Chillin'Competition

Relaxing whilst doing Competition Law is not an Oxymoron

Announcing the Winner and Finalists of Chillin’Competition’s 2nd Rubén Perea Award

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On 1 April 2020 we lost Rubén Perea, a truly extraordinary young man who was about to start a career in competition law. We decided to set up an award to honour his memory, and to recognize the work of other promising competition lawyers/economists under 30. Today we are announcing the winner and runners-up of the 2nd edition of this award.

The winner of the 2nd (2021) edition of the Rubén Perea Award is JÉSSICA NEMETH, for her paper “Blockchain, Behavioral Remedies and Merger Control: How can access remedies do better?”.

Lass Tuesday Jessica and the winner of the first edition (Vladya Reverdin) received their awards from EVP Vestager, who very kindly accepted to give out the awards at her offices:

The jury also selected 4 finalists whose papers will be published in a special JECLAP issue. The finalists are:

-“Firm’s own price elasticity of demand in dominant position analysis” (by Jan Kupcik)

-“Trading Off the Orchard for an Apple: the iOS 14.5 privacy update” (by Alba Ribera)

-“Is ‘‘more’’ better? Broadening the right to sue in competition damages claims in both sides of the Atlantic” (by Grigorios Bacharis)

-“Should the New Competition Tool be put back on the table to remedy algorithmic tacit collusion?” (by Vasileios Tsoukalas)

Congratulations to Jessica, Alba, Jan, Grigorios and Vasileios, and many thanks to my fellow members of the jury, namely Damien Gerard, Lena Hornkohl, David Pérez de Lamo, Michele Piergiovanni and Gianni De Stefano.

We will soon be announcing the 3rd edition of the Rubén Perea Award. Stay tuned!

Written by Alfonso Lamadrid

24 March 2022 at 8:01 pm

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‘Law, Policy, Expertise: Judicial Review in EU Competition Law’ | My CELS seminar at the University of Cambridge

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The lunchtime seminars at Cambridge’s Centre for European Legal Studies have long been an institution in EU law. Having followed the activities of the Centre since my days as a Teaching Assistant in Bruges, I was delighted to accept their invitation. You can access the video of my presentation here, and the PPT I used here.

The topic I chose, judicial review, is dear to my heart (and hopefully relevant for EU lawyers at large). My presentation focused on the complex relationship between law, policy and expertise. In our field, the EU courts are consistently asked to walk the fine line between the exercise of effective judicial review and the respect for the policy choices of the European Commission.

Judicial review is particularly complex considering that issues of law are subject to full review whereas policy-making is, if at all, only controlled for manifest errors of assessment. As I put it during the lecture, the challenge for the EU courts is thus to avoid the cross-contamination of standards of review.

Against this background, I discussed what I called some of the hallmarks of effective judicial review in the case law. They include the following:

  1. Policy must be implemented through clear legal criteria that can be anticipated and subject to judicial review
  2. Policy must be grounded on the expert consensus
  3. Policy-making must be consistent with prior commitments
  4. The relevant economic and legal realities must be considered
  5. Consistency within and across provisions

On the first of these hallmarks, I pointed out that the interpretation of legal provisions must make it possible to distinguish between issues of law and issues of policy. The case law suggests that, where the interpretation would blur the line between both issues, it is unlikely to survive judicial review. CK Telecoms provides a wonderful example in this regard.

The second hallmark is one that I have discussed at length. The interpretation of the law must be grounded on the expert consensus (as opposed to informal, fringe or heterodox views). Ongoing developments raise a couple of fascinating questions:

  • First: can an infringement be established in the absence of consensus? The rules on the allocation of the burden of proof would suggest that consensus is a precondition for a finding of infringement.
  • Second: can the review of administrative action itself rely on informal analysis? The logic of the system would lead to the conclusion that it cannot.

Finally, the renvoi judgment in Intel was very useful to illustrate the third and fourth hallmarks (the fifth was left for a forthcoming paper). That judgment shows that the EU courts expect the Commission to behave in a manner consistent with its policy commitments (for instance, if a policy document declares that it will consider the coverage of a practice, one can reasonably expect it to look at the matter subsequently, unless it explains why it is not appropriate in a particular case).

