Competition Law Bulletin - zhonglun.com · Competition Law Bulletin October 2015 | Issue 11 ......
Transcript of Competition Law Bulletin - zhonglun.com · Competition Law Bulletin October 2015 | Issue 11 ......
Competition Law Bulletin
October 2015 | Issue 11
Prepared by
Zhong Lun Antitrust Practice Group
Advisory Board
WU Peng, JIANG Xiansheng, XUE Yi, XU Yunhe, YU Xingang
CEN Zhaoqi, ZHANG Baisha, XIONG Rong
Editorial Staff
CAO Meijuan, ZHENG Haiming, QIN Ying, CHEN Zhao
GU Tian, HOU Huiying, HONG Lushen, XU Jie
Contact us
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Beijing 100022, P.R. China
Tel: + (8610) 59572288
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E-mail: [email protected]
Website: http://www.zhonglun.com
October 2015 Issue 11
Content
Enforcement
China
MOFCOM approves share purchase
application in Zhujiang Brewery by AB
InBev MOFCOM imposes penalty on Fujian
Electronics for failure to notify its
acquisition of CHINO-E MOFCOM imposes penalty on
Shanghai Fosun Pharmaceutical
Development for failure to notify its
acquisition of Suzhou Erye MOFCOM imposes penalties on CSR
Nanjing Puzhen and Bombardier Sweden
for failure to notify JV MOFCOM imposes penalty on Bestv
New Media and Microsoft for failure to
notify JV MOFCOM unconditionally clears 79
concentrations of undertakings in the third
quarter of 2015 MOFCOM conditionally clears
Nokia‟s acquisition of Alcatel-Lucent MOFCOM partially removes
restrictive conditions on Seagate‟s
acquisition of the hard disk drive business of
Samsung Electronics MOFCOM partially removes
restrictive conditions on Western Digital‟s
acquisition of HGST NDRC admonishes Anhui Provincial
Government to correct conducts of Health
and Family Planning Commission of
Bengbu city Guangdong DRC fines
Dongfeng-Nissan RMB 123.3 m for price
monopoly Inner Mongolia AIC suspends
investigation against Inner Mongolia Branch
of China Mobile for abuse of market
dominance NDRC holds anti-price monopoly
seminar with antitrust experts Three Antitrust Enforcement
Authorities meet with representatives of US
businesses The 10th EU-China competition policy
seminar held in Beijing
United States
DOJ requires GE to divest aftermarket
business in order to complete Alstom
purchase DOJ closes its investigation on
Expedia's acquisition of Orbitz KYB agrees to plead guilty and pay
$62 million criminal fine for fixing price of
shock absorbers DOJ imposes penalty on Len Blavatnik
for violating antitrust premerger notification
requirements FTC requires Pfizer to sell rights to
four products as a condition of acquiring
Hospira FTC approves ZF Friedrichshafen AG
and TRW Automotive Holdings Corp. to
divest TRW‟s linkage and suspension
business in North America and Europe FTC requires divestitures prior to
merger of orthopedic device companies FTC approves fiscal year 2014 HSR
premerger notification report
European Union
EC conditionally approves acquisition
of Hospira by Pfizer EC welcomes General Court rulings
upholding TV and computer monitor tubes
cartel decision EC opens formal investigation into
International Skating Union's eligibility
rules EC opens in-depth investigation into
proposed acquisition of BASE Belgium by
Liberty Global German Federal Cartel Office fines
providers of container transport services
4.56 million euros in the area of the German
seaports UK Competition and Markets
Authority closes hotel online booking
investigation France Competition Authority
investigates Google case
Australia
ACCC issues opinions on competition
law enforcement in the broad industrial
relations area Federal Court fines Omniblend
$17,500 for resale price maintenance Federal Court fines Visa $18 million
for anti-competitive conduct
Korea
KFTC fines Samyang Foods and its
affiliate firm for inter-affiliate trading
activities KFTC fines Daelim industrial and
other three construction firms for bid rigging
Japan
JFTC rejected appeals by Air Liquide
Japan related to air separation gas price
October 2015 Issue 11
cartels
Brazil
CADE signs agreement with
construction company Camargo Corrêa in
the investigation of Petrobras‟ bid rigging
cartel CADE rejects the acquisition of
Condor by Tigre
Russia
Google abuses dominate position on
the market of pre-installed application
stores
India
CCI fines Kerala movie association
and two of its office-holders for alleged
anticompetitive conducts
South Africa
SACC recommends prohibition of
MTN and Telkom RAN sharing and
bi-literal roaming merger
Legislation
China
China (Tianjin) Pilot Free Trade Zone
issues a set of measures on antitrust
enforcement
United State
DOJ and FTC sign antitrust
memorandum of understanding with KFTC
European Union
UK CMA publishes guidance on new
compensation schemes power in
competition cases
Brazil
CADE presents proposal of guidelines
on Competition Compliance Programs
Zhong Lun in the News
China Cross-Border Investment Legal
Summit held by Zhong Lun –2015
October 2015 Issue 11
1 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
Enforcement
China
MOFCOM approves share purchase application in Zhujiang Brewery by AB InBev
On August 25th
, 2015, Ministry of Commerce of the People‟s Republic of China (MOFCOM)
approved Brussels-based brewer Anheuser-Busch InBev‟s (AB InBev) application for purchase
of shares in Zhujiang Brewery. The transaction enabled Interbrew Investment International to
increase its shares in Shenzhen-listed peer Guangzhou Zhujiang Brewery from 25.62% to
29.99%.
On November 18th
, 2008, MOFCOM conditionally approved acquisition of Anheuser-Busch
Companies Inc. (Anheuser-Busch) by Inbev N.V/S.A, and one of the conditions was that AB
InBev should not increase its then existing shares of Zhujiang Brewery. If share increase is
required, AB InBev should submit an application to MOFCOM before completion. On July 29th
,
2015, AB InBev notified the transaction to MOFCOM. Upon investigation, MOFCOM approved
the transaction because the increased shares were relatively small and wouldn‟t result in material
change in control over Zhujiang Brewery. >>Read More Back
---------------------------------
MOFCOM imposes penalty on Fujian Electronics for failure to notify its acquisition of
CHINO-E
On September 16th
, 2015, MOFCOM announced the administrative sanction decision on Fujian
Electronics Information (Group) (Fujian Electronics) for failure to notify a 35% stake acquisition
of Shenzhen CHINO-E Communication (CHINO-E). MOFCOM imposed a fine of 150,000
RMB on Fujian Electronics.
