On December 31, the Open Markets Institute submitted a comment to the Federal Trade Commission for its fifth session of "Competition and Consumer Protection in the 21st Century" hearings.

In the comment, titled "The Urgent Need for Strong Vertical Merger Guidelines," OMI discusses the Clayton Act's legislative history, the economic theories of harm behind vertically integrated corporate power, why new guidelines are necessary, and the principles that new guidelines should follow. In particular, OMI argues that enforcers should model new guidelines on the 1968 Merger Guidelines' section on vertical mergers.

Read the comment here.