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Antitrust Matters Episode 11: The EU's and UK's Differing New Antitrust Regimes
Antitrust Matters provides engaging and timely conversations about competition policy in the digital age. Antitrust has always mattered to consumers and businesses, and to antitrust lawyers and economists, but today it also is in the political and public discourse more than ever. From the prices we pay for food, travel, financial services, payments to the way we interact daily using digital apps and platforms, antitrust touches each and every one of us in ways we may not even realize. Antitrust Matters brings you you perspectives of experts and visionaries in the field who discuss where antitrust law has been, where it is going and why it is so important to our current political discourse.
In this episode, our guests, Robin Noble and Helen Ralston-Smith, expert economists with Oxera Consulting discuss with Jeff Shinder and Stephen Critchley the UK's post-Brexit divergence from EU competition law generally but taking a particularly deep dive into the UK's and EU's new vertical agreements rules which both came into force earlier this year.
Episode Transcript and Show Notes:
Jeff Shinder:
Welcome to Antitrust Matters, a Constantine Cannon podcast where we have engaging and timely conversations about competition policy in the digital age. My name is Jeff Shinder and I'll be your host. Antitrust has always mattered to consumers and businesses, but today it is also in the public discourse more than ever. From how we get our food on our plates, to how we travel, to the way we interact daily using digital apps and platforms, antitrust touches each and every one of us in ways we may not even realize. In Antitrust Matters, we bring you perspectives of experts and visionaries in the field who discuss where antitrust law has been, where it is going, and why it matters today more than ever before.
Welcome everyone. We are back with the Antitrust Matters podcast, and we're going to do something a little different today. We're going to cross the pond and we're going to get a report on some interesting issues and recent cases that have been adjudicated over in the United Kingdom and a view from our friends in the UK regarding the state of competition law on some important topics that my partner, Stephen Critchley, will introduce. Stephen is a competition law and competition litigation specialist. Along with Stephen, we are joined by two economists from Oxera. Oxera is a European economic and finance consultancy. We have two partners from Oxera here, Helen Ralston-Smith and Robin Noble.
Helen Ralston-Smith specializes in financial services markets and has experience in competition, policy and regulation, litigation and arbitration. She has analyzed the economics of markets on both the wholesale and retail sides to the financial services sector. Much of her work has been focused on high profile issues, including the European Commission's investigation into the proposed London Stock Exchange and Deutsche Börse merger, the impact of the financial transaction, tax and the investigation into FX trading by various competition and financial regulators.
Robin Noble is a partner at Oxera with more than 18 years experience. He specializes in digital issues, competition, economics, and quantifying damages. He advises governments, regulators, and businesses on high profile issues and is recognized as a leader in his field. He leads Oxera's work in the digital arena, his advises high profile clients such as Amazon, Google, and Microsoft. Issues he has examined in this area include valuing data, policy and regulatory issues in the UK and EU, cryptocurrencies and algorithms. Welcome, Helen. Welcome, Robin. Stephen, it's great to have you here. I'm going to toss the baton from New York to London and you can introduce our topics and I will turn it over to you. And again, I'm looking forward to a very interesting discussion.
Stephen Critchley:
Thank you, Jeff. So, we're going to be discussing today specifically vertical agreements and the vertical agreements regimes in the UK and in the EU. For context, I'm going to start by setting out the basic framework, governing vertical agreements, which is the dry bit, in other words, before Helen and Robin get into some real world examples. So, I'll canter through it quickly. The old EU regime, which governed vertical agreements in the UK expired on the 1st of June. That's not a Brexit thing, it expired all across Europe. So, on the 1st of June, the EU and the UK both introduced new regimes. And today, what we're going to be doing is a three-way comparison between the old regime and the two new ones.
The framework's easy because it's the same for all three regimes. The legislation against anti-competitive agreements is the same. The UK legislation is basically a copy and paste of the EU legislation. And despite Brexit, I don't think there's any plans to change that. So, the framework is this. The, legislation is short, it doesn't give all the details you need to comply with it. So, the European Commission and now also the UK's competition and Markets Authority publish lengthy guidance on how to comply with the legislation. And there's different guidance for horizontal agreements. Today we're just talking about vertical agreements, ensuring compliance with the guidance can be pretty technical and costly, particularly for smaller companies. So, there is a vertical agreements block exemption, which specifies that if the market shares the parties to the agreement are below 30% on their respective levels of the supply chain, the agreement is within a safe harbor.
Agreements within the safe harbor may be unlawful if they contain certain, what are called, hardcore restraints. In other words, the most objectionable restraints, these hardcore restraints are listed in the block exemption, things like price fixing, which in the context of vertical agreements, means fixing the purchaser's onward sale price. But so long as the parties have market shares under 30% and their agreement avoids hardcore restraints, then it's lawful and the parties don't need to bother themselves with the guidance. If, on the other hand, a market share threshold is exceeded or if it's not exceeded, but the agreement contains a hardcore restraint, then the parties need to reach for the guidance. And in the case of a hardcore restraint, the guidance probably won't save you. So, that's the framework within which Robin and Helen will be speaking. Now, this divergence between the EU and UK vertical agreement regimes is, needless to say, not the only consequence that Brexit has had on competition law.
So, Jeff's asked me to pull the camera back and give an idea of where today's subject sits in the overall story of Brexit, which is a fairly daunting ask given the size of the subject. But very briefly, I'll try to summarize the effects of Brexit. First of all, legislation. Whilst the UK was in the EU, EU laws became so pervasive that we couldn't just scrap them all when we left, it would just have left a massive hole. So, the EU Withdrawal Act, a UK Act parliament created something called Retained EU Law. Essentially it turned EU law into UK law. So, calling it Retained EU Law is really a misnomer. It's UK law now, it just has origins as EU law. The idea was that we would then be free to change the law and diverge from the EU at our leisure. So, the old Vertical agreements block exemption that we're talking about today, that was Retained EU Law, which is why it governed us until it lapsed last June.
Now, that leisurely divergence is likely to get upended because during the, blink and you missed it, Liz Truss Administration, the government published draft legislation to revoke at the end of 2023 all Retained EU Laws except any which might be chosen to be explicitly preserved. So, it's basically the opposite of the Withdrawal Act, which retained EU laws to avoid massive gaps in our legislation. The new law is almost designed to create gaps, so it's set to turbocharge our divergence from the EU. Although, if you ask me, it's divergence for divergence's sake and it's been widely criticized as a bull in a China shop measure, which is just political, but there's been no indication from Sunak that he will change course on that.
As I said, the UK legislation against Anti-Competitive Agreements is a copy and paste of the EU legislation. The other behavioral competition law (against Abuse of Dominance) is also a copy and paste of the EU legislation. And both of those laws are immune from this revocation. The law against Anti-Competitive Agreements and against Abuse of dominance were copied from EU law, but they were copied donkeys years ago and they're UK law, they have been ever since the Competition Act 1998. However, we've just got rid of section 60 of the Competition Act 1998, which obliged the UK courts to interpret those laws consistently with the EU Court of Justice. So, over time now, section 60 has been repealed, the UK and EU regimes will start to drift apart. What we're going to chat about today, the divergence of UK and EU vertical agreements regimes wouldn't have been possible without the repeal of Section 60. Okay. So, that's the first big point, the new legislative landscape.
Second point, investigations. Businesses can now be subject to parallel investigations if they're alleged anti-competitive conduct effects both the EU and UK markets. Similarly, with merger control, where a merger has an EU dimension, the National Regulator cedes control to the European Commission, but not for the UK anymore. If a merger affects the EU and the UK, you need to apply for parallel merger clearance from the commission and from the UK's competition and markets authority.
Finally, you've got state aid. Now, these are rules to keep a level playing field in the EU single market by preventing member state governments from subsidizing their own pet industries. There are exceptions to it. The bank bailouts during the financial crisis were a big one. Still, I think if an EU member state tried to pass something like Biden's Inflation Reduction Act, the European Commission's entire dashboard would start flashing red. The UK is introducing its own looser state aid regime and EU state aid rules will continue to apply in Northern Ireland because Northern Ireland is remaining in the EU single market to avoid a hard customs border between it and the Irish Republic for extremely important political reasons. This does, however, require barriers to trade between Northern Ireland and Great Britain, which is an unresolved issue and there's a whole podcast to be had about the ructions that that has been causing.
So, that's the helicopter view of the effects of Brexit on competition law. At the risk of giving our listeners whiplash, not only are we going to zoom back into vertical agreements. We're going to take a deeper dive into it. So, I've given you the framework which is common to the UK and the EU. Just to remind you, it's a block exemption which offers a safe harbor to agreements between parties with under 30% market share, so long as there's no hardcore restraints and there's guidance to help apply the law outside of the harbor.
And so, our guests Helen and Robin are going to discuss some, but by no means all of the differences between the old EU regime and the new EU and UK ones. I think the first one you wanted to discuss, Helen and Robin, was most favored nation clauses or MFNs, where a hotel booking site, for example, says to the hotels, "Look, if you want to list on our website, you can, but you can't sell rooms directly to customers more cheaply than you sell them through our website." So-called narrow MFNs. Or you can have wide MFNs, where the website says, "Not only can't you sell more cheaply direct to customers, but you can't sell more cheaply through other channels either." So, for example, through other hotel websites. The old regime was almost completely silent about MFNs because back in the day they mainly cropped up in business to business deals. But with the advent of the internet, e-commerce and especially price comparison sites, they have become much more of a thing. So, Helen, if I can hand over to you on the question of MFNs.