On August 12th
, 2014, Fujian Electronics notified a 100% equity acquisition of CHINO-E to
MOFCOM. However, during the public notice period, a third party reported that Fujian
Electronics had already acquired control of CHINO-E before the notification. On December 15th
,
2014, MOFCOM docketed the case on Fujian Electronics for failure to notify and conducted an
antitrust investigation. Upon investigation, MOFCOM found that Fujian Electronics signed an
equity transfer agreement with several shareholders of CHINO-E and acquired 35% equity of
CHINO-E for 280 million RMB. The transaction was not notified by Fujian Electronics before
completion.
Upon investigation, MOFCOM concluded that Fujian Electronics violated Article 21 of the
Anti-monopoly Law, which provides that where a proposed concentration of undertakings meets
the notification thresholds prescribed by the State Council, the participating undertaking should
make a notification filing with the competent State Council Anti-monopoly Enforcement
Authority in advance, and may not consummate the concentration without such filing. >>Read
More Back
---------------------------------
MOFCOM imposes penalty on Shanghai Fosun Pharmaceutical Development for failure to
notify its acquisition of Suzhou Erye
On September 16th
, 2015, MOFCOM announced the administrative sanction decision on
Shanghai Fosun Pharmaceutical Development Co Ltd., (Shanghai Fosun Pharmaceutical
Development) for failure to notify a 35% equity acquisition of Suzhou Erye Pharmaceutical
(Suzhou Erye). MOFCOM imposed a fine of 200,000 RMB on Shanghai Fosun Pharmaceutical
Development.
October 2015 Issue 11
2 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
In December 2014, Shanghai Fosun Pharmaceutical (Group) Co Ltd., (Fosun Pharmaceutical)
submitted a consultation application to MOFCOM on a 65% equity acquisition of Suzhou Erye.
Fosun Pharmaceutical planned to acquire 35% and 30% equity of Suzhou Erye through
Shanghai Fosun Pharmaceutical Development and an overseas subsidiary respectively. At the
consultation meeting, MOFCOM found that Fosun Pharmaceutical had completed the
acquisition of the 35% equity in Suzhou Erye without notification. On March 16th
, 2015,
MOFCOM docketed the case on Shanghai Fosun Pharmaceutical Development for failure to
notify and conducted an antitrust investigation.
Upon investigation, MOFCOM concluded that Shanghai Fosun Pharmaceutical Development
violated Article 21 of the Anti-monopoly Law, which requires a notification filing of such
concentration before its consummation. >>Read More Back
---------------------------------
MOFCOM imposes penalties on CSR Nanjing Puzhen and Bombardier Sweden for failure
to notify JV
On September 16th
, 2015, MOFCOM announced the administrative sanction decision on CSR
Nanjing Puzhen and Bombardier Sweden for their failure to notify their proposed joint venture.
MOFCOM imposed a fine of 150,000 RMB on CSR Nanjing Puzhen and Bombardier Sweden
respectively.
On November 3rd
, 2014, CSR Nanjing Puzhen and Bombardier Sweden signed an agreement to
establish a joint venture (JV) for manufacturing monorail and automated people mover cars. The
JV obtained a business license on November 11th
, 2014. On December 29th
, 2014, the two parties
submitted an application of notification to correct their non-compliant conduct. On March 3rd
,
2015, MOFCOM docketed the case on CSR Nanjing Puzhen and Bombardier Sweden for failure
to notify and conducted an antitrust investigation.
Upon investigation, MOFCOM concluded that CSR Nanjing Puzhen and Bombardier Sweden
violated Article 21 of the Anti-monopoly Law, which requires a notification filing of such
concentration before its consummation. >>Read More Back
---------------------------------
MOFCOM imposes penalty on Bestv New Media and Microsoft for failure to notify JV
On September 16th
, 2015, MOFCOM announced the administrative sanction decision on Bestv
New Media and Microsoft for their failure to notify their proposed joint venture. MOFCOM
imposed a fine of 200,000 RMB on Bestv New Media and Microsoft respectively.
In June 2014, MOFCOM received a complaint against Bestv New Media and Microsoft for
suspected failure to notify. On January 6th
, 2015, MOFCOM docketed the case on Bestv New
Media and Microsoft for failure to notify and conducted an antitrust investigation. Upon
investigation, it was found that Bestv New Media and Microsoft signed an agreement to
establish a joint venture (JV) in the Shanghai Pilot Free Trade Zone on September 17th
, 2013.
The JV was established on October 1st, 2013, and engaged in design, development,
manufacturing and sales of game entertainment application software.
Upon investigation, MOFCOM concluded that Bestv New Media and Microsoft violated
Article 21 of the Anti-monopoly Law, which requires a notification filing of such concentration
before its consummation. >>Read More Back
---------------------------------
October 2015 Issue 11
3 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
MOFCOM unconditionally clears 79 concentrations of undertakings in the third quarter of
2015
On October 9th
, 2015, MOFCOM issued a case review list setting out the 79 unconditionally
cleared concentrations of undertakings in the third quarter of 2015. >>Read More Back
--------------------------------
MOFCOM conditionally clears Nokia’s acquisition of Alcatel-Lucent
On October 19th
, 2015, MOFCOM approved Nokia‟s acquisition of 100% equity of
Alcatel-Lucent with restrictive conditions. Nokia‟s commitments were as follows: (1) on a
reciprocal basis, it shall not enforce SEPs-based injunctions to prevent implementation of
standard with FRAND (fair, reasonable and non-discriminatory) commitment, etc; (2) where
Nokia transfers its SEPs to a third party in the future, Nokia shall notify its current Chinese
licensees and any Chinese company which is actively engaging in licensing negotiation with it
of the transfer of such SEPs; (3) When Nokia transfers its SEPs to a new holder in the future,
Nokia shall only proceed with such transfer when the new holder agrees to be bound by the
FRAND obligations Nokia committed with respect to the those SEPs to the standard-setting
organization (SSOs), so that the FRAND obligation will be passed on to the new holder at same
time.