The fourth hallmark addresses what is arguably the most consistent lesson of the past few years: any legal conclusions must result from a careful analysis of the relevant economic and legal realities. The object and/or effect of a practice cannot be based on hypotheticals or on abstract considerations. By the same token, arguments capable of casting doubts on the premises on which administrative action is based must be taken seriously by an authority if a decision is to survive judicial scrutiny.

It would be wonderful to get your views on the presentation. Have a wonderful weekend!

Written by Pablo Ibanez Colomo

18 March 2022 at 1:19 pm

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GCLC Annual Conference (in Bruges and online), 25-26 March 2022

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The Global Competition Law Centre will be holding its annual conference at the College of Europe in Bruges (as well as online) on 25-26 March 2022. For many years, and leaving Chillin’Competition conferences aside, this has been arguably the most substantive event on EU competition law. This is a conference with no agenda other than contributing to the understanding and the refinement of our discipline. Every year it brings together a balanced mix of competition law experts from public institutions, academia and private practice genuinely interested in discussing substance.

This year’s program is available here.

I will be taking part in panel 6 on the role of the EU Courts, together with General Court President Marc van der Woude, Judge Ingeborg Simonsson and Damien Gerard as Chair. My presentation will be titled “The role of the EU Courts: a view from the Bar“.

You can CLICK HERE for further information and registration. Whoever registers via this link (and lets me know) will get a post-conference beer at my favorite bar in Bruges (here is a view from that, the, Bar).

Written by Alfonso Lamadrid

14 March 2022 at 9:43 am

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Competition Law in Hi-Tech Markets (25 February 2022)

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Chillin'Competition | Relaxing whilst doing Competition Law is not an  Oxymoron | Page 8

The 2022 edition of the annual IEB seminar on “Competition Law in Hi-Tech markets” will take place next Friday 25 February at 16 .00 CET. This will be a hybrid seminar, with most speakers participating in-person at the Instituto de Estudios Bursátiles in Madrid and others joining via Teams. Should you be interested in joining, either in-person or remotely, please contact competencia@ieb.es

The program is the following:

Panel I- Recent competition law developments in hi-tech markets  (16.00-17.30 CET)

-Moderator: Lewis Crofts (MLex) 

-Nicholas Banasevic (Gibson Dunn)

-Milan Kristof (Court of Justice of the European Union)

-Alfonso Lamadrid (Garrigues)

Panel II- From antitrust to ex ante regulation (17.45-19.15 CET) 

-Moderator: Lewis Crofts (MLex)

-Pedro Hinojo (CNMC)

-Kay Jebelli (Computer and Communications Industry Association)

-Natalia Moreno (European University Institute)

-Anne Witt (EDHEC Business School)

Written by Alfonso Lamadrid

17 February 2022 at 8:20 pm

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The (growing) role of the Guidance Paper on exclusionary abuses in the case law: the legal and the non-legal

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EMAs Trial Master File Guidance Is In Effect Does Your TMF Measure Up

The most recent developments on exclusionary abuses suggest that the reports of the demise of the Guidance Paper on exclusionary abuses might have been exaggerated. Just when we thought that it might have fallen out of favour, it has been cited in AG Rantos’s Opinion in Servizio Elettrico and by the General Court in its Intel renvoi.

These references might seem surprising at first glance. After all, the Guidance Paper is not, and was never intended to be, a statement of the law. It is for the Court of Justice, not the Commission, to interpret the scope of Article 102 TFEU. Why, then, the references to the instrument? I can think of a number of legal and non-legal reasons.

The legal: pre-commitment devices and good administration

A point that transpires clearly from a reading of the Intel renvoi is that, while the Guidance is not a statement of the law, it is not devoid of effects, either. We have long known that soft law instruments bind the authority that has issued them. Suffice it to think in this regard of the de minimis Notice (as explained by the Court in Expedia; and by Alfonso in a number of posts, such as this one).

The above is a logical and necessary corollary to the principle of good administration: if a public authority has publicly announced that it will exercise its powers in a certain way, it is reasonable to expect that its subsequent behaviour will follow the position stated in the relevant instrument (irrespective of whether it is a form of ‘soft’ or ‘hard’ law). And it is likely that review judges will assume that an administrative authority will keep its word in its dealings with individuals.