Helen Ralston-Smith:
Sure. Thank you, Stephen. Yes. So, that's exactly right. So, the new regime in the UK and Europe has now tightened the use, or suggested guidance that tightens the use, of wide MFNs. And in particular, I think you were explaining the safe harbors. In the case of the UK, wide MFNs are now referred to as hardcore. So, it wouldn't naturally fall into that area of safe harbor even if you were small provider meeting the other criteria. And that's quite interesting, for me at least, because I recently testified, or actually, a year ago, I testified for CompareTheMarket in its appeal of the CMA, the UK authorities infringement decision against their wide MFNs in home insurance.
And the reason this is a hot topic is the judgment came out at the end of August, only a couple months after the UK VABEO, Vertical Block Exemption Regime, was published in law. And the surprising point there, perhaps to some, is against this wave of regulation starting to push back about wide MFNs, the UK competition court decided that in this case there was no effect on insurance on the two main outcomes of competition, I.E. These weren't Anti-competitive and fully turned over the UK authorities infringement decision.
Helen, if I could jump in, there's a couple of terms you used that I just want to make sure that our audience understands because they're not native to the US. So, wide MFNs. And I've read the decision and it talks about narrow MFNs and wide MFNs. Could you explain both?
Yeah, absolutely. Apologies for that. So, one way to think about these MFNs is as best price guarantees. We all get what that means. So, best price guarantee, when it's a narrow MFN, and they're also actually called narrow parity clauses as well. When it's narrow, that best price guarantee is from a platform, but it's only giving you the best price relative to direct websites. So, a classic example here is if you are looking on a hotel booking website, if that booking platform has a narrow best price guarantee or a narrow parity clause, the hotel can't offer a better price direct. So, the consumer can't save money by ringing up the hotel and trying to sidestep the platform. And when it's a wide MFN, that best price guarantee is broader, it covers other platforms as well. And that's the general principle.
So, the notion where the wide MFN is that it has the potential to undermine competition between the price comparison platforms, would that be correct?
Yeah, absolutely. So, the theories of harm and the way in which these MFNs can cause harm is they inhibit the ability of price differentiation between platforms. So, they can restrict what's often referred to as intra-brand competition, which is the competition between different sales channels. And the way in which that happens is partly indirect. So, firstly, the first effect is they prevent the supplier offering a lower price in a different distribution channel. So, that in itself can restrict retail price competition. By definition, you can't have lower prices elsewhere. But that has this knock-on effect on the platform-to-platform, or, distribution channel-to-distribution channel, competition.
Because the platform knows they can't get a lower price from the supplier, by for example, reducing their commissions. They have a lower incentive to do so, so they have less incentive to discount their commissions and attract lower prices from suppliers. The wide MFN would require that supplier to offer the same discount to the platform imposing that condition.
And so, is it correct that theory failed in the CompareTheMarket case? And if that's true, if you could explain to our viewers, our audience, why it failed.
Yeah. So, that's a theory, firstly. So, as you say, it can fail. There are a lot of theoretical models that explain the mechanisms about how that [harm] can arise. But in this market, it was quite important two big things. One was market definition, and related to that, was the coverage of the MFNs. And related to that, the extent to which the suppliers adhered which in turn affected coverage. So, firstly, what is this case about? So, what is CompareTheMarket? So, in the UK, for the distribution of insurance, a lot of retail insurance products like home insurance or car insurance, there are a number, there are four in particular, websites. A bit like online marketplaces, a bit like Amazon, a bit like various kinds of online marketplaces where you can quickly and easily search between many insurance products and find the best price.
But that's not the only way to buy insurance. And that was a really important question in this case, how important were these platforms in distributing the home insurance relative to the direct sales by the insurance? Why is that important? Well, the direct sales, to an extent, where outside the scope of the wide MFN (renewals) and could impose direct competition and mitigate any anti-competitive effects. And even within the scope of PCW sales, that's our acronym for price comparison websites, not all insurers agreed to the wide MFN. Now, that's quite interesting. Roughly, half of the insurers by sales agreed to the wide MFN. So, even in that price comparison website only market, so when you're considering customers that only look online, even those people could be attracted by discounting because many insurers were not tied to the wide MFN at all.
Okay. I have one more topic on that case, Robin, and I want to bring you into the conversation, but I can't help myself on the two-sided market element to the decision. Helen, as you know, two-sided markets has been an important topic of conversation in the United States, Ohio V. American Express ushering in a major sea change in the law here requiring two-sided market treatment for so-called transactions markets where there's a simultaneous handshake between one side and the other. And ensuing cases then discussed, is it a transactions market or not? Are the network effects indirect? Sufficiently indirect such that it should be treated as one? A platform that links two distinct markets? And the courts are trying to figure out the teaching of Ohio V. American Express. And that decision has been much criticized. And I noted, in reading compare the market, that the tribunal noted the "Powerful dissent of Justice Breyer."
So, if you could spend a moment just discussing how the two-sided market issue came out. Robin, I promise to bring you into the conversation, but this is an issue that is consequential.
Robin Noble:
Keep diving because this is absolutely fascinating stuff. It's a case that's really made a lot of headlines in the UK and it's being much talked about across Europe. So, yes, we should keep diving deeper.
Yes. So, I think market definition is another really important aspect of the judgment which has wider, broader implications than just parity clauses and MFNs which are a specific conduct. So, what are the issues at stake? The first question and a big question is, should you define one single market which encapsulates both sides of the platform? So, here, the insurers and the consumers. Or should you define two markets on each side? That's often considered the most important question. And I understand in the US, with the transaction markets, you have agreement that it's one market for both sides. Now, that is my opinion and that would be consensus actually of the CMA in this case as well. That there's a single market for both sides. The reason I laugh is despite consensus by the economists that that's the right approach in this case, the court took a different view. They said that it could be two markets on both sides or it should be, you should define two markets one on each side.
Now, that sounds controversial but I really don't think it's actually that different to where the evidence that Oxera put forward on behalf of CompareTheMarket. So, why do I say that? Well, the main thing to take away from the judgment is the real importance to test both sides of the platform very carefully and thoroughly. What the CMA did was they tested the competitive constraints on the supplier side. Well, they agreed that you should test both sides but they thought it was sufficient to test the consumer side only through the pass through of the supplier, the platform fee to suppliers to consumers. So, putting this in real terms, a price comparison website, like many online marketplaces, charges suppliers a commission and there's no price to consumers.
They get free search, there's no explicit price. So, the CMAs approach was we've got a commission fee, that's where the platform earns its money, lets impose a SSNIP test, the hypothetical monopolist test to that, and see how many suppliers divert and how many consumers would divert from the pass through. Our view is that's not testing the consumer side properly. By definition, there's a partial pass through of the SSNIP, it's not a SSNIP, it's a half a SSNIP, for example. And that is what the court agreed with, that you need to test the consumer side properly. I would suggest testing the consumer side properly in the context of zero price markets by, in this case, we've got retail prices to consumers, they're selling insurance just like on other platforms you're selling goods and other types of retail. So, why not take those prices and apply a SSNIP to them?
And we're in a digital market setting. So, you've got a bucket load of data to look at how customers might switch away from that platform in response to small changes and prices. So, it's not actually that hard to quantify or really explore firmer than just hypothesize in your mind. And that's what we did. We had the data, we found that it's likely there'd be enough consumers to switch to the renewal channel or insurers direct to broaden the market. The court took a different view. They really wanted to test the consumer side and saw a disadvantage of only applying it to retail prices: there are some consumers that browse and you don't test their diversion if you only apply it to purchasers, which is the case with retail prices.
So, they introduced a special fee, a new fee, which is quite novel. This platform doesn't charge consumers at all. They said, "Why don't you introduce a fee?" That fee really has a similar effect to the SSNIP on retail prices. And they deduced from the evidence that everyone's put forward about the high price sensitivity of consumers, the market is broader on the consumer side. So, they concluded, agreed with the CMA that the suppliers may not switch, that that might be a narrow market price comparison website only. But on the consumer side, it was a broad market including the direct channel. And then, they kind of forget about the insurer side of the market when they do the effects analysis, which in this case is entirely right because the concern, as we were talking about before, is that the wide MFN restricts price competition, retail price competition and commissions. So, you'll think about retail prices and its consumers who respond to retail prices. So, that consumer market is, perhaps, more important.
Robin, I think you wanted-
Yeah. I was going to just answer that, Jeff. I mean, in a sense, zooming out a little bit from this specific case, because, of course, there's a lot of specificity in what Helen's describing because we're talking there about insurance markets and renewal is really important in that. You've been insured by someone, you will receive a letter from that insurer offering to renew your policy. And so, of course, that's a really key part of the factual matrix of a case like that. But for me, when you zoom out and look at, what lessons does the in-house counsel take from a case like this? For me, there are really three. The first is that, as Helen articulated, as I think both yourself and Stephen articulated, there's a lot of theory behind why it is MFNs can be good, but also MFNs can be bad.
