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Concurrences
Revue des droits de la concurrence
Competition Law Journal
Sharis A. Pozen: An insider’s
candid views of competition
issues past and future
Interview l Concurrences N° 4-2012
www.concurrences.com
Sharis a. Pozen
[email protected]
l Partner, Skadden, Arps, Slate, Meagher, & Flam LLP
l Former Acting Assistant Attorney General for the Antitrust Division
of the U.S. Department of Justice, Washington, D.C.
Sharis A. Pozen*
[email protected]
Partner, Skadden, Arps, Slate,
Meagher, & Flam LLP
Former Acting Assistant Attorney General
for the Antitrust Division of the U.S.
Department of Justice, Washington, D.C.
August 2011 to April 2012
Acting Assistant Attorney
General, Antitrust Division, U.S.
Department of Justice
February 2009 to August
2011
Principal Deputy Assistant
Attorney General, Antitrust
Division U.S. Department
of Justice
Chief of Staff and Counsel,
Antitrust Division U.S.
Department of Justice
January 2000 to February
2009
Partner, Private Practice, Antitrust
Practice Group Director and
Administrator
September 1989 to January
1995
U.S. Federal Trade Commission
Attorney Advisor, Commissioners Yao and
Varney
Counsel, Office of Competition Bureau
Director
Staff Attorney, Competition Bureau
* Interview conducted by Tiffany Rider, Counsel, Skadden,
Antitrust and Competition Practice
* Sharis A. Pozen, former acting assistant attorney general
of the Antitrust Division of the U.S. Department of Justice,
discusses her career in government and her most significant
matters at DOJ. Ms. Pozen also offers her thoughts on how
to engage with antitrust authorities and her view of
the trends to watch in antitrust enforcement. She is one of
the few antitrust practitioners who has served in high-level
positions at both the DOJ and FTC.
Sharis A. Pozen: An insider’s
candid views of competition
issues past and future
You have had a successful career both in the government, at the U.S. Department
of Justice (DOJ) and Federal Trade Commission (FTC) — and in private practice.
Can you discuss your keys to success and your most recent transition from Acting
Assistant Attorney General at DOJ back to private practice?
I have been very lucky throughout my career, in government and in private practice,
to work with some of the very best antitrust attorneys, and they have been my role
models. They taught me so much about so many things. As a result, I have three things
that I live by and I believe they have been keys to any success I’ve had. First, do the
best work every time because everything counts. And this is something I learned the
hard way – I know I didn’t do my very best work every time. So for example, if you
are sending an email, go back and read it one more time, whether you are sending it
to a colleague or a client, because everything you do reflects on you as an attorney
and as a colleague. Second, get to know people in your field. Meet others through
work and get involved in organizations that include others in your field, like the
ABA, the IBA or your local bar association. If you executed the first point of doing
good work, then the people who get to know you may recommend you for different
positions. This is what has happened to me over time. Almost every job I held in
government or private practice came through a colleague recommending me. Third
and finally, don’t give up on antitrust or on law generally. It is a terrific field, I say
this particularly for the junior practitioners. You have to balance a lot – personally
and professionally. But you can do it, so long as you have supportive people at home
and work.
As for transitioning between government and private practice, the pressures are very
different. When I initially went from the FTC into private practice, I was worried
about what it was going to be like to work for corporations. But I found that the
analysis is the same, whether you are working for the government or corporations.
And in private practice, clients want an accurate and realistic assessment of the
antitrust risks associated with their proposed transaction, agreement or conduct.
I always look at it like this: I assess the antitrust risk; they make the business decisions.
Why did you choose to join the antitrust Bar? What will your practice be focused on
in private practice?
You come out of the government without a team and with former clients, not actual
clients. So I was looking for a great team. I was looking for the full package of talented
partners, counsel, associates and support staff with whom to work. The Skadden
antitrust group is full of exceptional lawyers that produce high-quality work.
They have an excellent reputation for top-notch work and high ethical standards.
I actually talked to colleagues inside and out of government about Skadden prior
to accepting its offer, and the report was always the same – they are some of the
very best antitrust attorneys with whom I have worked. I also wanted an antitrust
practice with a solid client base, which they have. Skadden also has a broad antitrust
practice that supports my practicing all facets of antitrust law – M&A, conduct,
criminal and litigation.