In the specific context of the Guidance, it is reasonable to anticipate that the Commission will follow the approach to the prioritisation of cases that is enshrined in the document. If there was any doubt: this fact does not mean that the Commission can never depart from the Guidance. It simply means that, if it ever prioritises a case in accordance with a different set of criteria, its decision must at least explain the reasons why it is following another approach.

The non-legal: a good, concise document that captures the case law and the expert consensus

The above is certainly relevant, but I do not believe it tells the whole story. Reading the Intel renvoi and AG Rantos’s’ Opinion in Servizio Elettrico suggests that the reasons behing the rising prominence of the Guidance Paper in the case law go beyond the strictly legal.

Arguably, the main reasons are in fact non-legal. I can think of three interrelated ones. The Guidance Paper is, first and foremost, a very good policy document. It is concise, clear and useful for courts. It provides the right amount of detail in an orderly way.

What is more, the Guidance Paper is very much in line with the case law as it has evolved since Post Danmark I. As the Intel saga shows, the criteria to assess foreclosure, as laid down in the relevant judgments, is aligned with para 20 (extent of the dominant position, coverage of the practice, features of the relevant market, evidence of actual effects and possible foreclosure strategy).

As far as price-based conduct is concerned, the approach proposed in paras 23-27 faithfully reflects the consistent case law since Deutsche Telekom and TeliaSonera all the way to Post Danmark II and Intel (not only because of the cost benchmarks proposed, but also in relation to the ‘as efficient competitor’ principle and the potential exceptions to the principle that might arise in a given economic and legal context).

Finally, the Guidance Paper captures the expert consensus. Its primary purpose was in fact to bring the Commission’s practice in line with mainstream economics. And if there is something that my research has taught me, it is that the Court of Justice has consistently crafted the law around the expert consensus. The latter is, in fact, a key constraint on administrative action in the context of Article 102 TFEU. From this perspective, the Guidance could be seen as a digest of mainstream positions and, as such, the sort of document that review courts are likely to cite.

Written by Pablo Ibanez Colomo

9 February 2022 at 11:28 am

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Case T‑286/09 RENV, Intel v Commission, or the sign of an effective competition law system

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Intel® Core™ X-Series Processor Family

When reading the General Court’s renvoi judgment in Intel, I immediately thought that the annulment of the Commission decision is, above all, a reliable sign that the European Union has an effective competition law system. If administrative action were never quashed, it would mean either that the authority is too risk-averse (and therefore that there is insufficient enforcement across the board) or that judicial review is overly deferential (and therefore that there are insufficient checks in the system).

In this particular instance, moreover, it is difficult to see how, in spite of the inevitable footballising takes (‘upset’, ‘big win’, ‘blow’), the outcome represents anything other than a victory for EU competition law and policy.

It is true that the original decision was annulled. It is also true, on the other hand, that the judgment shows (just like the Court’s ruling on appeal) that the law is in line with the Commission’s enforcement priorities as outlined in the Guidance Paper and with the economic consensus (which has long emphasised that anticompetitive effects are not an inevitable outcome of exclusive dealing and conditional rebates). The institutional setup has delivered a legal outcome that comes a step closer to the optimum.

Some may retort that the case has taken too long and may even go as far as to suggest that the length of the proceedings (the original decision was adopted when I was still working on my PhD) is a sign of dysfunction in the system. I struggle to agree with this take.

The pace of law is not, and should never be, the pace of policy. The law, as interpreted by the Court of Justice, evolves slowly and incrementally. Those in favour of moving fast and breaking things may find it frustrating. In my view, however, the cautious process that characterises the EU legal order is a manifestation of the ‘Union of law’ and as such an effective check against arbitrary whims (it is also superior, for many of us, to a system based on administrative discretion).

The renvoi judgment: the implementation of an ‘arrêt cadre

As I have mentioned a number of times before, the Court’s 2017 judgment in Intel is an arrêt cadre: it was confined to providing a set of principles to be fleshed out when engaging with the facts in a particular economic and legal context. Because the judgment was relatively brief, it opened the door to some speculation about its exact meaning. This week’s ruling clarifies a few crucial points:

First (para 124), the ‘by object’ status of exclusive dealing and loyalty rebates is based on a presumption that these practices are capable of restricting competition (that is, of foreclosing equally efficient rivals). This presumption can be rebutted by a dominant undertaking. As a result, the Commission had erred in law by arguing that it was not necessary to evaluate the rebates’ capability to foreclose competition (para 145).