And I think it's worth getting under the skin of that because it helps you understand the ways in which some of them are a little bit counterintuitive, that certain types of parity causes on their face can be good but could actually, under certain circumstances, have some harm. And I think everyone accepts that, theoretically, these things can happen. But I think there are two other really critical lessons that come out from this case. One is, Helen used the word substitution a lot and I think that's a real buzzword and something you should take away because it is critical. Whatever framework you're going to use to think about this, it's almost trite to say that, fundamentally, antitrust competition economics is a lot about substitution. It's the ability of suppliers to substitute to other sales channels. It's about the ability of consumers to substitute to other buying channels.
Whichever framework you're going to use, understanding the degree of substitution is really, really important. Conceptualizing of it and then going to get the detail on it. And then, I think the third real message from that is that the facts matter, renewal really mattered in that case. This was a great way for the incumbent to contact their customer and it meant that they were always competing against the renewal. You've got a renewal that you receive in the post that's normally the prompt to then go to a comparison website in the first place. Now, of course, that's not true for a lot of other mediums. You talk about hotel bookings, well, maybe there are people that get renewals, they have long term leases, but normally that's not the way the world works.
You are going on holiday somewhere, you want to go and visit somewhere, you are proactively reaching out. It's a different kind of search. And the same, again, for resale websites, et cetera. So, the facts really, really matter. The context really, really matters. And so, one has to think pretty hard about these things.
It might not have been clear, but just to clarify, renewals would not be captured by these wide MFNs. An insurer was free to offer any price through the offline (paper) distribution channel. So, via the renewal, hence, why this coverage, the scope of these wide MFNs, when you consider the proper market as defined by the courts, the broader one, they're much narrower, and therefore, their ability to have anti-competitive effects is inherently limited.
So, let me follow up on a couple things here, if we stay. And I want you both to comment on this. Helen, you walked us through the market definition analysis and I understand why the tribunal would have an issue with the pass through approach. And as I understand what you explained, this is how I netted it out, if I get it wrong, you'll tell me, is that this is a platform that links two sets of interdependent suppliers, of home insurance, on the one hand and the consumers of home insurance on the other hand. So, it has two sided characteristics. I think that's easy and doesn't help that much towards the ultimate outcome. And that on both sides of the platform, the tribunal essentially said, "Do a traditional market definition analysis." Almost as if there are really two distinct markets to evaluate, ultimately, whether there was harm on the consumer side since, as you articulated well, the issue of a wide MFN would be whether pricing to the, what we'll call, the end consumer was elevated.
And so, this raises the following question in my mind, what does the two-sided market nomenclature add if, ultimately, what was demanded was an evaluation of what essentially are two distinct but linked markets? And, to my mind, this is what Justice Breyer, forgive me for expounding on US law, we're here to talk about what happened in the UK, this is what I thought Justice Breyer was talking about in his dissent as the right way to analyze these platforms, which are fairly ubiquitous now. So, did I get anything wrong?
I think I've got two points to say here. So, I think the key to the question was why does two-sided-ness matter here? And I want to just… The first point I'll make is actually a really important part for the judgment and I think a takeaway for a lot of digital markets is almost that point. The court said, "The CMA is basically…" A phrase I use, at least in England, is "They've lost the wood for the trees." Basically, this is just an intermediary. And the CMA is so focused on trying to find other comparison websites or the full features, the full bells and whistles that a price comparison website offers, that it's missing the competitive constraints of the direct channel. Effectively, consumers can buy insurance through intermediaries or they can go to insurers direct. And yes, one of these intermediaries offers other things such as comparison and search.
The main thing that a consumer values from that intermediary is the product, the insurance product. And there are other ways they can go about getting that, and I think that's an important takeaway. And then, we see that in other precedent. However, when it comes to effects, I would push back and I would say that there's actually… The competitive pressure on the consumer side in this situation also prevented harm on the supplier side and it would be much easier to show you with a visual. But if you think it through, if there's competitive pressure keeping prices to consumers at the competitive level, it also means you can't have the platform charging higher commissions to some suppliers, which is the way in which the theories of harm work through. Because, effectively, this is a competitive market, the insurer market is competitive. So, if it can't pass this through, higher commissions through to higher retail prices, then they can't pay those higher commissions themselves.
And how does that work? Well, you can think about it as the platform faces competitive constraints in this situation by the value chain, the bundle, the suppliers and the platforms or the renewal channels that aren't covered by the wide MFN. So, suppose an insurer is going around offering 150 pounds on the wide MFN platform. There's an insurer on that platform, not constrained by the wide MFN, that's free to offer 145 pounds and they will win the customers from that insurer. Simply, another platform can go around and offer lower commissions and attract that insurers lower 145 pounds and win customers from the wide MFN platform. So, the wide MFN platform itself is hurt by keeping commissions up. So, through the competition on the consumer side, actually the harm on the supplier side dissipates and that's because it's a two-sided market.
Okay. That was great. Appreciate that, Helen. Robin, do you have anything to add?
I think Helen covered the key points which is, I think, in a sense… I mean, maybe, again, one of the lessons here is in cases like this, it can be helpful to almost think of it both ways round and try to test the logic. Don't almost fall into the… What I think, sometimes, can be the alluring trap of trying to put lots of things into the two-sided markets bucket. That's pretty fashionable to do that. And I think, in a way, back to the substitution point, one of the messages from this case, I think, is about sometimes simpler can be clearer and more insightful and it can really stress test whether or not a theory of harm that might be very reliant on a two-sided intellectual structure actually isn't robust. And sometimes the answer is it's not.
Well, one thing I'll say before I hand the baton back to Stephen is any sensible discussion of any antitrust issue in any jurisdiction, what you said, Robin, the facts matter, has to be front and center. The facts always, always matter. And, as basic as that is, it is worth emphasizing. Stephen, let me turn it back to you because I know there's some other topics that you want to navigate.
I was going to say a final word on the MFNs, actually, because we were talking about the different regimes, the new EU regime and the new UK regime. It's worth mentioning that under the new UK regime they made wide MFNs hardcore, but they didn't do that under the new EU regime. So, there's a divergence there. And Helen mentioned, when we were chatting offline, about isn't it interesting the moment the UK says, "Wide MFNs, these are terribly restrictive and they're hardcore." Almost immediately, the competition appeal tribunal comes out and says, "There's nothing wrong with the wide MFN in this particular case." And how do you square that circle? I mean, when I was introducing this earlier, I said that if you've got a hardcore restriction, it's not necessarily unlawful, it just means you're not in the safe harbor and you've got to reach for the guidance.
And I said in the case of a hardcore restriction, the guidance probably won't save you. I think this is an example where the guidance would save you. And it just goes to show, as you were saying, Jeff, it turns on its facts and it's not the end of the world if the block exemption says this is a hardcore restriction because it could be you say, "Well, okay. Then, I'm outside of the safe harbor, but anyway let's have a look at the guidance. And it could be that this is lawful anyway and it's worth taking a shot at it." So, that is what I would say on that one. But yes, time is a thing. And moving on, Robin and Helen, what was the next point you wanted to discuss? Was it differentiation of pricing, online and offline?
Dual pricing, I guess, is another interesting topic that it's worth diving into. And just to explain some of the background on this, under the old EU regime in our three-way comparison, dual pricing, which is where, as a supplier, you are charging different prices to one group of sellers and another group of sellers. In particular, one group of sellers being online sellers and another group of sellers being offline or physical sellers. That was regarded as a hardcore restriction in the old regime. Under both the new regimes there is a new approach which is much more accommodating towards this kind of dual pricing. And the examples that they use are typically the online versus the offline. And typically, they talk about how it might be the case that as a manufacturer you might wish to charge online sellers somewhat higher prices than offline sellers.
And they cite examples, like the fact that offline seller might be doing an installation for their customers, but an online seller might not. And of course, that might then impose costs on the manufacturer. It might be that there are more warranty claims, for example, from the online sales because perhaps they're not being installed quite so well by the home installer as opposed to the more professional physical training business. Now, of course, if we remind ourselves, if we wind back the clock a little bit, it's worth reminding ourselves almost why is it there was this distaste or lack of enthusiasm in the guidelines about your pricing. In one level, one explanation certainly that I've heard a few times in Brussels is that, in fact, it wasn't a really a competition issue at all. This is more about EU single market and the fact that online sales were seen, at least some years ago, as needing a little bit of nurturing.
And that since having manufacturers or brands deliberately discriminating against online sales by charging online sellers higher wholesale prices than physical sellers would be harmful both to the growth of the internet in Europe, but also potentially to cross-border sales, which is so important within the EU. And obviously, online cross-border sales, perhaps a little bit easier to nurture than physical cross-border sales for obvious reasons. But I think this is actually really quite an interesting development and it's a change of tone in both of the guidelines. And it's also quite interesting in a sense the type of evidence that is now being talked about in this guidelines about… Well, not necessarily that the low bar, but it's not requiring that you have a great steal of evidence. There is some discussion in the guidelines about how one should think about what a cost orientated differential might be between the two, perhaps looking back to some of those points around whether it imposes more costs on you because of faulty sales, et cetera.