MOFCOM analyzed the horizontal overlaps of the two parties‟ businesses in the wireless
communication network equipment market and related services markets, including radio access
network, core network systems and network infrastructure services market. In addition,
MOFCOM also reviewed the competition concerns which may be raised by Nokia‟s holding of
communication technology SEPs after the concentration. Upon investigation, MOFCOM
concluded that the proposed acquisition of a 100% equity in Alcatel-Lucent by Nokia would
have eliminative or restrictive competitive effect on the wireless communication SEP licensing
market. Based on Nokia‟s commitments to MOFCOM, MOFCOM decided to conditionally
clear the concentration.
Nokia is a multinational communication and information technology company with three major
business units: Nokia Network, HERE map and Nokia Technology. The business units of
Alcatel-Lucent include access networks and core networks. >>Read More Back
--------------------------------
MOFCOM partially removes restrictive conditions on Seagate’s acquisition of the hard
disk drive business of Samsung Electronics
On October 22nd
, 2015, MOFCOM agreed to modify the restrictive conditions imposed on
Seagate Technology‟s acquisition of the hard disk drive business of Samsung Electronics.
Seagate should implement the following obligations: (1) after concentration, Seagate should
neither substantively change its existing business model, no force or covertly force their
customers to exclusively purchase hard-disk products from Seagate; (2) Seagate should not
force TDK China to supply magnetic heads exclusively to Seagate (or other Seagate-controlled
companies) or limit the number of magnetic heads TDK China would supply to other hard drive
disk manufacturers; (3) Seagate should continue to invest in innovation in a manner that was
consistent with its practice in recent years, to ensure that they will bring more innovative
products and solutions to customers.
In May 2013, Seagate submitted an application with MOFCOM for removing the first and
second conditions in the public announcement [2011] No. 90. Through assessment, MOFCOM
concluded that Seagate‟s application could not have adverse effect on the market competition,
and found the commitment could help reduce restrictive competition impacts. Therefore,
MOFCOM agreed to Seagate‟s application and required it to continue to fulfill all other
October 2015 Issue 11
4 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
remaining conditions. >>Read More Back
---------------------------------
MOFCOM partially removes restrictive conditions on Western Digital’s acquisition of
HGST
On October 19th
, 2015, MOFCOM agreed to modify the restrictive conditions imposed on
Western Digital‟s acquisition of Hitachi Global Storage Technologies (HGST). Western Digital
should implement the following obligations: (1) Western Digital and HGST should maintain
independence of sales and brands; (2) after concentration, Western Digital should neither
substantively change its existing business model, no force or covertly force their customers to
exclusively purchase hard-disk products from Western Digital; (3) Western Digital should
continue to invest in innovation in a manner that is consistent with its practice in recent years,
to ensure that they will bring more innovative products and solutions to customers.
In March 2014, Western Digital submitted an application to MOFCOM for removing the first
and second conditions in the public announcement [2012] No. 9. At that time, MOFCOM was
investigating the suspected violations of two restrictive conditions by Western Digital, so the
application was not docketed. On January 30th
, 2015, MOFCOM completed the investigations.
Therefore, MOFCOM accepted the application officially and started related assessment work.
Through assessment, MOFCOM concluded the final solutions submitted by Western Digital
were sufficient to reduce the adverse impact. >>Read More Back
---------------------------------
NDRC admonishes Anhui Provincial Government to correct conducts of Health and
Family Planning Commission of Bengbu city
On August 26th
, 2015, National Development and Reform Commission (NDRC) announced an
anti-administrative monopoly advisory opinion to Anhui Provincial Government, suggesting
rectifications of abuse of administrative power involving drug procurement by Health and
Family Planning Commission of Bengbu City (Bengbu HFPC).
NDRC investigated the case against Bengbu HFPC based on complaints it received. Upon
investigation, it was found that Bengbu HFPC issued three official notices to organize drug
procurement tendering in April and May this year. It designated certain drug makers for 30 types
of medicines, excluding and restricting other drug companies from competition. In addition, it
imposed discriminatory annual sales requirements and limited the number of bidders against
non-local bidding companies in violation of Articles 32, 34 and 37 of the Anti-monopoly
Law. >>Read More Back
---------------------------------
Guangdong DRC fines Dongfeng-Nissan RMB 123.3 m for price monopoly
On September 10th
, 2015, Guangzhou Development and Reform Commission (GZDRC)
imposed a RMB 123.3 million fine (3% of the revenue of the preceding year in the relevant
markets) on Dongfeng-Nissan for resale price maintenance, and another RMB 19.12 million (2%
and 4% of the revenue of the preceding year in the relevant markets) on 17 Guangzhou-based
dealers for price fixing.
In August 2014, GZDRC started an antitrust investigation on Dongfeng-Nissan. Upon
investigation, GZDRC found that Dongfeng-Nissan severely restricted Guangzhou-based dealers‟
online, phone, and in-store price quotes and final transaction prices between 2012 and July 2014.
In addition, it penalized those Guangzhou-based dealers that had violated its price control
measures in 2013. GZDRC also found between April 2014 and July 2014, Guangzhou-based
October 2015 Issue 11
5 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
dealers held several meetings to reach and implement price monopoly agreements for certain car
models, in violation of Articles 13 and 14 of the Anti-monopoly Law. >>Read More Back
---------------------------------
Inner Mongolia AIC suspends investigation against Inner Mongolia Branch of China
Mobile for abuse of market dominance
On September 17th
, 2015, State Administration for Industry and Commerce (SAIC) published on
its official website that the Administration for Industry and Commerce of Inner Mongolia
Autonomous Region (Inner Mongolia AIC) had suspended the antitrust investigation against
Inner Mongolia Branch of China Mobile Communications Corporation (Inner Mongolia Branch
of China Mobile).
