Chillin'Competition

Relaxing whilst doing Competition Law is not an Oxymoron

SAVE THE DATE – 14 September: Chillin’ event in London (@LSELaw)

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LSE Law

For many reasons, 2018 has been an eventful year. For the two of us. Some of these reasons are professional. You will not be surprised if I told you that I am immensely proud to have been promoted to a chair at LSE. And (it’s been in the making so long that it feels unreal) my book is coming out in a couple of weeks.

Alfonso and I felt these two landmarks gave us a wonderful excuse to have an event in London, at LSE Law (by Lincoln’s Inn Fields) – when the weather is still nice (well, fingers crossed) and classes have not yet started.

The idea is to bring some friends and colleagues and discuss some of the major themes I explored in my book. We will have three panels. And for a change, some non-competition lawyers will come along to provide a different perspective.

The event will take place in the afternoon of 14 September – in case you’re wondering, and you’re not based in London, it’s a Friday (and thus hopefully easier for those living or working elsewhere).

Marc van der Woude, Vice-President at the General Court and eminent competition lawyer, has been kind enough to accept our invitation to deliver a keynote speech.

In addition, the event will feature the following luminaries:

  • Paul Daly (University of Cambridge)
  • Michal Gal (University of Haifa)
  • Damien Gerard (European Commission)
  • Eric Gippini Fournier (European Commission)
  • Carol Harlow (LSE)
  • Andriani Kalintiri (LSE, and soon City Law School)
  • Bill Kovacic (George Washington University and King’s College London)
  • Alfonso Lamadrid (Garrigues)
  • Ioannis Lianos (University College London)
  • Joana Mendes (University of Luxembourg)
  • Jorge Padilla (Compass Lexecon)
  • Denis Waelbroeck (Ashurst and Université libre de Bruxelles)

Please watch this space for news about the programme and about how to register. We look forward to seeing many of you there for this occasion.

 

Written by Pablo Ibanez Colomo

22 June 2018 at 5:33 pm

Posted in Uncategorized

Why I don’t understand the case law on object restrictions, by Svend Albaek (DG Comp)

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I don't understand

On 20 April, the Florence Competition Programme organised a workshop on EU competition law after Intel and Cartes Bancaires. The organisers managed to put together a great (and fun) line-up. The keynote speech was delivered by Svend Albaek, Deputy Chief Economist at DG Comp. He shared his personal views on the notion of restriction by object. The speech was really interesting and thought-provoking. I asked whether it would be possible to publish it on Chillin’. Alfonso and I were really pleased that the answer was yes. We leave you with Svend:

In this short comment I will explain why I think that after working more than 18 years in DG Competition I still don’t really understand what the case law says on object restrictions. I probably have to give a bit of warning first. When I once tried to get help on this topic from a well-known law professor, his answer was something along the lines of “oh, you economists always want everything to be so logical; that’s not necessarily the way things work”.

So yes, I may be damaged by my training, but I really would like to see a clear logical construction underlying the characterisation of object restrictions. What I will do in this comment is to present one possible such logical construction and then point out where I think this construction does not entirely fit the way object restrictions are presented in the case law.

So what is this construction? Well, we could call it “per se light”, in the sense of something similar to the US per se concept but with the possibility – and I stress possibility for reasons that will become clear later – of an efficiency defence under Article 101(3).

The idea would be that an object restriction is a practice that (in an admittedly slightly loose formulation) looks like it (1) could plausibly be anti-competitive and (2) could never – or almost never – have pro-competitive countervailing effects. That is, it is not a plausible source of efficiency gains. If this is the case, we would (almost never) condemn a practice that has a net pro-competitive effect. In the worst case, we might attack something that only has a negligible anti-competitive effect.

Probably many readers will know an article (“Defining ‘By Object’ restrictions“) that my good friend and colleague Luc Peeperkorn published in 2015. What I’m thinking of is pretty similar to what Luc suggests, and I was pleased to find out recently that also Pablo Ibáñez and Alfonso Lamadrid think along similar lines (“On the notion of restriction of competition: what we know and what we don’t know we know“). I apologise if there are more people out there that should have been mentioned but whom I just don’t know about because I haven’t had the time to make a proper literature search. However, as you can understand, I’m certainly not trying to claim originality here when I say “my” construction. You will find much of what I write here stated in more detail – and probably better argued – in the articles of Luc, Pablo and Alfonso, so I encourage you to read them if you are interested in the topic.