But no, I think that's quite an interesting point, I think, for people to be aware of. And actually, it flows into another related point, which is that, as you might imagine, given the history of the EU and the UK, both guidelines are not particularly welcoming of resale price maintenance, which comes together in the context of online sales. Because we have started to see, in enforcement terms, quite a few cases emerging around Europe that have really been looking very hard at resale price maintenance. And so, it's not just the fact that the guidelines say that resale price maintenance is a hardcore restriction and doesn't benefit, it's also that it's being pursued more generally. And you've even started to see litigations emerging, business on business litigations not involving authorities either that have been exploring that topic.
So Robin, if I may follow up on the second point you made, because that's an interesting divergence between what's happening over in Europe and the United States where resale price maintenance post Legion is a rule of reason issue, can be anti-competitive if there's horizontal effects, but the tenor of the Legion decision recognized the possibility of the resale price maintenance can facilitate pro-competitive outcomes that are beneficial for consumers. And as we noted earlier, the facts matter. So, if you could speak to the, why is it the case in your view that the direction of the law and litigation is different in Europe? Are we missing something here in the US?
Well, I guess maybe if I start by talking about some of the litigation, because, in a way, what's really interesting about the litigation is that, naturally, I think the litigation is actually drawn more naturally to the US view because, of course, the litigations that you see tend to be business on business. This is a retailer litigating against its supplier. And of course, it's worth thinking about why is that happening? Because traditionally, one reason why authorities and legislators don't like resale price maintenance is actually quite similar to the points that Helen was making about intra brand competition. Because what does resale price maintenance do, is it reduces the competition between retailers, and that may reduce overall competition, which may then result in higher prices for consumers. Now, that does have some logic associated with it, but I think, as we talked about earlier, facts matter. And I think that's where the US perspective comes in of, well, that can work, but it doesn't always work, so let's look at the facts.
But it's worth, just go back to those litigations because those litigations tend to be a retailer against the wholesaler. Now, if you think resale price maintenance is having this effect, how is it doing it? Well, what it's doing, typically, if it's working and it's harming consumers, is that it is raising the margins that retailers can earn because there's less competition between them, so they don't drive down the margins between each other so ferociously, therefore, the price to the end consumer goes up. And if you think about that through, what does that mean? That means actually retailers, maybe they quite like resale price maintenance. They don't have to compete so hard with each other. They might sell a few less units, but they earn bigger margins on the units that they do sell. So, it's actually, potentially more profitable for them to be in a resale price maintenance world than a not resale price maintenance world.
But then again, go back to the fact that this is retailers suing their suppliers. But then, look a bit deeper and what it tends to be is this online specialists suing their suppliers. And of course, why does that make sense? Well, that makes sense because you may think that, well, what differentiates an online specialist? Is low prices. What differentiates a high street retailer? It tends to be location, service, in-store experience, et cetera, maybe slightly higher prices. And of course, if you have effective resale price maintenance that applied to the online and the offline, well, actually, that can mean, well, why would I want to go to an online seller when I can get the in-store experience, I can get the benefit of the advice from the salesperson essentially for free, because I can't get it cheaper anywhere else. So, potentially, what happens in a situation like that is that effective resale price maintenance really takes away the competitive advantage that an online seller has got.
And essentially, you do work through the mass very high elasticity of demand for that firm, there's lots of sales, it's actually quite bad for them. And so, again, the theory works, but in a litigation you've got to test the facts. You've got to go and find out, "Okay. How many sales did you lose? Who did you lose them to? Was the resale price maintenance actually affected?" All of those kinds of things. And there's a few cases… None of them have gone to trial, so we don't know all the facts that are associated with them, but they cover things like lawn and bowling shoes, lingerie products. There's all sorts of things that people buy online and wherever they buy them online, this is the potential for cases like this.
So Robin, there are two issues lurking in your answer that I want to just probe a little deeper on. One is, is the resale price maintenance and the fact patterns you just went into a legitimate device to protect against free riding? So, that's one question. Second is, interbrand versus intrabrand competition. And here, the Supreme Court has said, "The primary purpose of the antitrust laws is the protection of intrabrand competition." Which doesn't mean you can't have a violation of the antitrust laws based upon a restraint intrabrand, but it does mean here… And the question is, is it different? And Stephen, you may want to jump in too here. Is it different in the United Kingdom or Europe? Because I hear that fact pattern… So, maybe there's a restraint intrabrand, but if there's vigorous competition interbrand, what's the problem? I mean, that's the US perspective on it. So, I toss two things at you.
Let me try and grab with the second one first, which is the inter versus intra. And again, I mean, this is where I think the litigations are perhaps the closer mirror to the US, which is that, in a sense, those are the facts in these cases. I mean, we've advised on several of them. You have to look very hard at the intrabrand competition. So, who are the rivals? Are you the only online specialist if you are the claimant? Are there lots of other people like you? How price sensitive are customers for this specific product? But then, of course, you've got to look at the interbrand dynamics too. How important is this particular brand to you? How many other brands do you carry? How easy is it, for you as a retailer, to switch to other brands as well? Because, of course, it's not just… If you're talking about the harm to a retailer, it's not just about the overall harm to competition, it's about the harm to them.
Most retailers don't stock all products, they stock a subset. And so, you've got to explore all of those topics. But I think, zooming back out, I guess it's a bit hard to draw general lessons about, does Europe have a different view about inter versus intra? I guess perhaps it's got a little bit less faith in the power of competition of one layer of a value chain to save you from reductions in competition at another layer of a value chain. That might be one hypothesis to explore.
Is substitutability an issue here, Robin? I mean, you were saying it's always about substitutability. I mean, the example that was occurring to me as you were talking was tomato ketchup. I don't know how it is in the state, but there are some people that are only going to have Heinz tomato ketchup. They want their Heinz. And I think what you were saying, Jeff, was that provided you've got competition between different brands of ketchup, who cares. Whereas, if you've got a consumer base that doesn't see it as particularly substitutable, then that's when it's more important to have measures which seek to promote competition even within the supply chain of one particular brand.
Robin, I'm tempted to toss this back to you, or to Helen. I see Helen…
I was just going to say, from one economics perspective, is… I mean, Heinz is a good example perhaps because you've got to think about the value chain and how much value is created by the brand as opposed to the retailer there. And perhaps Heinz is quite cheap to produce. So, it's actually the logistics and the retail there where there's more cost involved. And so, competition at that point of the value chain might have a bigger impact on a consumer overall price. Whereas, in my case of the MFN case in home insurance, the home insurance product is the valuable part. And the court was seeing that, at the most, wide MFNs were restricting intrabrand competition, which is a small component of the overall consumer cost. But they can actually intensify in interbrand competition by reducing search costs and clarifying where the best price is for the right brand.
So, I think that would be one way to try and evaluate. If you were to want to look at the overall impact on consumer costs, think about the value chain and where is the value, where is the cost most.
Yeah. And I guess, Jeff, you are bridging to the conversed here in the sense of, we economists are great enthusiasts of effects based analysis, looking at the facts of every individual case. But I guess, as pragmatists, we can also see the value that policy makers can sometimes take the view, we just want to take a judgment call on something, we want to guide the nature of competition in a particular area, in a particular direction. And if we're concerned, if we find some of these theories compelling enough of the time, then maybe we just want to make it harder for people to do those kinds of things in the first place. And of course, there are pros and cons of making choices like that.
You see that in other related legislation. I mean, we go slightly beyond the vertical sphere, but those kinds of debates are right at the heart of the discussions around the Digital Markets Act, where essentially there are some parts of that that are based on competition and antitrust thinking, but there are other parts that are drawing much more heavily on more traditional regulatory market design principles about, how do we want things to work? We want to steer competition in a particular way because we think that is the better way? And in a sense, for better or worse, those are the kinds of judgments the policy makers make and we just have to look carefully at them. And business people have to think carefully about, well, how do you comply with those rules? How do you make the best of them? How do you optimize with them?
So, let me say that we have a few topics here that would merit a follow-up podcast. First of all, I'll throw a prop to my partner in London for his very quick summary of Brexit, which merits its own discussion. And two-sided markets, we should have a two-sided market focused discussion on both sides of the pond. And this discussion of dual pricing, dual distribution also merits further, deeper dives. But we will save that for another day because-
I would just like to add one, Jeff. At the very end there Robin threw in something called the Digital Markets Act. I'm not sure if this is something that's come across your radar yet. It's new EU legislation which is aimed at regulating just the behavior of the largest tech firms and which, like GDPR is set to have ramifications all over the world. So, that is another piece which could very likely be of interest for a future podcast.
I completely concur. So, Robin and Helen, we'll have you back. Who wants the last word, the economist or lawyer?
The title of this series is Antitrust Matters, but I guess one of the messages from this is Facts Matter.
Bravo, I want to thank you all. This has been great. Stephen, thank you for putting this together. Helen, Robin, it was fascinating and a pleasure meeting you in all this and we will have you back. Be well everybody. And thanks for your time here.
That's all for our show today. If you like the podcast, make sure to subscribe to Antitrust Matters and leave us comments on how we were doing or on the topics you would like us to cover going forward. You can also follow us on Twitter, or follow the Constantine Cannon antitrust team on LinkedIn. Until next time, be well, and remember antitrust matters.