On April 21st, 2015, as authorized by SAIC, Inner Mongolia AIC docketed the case and
conducted antitrust investigation against Inner Mongolia Branch of China Mobile. Upon
investigation, Inner Mongolia AIC found that Inner Mongolia Branch of China Mobile had more
than 15 million customers, accounting for 64.08% of all cellphone users in the Inner Mongolia
Autonomous Region. When Inner Mongolia Branch of China Mobile provided mobile internet
services, customer‟s unused data allowance would expire at the end of every month.
Inner Mongolia Branch of China Mobile admitted its policy of monthly automatic expiration of
data plan, and recognized that its behavior had anti-competitive effects. On May 12th
, 2015, Inner
Mongolia Branch of China Mobile submitted an application to suspend the investigation, and
committed to rectify its behaviors in order to reduce the adverse impacts. >>Read More Back
---------------------------------
NDRC holds anti-price monopoly seminar with antitrust experts
On September 9th
, 2015, NDRC held anti-price monopoly seminar with antitrust experts, and
received suggestions and advice from the Expert Advisory Panel of the National
Anti-Monopoly Commission. This seminar was hosted by Zhang Handong, the director of Price
Supervision Bureau of NDRC. The officials from NDRC briefed the attendees on recent work
progress, including antitrust legislation, law enforcement, competition policy and international
cooperation and communication, etc.
At the meeting, the experts gave advice on anti-price monopoly work, including:
Paying attention to competition policy to promote economic development;
Strengthening antitrust cases information disclosure and publicity;
Increasing investigation on administrative monopoly cases;
Making scientifically sound antitrust guidance;
Increasing antitrust training for businesses and international cooperation;
Increasing communication between Antitrust Enforcement Authorities and the Expert
Advisory Panel. >>Read More Back
---------------------------------
Three Antitrust Enforcement Authorities meet with representatives of US businesses
On September 10th
, 2015, MOFCOM, NDRC and SAIC met with representatives of US
businesses to discuss antitrust issues.
At the meeting, three Antitrust Enforcement Authorities respectively introduced antitrust case
review work for the period between the implementation of the Anti-monopoly Law in 2008 and
the first half of 2015. MOFCOM had settled 1,143 cases, including 1,117 unconditionally
October 2015 Issue 11
6 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
approved cases, 24 conditionally approved cases and 2 rejected cases. SAIC and provincial
industry and commerce regulators had investigated and sanctioned 54 antitrust cases, including
31 monopoly agreements and 23 abuses of market dominance, of which 23 had been settled.
NDRC and local price regulators had investigated and issued enforcement decisions in 55 cases,
including 16 by NDRC and 39 by local price-related antitrust regulators.
In addition, the meeting also discussed a variety of issues, such as whether simple review
procedures should be applied in merger reviews concerning sensitive industries, how to deal with
public interest in antitrust reviews, how to determine appropriate pricing in the course of price
supervision, auto antitrust guidelines and antitrust guidelines concerning intellectual property
rights. >>Read More Back
---------------------------------
The 10th EU-China competition policy seminar held in Beijing
On October 15th
, 2015, China‟s Antitrust Enforcement Authorities and EC‟s DG Competition
jointly held the 10th EU-China competition policy seminar in Beijing. Anti-monopoly Bureau of
MOFCOM and EC‟s DG Competition signed a merger review cooperation agreement, setting
out the content of cooperation, the scope of cooperation and the exchange of information, and
information confidentiality, etc. >>Read More Back
---------------------------------
United States
DOJ requires GE to divest aftermarket business in order to complete Alstom purchase
On September 8th
, 2015, Department of Justice (DOJ) announced that it would require General
Electric Company (GE) to divest Alstom S.A.‟s subsidiary Power Systems Mfg. LLC (PSM) in
order for GE to proceed with its proposed approximately $13.8 billion acquisition of Alstom.
DOJ filed a civil antitrust lawsuit in the U.S. District Court of the District of Columbia to block
the proposed transaction. At the same time, DOJ filed a proposed settlement that, if approved by
the court, would resolve the department‟s competitive concerns alleged in the lawsuit. >>Read
More Back
---------------------------------
DOJ closes its investigation on Expedia's acquisition of Orbitz
On September 16th
, 2015, Assistant Attorney General Bill Baer of DOJ Antitrust Division
released the following statement on the division‟s decision to close its investigation into
Expedia‟s $1.3 billion acquisition of Orbitz:
“We know online travel booking is important to U.S. consumers and to the airlines, car rental
companies and hotels that serve those consumers. Over the course of a six-month investigation,
lawyers and economists from the Antitrust Division reviewed tens of thousands of business
documents, analyzed transactional data from the merging companies and from other industry
players and interviewed over 60 industry participants of various types and sizes”.
“The Antitrust Division investigated the concerns that have been expressed about this transaction.
We took those concerns seriously and factored into our analysis all of the information provided
by third parties. At the end of this process, however, we concluded that the acquisition is unlikely
to harm competition and consumers”. >>Read More Back
---------------------------------
October 2015 Issue 11
7 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
KYB agrees to plead guilty and pay $62 million criminal fine for fixing price of shock
absorbers
On September 16th
, 2015, Kayaba Industry Co. Ltd., dba KYB Corporation (KYB) agreed to
plead guilty and to pay a $62 million criminal fine for its role in a conspiracy to fix the price of
shock absorbers installed in cars and motorcycles sold to U.S. consumers.
According to charges, KYB conspired from the mid-1990s until 2012 to fix the prices of shock
absorbers sold to Fuji Heavy Industries Ltd. (manufacturer of Subaru vehicles), Honda Motor Co.
Ltd., Kawasaki Heavy Industries Ltd., Nissan Motor Company Ltd., Suzuki Motor Corporation
and Toyota Motor Company, including their subsidiaries in the United States. >>Read More
Back
---------------------------------
DOJ imposes penalty on Len Blavatnik for violating antitrust premerger notification
requirements
On October 6th
, 2015, DOJ filed a civil antitrust lawsuit in U.S. District Court in Washington,
D.C., against Len Blavatnik for violating the premerger notification and waiting period
requirements of the Hart-Scott-Rodino (HSR) Act of 1976 when he acquired voting securities of
TangoMe Inc. in August 2014. At the same time, DOJ filed a proposed settlement, subject to
approval by the court, under which Blavatnik had agreed to pay a $656,000 civil penalty to
resolve the lawsuit.
