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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.
David S. Evans
The antitrust economics of tying: a farewell to per se illegality