We can, of course, find something pretty similar to this view in certain Commission documents. And, importantly, we can find traces of it also in Cartes Bancaires, most clearly in Wahl’s Opinion’s in paragraphs 55-58. However, it is, in my view, not spelled out as clearly as Luc, Pablo and Alfonso do.

This construction sounds very much like the US approach to per se infringements, only that there the parties cannot invoke efficiency arguments – or at least not in the lower courts – while in Europe this is still possible under Article 101(3). But the Commission does say in its Guidance on object restrictions that “practice shows that restrictions by object are unlikely to fulfil the four conditions set out in Article 101(3)”. So in reality, it sounds like we would be pretty close to a per se approach. Thus my expression “per se light”.

Now, this may sound fine and logical – perhaps also to the reader – but, unfortunately, I don’t think it reflects reality. Or at least not perfectly. Or at least not yet, if one thinks that the ECJ is in a – probably very slow – process of changing the case law.

I see two major problem areas, which I should say that Pablo and Alfonso also identity in their paper where they call them “outliers”.

The first is with respect to what we could call “internal market partitioning cases”. It is generally recognised – both in economics and in competition law – that territorial restrictions in distribution agreements can bring efficiency gains. If that is true, probably also absolute territorial protection can bring efficiency gains, and it should then not be classified as an object restriction according to my “construction”. The distinction between active and passive sales used in the case law does not really fit with this way of thinking. Something else is clearly going on. Pablo and Alfonso put it this way:

“The peculiar legal status of absolute territorial protection and other practices aimed at limiting trade between member states is explained by the fact that market integration is an autonomous objective of EU competition law”.

So basically, I think I can forget about trying to fit this into my neat logical construction.

The other outlier is Resale Price Maintenance. Many economists think there can be efficiency explanations for almost all – if not all – vertical restrictions and that it is therefore wrong to treat these as object restrictions. And many economists would without much hesitation include RPM in this way of thinking. Now, you may know that Luc Peeperkorn strongly believes that RPM should be an object restriction. So when I had read his article on object restrictions, I immediately went to his office to tease him by saying that he had just argued very eloquently for why RPM should not be an object restriction, since obviously there could be efficiency reasons for imposing RPM; for instance, avoiding free riding by retailers on service provided by other retailers. Luc’s answer was that he does not agree that RPM can be expected to lead to appreciable efficiencies and fulfil the conditions of Article 101(3) since (1) although RPM provides the retailers with a higher margin, it does not take away the free riding incentive; (2) it can thus not be expected that the retailers will voluntarily, without detailed monitoring and disciplining, spend this extra margin on free-rideable services such as product promotion; which (3) implies that there will normally be more effective and less restrictive means of achieving the same efficiencies. I’m not entirely convinced that this is true; consequently, I’m not convinced that RPM being an object restriction fits into my construction either.

Next I would like to ask a couple of questions. First, can the finding of an object restriction depend on the market power of the parties? The ECJ seemed to say so in Allianz Hungária, only to backtrack in Cartes Bancaires. And it would indeed not make sense according to my construction. Because my construction is based on categories of behaviour; I think this may be what the ECJ means when it uses the expression “types of coordination” in Cartes Bancaires (e.g. in paragraph 50). In my view, Wahl’s Opinion also strongly hints at this when he writes that “only conduct whose harmful nature is proven and easily identifiable” should be regarded as an object restriction. So the idea would be that one can easily see that a certain conduct falls into an “easily identifiable” category (e.g. price fixing or market sharing) and therefore conclude that something is an object restriction. But, in my view, that a restriction is a plausible source of efficiency gains cannot depend on market power. It may well be that the result of the ultimate balancing will depend on this, but that would imply that we may expect an effects analysis to end up with a negative (net) result if the parties have (a lot of) market power and with a positive (net) result if they don’t. The conclusion should not be that we think a category of conduct is an object restriction if the parties have market power but not if they don’t. In parenthesis, this way of thinking also made it hard for me to understand the way the General Court in paragraph 89 of its Intel judgment dismissed the relevance of Delimitis. But it seems that the ECJ has now cleared this up in its own Intel judgment.