The HSR Act of 1976, an amendment to the Clayton Act, imposes notification and waiting period
requirements for transactions meeting certain size thresholds so that they can undergo premerger
antitrust review. Federal courts can assess civil penalties for premerger notification violations
under the HSR Act in lawsuits brought by DOJ. For a party in violation of the HSR Act, the
maximum civil penalty is $16,000 per day. >>Read More Back
---------------------------------
FTC requires Pfizer to sell rights to four products as a condition of acquiring Hospira
On August 24th
, 2015, Pfizer Inc. agreed to sell the rights and assets related to four
pharmaceutical products in order to settle FTC charges that its proposed $16 billion acquisition
of Hospira, Inc. was anticompetitive.
Pfizer is one of the world‟s largest drug companies and principally competes with Hospira in
markets for certain sterile injectable pharmaceutical products. The FTC settlement order
preserves competition by requiring the companies to divest four products to the U.S.-based
generic pharmaceutical company Alvogen Group Inc. >>Read More Back
---------------------------------
FTC approves ZF Friedrichshafen AG and TRW Automotive Holdings Corp. to divest
TRW’s linkage and suspension business in North America and Europe
On August 28th
, 2015, FTC approved an application from ZF Friedrichshafen AG and TRW
Automotive Holdings Corp. to sell TRW‟s North American and European linkage and suspension
business for heavy and light vehicles to the Tokyo-based global machine component
manufacturer THK Co., Ltd.
The divestiture was required by the FTC‟s June 2015 final order settling charges that the $12.4
billion merger of ZF and TRW – combining two of the world‟s largest automotive parts
manufacturers – would likely harm competition in the North American market for heavy vehicle
tie rods. The parties‟ divestiture also addressed competition concerns raised by the European
October 2015 Issue 11
8 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
Commission. The linkage and suspension business to be divested included five manufacturing
plants in Michigan, Canada, the Czech Republic, and Germany, and a research and development
lab in Germany, which THK will lease from TRW until THK completes its move to new
space. >>Read More Back
---------------------------------
FTC requires divestitures prior to merger of orthopedic device companies
On September 30th
, 2015, Wright Medical Group, Inc. and Tornier N.V. agreed to sell Tornier‟s
U.S. rights and assets related to its total ankle replacements and total silastic toe joint
replacements to resolve FTC charges that the proposed $3.3 billion merger would illegally reduce
competition for these devices.
Headquartered in Memphis, Tennessee, Wright is a global orthopedic device company. Tornier,
based in Amsterdam, the Netherlands, also operates globally, developing and marketing
orthopedic products for use in the upper and lower extremity joints, sports medicine, and
biologics.
According to the FTC‟s complaint, the proposed merger of Wright and Tornier would violate
federal antitrust laws by substantially lessening competition in the U.S. markets for total ankle
replacements and total silastic toe joint replacements. Wright and Tornier were close competitors
and significant suppliers of these orthopedic devices in the United States. >>Read More Back
---------------------------------
FTC approves fiscal year 2014 HSR premerger notification report
On August 12th
, 2015, FTC, together with the DOJ‟s Assistant Attorney General for Antitrust,
released the agencies‟ 37th Annual Hart-Scott-Rodino Report. The report presented fiscal year
2014 (FY 2014) data on the agencies‟ HSR Premerger Notification Program. The program
allowed the agencies to identify and challenge transactions that may substantially lessen
competition in violation of federal antitrust laws.
The report noted that 1,663 transactions were reported to antitrust agencies during FY 2014, a 25
percent increase from the 1,326 transactions reported in FY 2013. In FY 2014, the agencies
brought 33 enforcement actions that preserved competition in broad sectors of the economy
including consumer goods and services, pharmaceuticals, hospitals, high tech and industrial
goods, and energy. >>Read More Back
---------------------------------
European Union
EC conditionally approves acquisition of Hospira by Pfizer
On August 4th
, 2015, the European Commission (EC) approved the proposed acquisition of
Hospira by Pfizer under the EU Merger Regulation. Both companies are US based and active
globally in the development and marketing of human pharmaceuticals. The approval was
conditional on Pfizer divesting certain sterile injectable drugs, as well as its infliximab biosimilar
drug, which was currently under development.
EC expressed concerns that the merged entity would have faced insufficient competitive pressure
from the remaining players in the corresponding markets, with a risk of price rises and
discontinuation of the development of Pfizer's infliximab biosimilar drug. The commitments
offered by the companies addressed these by removing the overlap between Pfizer and Hospira in
all the markets where EC identified competition concerns. >>Read More Back
---------------------------------
October 2015 Issue 11
9 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
EC welcomes General Court rulings upholding TV and computer monitor tubes cartel
decision
In November 2007, EC started unannounced inspections against Chunghwa, LG, Panasonic and
others for suspected cartel. On December 5th
, 2012, EC fined seven international groups of
companies a total of € 1,470,515,000 for participating in either one or both of two distinct cartels
in the sector of cathode ray tubes (CRT). One cartel concerned colour picture tubes (CPT) used
for televisions and the other one colour display tubes ("CDT") used in computer monitors. The
undertakings involved were Chunghwa, LG Electronics, MTPD (former JV between Panasonic
and Toshiba, and currently a Panasonic subsidiary), Panasonic, Philips, Samsung SDI,
Technicolor (formerly Thomson) and Toshiba. Chunghwa received full immunity from fines
under the Commission's 2006 Leniency Notice.
