, including in Malaysia and Hong Kong.
If you have a suggestion for a topic to cover or would like to find out how to contribute, please
contact insight@globalcompetitionreview.com. GCR thanks all of the contributors for their time
and effort.
Global Competition Review

London
March 2020
vi
India: Leniency
Ram Kumar Poornachandran and Ankita Gulati
Introduction
Since the enforcement of the substantive provisions of the Competition Act 2002 (the Competition
Act), there have been a total of 10 decisions passed by the Competition Commission of India (CCI)
involving leniency applications. Through its decisional practice as well as amendments to the
relevant regulations, the CCI has sought to promote the Indian leniency regime as a key feature
of its enforcement agenda. In 2018, the chairperson of the CCI at the time stated that the leniency
regime had been a great success in facilitating enforcement actions against cartels.1 This chapter
seeks to provide a description of the broad features of the Indian leniency regime and shed light
on emerging trends.
Legal framework
The Indian leniency regime is governed by section 46 of the Competition Act and the Competition
Commission of India (Lesser Penalty) Regulations 2009 (Leniency Regulations).2
The Indian leniency programme is applicable to ‘cartels’ under the Competition Act. A cartel
is defined as:
an association of producers, sellers, distributors, traders or service providers who, by agree-

ment amongst themselves, limit, control or attempt to control the production, distribution,
sale or price of, or, trade in goods or provision of services.
1 Leniency provisions ‘fantastic’ in acting against cartels: CCI chief, The Economic Times, 13 May 2018,
available at: https://economictimes.indiatimes.com/news/economy/policy/leniency-provisions-fantastic-
in-acting-against-cartels-cci-chief/articleshow/64148661.cms?utm_source=contentofinterest&utm_
medium=text&utm_campaign=cppst.
2 Amended through the Competition Commission of India (Lesser Penalty) Amendment Regulations, 2017
(2017 Amendment).
105
India: Leniency | Talwar Thakore & Associates
By definition, leniency applicants volunteer self-incriminating information concerning a cartel

in which they have participated, directly or indirectly, in exchange for either full immunity or a
significant reduction in penalties that would otherwise have been imposed.
The Competition Act prohibits any agreement between entities in ‘identical/similar trade of
goods or services’ (ie, horizontal agreements) that:
• directly or indirectly determines prices;
• limits or controls production, supply, markets, technical developments, investment or provi-
sion of services;
• shares the market, source of production, provision of services through the allocation of the
geographical area of the market or type of goods or services, or number of customers in the
market or any other similar way; or
• directly or indirectly results in bid-rigging.3
Horizontal agreements including cartels are presumed to cause an appreciable adverse effect on
competition (AAEC), although the presumption is rebuttable.
Under the Competition Act,4 cartelisation is a civil contravention and does not incur criminal
liability. The CCI can impose a penalty on cartel participants of up to 10 per cent of the average
turnover of the preceding three financial years for anticompetitive conduct. Further, in the case of
cartels, the CCI also has the discretion to impose a penalty of up to three times a cartel participant’s
profit or 10 per cent of its turnover, for each year of continuation of the cartel.
Who can apply for leniency under the Indian regime?

Initially, the leniency regime was only applicable to an ‘enterprise’ (ie, an entity having economic
operations). Despite this, the CCI, in its first leniency decision passed on 18 January 2017,5 granted
leniency to an individual who volunteered information on the bid-rigging of tenders raised by
Indian Railways for supply of fans.
The extension of the Indian leniency programme to individuals can be linked to the following.
First, individuals were increasingly at risk of being personally liable for their involvement in a
cartel, through penalties. Second, if penalties were levied on an individual under the Competition
Act of over 5,000 rupees, such a person would be disqualified to sit as a board director in a company
registered under the Indian Companies Act. Third, since the Brushless DC Fans Cartel decision,
it appears that the CCI recognised the need to allow individual whistle-blowers to also apply for
leniency and provide meaningful disclosure. Accordingly, amendments were made to the Indian
leniency regime in August 2017 (2017 Amendment) to broaden the definition of an ‘applicant’6 to
also include individuals involved in cartels.
3 Section 3(3) of the Competition Act.