Second (para 165), where the Commission’s case is based on the ‘supposition’ that the behaviour under consideration cannot be explained on grounds other than the restriction of competition, the decision will necessarily be annulled where the dominant undertaking provides evidence casting the facts in a different light. This point is particularly important in relation to ‘by object’ abuses (unsurprisingly, para 165 cites two Article 101 TFEU cases).

Third (paras 119 and 125), the evaluation of the foreclosure effects of the rebate scheme must be based on all five criteria identified by the Court of Justice in para 139 of its judgment, namely: (i) the extent of the dominant position; (ii) the coverage of the practice; (iii) the conditions and arrangements for the award of the rebates; (iv) the length and amount of the latter; (v) and the existence of an exclusionary strategy.

Fourth, the ‘as efficient competitor’ test is not an indispensable ingredient of the analysis (para 126). However, such test will be a relevant factor where the Commission has carried it out as part of its assessment of the foreclosure effects of the rebate scheme.

One is tempted to add that, in practice, the ‘as efficient competitor’ test will feature prominently. As the General Court explains in paras 152-159, this test may show that an equally efficient rival would be able to match the dominant firm’s prices and is therefore likely to be advanced by any dominant firm in a case involving conditional rebates.

The assessment of anticompetitive effects is a meaningful one

A fundamental lesson to draw from this renvoi judgment is that the assessment of anticompetitive effects in EU competition law is a meaningful one. It is not a formality. What is more, merely showing that rivals are placed at a disadvantage is clearly insufficient to establish actual or potential foreclosure to the requisite legal standard.

If you read the various sections devoted to each individual scheme, you will see the detail into which the assessment goes. The additional factors need to be robust enough to cast doubt on the prima facie findings resulting from the ‘as efficient competitor’ test. Similarly, the nature and operation of the rebates will be subject to a detailed analysis.

More generally, the judgment confirms the importance of the coverage of the practice to evaluate its impact. In this regard, it notes that the contested decision failed to determine this factor (para 499), which would place the said decision at odds with the Court’s judgment in Intel and, importantly, with the Commission’s own Guidance Paper.

Final thoughts

It would be very difficult to argue that the many lessons to draw from the renvoi judgment apply exclusively to rebate schemes. Some points are relevant across the board, and certainly beyond price-based conduct. This is obviously true of the factors in light of which actual or potential foreclosure is assessed. For instance, it would be difficult to credibly claim that the coverage and/or the nature of the practices would not play a role non-price-based cases.

The possibility for firms to provide evidence showing that a practice can be explained on grounds other than the restriction of competition is also obviously applicable across the board. This point would be of particular relevance in relation to the so-called ‘naked restraints’ in Intel. These restraints were assumed to have an anticompetitive object. However, they always seemed to me like exclusivity obligations by another name, and thus capable of being rationalised on pro-competitive grounds.

I very much look forward to your comments (as always, nothing to disclose). Have a wonderful weekend!

Written by Pablo Ibanez Colomo

28 January 2022 at 6:04 pm

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Recent Developments in EU Competition Law (IEB Webinar, 4 February 2022)

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Every year Fernando Castillo de la Torre (Director of the Competition team at the Commission’s Legal Service) and Eric Gippini-Fournier (recently appointed as Competition Hearing Officer) coordinate a high-level, one-afternoon seminar in the context of the IEB competition law course. They always make sure that this is one of the top-quality seminars in our field.

Unfortunately for those of us who were planning to travel to Madrid, we have now decided to move the discussion online. This should nonetheless be good news for those of you interested in joining remotely.

For more information and registrations, please write to competencia@ieb.es

The program is the following:

16:00 – 17:45: The review of the horizontal guidelines and block exemptions, and “sustainability agreements”

Georgiana Capraru Ianus. DG Competition, European Commission.

Belén Irissarry. Clifford Chance.

Giorgio Monti. Tilburg University.

Ekaterina Rousseva. Legal Service, European Commission.

Chair: Fernando Castillo de la Torre. Legal Service, European Commission.

18:00 – 20:00: The meaning and relevance of competition “on the merits”

Helmut Brokelmann. MLAB Abogados.