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Hillary's Gaza Problem
From Jordan, The Daily Beast's Salameh Nematt on how Hillary Clinton can jumpstart the Mideast peace negotiations her husband left behind in 2000.
Salameh Nematt
Updated Jul. 14, 2017 7:48PM ET / Published Dec. 29, 2008 8:40AM ET
Eyad Baba/AP
Israel's massive blitzkrieg of the Gaza Strip, which has killed nearly 330 Palestinians so far and injured more than 1,000, continued Monday with no end in sight.
The carnage inflicted by "Operation Cast Lead"—ostensibly in retaliation for the death of one Israeli in rocket attacks by the Palestinian Islamic Resistance Movement (Hamas)—is the largest Israeli action in Gaza since 1967. It has raised political tensions across the Middle East and pushed the Palestinian-Israeli conflict to the forefront of the foreign policy challenges facing the incoming U.S. administration of Barack Obama, which is already saddled with a global economic crisis, unfinished wars in Iraq and Afghanistan, and a looming nuclear threat from Iran.
There is a real danger that the Mideast peace process, already in a coma in the last days of George W. Bush's presidency, could be killed off by renewed violence.
There is a real danger that the Mideast peace process, already in a coma in the last days of George W. Bush's presidency, could be killed off by renewed violence, which will make it more difficult to overcome divisions within both the Israeli and Palestinian camps. The split among the Palestinians between the mainstream Fatah movement, controlling the Palestinian Authority in the West Bank, and Hamas, which controls Gaza, has been further deepened by the PA's apparent complicity to rid Gaza of Hamas. And Israel is likely to tilt further away from the pro-negotiation stance adopted by the centrist Kadima Party in power today if, as expected, hardline Likud leader Benjamin Netanyahu wins February's elections there.
Mindful of Washington's strategic alliance with Israel, and aware of the need to maintain a measure of neutrality that would enable his administration to be an effective mediator, President-elect Obama did not immediately comment on the airstrikes and may choose to let the crisis play out before he commits the new administration to a specific position.
Once he takes office on January 20, Obama would appear to have two narrow options. First: Send Hillary Clinton to restart negotiations from the point they reached in 2000, when her husband, President Bill Clinton, brought a historic peace agreement as close as it's ever been. But that deal collapsed, largely due to miscalculations by then-Prime Minister Ehud Barak (the current defense minister) and Palestinian leader Yasser Arafat, and the second Palestinian intifada broke out instead.
Second: Manage the immediate crisis by brokering a new cease-fire between Israel and Hamas, with the help of regional powers, thus abandoning any grandiose hopes of a peace agreement until political circumstances improve.
In the meantime, the political climate in the Middle East will improve or further deteriorate depending on how the Iraq war pans out. If the U.S. appears to be withdrawing from Iraq and abandoning the region to Iran's designs, it is likely to harden the hostilities between Israel and Palestine. If the occupation of Iraq looks more like a success, this may encourage radicals on both sides to join the bandwagon of so-called moderate regional powers such as Turkey and Egypt.
For now, the Arab world is expressing outrage at the Israeli action, while most Western powers are urging restraint all around. On Saturday, the Bush administration cautioned Israel to avoid civilian casualties in airstrikes on Gaza and said Hamas must stop its rocket attacks into Israel for the violence to cease. Secretary of State Condoleezza Rice said the United States "holds Hamas responsible for breaking the cease-fire and for the renewal of violence in Gaza." She added that the cease-fire between Israel and Hamas, which expired more than a week ago, "should be restored immediately"—a plea seconded by PA President Mahmoud Abbas.
The spokesman for European Union foreign policy chief Javier Solana also called for both sides to declare a cease-fire, and this plea was echoed by France, Russia, and Britain. British Prime Minister Gordon Brown reportedly contacted his Israeli counterpart, Ehud Olmert, and made it clear Israel must stick by its humanitarian obligations in Gaza.
Arab League head Amr Moussa called for an emergency meeting of all Arab foreign ministers in Cairo Sunday, while the Egyptian government summoned the Israeli ambassador to express its condemnation of the airstrikes, and King Abdullah II of Jordan called for an immediate halt to all military actions, saying the attacks targeted innocent civilians in Palestine.
Lebanon's prime minister, Fuad Siniora, described the Israeli attacks as a "criminal operation," and Iran's supreme leader, Ayatollah Ali Khamenei, issued a religious decree ordering Muslims to defend the Palestinians. But there was no indication that Iran would give the green light to its proxy Hezbollah militia in Lebanon to launch rocket attacks across the border into Israel.
A Syrian official said Sunday that Damascus was suspending its indirect peace talks with Israel, and Turkish Prime Minister Recep Tayyip Erdogan announced that he, too, had frozen his contacts with outgoing Israeli Prime Minister Olmert.
On Monday, Israel bombed the Islamic University and government compound in Gaza City, centers of Hamas power. By the end of the day, Israel was close to exhausting its target bank for aerial bombing, according to Israeli military analysts quoted by the Haaretz newspaper. Now it will have to either launch a ground operation or bring the campaign to a speedy conclusion.
Thus far, however, Israel has been sending conflicting messages about where the operation is headed. Asked whether Israel would follow up the airstrikes with a ground offensive, Defense Minister Ehud Barak said, "If boots on the ground will be needed, they will be there."
But Israeli Foreign Minister Tzipi Livni told the foreign media that Israel does not seek to reoccupy Gaza, and government sources said the Foreign Ministry is already working on an exit strategy—though this strategy would not involve stationing an international force in Gaza. Livni, who hopes to defeat the right-wing hawks to become prime minister in the February elections, has also said the rule of Hamas in Gaza must be ended because the Islamists will never make peace with Israel.
RELATED: Shattered Peace by Judith Miller
RELATED: Why Israel Named Its Gaza War After a Hanukkah Poem About Dreidels by Ethan Perlson
Salameh Nematt is the international editor of The Daily Beast. He is the former Washington bureau chief for the international Arab daily Al Hayat, where he reported on US foreign policy, the war in Iraq, and the US drive for democratization in the broader Middle East. He has also written extensively on regional and global energy issues and their political implications.