4 Section 27 of the Competition Act.
5 Cartelization in respect of tenders floated by Indian Railways for supply of Brushless DC Fans and other
electrical items, Suo Moto Case No. 03 of 2014.
6 Regulation 2(b) of the Leniency Regulations.
106
Talwar Thakore & Associates | India: Leniency
Conditions for grant of leniency

The CCI has the power to grant complete immunity or a reduction in penalties to a whistle-blower
who makes a ‘full, true and vital disclosure’ regarding the alleged offenses of the cartel, provided
that the leniency applicant:
(i) ceases to participate in the cartel (unless directed otherwise by the CCI);7
(ii) does not conceal, destroy, manipulate or remove any relevant evidence;8
(iii) continues to cooperate genuinely, fully, continuously and expeditiously with the CCI, until
completion of the proceedings;9 and
(iv) complies with any other restrictions or conditions imposed by the CCI.10
In practice, the CCI places more emphasis on factors (ii) and (iii), in determining the granting of
leniency and reduction in fines. The CCI has thus far not required an enterprise or individual to
continue to engage in the cartel, as a part of its leniency proceeding.
Filing a marker
The CCI grants a reduction in penalty based on a marker system. Under the marker system, the
first leniency applicant would be accorded the first ‘priority status’11 as long as they either:
• make a vital disclosure of evidence of the cartel, which allows the CCI to form its prima facie
opinion (ie, submit evidence to the CCI to trigger an investigation by the the Office of the
Director General (DG));12 or
• provide evidence that allows the CCI to establish the existence of the cartel.
The leniency applicant with the first priority status would be granted the benefit of a reduction in
penalty up to or equal to 100 per cent of the total penalty leviable13.
Thereafter, subsequent leniency applicants are granted reductions in penalty if they submit
relevant evidence that adds significant value to the evidence already available with the CCI.
Accordingly, all leniency applicants (subsequent to the first priority status) would need to submit
evidence that enhances the ability of the CCI or DG to establish the infringement.14 The leniency
applicant who secures the second priority status may be granted a reduction of penalty up to or
7 Regulation 3(1)(a) of the Leniency Regulations.

8 Regulation 3(1)(e) of the Leniency Regulations.
9 Regulation 3(1)(d) of the Leniency Regulations.
10 Regulation 3(3) of the Leniency Regulations.
11 Regulation 4(a) of the Leniency Regulations.
12 The DG is the investigative wing of the CCI.
13 ibid.
14 Regulation 4(b) of the Leniency Regulations.
107
equal to 50 per cent of the total penalty leviable.15 Leniency applicants marked with the third or
subsequent priority status will be granted reductions in penalty up to or equal to 30 per cent of
the total penalty leviable.16
Until 2017, there were only three markers available under the Indian leniency system. However,
with the 2017 Amendment, the limit on the number of markers was removed to allow for more than
three leniency applicants.
Evaluation of the leniency application

The grant of a ‘priority status’ by the CCI does not automatically entitle an applicant, as such,
to reduced penalties.17 The CCI typically will not inform leniency applicants of their position in
the priority status or marker, so as to incentivise applicants to provide maximum evidence and
continue to cooperate with the investigation.
Under the Leniency Regulations, the CCI, while deciding to grant a reduction in penalty, is
required to consider the following factors:
(i) the stage at which the leniency applicant makes the disclosure;
(ii) the evidence already in possession of CCI;
(iii) the quality of the information provided by the leniency applicant; and
(iv) the facts and circumstances of the case.18
Penalties
While considering the application from the first leniency applicant, the CCI places significant
importance on points (i) and (ii) above. Every instance of the CCI granting a 100 per cent reduc-
tion in penalties19 has occurred where the leniency applicant has provided evidence that brought
the cartel to the knowledge of the CCI. In such cases, the CCI will form a prima facie opinion and
direct the DG to investigate. In Brushless DC Fans cartel,20 the first leniency applicant was granted
a 75 per cent reduction, as the application was filed during the last stages of the DG investigation.
However, in all subsequent cases21 where a leniency applicant obtained the first marker after the
investigation was commenced, the CCI has granted only a 50 per cent reduction.
All leniency applicants, after the first marker, are judged primarily on the basis of the quality
and nature of the evidence. This is crucial to obtain a higher reduction in fines. Depending on
the value added to the evidence already possessed by the CCI and DG, a reduction in the range of
50–20 per cent is typically granted. This is to ensure that leniency applicants are encouraged to
provide new evidence and continuous cooperation with the CCI and DG. It is also important to
15 Regulation 4(c)(i) of the Leniency Regulations.