EC welcomed judgments by the EU General Court on September 9th
, 2015 in the TV and
computer monitor tubes cartel upholding the majority of the Commission's decision, regarding
both the substantive issues and the general principles followed to set the level of fines (the fines
remain the highest ever combined fines for cartels – just over € 1.4 billion).However, the General
Court reduced the fines for Panasonic, Toshiba and MTPD as it found that the companies
provided more detailed value of sales figures than what EC had used. >>Read More Back
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EC opens formal investigation into International Skating Union's eligibility rules
On October 5th
, 2015, EC opened a formal antitrust investigation into International Skating
Union (ISU) rules that permanently ban skaters from competitions such as the Winter Olympics
and the ISU World and European Championships if they take part in events not approved by the
ISU. The investigation followed a complaint by two Dutch ice speed skaters, Mark Tuitert and
Niels Kerstholt.
The ISU is the sole body recognised by the International Olympic Committee (IOC) to
administer the sports of figure skating and speed skating on ice. Its members are national
ice-skating associations. These ISU rules may prevent alternative event organisers from entering
the market or drive them out of business. If confirmed, such practices could constitute
anti-competitive agreements and/or an abuse of a dominant market position in breach of EU
antitrust rules. >>Read More Back
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EC opens in-depth investigation into proposed acquisition of BASE Belgium by Liberty
Global
On October 5th
, 2015, EC opened an in-depth investigation to assess whether the proposed
acquisition of BASE Company NV by Liberty Global would harm effective competition. The
transaction would combine BASE, Belgium's third largest mobile network operator by revenue
and second largest by number of subscribers, with Telenet, Liberty Global's subsidiary and the
largest mobile virtual network operator in Belgium. Telenet does not have its own mobile
network and currently uses the Mobistar network to offer mobile services to its customers. It
would also combine a strong fixed line telecommunications company (Telenet) with a mobile
network operator (BASE).
On the basis of its initial investigation, EC had concerns that the transaction could lead to higher
prices, less choice and less innovative services for customers in the Belgian telecommunications
market. EC had 90 working days, until 18th
February 2016, to take a decision. >>Read More
Back
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October 2015 Issue 11
10 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
German Federal Cartel Office fines providers of container transport services 4.56 million
euros in the area of the German seaports
On August 25th
, 2015, German Federal Cartel Office imposed fines totalling approx. €4.56
million on seven companies, the persons responsible within these companies and the association
of companies FCDS committee on account of concerted practices concerning container transport
services provided in the area of the German seaports of Hamburg, Bremen and Bremerhaven.
The companies regularly discussed and coordinated possible reactions to different cost increases.
There were indications that the initial infringements date back as far as 2001. In some years
percentage rates of increase for freight rates were agreed. Furthermore, in several years the
companies agreed on the introduction or increase of various surcharges on the basic freight rate.
All the companies, the individuals responsible and the FCDS agreed to have the proceedings
terminated by settlement. Several companies cooperated with the Bundeskartellamt in clarifying
the facts of the case and were granted a reduction of their fines in line with the authority's
lenience program. >>Read More Back
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UK Competition and Markets Authority closes hotel online booking investigation
On September 16th
, 2015, UK Competition and Markets Authority (CMA) closed an
investigation into suspected breaches of competition law in the hotel online booking sector. The
investigation was launched by the CMA‟s predecessor, the Office of Fair Trading (OFT). It
focused on restrictions in agreements between InterContinental Hotels Group and Hotel
Inter-Continental London Limited (IHG) and each of Booking.com and Expedia, which
prevented the online travel agents from discounting the price of room-only hotel accommodation.
The OFT issued a provisional decision in July 2012 and accepted formal commitments from IHG,
Booking.com and Expedia in January 2014. The Competition Appeal Tribunal remitted the case
back to the CMA for reconsideration in September 2014 following an appeal in respect of the
commitments decision by Skyscanner.
Having reconsidered the matter, the CMA had decided to close the investigation. It would
maintain a careful watch on how the market develops both in the UK and across Europe and
would continue to liaise closely with fellow national competition authorities and EC. The
continued monitoring would include observing the effects of recent Europe-wide changes
introduced by Booking.com and Expedia. These changes removed from their contracts with
hotels certain „rate parity‟ or „most favored nation clause‟s restrictions that prevent hotels from
offering cheaper room rates on competing online travel agents‟ sites than they offer on
Booking.com or Expedia. >>Read More Back
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France Competition Authority investigates Google case
In January 2015, France Competition Authority received a complaint from Gibmedia that Google
suspended without notice the AdWords account that it used to display advertisements on its
websites, and Gibmedia requested interim measures. Google claimed that the suspension was
justified because Gibmedia did not comply with three AdWords rules, namely the ban on
charging for goods or services that are normally free, transparency to consumers and the ban on
using concealment techniques.
Through this investigation, Google had not defined the AdWords terms and conditions, as well as
the account suspension process in a sufficiently transparent, clear and objective manner. These
facts, if confirmed by the investigation, would be liable to constitute an anticompetitive practice.
The Competition Authority decided to continue investigating the merits of the case. The
Competition Authority did not order any interim measures, considering that no serious or
immediate harm to the interests of the consumers, the industry or the complainant company had
October 2015 Issue 11
11 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
been qualified. >>Read More Back
---------------------------------
Australia
ACCC issues opinions on competition law enforcement in the broad industrial relations
area
On August 15th
, 2015, the ACCC Chairman Rod Sims discussed the ACCC‟s enforcement of
competition law as it applies to alleged union behavior in the general industrial relations area.
The Competition and Consumer Act have exemptions for agreements relating to employment
conditions, but it does not mean the role of unions is to regulate markets by anti-competitive
conducts, said Mr. Sims. “With this in mind, the ACCC may currently have more union-related
major investigations than ever before.”
In response to allegations raised in the Royal Commission hearings in Canberra, the ACCC was
currently investigating two instances of potential cartel behaviors in the ACT construction sector,
which involved a wide range of restrictive behaviors beyond the original allegations of price
fixing.
“It is possible that in the past the ACCC has not looked sufficiently into such additional
restrictive behaviors that could amount to a contract, agreement or understanding that has the
purpose or effect of substantially lessening competition, thinking such matters were covered by
the carve outs and exemptions discussed above. The alleged behavior in Canberra may provide
an avenue to do so in the context of investigating the alleged cartel behavior.”>>Read More Back
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Federal Court fines Omniblend $17,500 for resale price maintenance
On August 20th
, 2015, the Federal Court of Australia ordered Omniblend Australia Pty Ltd
(Omniblend) to pay a pecuniary penalty of $17,500 for aiding, abetting, counseling and
procuring an overseas supplier, Taiwan Star International (TSI), to engage in resale price
maintenance.