Finally, a question related to efficiencies and object restrictions. I have a couple of times heard Richard Whish argue that competition agencies and courts should show more willingness to use Article 101(3). I have a lot of sympathy for that. But Prof Whish then pointed to decisions by the Singaporean competition authority concerning airline alliances as a kind of model to follow. As far as I understand – and I must admit that I have not read the decisions – the authority found that the alliances were object restrictions; I guess because the alliance partners would be coordinating on several parameters of competition. But the authority then apparently went on to recognise efficiencies under the equivalent of Article 101(3) and in the end found that the alliances were not anticompetitive. As I wrote, I understand that Prof Whish sees this as a positive example to learn from. But in my construction this example would not make sense. Although, of course, the formal right of the parties to have a go under Article 101(3) is always there, one would not expect to clear something that is an object restriction through efficiencies – and certainly not several times. If one does identify substantial efficiencies (several times), one would rather reach the conclusion that the original categorisation as object restriction likely was mistaken, analyse the effects of the restriction, and reach the conclusion that the net effect is positive and the restriction therefore not anticompetitive. However, as Prof Whish is Prof Whish and I’m an amateur compared to him, my tentative conclusion from this discussion is that my construction may not reflect the real world.

But if so, what is the alternative? I hope that one day I will understand this better.

Written by Pablo Ibanez Colomo

14 June 2018 at 11:02 am

Posted in Uncategorized

Breaking Antitrust News from Brussels, North Korea, the U.S. and Luxembourg

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Resultado de imagen de cnn breaking news antitrust

-It has been reported this week that the European Commission is getting ready to take a step that could have profound implications on the internet as we know it. We did not know whether to comment on this development or not given my conflict of interest, but the Commission’s view would appear to put at risk what this blog stands for as well as part of my work during the past two years. Yes, you guessed right, legal memes are allegedly at risk; for more, see here.

-Yesterday was a historically surreal day. But contrary to what has been reported, Trump and Kim Jong-Un had interacted before (on Twitter, regarding antitrust, and Commissioner Vestager was involved). Click here to see the screenshots (from slide 3 onwards).

-In what many see as a blow to Trump, the AT&T/Time Warner merger was unconditionally cleared yesterday after the DOJ’s suit was dismissed. The full text of Judge Leon’s Opinion is available here. Its drafting seems to be quite specific and not a challenge to the growing concern about vertical mergers. The Judge himself has stated that “the temptation by some to view this decision as being something more than a resolution of this specific case should be resisted by one and all”. This development will trigger many comments, but the most succinct, persuasive and full blown attack against vertical mergers we have read so far comes from 30 Rock and is available here  (make sure to click) 😉

-Moving on to more serious news, the Luxemburgish competition authority has exempted an algorithm price fixing mechanism for taxis. The Decision available here (in French) notes that the joint use of a multi-sided platform that fixes prices constitutes a horizontal agreement, but concludes that the agreement shall be exempted given the efficiencies generated by the agreement (which include lower prices for consumers thanks to the algorithm) and the absence of any viable alternative to attain them. Would the Commission and other NCAs agree with this view? We don’t know because the case concerns only Luxemburgish law (otherwise an exemption would not have been possible pursuant to the Tele 2 Polska case law). According to the decision, the taxi sector is subject to national regulation and does not impact trade between Member States (which arguably doesn’t fit squarely with what the CJEU held in paras. 65-70 of Eventech). Since Member States can’t exempt agreements under EU Law, they may be led to adopt this sort of jurisdictional interpretations, which may in turn not be ideal for legal certainty and for the internal market.

Wouldn’t it be nice if the European Commission decided to adopt 101(3) decisions too? Quizz question: what was the last 101(3) exemption granted by the Commission?  It’s already been 7 years (!) since we wrote about The Slow Death of Article 101(3), and it’s not that the landscape has improved.

Written by Alfonso Lamadrid

13 June 2018 at 11:10 am

Posted in Uncategorized

Mighty Simple: Important Competition Lessons from McDonald’s Quarter Pounder

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Quarter-Pounder-with-Cheese

Other stuff on our plate has prevented us from commenting on many of the competition law developments that took place in the past few weeks. But we know you are hungry for commentary. Without a doubt, the meatiest recent development is the class action accusing McDonald’s of anticompetitive tying.  Don’t assume this is just going to be another post with puns; there really is food for thought here.