redpajama_set_name: RedPajamaCommonCrawl


President Donald Trump's daughter, Ivanka Trump, and the acting head of the Overseas Private Investment Corporation (OPIC), David Bohigian, announced the initiative Monday in Addis Ababa, Ethiopia, where they are part of a U.S. government delegation.
Later in the day, Ivanka Trump met with President Sahle-Work Zewde. They discussed a need for reform in Africa that would lead to improved opportunity and inclusivity for women.
She also held discussions on women's empowerment with Prime Minister Abiy Ahmed, commending him for increasing the number of women in leadership positions in his government.
On Sunday, Bohigian signed a "letter of interest" with an Ethiopian company called Muya to help support the company through OPIC financing. Muya, owned by fasion designer Sara Abera, produces household products and was the first Ethiopian company to obtain membership in the World Fair Trade Organization.


Sonic Advance (ソニック アドバンス) is a 2D Sonic the Hedgehog platform game released for the Game Boy Advance in late 2001. It was the first Sonic game to be released for the system, and along with Sonic Adventure 2: Battle (which was released in Japan on the same day), stands as the first Sonic game to be released on a Nintendo console, systems which traditionally rivaled those built by Sega.
The evil scientist, Dr. Eggman, has hatched another dastardly plot. He plans to build a Dr. Eggman Empire by turning all the animals into robots. "If I gather all 7 Chaos Emeralds, I'll gain unimaginable power!" You can't just watch your comrades become tools of Dr. Eggman!
Command Sonic as he dashes into action along with his pals, Amy, Knuckles, and Tails, to stop the evil Dr. Eggman!
The Story begins as Sonic goes to search for Eggman around the South Island, by collecting Chaos Emeralds. Sonic arrives in Angel Island and he sees a robotic lookalike of Knuckles named Mecha Knuckles, and Eggman built the Egg Rocket which will go in outer space, so Sonic goes in and finds Eggman. Later he finds Eggman and chases him outside and defeats him.
Bad Ending: After Sonic defeats Eggman, Sonic doesn't have enough chaos emeralds. He falls down to Earth and is caught by Tails in his Tornado.
Good Ending: After Sonic defeats Eggman, he collects all the chaos emeralds and he turns into Super Sonic and chases Eggman onto the moon for his first time. After Super Sonic defeats Eggman and flies off the moon, Tails, Knuckles, and Amy wondered what happened to Sonic, so Tails goes to search for Sonic a few days later. He finds Super Sonic who came from the moon, as Tails waves to him.
Sonic Advance features four playable characters; Sonic the Hedgehog, Miles "Tails" Prower, Knuckles the Echidna, and, for the first time as a playable character in a classic-style 2D Sonic game, Amy Rose. Sonic can have Tails follow him, Sonic 2-style, by entering a special code at the character select screen. All characters have separate save-games which record their individual progress.
The player must play through 6 normal zones, followed by the X-Zone and The Moon Zone if certain conditions are met. Each of the normal zones contains two acts. Act 1 is completed by passing a signpost and Act 2 is completed by defeating one of Dr. Eggman's machines and opening the capsule that subsequently falls from the sky, releasing the captive animals. Sonic Advance was the last game in the Sonic series until Sonic 4 to use end-level signposts and capsules and Sonic's leg spin animation, and the first 2-D Sonic game that allows your character to grind on rails.
The special stages are accessible from Special Springs, which are placed near the top in certain acts. Each normal zone contains one Special Spring, except for Ice Mountain Zone which contains two: one in each act. Chaos Emeralds can be collected if one passes the stage. The chaos emeralds are "shared" between characters. Once the player has collected all the Emeralds and completed the X-Zone with all four characters, they can access the Moon Zone by completing the X-Zone again with Sonic.
This is one of several games to include the Tiny Chao Garden minigame. It is unlocked by default in this game.
Controls are similar to previous 2D Sonic installments, and platform games in general. For all four characters, the button makes them jump. Sonic, Tails, and Knuckles all simultaneously spin attack when jumping as in previous games, however Amy does not, making her significantly more vulnerable in a number of circumstances in the game, effectively making her the most difficult to play as. While stationary, hold to look above and to look below. Sonic, Tails, and Knuckles can spin dash by holding and pressing , another classic feature, and can roll if running and pressing . Amy's behavior when these buttons are pressed is different, and is considered a special ability. Each character has their own unique abilities, which influence the game's overall difficulty.
Each character's abilities are modeled after their special moves in Sonic Adventure. Sonic is the fastest character overall, Tails can fly and swim, Knuckles can glide and climb walls and Amy has her hammer. Each character's strengths and weaknesses particularly come into play when fighting bosses or trying to find access to the special stages.
All the characters can perform an attack by pressing the button. These moves are most often less effective than a spin jump or a spin dash due to their short range. One of the characters can make combo attacks by pressing the button repeatedly. These and other special moves are explained below.
Double Spin Attack (also known as the W Kaiten Attack or Insta-Shield): Press after jumping and a flash shaped like lightning will cover Sonic for a split second, increasing his attack range and speed.
Jump Dash: Press or twice in rapid succession after jumping and Sonic will dash in midair, increasing his speed. Sonic is vulnerable in this state.
Somersault: Press twice in rapid succession. With the first tap, Sonic rolls into a ball less tight than his usual spin attack. This only lasts a moment. Press again while he is in this rolling state and Sonic will perform a somersault, which can damage enemies in front of him. Sonic does a couple of somersaults, does a flip, then slides along the ground and stops.
Skid Attack: Press during a Somersault and Sonic will flip forward and skid along the ground for a moment, damaging enemies in his path.
Backflip: Press during a Somersault and Sonic will jump into the air backwards in a light spin. Sonic is vulnerable in this state.
Rushing Attack (Super Sonic only): Press and Super Sonic will speed up and attack in a blaze of light.
Fly: Press after jumping and Tails will begin fly. He will gain height by tapping again repeatedly, using the D-pad to control what direction Tails is going. He will not stop flying until he lands on something. Tails can damage enemies while in midair if he hits them with his tails. Tails can fly for 8 seconds. When underwater, this move will cause Tails to Swim, which is identical to flight except he cannot damage enemies. Like flying, Tails can only swim for 8 seconds, and can only stop by landing on something.
Tail Attack: Press on the ground or in midair, while not flying or swimming, and Tails whips his tails around, damaging enemies immediately in front of him.
Glide: Press and hold after jumping and Knuckles will glide sideways while slowly losing height. Press or and he will change his direction accordingly. Enemies in his path will take damage on contact with his fists. Release and Knuckles will fall, being vulnerable until he lands on something. When underwater, Knuckles will Swim, which is identical to gliding except he cannot damage enemies. Knuckles cannot gain height like Tails and he loses altitude at the same rate as gliding.
Climb: If Knuckles glides or swims into a wall, he will cling to it. Press or and he will climb or descend it. Press and he will jump off. When he gets to the edge of a ledge, Knuckles will pull himself up onto it.
Float: If Knuckles lands in a body of water, he will rise to the surface and float, regardless of how deep he initially goes. Press or and he will change his direction accordingly. Press and Knuckles will sink. Press and he will jump.
Punch Attack: Press on the ground and Knuckles will let go a right cross, damaging enemies in front of him. Press again and he will punch a second time, but with his left hand.
Uppercut: Press quickly after his second punch and Knuckles will perform an uppercut, damaging nearby enemies.
Giant Steps: Press + while on the ground and Amy will take a giant step forward as opposed to a spin dash. This can be repeated so long as there is room. This move is good for getting up steep slopes.
Head Slide Attack: Press during a Giant Step and Amy will slide forward, damaging enemies in her path.
Hammer Jump: Press + while on the ground and Amy will smash her hammer into it, launching her into the air.
Hammer Whirl: Press + in midair and Amy will swirl down toward the ground. If an enemy is hit, she will bounce up.
Hammer Attack: Press and Amy will swing her hammer, damaging enemies immediately in front of her. If on the ground, press again quickly and she will swing it a second time, with farther reach.
High Jump: Press such that the hammer hits a spring and Amy will be launched to great heights.
NOTE 1: This game's Sound Test does not feature corresponding titles. Titles are made in relation to the next game in the series, which features such a Sound Test.
NOTE 2: There are additional entries beyond the regular maximum amount (42) that include unlisted music (especially from the multiplayer modes), empty tracks, sound effects and duplicates. The maximum range is 199; 200 and up crashes the game.
1,210,000 Game Boy Advance US The Magic Box - US Platinum Videogame Chart These sales numbers makes Sonic Advance the only handheld Sonic game confirmed to have sold over one million units in one region.
Some of the game's music is remixed from previous Mega Drive games. The remixed music includes the Options (Sonic 1's Scrap Brain Zone), Player Data (Sonic 1's Star Light Zone), 2P select (Sonic 2's 2P Emerald Hill Zone), invincibility (Sonic 1's Invincibility), and the first two bosses in the X-Zone (Sonic 1 and Sonic 2's boss musics).
There is a mobile port created by Gameloft where you can only play as Sonic the Hedgehog and 3-4 Zones, depending on your device.
This page was last edited on 23 March 2019, at 11:37.


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AFP Modernization & Defense Acquisitions »
PAF Search and Rescue Basing and Hangarage Project
Author Topic: PAF Search and Rescue Basing and Hangarage Project (Read 6123 times)
From Herbie's post from November 15, 2013
From the ITB, "The Department of National Defense/Armed Forces of the Philippines (DND/AFP), through the General Appropriations Act and the AFP Modernization Act Trust Fund 2000, intends to apply the sum of ONE HUNDRED FOURTY EIGHT MILLION, NINE HUNDRED NINETY NINE THOUSAND, THREE HUNDRED SEVENTY EIGHT PESOS, AND TWENTY TWO CENTAVOS (PHP 148,999,378.22) being the Approved Budget for the Contract (ABC) to payments under the contract for the Constructions of the two (2) PAF SAR Basing and Hangarage Projects including Other Requirements...
The project involves the construction of one (1) unit each of SAR Basing and Hangarage at Sanga-Sanga Tawi-Tawi and Puerto Princesa, Palawan and Other Requirements. The plan is to upgrade the capability requirements of the PAF and improve the operational effectiveness by constructing hangars and facilities as support systems to sustain the Search and Rescue Operations of the PAF and support the maritime security and protection of the Malampaya Natural Gas-to-Power Project, Reed bank, and the future Sulu Oil Rig."
PAF SAR Basing and Hangarage Project
It seems the Search and Rescue Seaplane Acquisition Project seems to be "partner" project of this explaining the AESA radar requirement and float capability to give maritime domain awareness and rescue capability at the same time.
PAF LRPA Basing and Hangarage Construction Project (LRPABAHCP)
Some details before from the PAF website.
« Last Edit: October 03, 2016, 08:58:17 PM by Herbie »
Re: PAF Search and Rescue Basing and Hangarage Project
"PAF Search and Rescue Basing and Hangarage Project" Award Notice Abstract
Quote from: Herbie on October 10, 2016, 11:33:33 AM
As of today, no mobilization or start of construction for the 505th's hangars has commenced at the TOG 11.
40niner
Obsolete weapons do not deter.
@Spoon -- the two PAF SAR Hangars will be implemented at Sanga-Sanga, Tawi-Tawi and Puerto Princesa, Palawan. (check out the original/first post)
I think you are confused by the main office address of the winning contractor (Davao-based).
Obsolete weapons do not deter. You do not base a defence policy on someone else's good intentions.
- Apr 7, 1989 [Baroness Margaret Thatcher, UK PM (1979-90)]
Quote from: 40niner on October 11, 2016, 06:42:03 AM
I think I believe so. Thanks for the review and correction sir.