16 Regulation 4(c)(ii) of the Leniency Regulations.
19 Case No. 02 of 2013; Case No. 07(01) of 2014; Case No. 02 of 2016; Case No. 02 of 2017; Case No.
03 of 2017.
20 Suo Moto Case No. 03 of 2014.
21 Suo Moto Case No. 03 of 2016; Case No. 50 of 2015.
108
note that a leniency applicant may still be liable for compensation claims under section 53(N) of
the Competition Act, as there is no provision granting any immunity from subsequent compensa-
tion claims.
Trends emerging from the CCI’s leniency orders

What constitutes significant value addition
Interestingly, in Cartelization in Respect of Zinc Carbon Dry Cell Batteries Market in India,22 the CCI
deviated from the typical factors to grant reductions in penalty to the second and third leniency
applicants. The CCI stated that, although the second and third leniency applicants did not provide
the CCI with any new evidence, they had helped the CCI corroborate and connect the evidence
already in its possession. Accordingly, the second and third leniency applicants were granted a 30
per cent and 20 per cent reduction in penalty respectively. Similarly, in Cartelization in Tender Nos.
21 and 28 of 2013 of Pune Municipal Corporation for Solid Waste Processing,23 the CCI granted a 50
per cent reduction in penalty to the leniency applicant who was the first to approach the CCI for
leniency and ‘provided a better picture of the operation of the cartel’, even though no significant
additional evidence was submitted.
However, in Nagrik Chetna Manch,24 the CCI did not grant any reduction in penalty to the last
two leniency applicants as they did not provide any significant value addition to the evidence avail-
able with the CCI. This is despite their complete cooperation during the investigation. Therefore,
the CCI is likely to adopt a flexible approach, depending on the facts and circumstances of each
case, to determine what comprises significant value addition by a leniency applicant.
Leniency application by a ringleader

In Nagrik Chetna Manch,25 the CCI noted that one of the leniency applicants had orchestrated the
cartel. Despite the fact that the leniency applicant was responsible for initiating the cartel and
provided a ‘minimal’ value addition to the investigation, the CCI nonetheless granted a 25 per cent
reduction in penalty. It appears that the CCI gave due regard to the marker awarded (second with
respect to one set of tenders and third with respect to another set of tenders) while granting the
reduction in penalty. This was despite the leniency applicant’s ringleader status in all the cartels
and minimal value addition to the evidence. Subsequently, the same leniency applicant was found
to be the orchestrator of bid-rigging to two other sets of tenders.26 In its subsequent order penal-
ising the company for the latter two sets of tenders, no reductions in penalty were granted.
22 Suo Moto Case No. 02 of 2016.

23 Suo Moto Case No, 03 of 2016.
24 Case No. 50 of 2015.
25 Case No. 50 of 2015.
26 Suo Moto No. 03 of 2016 and Suo Moto Case No. 04 of 2016.
109
This set of cases demonstrates that the CCI is not likely to disregard the leniency application
of a ringleader or orchestrator of a cartel, provided they cooperate fully with the investigation.
However, where there are multiple instances of cartelisation by the same entity, the CCI is likely
to consider previous contraventions as an aggravating factor.
Procedure for application for leniency

Timing of application
A leniency application ideally should be submitted before the CCI forms a prima facie opinion,
which sends the case to the DG for investigation. A leniency application can also be filed after the
CCI passes its prima facie order but before the DG’s investigation report is final.27
Contents of the application

An application for reduction of penalty may be made to the CCI in writing or conveyed to the CCI
orally, or through e-mail or fax.28 A written application must include the following information:
• name and address of the leniency applicant;
• names and addresses of all other enterprises involved in the cartel;
• a detailed description of the alleged cartel arrangement, including its aims and objectives,
details of activities, commencement and duration, among others;
• the product market and geographic market involved;
• the estimated volume of business affected in India;
• the names, positions, office locations and home addresses of all individuals who are or have
been associated with the alleged cartel, including on behalf of the applicant;
• the details of other competition jurisdictions where the leniency applicant has or intends to
ask for leniency;
• a descriptive list of evidence provided in support of the application for a lesser penalty; and
• any other material information as may be directed by the CCI.29
If the leniency applicant is a company, the leniency applicant must also provide the names of the
individuals involved in the cartel on its behalf.30 Individuals named by the leniency applicant are
likely to be granted the same reduction in penalty as the leniency applicant or company.
Receipt of application
The CCI is required to consider a leniency application within five working days of receipt.31
Thereafter, the CCI will:
27 Section 46 of the Competition Act.