Your tenure as Acting Assistant Attorney General of the Antitrust Division is likely
best known for the challenge to AT&T/T-Mobile. Can you walk through some of
the highlights and significance of that matter?
While we received a lot of attention for suing to stop the merger, it was clear to us from
the beginning that under the Horizontal Merger Guidelines, the proposed transaction
Concurrences N° 4-2012 I Interview
1
S. A. Pozen: An insiders candid views of competition issues past and future
Ce document est protégé au titre du droit d'auteur par les conventions internationales en vigueur et le Code de la propriété intellectuelle du 1er juillet 1992. Toute utilisation non autorisée constitue une contrefaçon, délit pénalement sanctionné jusqu'à 3 ans d'emprisonnement et 300 000 € d'amende
(art. L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
@ Interview
On the non-merger side, we also took cases to trial. I am
hopeful that the challenge to the merchant rules in the
American Express litigation, the challenge to most-favored
nation clauses in BCBS of Michigan, and the challenge
to illegal coordination and agreements among market
participants in the e-books case will advance antitrust
jurisprudence and give the private bar and business more
clarity and certainty in these important areas.
The resources involved also were significant. AT&T had,
at last count, up to nine law firms engaged advocating for
the merger. DOJ needed help, and we brought in Glenn
Pomerantz and David Dinielli from Munger Tolls – both
expert antitrust litigators. They were a terrific support to our
trial team and to now Acting Assistant Attorney General,
Joe Wayland, who was lead trial counsel on that matter.
A common question is why did we sue when we did?
The answer is actually quite simple. We had completed
our review and had all the information from the parties.
We spent extra time reviewing the alleged efficiencies, and
we communicated with the parties throughout the process.
We also were also very concerned that T-Mobile was being
diminished as a competitor in the marketplace, given the
pending merger and the media attention around it. We did
not feel that it was any surprise.
Is there an experience at DOJ that stands out — a memory
you can share?
I distinctly remember going to the Supreme Court to hear
the argument in American Needle, Inc. v National Football
League. I attended with Christine Varney, then Assistant
Attorney General, we both had applied to be members
of the Supreme Court bar, and were sworn in prior to the
argument. Becoming part of the Supreme Court bar that
day allowed us to sit in front of the bar for the argument.
The combination of the argument for an antitrust case
with the Justices delving deeply into antitrust law, in a case
in which I had been involved in shaping, attending with
Christine Varney and being sworn in prior to the argument
by my former partner, now Chief Justice Roberts, culminated
into quite a memorable event. I guess you can say I was in
antitrust heaven, particularly when the court largely adopted
the government’s analysis of the issues in its subsequent
decision.
Another common question is whether we were influenced by
the promise of job growth or by the many commercials in the
Washington, D.C. area focusing on this issue. We were aware
of the political discussion that involved jobs, but job growth
is relevant to antitrust analysis to the extent it would bear on
increasing competition and, in turn, innovation, and growth.
While at DOJ, what did you see as your most significant
accomplishments?
Within criminal enforcement, we stayed focused on large
international cartels, while also bringing a number of smaller
cartel cases. On the large cases, we coordinated effectively
with international enforcement authorities to prosecute
these antitrust violations that are so harmful to consumers.
This work in criminal enforcement will hopefully promote
detection and deterrence going forward.
What do you think is the best way to engage with antitrust
authorities and more generally with policy-makers and
regulators in Washington? Can you give examples of what
you saw that worked and what didn’t?
You need to find a way to engage constructively. Certainly
make your affirmative case through marshalling the facts and
case law. But if there are weaknesses, then it is best to admit
to them and explain why they do not matter, rather than
try to deny the obvious. It also helps to be respectful of the
government’s process. It is a process and can take time. The
government has a job to do, and things move along smoother
if you help them do that job.
Within merger review, we took the challenge of the proposed
acquisition by H&R Block Inc. of Tax ACT through a full
trial on the merits. It yielded a thorough judicial opinion,
which I believe advances antitrust jurisprudence in the area
of merger review, particularly in the District Court for the
District of Columbia. We also infused the Division staff with
trial lawyers.
Concurrences N° 4-2012 I Interview
You also have to play it straight with the government.