María Pilar Canedo. Comisión Nacional de los Mercados y la Competencia and Deusto University.

Damien Geradin. Geradin Partners.

Viktoria Robertson. University of Economics and Business, Vienna.

Chair: Eric Gippini-Fournier. Competition Hearing Officer, European Commission.

Written by areeader

24 January 2022 at 12:48 pm

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Antitrust Music (a playlist)

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In a very questionable use of his free time, Nuno Carrolo dos Santos (Vieira de Almeida) has spent years compiling a themed Spotify playlist of 101 songs that might be appealing (or maybe not) to competition experts.

You can check out this work of a lifetime here: Spotify – Antitrust Music

The playlist includes (real) songs like “Oligopsony Sucks”, “Cartel Swag”, “Short Form and/or long Form”, “Monopolistic Industry”, “Deadline and Commitments”, “State aid Blues” and “Predatory Impalement”.

Nuno has made the list collaborative so that other people might be able to add new songs. The geekiness bar is high, but no such bar is too high for the readers of this blog.

All featured musicians should be honoured and humbled to have made it to such a prestigious playlist. Given the Bob Dylan Nobel prize precedent, however, they will surely be left wondering why there are no writing award categories for the best lyrics in a sort-of-antitrust-themed song (subdivided by area of competition law and type of music, of course).

Written by areeader

20 January 2022 at 10:48 am

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EU Competition Procedure (4th edition)

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Oxford University Press has just published the 4th edition of the procedural bible in EU competition law. EU Competition Procedure (edited by Luis Ortiz Blanco) is, as you know, an essential facility for anyone active in our field.

My very first task as an intern, in my first contact with competition law some 17 years ago, was to do research for the 2nd edition of this book. Since then I have been fortunate to join a distinguished team of authors that, in this edition, includes Corneliu Hödlmayr (European Commission), Johannes Holzwarth (European Commission), Konstantin Jörgens (Garrigues), Manuel Kellerbauer (European Commission), Luis Ortiz Blanco (Garrigues), Ralf Sauer (European Commission), Ailsa Sinclair (European Commission), Maria Luisa Tierno Centella (CNMC), Marcos Araujo Boyd, Nicolas von Lingen (European Commission), José Luis Buendía (Garrigues), Jean-Paul Keppenne (European Commission), Carlos Urraca Caviedes (European Commission), Kieron Beal, (Blackstone Chambers) and Gordon Blanke (Blanke Arbitration).

Readers of Chillin’Competition interested in buying the book will receive a 30% discount, courtesy of OUP. The discount will apply automatically if you click on this link.

Written by Alfonso Lamadrid

19 January 2022 at 11:20 am

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Agree or disagree, abuses ‘by object’ are a thing unless the case law changes

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Groundhog Day movie review & film summary (1993) | Roger Ebert

The story of competition law is, above all, a story of eternal returns. It is a story of well-established doctrines that are progressively eroded until it becomes clear they were right all along and repentant authorities return to them. A story of disdain for economic analysis that is followed by enthusiastic embrace and subsequent abandon in favour of other approaches.

Against this background, I thought it would be fitting to start the blogging year exactly where I left it at the beginning of 2021 (see here). In that post, I explained that the case law distinguishes between abuses ‘by object’ and ‘by effect’. In other words: some behaviour is deemed abusive without it being necessary for the authority or claimant to show that it has an actual or potential impact on competition.

Almost exactly a year later, in this Groundhog Day of sorts, we have gone full circle. The issue has come to the fore again and I find myself writing about it. The Google Shopping judgment is part of the reason why. In a particularly interesting (but wholly inconsequential for the outcome of the case itself), the General Court touches upon the question (see paras 435-437 of the judgment).

Advocate General Rantos’s Opinion in Servizio Elettrico also addresses the point, and goes as far as to claim, uncontroversially, that there is no such thing as a per se abuse in the EU legal order (see para 55 of the Opinion).

So, coming back to the question: are abuses ‘by object’ a thing? There should be no doubt about it, in my view. This said, it makes sense that I spend some time on legal terminology to avoid misunderstandings.