29 Schedule to the Leniency Regulations.
30 Regulation 3(1A) of the Leniency Regulations.
110
• mark the priority status of the leniency applicant and inform the leniency applicant that it has
been given priority status (but not provide the number in the queue); and
• direct the leniency applicant to submit a written application containing all the material infor-
mation required under the Leniency Regulations within 15 calendar days.
If the written application is not made within 15 calendar days, or within an extended period
granted by the CCI, the leniency applicant could lose their priority status.32
When can leniency be rejected

If the CCI finds that the evidence provided by the leniency applicant is false or not vital to the inves-
tigation, or that the leniency applicant has failed to comply with requisite conditions imposed,
the CCI may not grant any reduction in penalty.33 Where a leniency applicant fails to comply with
the conditions mentioned above, the CCI shall still be free to use the information and evidence
submitted by the leniency applicant to proceed in a case against such entities.34
If an application is rejected, the leniency applicant will be granted a hearing35 before the same.
Where the first leniency applicant’s application is rejected, subsequent leniency applicants will
move up in the priority status.36 Until the first leniency applicant’s application has been fully
evaluated, the CCI will not consider the application of the next leniency applicant.37 This does
not, however, preclude other entities from filing leniency applications.
Confidentiality of the leniency application

Under the Leniency Regulations, the CCI and the DG shall treat as confidential the identity of
the leniency applicant and the information, documents, and evidence furnished by the leniency
applicant.38
However, the CCI or the DG may disclose the identity of the leniency applicant or the evidence
submitted if:
• such disclosure is required under the law;
• the leniency applicant consents to such disclosure in writing, or
• there has been a public disclosure by the leniency applicant.39

33 Proviso to Section 46 of the Competition Act.
38 Regulation 6 of the Leniency Regulations.
39 ibid.
111
Further, if the DG deems that it is necessary to disclose the evidence submitted by the leniency
applicant to another party for the purposes of investigation and the leniency applicant has not
consented to such disclosure, the DG may disclose such information after recording reasons in
writing and taking prior approval of the CCI.40
In a recent leniency proceeding (Cartelisation in the supply of Electric Power Steering Systems),41
the CCI allowed the creation of a ‘confidentiality ring’. Following the creation of the confidentiality
ring, a non-confidential (qua parties) version of the DG’s report was shared among the parties.
The ‘confidentiality ring’ arrangement allows parties to access information that would be vital for
them to form legal defences in the matter.
It is also important to note that confidentiality under the Leniency Regulations applies only
to the contents of the Leniency Application. It does not apply to all evidence gathered by the DG
from the leniency applicant.42 For instance, statements made during the deposition of the leni-
ency applicant by the DG would not be kept confidential under the Leniency Regulations. The
confidential treatment of such evidence would need to be sought separately under other confi-
dentiality provisions.
Inspection by parties
The 2017 Amendment has also created a provision that allows parties to a proceeding (arising
from a leniency application) to inspect the non-confidential version of the information, evidence
and documents submitted by a leniency applicant. The inspection can be conducted, for a fee,
after the DG report is shared with the parties. Parties are not allowed to disclose the information,
evidence or documents obtained through an inspection, except for purposes of participating in
the legal proceedings.
Dawn raids
Recently, the DG has been exercising its powers of ‘search and seizure’ through dawn raids on
potential cartel participants. There have been six dawn raids so far in matters involving alleged
cartels. The increased use of dawn raids as an investigative tool by the CCI also jeopardises the
chances of filing leniency applications. The likelihood of adding significant value to the evidence
available with the CCI becomes low after the DG has seized evidence through a dawn raid. However,
it is understood that the CCI may grant a reduction in penalty to leniency applicants who help the
CCI connect and explain the evidence obtained through a dawn raid.
Conclusion
The CCI, in the past few years, has been effective in using the leniency process and dawn raids
as a tool to prove the existence of a cartel. Furthermore, thanks to training and cooperation with
other mature competition authorities, there is an increased reliance on economic analysis and
40 id.
41 Suo Moto Case no. 07 (01) of 2014.
42 Paragraph 72, Case No. 50 of 2015.
112
better appreciation of evidence by the DG and the CCI. This has resulted in a steep increase in
compliance efforts by companies in India. Specifically, companies are increasingly being watchful
of their interactions with competitors in relation to trade associations and supply and purchase
arrangements.
Ram Kumar Poornachandran