As a result, TSI sought to induce Omniblend‟s competitor not to sell OmniBlend blenders at a
price less than the price specified by TSI, and subsequently withheld supply of OmniBlend
Blenders to that competitor. Although Omniblend submitted that the conduct was provoked by
the competitor and that they had acted in defense of their commercial interests, this was not
accepted by the court as a legitimate excuse. >>Read More Back
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Federal Court fines Visa $18 million for anti-competitive conduct
On September 4th
, 2015, the Federal Court ordered Visa Worldwide Pte Ltd (Visa Worldwide),
the subsidiary of Visa Inc., to pay a pecuniary penalty of $18 million for engaging in
anti-competitive conduct.
Dynamic Currency Conversion (DCC) was a service which competed with Visa‟s currency
conversion services and gave international cardholders a choice to complete a transaction in their
home currency rather than in the local currency of the merchant, as Visa does. During the period
1 May 2010 to 6 October 2010, Visa Worldwide made changes to the Visa rules to the effect that
retail stores, hotels and restaurants that were not already offering DCC to their customers as at 30
April 2010 could not choose to offer DCC. The court declared that by this conduct Visa
contravened section 47 of the Competition and Consumer Act. >>Read More Back
October 2015 Issue 11
12 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
---------------------------------
Korea
KFTC fines Samyang Foods and its affiliate firm for inter-affiliate trading activities
On September 21st, 2015, the Korea Fair Trade Commission (KFTC) imposed a corrective order
and combined fines on Samyang Foods and Eco Green Campus for Samyang Foods providing
shuttles and employees to Eco Green Campus (its affiliate company) for free.
Between 1997 and March 2015, Samyang Foods arranged for its employees to provide free labor
service to Eco Green Campus. Also, from April 2007 to November 2014, Samyang Foods
provided shuttles to Eco Green Campus for free. In total, Samyang's personnel and vehicles
support was worth around KRW 2 billion.
KFTC stated that if a company provided unfair benefits to its affiliates, it impeded fair
competition. As the first unfair inter-affiliate trading case after the revision of Fair Trading Law,
this sanction case was significant as a reference. >>Read More Back
---------------------------------
KFTC fines Daelim industrial and other three construction firms for bid rigging
On October 5th
, 2015, KFTC imposed combined fines of KRW 28.6 billion (USD 24.4 million)
on Daelim Industrial and other three construction firms for alleged bid rigging on the Seohae
subway line project. Daelim Industrial was fined KRW 6.9 billion, and other three industrials
were fined a total of KRW 21.7 billion.
Through the investigation, it was found that these four companies had pre-arranged to draw lots
to determine their respective bids. And Daelim Industrial picked the highest number, 94.98%.
Through this sanction case, KFTC expected to eliminate the bid rigging activities of
infrastructure projects. >>Read More Back
---------------------------------
Japan
JFTC rejected appeals by Air Liquide Japan related to air separation gas price cartels
On October 2nd
, 2015, in accordance with Article 66 (2) of the Anti-monopoly Law, the Japan
Fair Trade Commission (JFTC) rejected appeals by Air Liquide Japan, the Japan-based unit of
France-based industrial gas company Air Liquide.
On October 5th
, 2011, JFTC opened the trial on Air Liquide Japan. JFTC found that Air Liquide
Japan violated the Anti-monopoly Law regarding pricing cartel for air separator gas between air
separation gas manufacturer and seller during the period from April 1st 2008 to January 18
th 2010.
JFTC imposed a fine of JPY 4.822bn. >>Read More Back
---------------------------------
Brazil
CADE signs agreement with construction company Camargo Corrêa in the investigation
of Petrobras’ bid rigging cartel
On August 19th
, 2015, the Administrative Council for Economic Defense (CADE) approved a
Cease and Desist Agreement with the construction company Construções e Comércio Camargo
Corrêa S/A – CCCC and the two former employees in the public hearing.
October 2015 Issue 11
13 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
According to this agreement, the construction company shall cease its involvement in the
conduct, recognize its involvement in the infringement, effectively collaborate with the
investigation and collect pecuniary contribution of more than BRL 104 million (the highest one
ever established under a Cease and Desist Agreement signed with CADE ). >>Read More Back
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CADE rejects the acquisition of Condor by Tigre
On September 2nd
, 2015, CADE rejected the acquisition of all quotas of Condor Pincéis Ltda.
(Condor) by Tigre S/A – Tubos e Conexões (Tigre). CADE thought this transaction would result
in damages to the sector, such as high concentration, barriers to entry and low rivalry.
In order to remedy competition concerns, the Companies proposed some behavioral measures in
the Merger Agreement, but CADE said the behavioral remedies didn‟t mitigate this transaction‟s
adverse competition impact. Therefore, CADE presented three pillars of structural remedies,
including sale of assets for paint brushes production, sale of wholesale centers and licensing of
brand Condor to third parties. However, the parties found the structural measures imposed by the
CADE unfeasible.
Condor is responsible for the manufacturing and selling of the tools for artistic and school
painting and estate property painting. While Tigre commercializes paint brushes, brushes, paint
rollers and other painting accessories. >>Read More Back
---------------------------------
Russia
Google abuses dominate position on the market of pre-installed application stores
On September 14th
, 2015, the Federal Antimonopoly Service (FAS) said Google violated Part 1
Article 10 of the Federal Law “On Protection of Competition” (abusing market dominance).
Through the investigation, FAS thought that Google violated the law by giving “Google Play”
app store to vendors of mobile devices to pre-install it on the mobile devices under the conditions
including mandatory pre-installment of “Google” applications and “Google” search system and
mandatory priority positioning on the device home page.
