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This book is an attempt to give an account of competition law and policy in the United States and the European Union, and to evaluate it in light of economic analysis, where necessary. The systems of competition in these jurisdictions now highly influence each other and those of several other countries in determining competition issues.
The regulators in both jurisdictions consistently work together, particularly in rooting out international cartels and in the preliminary assessments of large notified international mergers – where information is shared and discussions can entail deliberations over the appropriate economic theories. Interestingly, both are currently engaging in modernization reviews of their competition provisions.
Consequently, a comparative analysis of the current state of the law is a worthy academic expedition. Such a task is, however, laden with a plethora of difficulties not limited to the differences in governmental and institutional structures, but also to the objectives of the law.