Ram Kumar leads the competition practice of Talwar Thakore & Associates. He has advised
Indian and foreign clients on complex matters across various sectors such as pharmaceu-
ticals, petrochemicals, energy, media, fast-moving consumer goods, glass and healthcare.
He has successfully advised and represented a number of clients in merger transac-
tions, including: Linde in its merger with Praxair, 21st Century Fox in relation to the sale
of its business to Walt Disney Co, Lafarge in its global merger with Holcim, and Novartis
in its transformational restructuring with GlaxoSmithKline across three transactions and
business divisions. On the antitrust side, Ram has successfully defended Great Eastern
Energy Corporation Ltd and Saint Gobain against abuse of dominance allegations before
the Competition Commission of India (CCI). He recently represented Star India in securing
the quashing of a CCI investigation by the Bombay High Court. Ram has successfully repre-
sented Reliance Industries, Torrent Pharmaceuticals and 21st Century Fox in cartel investi-
gations. He has advised and represented clients (both Indian and multinational) in leniency
proceedings. He also regularly advises multinational companies on competition compli-
ance issues. Ram is a non-governmental adviser to the CCI.
Ram received his LLM degree from the National University of Singapore and holds a
postgraduate diploma in Competition Economics from King’s College London. He is consist-
ently rated for his expertise and experience by publications such as Chambers and Partners
(2015–2020), The Legal 500 and Who’s Who Legal: Future Leaders – Partners 2020.
113
Ankita Gulati
Ankita Gulati is an associate at the competition practice of Talwar Thakore & Associates.
Ankita received her LLM degree from the Columbia Law School in 2019 and her BA, LLB with
honours degree from National University of Juridical Sciences in 2015.

Talwar Thakore & Associates (TT&A) combines experienced partners and a strong, committed team to
offer quality legal advice on the ground in India. TT&A’s key areas of focus are finance, corporate M&A and
investments, debt capital markets, financial regulation and competition law.
The competition practice is recognised as being a market leader for its in-depth industry knowledge level
of services to clients. We are uniquely placed to assist our clients with specialist, strategic antitrust advice
to navigate through the emerging Indian competition law landscape and are known for the quality of work &
advice as reflected in positive client feedback, legal directories and, most importantly, the transactions we
work on.
TT&A has advised on some of the most significant competition matters in India, both in terms of size
and complexity. Given the nature of the work, it has developed special expertise in certain sectors (eg,
pharmaceuticals, media, broadcasting, petrochemicals and manufacturing).
TT&A has a ‘best friend’ relationship with Linklaters LLP. We frequently collaborate with Linklaters across
all our core practice areas including advising on complex and high-end corporate, capital markets, finance
and regulatory matters relating to India. A majority of our partners were previously with, and have spent
significant time at, Linklaters. Our associates are regularly seconded to various offices of Linklaters and
participate in common training and know-how programmes.
1114-1115, DLF Tower – B Ram Kumar Poornachandran

Jasola Business Centre ram.kumar@tta.in
New Delhi 110025
India Ankita Gulati
Tel: +91 11 462 99999 ankita.gulati@tta.in
www.tta.in
114
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Competition and Consumer Commission������������������������������������������������������ 24

Merger Control�������������������������������������������������������������������������������������������� 115

Merger Control�������������������������������������������������������������������������������������������� 157

Competition and Consumer Commission���������������������������������������������������� 180

Fair Trade Commission������������������������������������������������������������������������������� 185

Merger Control�������������������������������������������������������������������������������������������� 189

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Global Competition Review

an association of producers, sellers, distributors, traders or service providers who, by agree-

By definition, leniency applicants volunteer self-incriminating information concerning a cartel

Who can apply for leniency under the Indian regime?

3 Section 3(3) of the Competition Act.

Conditions for grant of leniency

7 Regulation 3(1)(a) of the Leniency Regulations.

Evaluation of the leniency application

15 Regulation 4(c)(i) of the Leniency Regulations.

Trends emerging from the CCI’s leniency orders

Leniency application by a ringleader

22 Suo Moto Case No. 02 of 2016.

Procedure for application for leniency

Contents of the application

27 Section 46 of the Competition Act.

When can leniency be rejected

Confidentiality of the leniency application

32 Regulation 5(4) of the Leniency Regulations.

Ram Kumar Poornachandran

Talwar Thakore & Associates

1114-1115, DLF Tower – B Ram Kumar Poornachandran

© Law Business Research 2020

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Competition and Consumer Commission�� 180

Fair Trade Commission�� 185

Merger Control�� 189

Merger Control�� 201