According to Article 14.31 of the code of the Russian Federation on administrative violations, if
the party violates Article 10 of the Federal Law “on protection of competition”, FAS may impose
fines from one hundredth to fifteen hundredths of the income gained by the violator from selling
goods (works, services) on the market where the violation was committed. >>Read More Back
---------------------------------
India
CCI fines Kerala movie association and two of its office-holders for alleged
anticompetitive conducts
On September 8th
, 2015, the Competition Commission of India (CCI) imposed penalties of INR
186,590.19 (USD 2,809) on an association of film theatre owners in the state of Kerala, in
southern India, and two of its office-holders for alleged anticompetitive practices.
According to complaints from third parties, the party restricted the third party to screen
Malayalam- and Tamil-language movies since May 2013. In addition, the party restricted the
screening of new movies across the state. Upon investigation, CCI believed that the party
violated the Competition Law, and caused an appreciable adverse effect on the competition in the
film exhibition industry in Kerala. >>Read More Back
October 2015 Issue 11
14 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
---------------------------------
South Africa
SACC recommends prohibition of MTN and Telkom RAN sharing and bi-literal roaming
merger
On August 14th
, 2015, South Africa Competition Commission (SACC) recommended to the
Competition Tribunal the prohibition of a large merger whereby MTN intends to acquire certain
Radio Access Network (RAN) assets of Telkom. The effect of the transaction was such that MTN
will be able to access additional spectrum capacity from Telkom to rollout a Long Term
Evolution (LTE) network.
SACC found that the proposed transaction was likely to substantially prevent or lessen
competition in the mobile services market. The access to additional spectrum capacity by MTN
will confer first mover advantages to it relating to network speed, capacity and mobile offerings.
MTN would be able to gain a significant competitive and time advantage, offering network and
services. >>Read More Back
---------------------------------
Legislation
China
China (Tianjin) Pilot Free Trade Zone issues a set of measures on antitrust enforcement
On September 22nd
, 2015, Tianjin Municipal Development and Reform Commission, Tianjin
Municipal Commission of Commerce and Market and Quality Supervision Management
Commission jointly issued a set of measures on antitrust enforcement in the Tianjin Free Trade
Zone (FTZ). These legislations took effect on October 15, 2015.
According to the relevant legislations, three agencies will jointly set up the coordination office,
which will carry out antitrust enforcement in the FTZ. In addition, the coordination office also
was responsible for transferring information on potential cases to relevant antitrust agencies,
coordinating with other relevant departments to carry out merger review and organizing antitrust
work, etc. >>Read More Back
---------------------------------
United State
DOJ and FTC sign antitrust memorandum of understanding with KFTC
On September 8th
, 2015, DOJ and FTC signed an antitrust memorandum of understanding (MOU)
with the Korea Fair Trade Commission (KFTC) to promote increased cooperation and
communication among the competition agencies in both countries. The MOU was signed in
Washington, D.C. by Assistant Attorney General Bill Baer of the Justice Department‟s Antitrust
Division, Chairwoman Edith Ramirez of the FTC and Chairman Jeong Jae-chan of the KFTC,
and went into effect upon signature.
“This memorandum of understanding recognizes the day-to-day working relationship we already
enjoy with the KFTC and expresses our interest in continuing and strengthening that relationship
in the years to come,” said Assistant Attorney General Baer. “Enforcement cooperation –
including candid and constructive dialogue – is critical to maintaining competitive markets in the
United States, Korea and around the world.” >>Read More Back
October 2015 Issue 11
15 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
---------------------------------
European Union
UK CMA publishes guidance on new compensation schemes power in competition cases
On August 14th
, 2015, UK Competition and Markets Authority (CMA) published guidance on a
new power to encourage competition law-breaking businesses to voluntarily pay compensation
to victims.
Under the guidance, businesses setting up voluntary redress schemes can, in certain
circumstances, receive a discount of up to 20% of any penalty imposed by CMA for a breach of
competition law. The guidance went on to provide details on how businesses can apply to the
CMA for approval of a scheme, how it will consider such applications, the procedural framework
for determining levels of compensation, and how schemes should operate. The new power
enabling the CMA or a sector regulator with concurrent competition powers to approve voluntary
redress schemes came into force on October 1, 2015. >>Read More Back
---------------------------------
Brazil
CADE presents proposal of guidelines on Competition Compliance Programs
On August 19th,2015, CADE presented the preliminary version of the guidelines for
Competition Compliance Programs – a set of internal measures adopted by an economic agent
that allow it to prevent or minimize risks of infringements to the statutes related to its activity, or
to detect them more quickly if they do take place.
The guidelines were directed at the creation of a program internal to companies that was effective
in avoiding infringements to the Brazilian Competition Law. The recommendations aim
especially at conducts, since the Council already developed and published the guidelines on Gun
Jumping in regards to mergers and acquisitions.
The main objective was to guide companies in implementing compliance directed at Competition
Law, how it can be implemented and what were the benefits of its adoption. The guidelines
suggested that either may or may not be adopted, according to each company‟s particularities.
The assessment by CADE of the adoption of these suggestions would happen on a case-by-case
basis. >>Read More Back
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Zhong Lun in the News
China Cross-Border Investment Legal Summit held by Zhong Lun –2015
On September 17th
, 2015, China Cross-Border Investment Legal Summit – 2015 was jointly held
in Beijing by Zhong Lun Law Firm and China Law Review of Law Press, and supported by
China Investment Promotion Agency (CIPA). More than 200 participants, including the
representatives from well-known industrial and financial companies, attended the forum.
In antitrust session, Dr. Wu Hanhong, member of the Expert Advisory Panel of the National
Anti-Monopoly Commission, gave speech on law and economic issues related to merger review.
Wu Peng and Cen Zhaoqin, partners of Zhong Lun Law Firm, Dr. Wu Hanhong, Dr. Cui Shufeng
from Chinese Academy of Social Sciences and Dr. Wang Xiaoru, an American antitrust expert,
jointly discussed topcis such as the notification thresholds for concentrations of undertakings,
legal liabilities for failure to notify, and notification concerning VIE merger transaction,
October 2015 Issue 11
16 Disclaimer: This bulletin is provided for informational purposes only and is not legal advice. The transmission and receipt
of information contained in the document do not form or constitute an attorney-client relationship.
etc. >>Read More Back
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