A practice is said to be prohibited ‘by object’ (whether under Article 101 or 102 TFEU) where two conditions are met. First, the breach of competition law can be established without it being necessary to demonstrate the actual or potential anticompetitive effects in the relevant economic and legal context. Second, the behaviour in question is prohibited because its object, or its ‘precise purpose’, is anticompetitive.

Under that definition, it seems clear that some conduct amounts to a ‘by object’ infringement under Article 102 TFEU (if there was any doubt: other potentially abusive practices are firmly ‘by effect’). The best example of ‘by object’ behaviour, and the one I often use, is that of predatory pricing within the meaning of AKZO.

If prices fall below average variable costs, the behaviour is deemed abusive. There would be no requirement for the authority or claimant to demonstrate the anticompetitive effects of such conduct. In fact, the Court expressly rejected, both in Tetra Pak II and Wanadoo, the need to establish the dominant firm’s ability to recoup its losses (which amounts, in essence, to establishing its likely impact on consumer welfare).

What is more, pricing below average variable costs is abusive because it can be safely presumed to have an anticompetitive object. As the Court puts it, such conduct makes no sense other than as a means for the dominant firm of ‘eliminating competitors so as to enable it subsequently to raise its prices by taking advantage of its monopolistic position‘.

AKZO is just one of several examples (for more, see here). If a practice is restrictive of competition by object under Article 101 TFEU, it is also deemed abusive by its very nature in the context of Article 102 TFEU. This point was explicitly addressed in Sot Lelos in relation to conduct aimed at partitioning the internal market (paras 65-66 of that judgment).

If, in light of these examples, it seems difficult to dispute that abuses ‘by object’ are a thing, why is the issue still controversial? I can think of two main reasons:

  • The fact that a finding of abuse presupposes anticompetitive effects.
  • The confusion between per se and by object infringements

Anticompetitive effects and allocation of the burden of proof

A finding of abuse presupposes that the practice is liable to produce anticompetitive effects (as the Court held in Generics). This (well-established) point of law is probably the most important source of misunderstandings.

Contrary to what is sometimes suggested, the above principle does not say anything about whether there is such thing as an abuse ‘by object’. It simply states that, for a practice to be prohibited under Articles 101 and 102 TFEU, it must be capable of producing anticompetitive effects. If it is not liable to producing such effects, it does not amount to an infringement.

The principle applies irrespective of whether we deal with ‘by object’ or ‘by effect’ conduct. In T-Mobile, the Court clarified that, for an agreement to restrict competition by object, it must be capable of having anticompetitive effects. In Murphy, we learnt that, where an agreement of that nature is not liable to produce such effects, it falls outside the scope of Article 101(1) TFEU.

The difference between ‘by object’ and ‘by effect’ conduct does not hinge on whether the practice can have anticompetitive effects. Such effects are a precondition for intervention. The difference between the two categories is another one. It has to do with the fact that anticompetitive effects are presumed in the case of ‘by object’ conduct and therefore need not be proved by the authority or claimant.

Since it is a presumption, firms can produce evidence showing that, in a specific economic and legal context, the behaviour is incapable of having anticompetitive effects. This is true of ‘by object’ conduct under both Articles 101 and 102 TFEU.

As far as Article 101 TFEU is concerned, the point was made explicit in Murphy, and the case law provides several examples (think of E.On Ruhrgas). In the context of Article 102, the clarification in Intel addressed this very question.

The confusion between ‘by object’ and per se

Another source of misunderstandings comes from the tendency to use per se and ‘by object’ as synonymous, or to believe they work in the same way.

It has been said many times (this article by Eric Gippini Fournier does so particularly eloquently) that per se infringements do not exist in EU competition law and that per se is a category that does not find easy accommodation in that legal order.

One key difference between per se and ‘by object’ (that is, the possibility to provide arguments showing that the practice is incapable of having anticompetitive effects in the specific economic and legal context) has been identified above. A second key difference between these two concepts is that it is always possible, both under Articles 101 and 102 TFEU, to provide arguments showing that the behaviour is on the whole pro-competitive.

If these differences are ignored, and ‘by object’ is assumed to mean ‘per se’, it is easy to see how one can be tempted to claim that there is no such thing as an abuse ‘by object’. Such positions, in any event, have little to do with the reality of the case law and the actual operation of the category.

Written by Pablo Ibanez Colomo

12 January 2022 at 11:47 am

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