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WildFact
There is a world somewhere between reality and fiction. Although ignored by many, it is very real and so are those living in it. This forum is about the natural world. Here, wild animals will be heard and respected. The forum offers a glimpse into an unknown world as well as a room with a view on the present and the future. Anyone able to speak on behalf of those living in the emerald forest and the deep blue sea is invited to join.
--- Peter Broekhuijsen ---
WildFact › Information Section › Extinct Animals › Prehistoric animals
First intact head of a prehistoric wolf!
animalfan6
06-22-2019, 07:48 AM ( This post was last modified: 06-24-2019, 06:44 PM by animalfan6 )
"The head of the first full-sized Pleistocene wolf has been discovered in eastern Siberia — and it's still intact.
Paleontologists believe the wolf, whose head had been preserved in permafrost for about 30,000 years, was fully grown at 2 to 4 years old when it died. A photo of the head shows it measures 15.7 inches long, which is notably bigger than the 9.1-to-11-inch length of the modern gray wolf's head.
Scientists discovered in recent years that a close relative of modern-day wolves lived in the Northern Hemisphere during the last ice age, said Love Dalén, one of the paleontologists studying the wolf's head. These Pleistocene steppe wolves come from a different evolutionary lineage than modern-day wolves, Dalén said, and were slightly larger with more robust jaw bones.
"There are numerous samples from them in terms of bones and teeth and so on, but this is the first frozen carcass from an adult wolf that has been found," Dalén, of the Swedish Museum of Natural History, said in an interview.
[This puppy was frozen for 12,400 years, and its body is nearly intact — fur and all]
A man who lives in the Abyisky district of Yakutia discovered the head last year. Dalén said he and other scientists were filming a documentary there when a Russian who had been searching for mammoth tusks brought the wolf's head to their camp.
Scientists recently announced the find at the opening of a woolly mammoth exhibit in Tokyo.
The Swedish Museum of Natural History plans to study the wolf's DNA, fur and skull, Dalén said, with help from scientists in Japan, Russia, the United States and other nations. Some of them are creating a digital model of the brain and the skull's interior, Albert Protopopov, of the Republic of Sakha Academy of Sciences, told CNN.
As global temperatures rise, Dalén said melting permafrost is causing more animal carcasses to surface. In this case, though, he said Siberian locals were excavating mammoth tusks by blasting away the permafrost.
[On a Russian outpost in the Pacific, fear and fantasies of a Japanese future]
A cave lion cub and a mammoth foot, among other fossils, also were found at the site.
Some of those other findings are equally or more exciting than the wolf's head, Dalén said, but he is particularly looking forward to trying to use the wolf's DNA to try to sequence the species's genome. That project will take at least another year and a half, he said.
The Pleistocene Epoch stretched from 2.6 million to 11,700 years ago and included the most recent ice age of global cooling. Large land mammals and birds, including mammoths, long-horned bison and saber-toothed cats, were prevalent."
*copyright Washington post*
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There is a father who will take out his anger on his children today. He will cut them to shreds with a sharp rebuke and they will shrink and go into hiding. He's done it before. He even saw the damage in their eyes but that did not deter him.
There is a middle-aged woman who will see dreaded circumstances repeat themselves. She will say, "Oh no, not again!" but she will make the same disastrous choice she made the last time. She does not see that God is giving her another chance in order to do something different.
Reuben, for all his faults, did make a different choice. (Although not one that was drastic enough.) He had sinned against his father many times throughout his youth and had experienced the stab in his own heart as he saw his father's pain. The last offense he committed was sleeping with Bilhah, his father's concubine. With this fresh in his memory, he will not agree to take the life of Joseph, his father's favored son. He cannot bear the thought of Jacob's grief yet again.
Do I really learn from my mistakes? The magical answer is 'yes'. Who is going to repeatedly put their hand over an open flame? That is naïve. When bad behavior is generational, thoughts of stopping happen long after the deed is done. By default, we live as our fathers did.
Jesus told Nicodemus two critical things. 1.) 'That which is born of the flesh is flesh.' We are like whom we came from. I am a product of a mother and father and will possess not only their physical characteristics but their holy and sinful bents as well. I will not deviate without spiritual transformation. And, 2.) 'That which is born of the Spirit is Spirit.' I am to be like by new Father because I was born of His Word and His Spirit. So here's the question that replays in my mind? Am I more like my new Father than my earthly parents? I should be if the new birth and the things of the Spirit are nurtured.
How does this relate to learning from my mistakes? When I repeat the foolishness of my youth, the Spirit of God calls to me. "Why are you doing that? You're now my own daughter and I'm calling you out to be like me, not them." Past mistakes are a mirror. I see the reflection of my former self against the reflection of my brother, Jesus, standing next to me. With just a glance, I walk away and have no appetite for the former things.
← How Do Others Experience Me?


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A Being So Gentle
A Frontier Love Story of Rachel and Andrew Jackson
Patricia Brady
The story of the marriage of Rachel and Andrew Jackson has come down to us as one of the most romantic love stories in American history. But aside from treatment in a chapter of the many biographies of Andrew – Rachel's story has been barely told (at least not since Irving Stone's The President's Lady!).
Although she never made it to the White House, Rachel Jackson was the source of as much controversy as any first lady in history. Even Andrew Jackson's most fervent critics admire him for his devotion to her and his defense of her reputation, which was sullied by the breakup of her first marriage and the timing of her elopement with Jackson.
In A Being So Gentle: The Frontier Love Story of Rachel and Andrew Jackson, historian Patricia Brady gives Rachel and Andrew Jackson, and their devoted relationship, new depth. Their story parallels the narrative of the still-young United States, a country in transition, confronted with new challenges and a new view of itself in the world.
Patricia Brady is the author of Martha Washington: An American Life, which Publisher's Weekly called "a splendid biography offers a compelling new portrait of this passionate, committed founding mother…" In this new book, she introduces us to yet another fascinating American woman, who committed herself to the building of the nation, while maintaining her individuality and her independence.
Published by St. Martin's Press
Praise for A Being So Gentle
A fast-paced political drama combined with a controversial love story that was shocking in its day. A Being So Gentle is, frankly, irresistable.
— John Berendt, author of Midnight in the Garden of Good and Evil


Medical billing training is actually part of the school we talked a couple of articles back, but you can also have a 6 month medical billing training if you are already a finance graduate or you have diploma for some sort of economic studies. The medical billing training is actually very useful for a graduate because it allows them to work in a lot more jobs, and since insurance is needed in all financial situations, it is probably a very good idea to have one of these medical billing training course done, just to be on the safe side in regard with your job and income.
Medical billing training courses are paid by you and usually they are in the range of a thousand dollars for the very advanced ones. You could probably find even cheaper ones, but I recommend getting the best. It will aye on the diploma that your medical billing training was done by a very well known school and that will surely get a better job.
You can also become the trainer or the teacher for the medical billing training program, and that could also be an interesting activity. In fact, many of those that train other in the art of medical billing have once been just like you, with no real experience in the job and with mostly ideas about what they would like to become in their lives.
So, there are a couple of ways to start earning some real money by either practicing medical billing for an insurance company or training other people to do it themselves. Of course, neither of the paths will be very simple, but it is better to struggle a little for something than to wait and see what life has to offer without moving a muscle.
Better still, you could also improve your finance knowledge and skills with a medical billing training program so that a couple of more doors are suddenly opened in your career. It is widely known fact that financial adviser's that can handle several different areas in economic activity are better paid and find a job much easier than those specialized on a single aspect of the trade.
I really recommend this radiology technician profession for those that are just starting to see what life really is about and that are struggling to make a living on washing dishes or repairing cars. Medical billing is simple to understand and you can actually do the course in six months to get your diploma.
De Mier said she and Nick Foles of Arizona air particulates.
interest. I'm going to book mark your site and keep checking for new information about once per week.
The role of the media baron is played by Amitabh Bachchan.
This site is among the leading movie download sites with a number of happy and satisfied customers.
it include such names as Roger Zelazny, Walter Jon Williams and anthology co-creator Melinda Snodgrass.


