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August 9,2006

Donald S. Clark
Office of the Secretary
Federal Trade Commission
Room H-135 (Annex Z)
600 Pennsylvania Avenue NW
Washington DC 20580

FEDERAL TRADE COMMISSION
RECIEVED DOCUMENT

AUG 10 2006

SECRETARY

RE: Comments Regarding Section 2 Hearings, Project No. P062106

Dear Mr. Clark:

I am pleased to submit my comments in the above-referenced proceeding on the analysis of product tying arrangements under Section 2. I have included my statement Untying the Knot: The Case for Overruling Jefferson Parish, together with four papers that I have previously (co-)written on this topic. My conclusion is that Jefferson Parish should be overruled and that tying arrangements should be analyzed under a structured rule of reason approach.

Any questions about my statement would be welcome.

Regards,



David S. Evans
Chairman, eSapience, Ltd., Cambridge, MA
Executive Director, Jevons Institute for Competition Law and Economics and Visiting Professor,
University College London, London, UK

The antitrust economics of tying: a farewell to per se illegality
A Pragmatic Approach to Identifying and Analysing Legitimate Tying Cases
Why Do Firms Bundle and Tie? Evidence from Competitive Markets and Implications for Tying Law
Tying : The Poster Child for Antitrust Modernization