Document Type

Response or Comment

Publication Date



These comments (originally submitted to the DOJ and FTC in November 2009) make a number of comments relevant to revising the Merger Guidelines. The comments focus on the use of the GUPPI (gross upward pricing pressure index) in unilateral effects analysis. They also comment on the deterrence and incipiency standard, exclusionary effects of horizontal mergers and market definition when there are multi-product firms or pre-merger coordination, among other issues.

Publication Citation

Steven C. Salop and Serge Moresi, Updating the Merger Guidelines: Comments (checked Mar. 30, 2016, 9:30 AM),