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Content List
DIY(Do It Yourself)
ancient text
Afropedea Tv
**Blog
Ancient Egyptian Architecture
Ancient Egyptian Architecture is architecture of Egypt during the pharaonic period. Ancient Egyptian Architecture is varied from temples, enclosed cities, canals, and dams.
1 Methods, techniques, materials, tools
2 Palaces
3 Walls
4 Canals
5 Dams
6 Tombs and Pyramids
7 Fortification
8 Temples
Methods, techniques, materials, tools
Initially, Egyptians built with mud. Mud was formed into mudbricks. Mudbricks were dried and hardened in the sun. Structures built with mudbricks would later be plastered with gypsum, giving a fresh shinning white finish. Later, Egyptians would become masters in stones. Limestone would be the material most used. Troyu and the Moqattam Hills, east of Cairo, were the source of numerous quarries from which limestone was cut. Granite was also used for the interior of tombs. Granite was quarried from Swenet, in modern day Aswan. Canals were usually dug to the construction site. Stones weighing tons were ferried on barges to the building sites. Levers and ramps were used to get the stones on sleds. Giant ropes of palm fibers and reeds were made to pull these giant stones in place. Manpower, not slaves but voluntary workers, were used for construction. Oxens were sometimes used for muscle, instead of human.
Egyptians made extensive use of the corbelled arch, which is layering where each top layer overhangs the one below.
Copper was the metal used to make tools. Diorite, hard stone, was used to cut, quarry limestone. Sleds without rollers were used to move large stones. During the Old Kingdom, the age of pyramid buildings, reliefs show 172 men moving a 60 ton statue on sleds without rollers.
Pharaohs built numerous palaces. Palaces were meant to last the lifetime of the pharaohs. They were not meant to last forever like tombs. They weren't built with stones. They were typically built with mudbricks. Because they were built with mudbricks, they did not survive antiquity. The Palaces were rectangular in shape.
The first recorded engineering fit of the Egyptians was the building of the walls surrounding the city of Memphis. Memphis was the capital of Egypt during the Old Kingdom.
The Egyptians were the first to engineer canals on a massive scale. Egyptians dug water-ways that run for kilometers used for both transportation and irrigation(Engineering an Empire: Egypt).
Because of flooding, Egyptians built dams. The Menes Dam, built to protect the city of Memphis is the first recorded dam in history. It did not survive antiquity(Engineering an Empire: Egypt).
Tombs and Pyramids
Tomb engineering was a major endeavor and lead to major architectural innovations. Initially tombs were made of mudbricks called mustabas. Mustabas consisted of surface level structure with different rooms and underground tombs cut out of bedrock. The structures were the beginning evolution of the pyramids. The first attemp at the building of a pyramid was the step pyramid at Saqqara by Pharaoh Djoser. Saqqara represent the first time in history stone architecture is used in the building of a major edifice. The complex consisted of a palace to the north and two buildings representing upper and lower Egypt. The pyramid complex was enclosed by a 3 story limestone wall. It's entranceway was lined with 40 stone columns, 33 ft high. The columns were the first 40 stone columns in recorded history. Later, Snefru , Djoser's heir attempted to build the first true pyramids. His first experiment was the Meydum Pyramid and later the Dashur Pyramid or Bent Pyramid. The first true pyramid was Snefru's Red Pyramid. Later, the largest and tallest pyramid the Great Pyramid of Giza would be built based on the earlier experiments(Engineering an Empire: Egypt).
Fortification
Fortification was a major aspect of Egyptian architecture. To retain territory and deal with threats from the south, Nubia, Pharaoh Sesotris built eight super-forts at Aswan, from Semna to Buhen, the first type architectural structures in the world on par with later Roman and European forts. The most famous was the Buhen Fort, which now resides under Lake Nasser. It could hold 1,000 soldiers. It comprised of multilayer wall and moat; first exterior wall, then moat, second wall with sections for archers. The forts were made of mudbricks(Engineering an Empire: Egypt).
Numerous temples were built by the Egyptians, famous among them was the Temple of Deir El-Bahri built to honor Queen Hatshepsut (18th Dynasty), by architect Senimut. It's a three layered temple connected by ramps. Each layer is donned with colonnades. The third layer consist of a sanctuary with two chapels. Another was the rock carved temple at Abu-Simbel, built by Ramses II, consisting of two atrium, the first atrium consisting of 8 giant statues, then a sanctuary, and side rooms. All were constructed by cutting one giant rock. The Karnak Temple built by Seti, contains 144 columns, seven stories high, with Great Hypostle Hall (Engineering an Empire: Egypt).
Related Article: Common Coptic Names, List of Pharaohs of Ancient Egypt, African Architecture ,Mangbetu Palace ,Ngundeng Pyramid ,Nsude Pyramid
Engineering an Empire: Egypt. Peter Weller(host). Egineering an Empire. Discovery Channel.
L. Sprague De Camp(1963). The Ancient Engineers. MIT Press. SBN 26254008 8(paperback). Library of Congress Card Number: 76-95278.
© 2010 Afropedia.org


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Home National Mi'kmaq lobster fishery in Nova Scotia grows to 10 boats from seven
Mi'kmaq lobster fishery in Nova Scotia grows to 10 boats from seven
National The Staff • September 30, 2020 • Views 108 • Comments off Share
SAULNIERVILLE — An Indigenous-run lobster fishery off the coast of southwestern Nova Scotia is slightly increasing the size of its fleet to 10 boats from seven, creating a total capacity of 500 traps.
Rhonda Knockwood, the director of operations for Sipekne'katik First Nation, says the community's fishery in St. Marys Bay continued through the weekend and on Monday, with five boats fishing, two being repaired and three more licensed by the band.
When the fishery began on Sept. 17, there were seven vessels with 50 traps each, for a total of 350 traps.
The Mi'kmaq harvesters point to a 1999 Supreme Court decision that affirms their treaty right to fish for a "moderate livelihood," though the second part of the decision allows Ottawa to set regulations in consultation with Indigenous communities and for the purpose of conservation.
The Sipekne'katik fishery still represents a small fraction of the commercial lobster licences issued in the fishing area around St. Marys Bay.
The federal Fisheries Department's website indicates that as of December 2018, there were 979 licences to fish the area, with most permitting 375 to 400 traps per licence _ meaning two large commercial boats would take as much as the entire current Mi'kmaq fishery.
Non-Indigenous fishing groups have resisted the fishery, arguing it shouldn't occur outside of the regulated season. A fleet of their vessels removed 350 Mi'kmaq lobster traps from the water on the weekend of Sept. 19-20.
Colin Sproul, president of the Bay of Fundy Inshore Fishermen's Association, has said lobster-fishing season in St. Marys Bay doesn't start until the last Monday of November in order to let the animals reproduce and to make sure their stocks aren't depleted.
Sproul could not be reached for further comment on Monday.
Last week, Sipekne'katik Chief Mike Sack said in a news release that the next challenge for his community is to alter provincial laws that are making it difficult for the Indigenous harvesters to sell their catch.
He has called for a meeting with Nova Scotia Premier Stephen McNeil to discuss how to better define what constitutes a "moderate livelihood fishery."
Sack said he recognizes it is currently illegal under provincial law for people to purchase lobster caught outside the commercial fishing licence system, which is operated by the federal Fisheries Department.
The First Nation leader has called on the premier, who is also the provincial minister of Aboriginal Affairs, to "remedy the legislated gaps." A spokesman for the premier said he was unavailable for comment on Monday.
The provincial Fisheries Department has said it is up to Ottawa and the Mi'kmaq of Nova Scotia to work out what constitutes a moderate livelihood fishery, as the province relies on the federal regulations to define what can be legally bought and sold.
"We encourage the federal government and Mi'kmaq of Nova Scotia to continue this important dialogue," the department said in an emailed statement.
Cheryl Maloney, consultation director for Sipekne'katik First Nation, said in an email that the new boats being brought into the St. Marys Bay fishery are financed by the harvesters.
"They have to fund their own fisheries. So as their boats and crews meet safety and insurance requirements, they can access (band licence) tags," she wrote.
Meanwhile, Knockwood said the confrontational actions of non-Indigenous harvesters on the waters off St. Marys Bay have ceased. "They're not in the bay and they're not pulling up our traps," she said.
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Origins of Totalitarianism
by Joshua Clover
Missy Elliott - The Cookbook
We need to change this poll now, today, because even ignoring its TOTAL INCAPACITY to reflect how music listening has changed over the last 30 years and especially the last seven, it is also STRAIGHT-UP RACIST: even if all the Dicks and Janes and ILXors know how put rainbow sprinkles on their lists and have dipshit threads about tokenism, this poll itself is structurally slanted away from how music is made outside of the crack-white universe in which the singer-songwriter is the hysterically disavowed totalitarian ideal that dominates rock and indie and the electronic diaspora and every other I'm-a-genius-and-here's-my-record form, and occasionally spits out an actual genius but mostly is just like getting beaten up by Big Willie in the prison yard the very morning after he's appeared on Conan acting sensitive and urging us to vote Democratic.
So listen: until I can vote for something like Artist of the Year and point out that Jazze Pha who—no offense to Ciara who seems supercharming and Missy who is my second favorite rap star ever—but if we can name names at all in the way this poll presumes is somehow natural then we would have to name Jazze Pha for both "Lose Control" and "1, 2 Step" which right there gives him one more perfect song than the guy who will win this poll and oh also he made tremendous tracks on albums by Nelly, Slim Thug, Young Jeezy, Bun B, Trina, David Banner, Jacki-O and I can't even remember what all else, this was his year even if he's not a sonic adventurist on par with the other great producers of the millennium but this is his year because he made more good minutes of music listening than anyone else but also because he is better at narrating both cultural history and daily life through dance beats than anyone since Nile Rogers & Bernard Edwards which is to say Jazze Pha makes the most embodied music of this particular time and Place.
More:Ciara (Singer)Jazze PhaNelly (Rapper)Pazz & JopTrina (Rapper)


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Volker Anger (ur. 2 maja 1968) – wschodnioniemiecki, a potem niemiecki zapaśnik walczący w stylu wolnym. Olimpijczyk z Seulu 1988, gdzie zajął siódme miejsce w kategorii 48 kg.

Czwarty na mistrzostwach Europy w 1988; piąty w 1994 roku.

Mistrz NRD w 1986 i 1989; trzeci w 1985. Mistrz Niemiec w 1992-1995; drugi w 1996 roku.

Przypisy

Wschodnioniemieccy olimpijczycy
Wschodnioniemieccy zapaśnicy
Niemieccy zapaśnicy
Uczestnicy Letnich Igrzysk Olimpijskich 1988
Urodzeni w 1968
Ludzie urodzeni w Berlinie

redpajama_set_name: RedPajamaWikipedia


Undertale is a role-playing video game created by indie developer Toby Fox. In the game, players control a human child who has fallen into the Underground, a large, secluded region underneath the surface of the Earth, separated by a magic barrier.
Many people think that they could survive Undertale easily, but can they really? In reality, it's all about the little choices you make. See if you would survive here!
What route are you gonna do?
Pacifist. Even though I may be thrown into life threatening situations, killing is wrong.
True Pacifist. I fit the above criteria and I'm a friendly person who would surely make friends with everyone!
Neutral. Even if killing is wrong, I may not have a choice.
*No more running away! Here I come!
b.. but... p!!!!!!!!!!!! OK!! TEM BUY DogResidu FOR 5G!!!
Which of these do you find most threatening?
You have the option to FLIRT with these monsters in the game. Which one should you NOT flirt with if you value your life?
Walk to the next room and drop it.