Background

The plaintiff challenges McDonald’s distribution of the Quarter Pounder line of burgers. The allegation is that McDonald’s only markets the Quarter Pounder and Double Quarter Pounder with cheese (in the past it also sold defaults without cheese) and only as part of a value meal. The plaintiff argues that this practice forces consumers to “pay for two slices of cheese, which they do not want, order, or receive”.  They estimate that non-cheese-eaters are charged 30 to 90 cents for the cheese they don’t want even if they have to ask for the cheese to be removed (or have to remove it themselves). This would enable McDonald’s to charge for cheese it does not deliver.  The plaintiffs have done their research and noted that the original 1975 trademark does not refer to cheese (only to a frozen beef patty, a sesame-seed bun, one tablespoon of diced fresh onion, mustard, ketchup and two Heinz pickle slices). The full class action complaint is available here.

McDonald’s has replied that “the advertised Quarter Pounder burger comes with cheese. We try to accommodate our customers’ requests by allowing them to customize their orders, such as a Quarter Pounder with no cheese.”

The merits

This is a US case, but imagine you wanted to run a case like this in the EU. Could it fly? What would you do to meet the requirements set by the case law? Is this really a crazy case as it may seem to many? Let’s see:

First, you would argue that the tying and the tied products are separate products. The two were once sold separately by McDonalds; cheese can be added or not; the trademark does not cite cheese; there are independent producers of cheese. At the same time it’s true that the forked versions of the Quarter Pounder do incorporate two slices of cheese (see e.g. here) [yes, there are many different types of McDonald’s forks]. Overall, one could get away with saying that a Quarter Pounder and cheese are different products. Box ticked.

Second, you could argue that McDonald’s is dominant in the tying product. You would only need to argue that McDonald’s franchisees don’t really have the option of buying burgers from any other source. So McDonald’s is dominant in the market for “franchisable burguers to be sold at McDonald’s restaurants”. The plaintiffs refer to McDonald’s market power in the “fast food quarter pound hamburger market” (para. 75). Box ticked.

Third, customers have no option of obtaining the tying product without the tied. That’s the point the plaintiff is making. One is certainly not forced to eat the cheese and to customize the burger further (you can pretty much put anything in there and McDonald’s will let you) but it is true that the cheese comes pre-installed as a default. The plaintiffs in this case also invoke the “uniqueness” and “desirability” of the tying products.

Fourth, you would need to show that the tying is capable of restricting competition. One can argue that McDonald’s is hindering consumers choice. You can even define a market for cheese to be used in McDonald’s Quarter Pounders and conclude that rival ingredients are being excluded (even if there is no technical obstacle for users to add other ingredients to be added to the Quarter Pounder; McDonald’s even facilitates that: see e.g. here).

Piece of cake. The plaintiffs wouldn’t even have to argue that they are overpaying, as they do in this class action. I guess they could make the same allegation even if McDonald’s provided the burger and the cheese for free.

[As this is a US damages claim, the plaintiffs also need to prove that they suffered injury as a result of their purchase. That may be easier to show, but I doubt the injury I have in mind could be attributed to the alleged tying…]

The lessons

One can argue anything in a competition case (see here for some example on market definition), but most of you will –hopefully- agree that the case makes little sense. But let’s try to slice and reason that intuition:

Franchise business model necessarily implies a package of interrelated items. Whilst tying is assumed to be restrictive (because it is presumed that it serves no procompetitive goal), franchise agreements are presumed procompetitive and justify even what would otherwise be seen as hardcore restrictions (non-compete clauses, outright exclusivity; see e.g para. 191 of the Vertical Guidelines). How do we then square this out? It all depends on the issue of severability. This was made clear by US Courts in a case involving… alleged McDonald’s tying (Principe v McDonalds; a case concerning licensees obligation to operate their franchises in premises leased from the franchisor). What is the actual licensed/franchised tying product? Is it just trademark or is it rather a business format?

In that case McDonald’s had argued that “the appellants are asking the court to invalidate the way McDonald’s does business and to require it to adopt the licensing procedures of its less successful competitors” (para. 23). The Fourth Circuit agreed. It observed the question depends on whether the items were “integral components of the business method being franchised” (para. 32).

After analyzing the specific contributions of the obligation at issue to McDonald’s business method (paras. 34-37, which take into consideration protecting the “system’s goodwill”, ensuring “consistent quality”. “broadening the applicant base and opening the door to persons who otherwise could not afford a McDonald’s franchise” as well as the extent of McDonald’s financial investment), it concluded the following:

All of these factors contribute significantly to the overall success of the McDonald’s system. The formula that produced system wide success, the formula that promises to make each new McDonald’s store successful, that formula is what McDonald’s sells its franchisees. To characterize the franchise as an unnecessary aggregation of separate products tied to the McDonald’s name is to miss the point entirely”.

Severability in Principe v McDonalds was analyzed at the “separate products” step, whilst in in the EU it would be part of the assessment of the economic and legal context (this is true of any restraint that may be part of a wider context, not only franchising; see e.g. Cartes Bancaires 73-79). But the substantive reasoning is pretty much the same. Ignoring the relevant context to any restraint leads to missing the point entirely. Much like in Principe v McDonald’s, EU Courts have also observed that restraints are deemed to fall outside the scope of the competition rules when the such analysis shows that they are related to a main operation that “could not be implemented or could only be implemented under more uncertain conditions, at substantially higher cost, over an appreciably longer period or with considerably less probability of success” (T-112/99, Métropole, para. 111).

This explains why competition experts would find this new class action complaint hard to swallow.

Written by Alfonso Lamadrid

5 June 2018 at 1:49 pm

Posted in Uncategorized

Discretionalists vs Legalists: the true divide in the competition law community?

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rival groups

The big debates about the soul of competition law/antitrust are back. And with these debates, commentators seek to identify what distinguishes the various stances regarding the purpose and intensity of intervention.

Most of these discussions relate to the goals of competition law, that is, about whether the discipline should be about the protection of consumer welfare, the competitive process or any other benchmark. Occasionally, debates revolve around whether or not the convenience of intervention should be measured against a particular goal.

I have written here before that these debates are, in my view, empty calories. Discussing the goals of competition law in the abstract rarely ever yields meaningful conclusions. More importantly, it does not say anything about the operation, in practice, of the legal system. I have always been of the opinion that we would be better off – and much wiser – if we avoided these debates altogether and thought hard about other stuff.

What is more, my impression is that these debates obscure the real divide in our community. Debates about the objectives of competition law reveal that there are two fundamentally different views about the discipline.

I see a clear difference between two broad tribes: the discretionalists and the legalists.

Who are the discretionalists? The discretionalists are those who believe that competition authorities (and courts) should be as unconstrained as possible to attain the result that is considered to be correct in any given case. Getting it right, in other words, matters more than other factors (such as the consistency or predictability of enforcement). For instance, following a precedent is less relevant than reaching the outcome that is deemed appropriate.

Who are the legalists? Legalists downplay the importance of ‘getting it right’ in every given case. What is more, legalists concede that enforcement errors (both type I and type II) cannot be avoided if our discipline is to be considered a legal one. For legalists, it is also important to place constraints on competition authorities and courts. These constraints would come, for instance, from the need to ensure that intervention is consistent and predictable. Thus, precedents should be followed unless there are truly compelling reasons to depart from them.

Is the ‘more economics-based’ approach discretionalist or legalist?

In and of itself, an effects-based approach to enforcement is compatible with both a discretionalist and a legalist view of enforcement.

Some proponents of the effects-based approach are clear discretionalists. For some economists, the only thing that matters at the end of the day is whether intervention will be welfare-increasing or welfare-decreasing. The analysis of this question is to be performed on a case-by-case basis. I would call this sub-group the ‘welfare discretionalists’.

This said, many commentators who have favoured a ‘more economics-based’ approach would also advocate a legalist approach to enforcement. For these, what matters is to design rules and standards so as to get it broadly right in the majority of cases, not increasing welfare in every given instance. Many economists understand the importance of consistency and predictability (in the same way many lawyers value economic analysis). I would call these lawyers and economists the ‘substance legalists’.

How about those who are sceptical about (if not opposed to) economic analysis?

Economic analysis may have become increasingly important in competition law, but there is no shortage of sceptics about its role. Again, these sceptics of economic analysis come in two flavours. Some of them are clear discretionalists, others are legalists.

The ‘public interest discretionalists’ would favour giving public authorities as much discretion as possible, even if it is at the expense of the process and outcomes that mainstream economics would favour. One expects ‘public interest discretionalists’ to criticise the consumer welfare benchmark for being overly narrow, and as such a source of under-enforcement. By the same token, they can be expected to argue for the incorporation of a broader range of economic and non-economic considerations in the analysis.

On the other hand, one can think of the ‘formal legalists’, who are sceptical of the role of economic analysis but place at least as much value on consistency and predictability as the ‘substance legalists’. A ‘formal legalist’ would typically emphasise the importance the administrability of competition law, and would favour ‘bright line’ rules defining clearly what is allowed and what is not.

Teribes

The graph above is my interpretation of the different approaches to the understanding of the role and purpose of competition law.

Where does the EU competition law system stand? As I see it, the EU courts have always placed substance above form (in general, and in the context of EU competition law in particular). In addition, they have always valued consistency, predictability and stability. This would mean that the EU courts embrace a ‘substance legalist’ approach – for good and persuasive reasons.

Traditionally, the Commission favoured a ‘public interest discretionalist’ view of competition law instead. It is not a secret, for instance, that it consistently interpreted Article 101(1) TFEU very broadly. As a result, the Commission conducted the thrust of the analysis under Article 101(3), in the context of which it used to enjoy discretion. This discretion was occasionally exercised to advance non-economic public interest goals.

And it is not a secret that the ‘public interest discretionalist’ approach to EU competition law regularly clashed with the key ‘substance legalist’ principles of the case law. Inevitably, many Commission decisions were annulled as a result.

Following the adoption of Regulation 1/2003 and the ‘modernisation’ process, the Commission’s approach is closer to the logic underpinning the case law – although some may argue that the rise of commitment decisions can lead to ‘welfare discretionalism’.

How about the rest of the world? Well, I would say that much of the excitement around the ‘New Brandeis’ school relates to the fact that its advocates seem to endorse a ‘public interest discretionalist’ approach, which is at odds with how the antitrust system has evolved in the US since the 1970s.

I would welcome your comments on the above. And happy bank holiday to those living in the UK!

 

Written by Pablo Ibanez Colomo

28 May 2018 at 9:09 am

Posted in Uncategorized

College of Europe Alumni in Competition (30 May) (Feat. us) [Update]

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Resultado de imagen para college of europe alumni

College of Europe alumni have set up the “Alumni in Competition” group. Like many platforms, this one seeks to leverage network effects. The idea is to bring together senior experts and young professionals with ties to the CoE to stimulate discussion and “inspire a new generation of competition professionals”.  

As it often happens, the goal is commendable but its implementation may be questionable: the organizers have decided to start off with an inaugural event featuring the two least inspirational speakers they could find: Pablo (as a young somewhat promising academic) and myself (as an established senior statesman, of course).

On the plus side, they have also invited Nick Banasevic (DG Comp) and Aleksandra Boutin (Compass Lexecon) (so there’s an enforcer, ana academic an economist and a lawyer) and they have been so sensible as to organize it at a bar. In fact, my impression is that the group intends to bring together senior experts and young professionals with ties to the CoE essentially to stimulate beer consumption. This is of course why we gladly accepted to take part and be the example that young professionals would be well advised not to follow.

Readers of this blog will not be fooled and know not to expect much from us (except perhaps a round from Pablo if he feels generous), but join us if you can! The event will take place next Wednesday 30 May at 20:00 at Piada Bar (Rue de Trèves 44– right across from the European Parliament).

Please confirm your attendance by registering under https://collegeofeurope.hivebrite.com/networks/events/8445

P.S. If anyone has registration issues, please contact: joanna.hornik@coleurope.eu

Written by Alfonso Lamadrid

23 May 2018 at 11:22 am

Posted in Uncategorized

#ChillinCompetitionFineArt (V)

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Remember when I’ll said I would stop posting memes and find the time for something substantive? Well, this is Round 5… Click here for Round 1 , Round 2 , Round 3 and Round 4.

41.”Commission asks company to be open-minded in compliance negotiations

open.PNG

 

42. “When you learn that your client was first in line for leniency

first.png

 

43. “When you learn that your client was not first in line for leniency

not first

 

44. “When opposing counsel tries to attack my credibility

credib.jpg

 

45. “Cartel

cartel.png

 

46. “Commission punishing a cartellist, with the whistleblower in the background

punish.png

 

47. “Reviewing Excel Sheets Prior to Merger Filing

Reviewing

 

48. “The Chief Alchemist

Alchemist.PNG

 

49. “When you learn what your partner makes

learn

 

50. “Body language while I listen to my opposing counsel in Court“.

body

 

51. “When I am deep in concentration and I don’t want people interrupting in my office

lock.PNG

 

52. “Leniency Statement“.

statement.PNG

 

53. “Co-conspirator takes the stand as your star witness”

conspi

 

54. “When the Judge says come see me in chambers

chambers

 

 

Written by Alfonso Lamadrid

18 May 2018 at 9:31 am

Posted in Uncategorized