If you don’t, it can lead to significant issues and delay in a
particular case and have a lasting impact on in any future
matter you or your client have before the government. We
had a situation where the parties were not cooperative in a
2
S. A. Pozen: An insiders candid views of competition issues past and future
Ce document est protégé au titre du droit d'auteur par les conventions internationales en vigueur et le Code de la propriété intellectuelle du 1er juillet 1992. Toute utilisation non autorisée constitue une contrefaçon, délit pénalement sanctionné jusqu'à 3 ans d'emprisonnement et 300 000 € d'amende
(art. L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
On AT&T/TMobile: “While we received a lot of attention for suing to stop the merger, it was clear to us from the beginning that under the Horizontal Merger Guidelines, the proposed transaction was presumptively anticompetitive.”
was presumptively anticompetitive. When we reviewed
whether the potential benefits of the proposed transaction
outweighed the likely competitive effects, the parties did not
present us with evidence that convinced us otherwise. We
also had good coordination and communications with the
Federal Communications Commission (FCC). Those lines of
communication were initially established during the review of
Comcast/NBC Universal and served the agencies well for the
review of AT&T/T-Mobile. It was good communication at
all levels, from the front office to the staff. They are the expert
agency on wireless communications and have the engineering
expertise that helped analyze the parties’ arguments on
several crucial technological issues.
we wanted to ensure we coordinated with all three agencies.
The MOU provides for specific high-level communication
among the DOJ, FTC and China’s three agencies, as well
as additional cooperation and communication. In addition,
the MOU that was signed on September 27 among India’s
competition authority, DOJ and FTC is a great achievement.
It also will allow regularized coordination and cooperation
among these agencies.
What do you see as the international competition challenges
going forward?
The processes and procedures for antitrust reviews can be
different in different countries. There are a variety of antitrust
regimes based on the culture and tradition of a given country.
And most mergers or non-merger investigations occur in
multiple jurisdictions, all within the same time frame. I think
it has been and will continue to be important to interact
with the various competition authorities in play on a given
matter at the right time and in the right way. This will be
particularly important and challenging with some of the
emerging competition regimes, such as the BRIC countries.
What changes did you see come out of the 2010 Horizontal
Merger Guidelines, either from the agencies or practitioners?
The 2010 Horizontal Merger Guidelines did not change the
analytical approach within the agencies, but instead more
accurately reflected the analytical approach that existed.
The revised guidelines were an effort in transparency. Those
practitioners that were before the agencies on a regular basis
knew this was the practice, but we wanted it accessible to all.
There were specific changes that more accurately reflected the
practice. For example, while we may plead a product market
once a case is to the point of filing a complaint with a court,
we start with an effects based analysis within the agencies.
The Guidelines made that clearer. In addition, the HHIs were
adjusted, as was the timeframe in which new entry will be
considered, and what type of efficiencies will be recognized.
Guidance also was added on price discrimination and
partial acquisitions. I have not seen much change from the
practitioners, although there may be more use of UPP data
presented in cases where data is available and it is relevant to
the analysis.
“It has been and will continue to be important to interact with the various competition authorities in play on a given matter at the right time and in the right way. This will be particularly important with the emerging competition regimes, such as the BRIC countries.”
Are there any hot areas in antitrust of which to be aware?
Healthcare, media, technology and communications, and
financial services all are industries where we have seen merger
and non-merger antitrust activity, and for financial services,
even cartel behavior. Whether it is because of consumer
trends, innovation or government regulation, these industries
have seen changes and will continue to be areas where the
antitrust laws will be highly relevant in the near future.
Along with these, the intersection of intellectual property
and antitrust is likely to be active, as we have witnesses in the
public statements of government officials around the world
on standard essential patents, and through the litigation that
is on-going related to this area.
Will you stay involved in the international antitrust scene?
Yes. Through my time at the DOJ, I developed relationships
with many people in international competition authorities.
I recently had the opportunity to participate in the
International Bar Association’s 16th Annual Competition
Conference in Florence with a number of international
competition leaders and practitioners. I also had the
great pleasure of speaking on a panel regarding leniency
programs at the request of the Italian competition authority.
These events were interesting forums at which we brought
together experiences and ideas from different perspectives
and different jurisdictions. I hope to continue to be involved
in these activities and interact with international competition
authorities at a policy level.
What are the international competition efforts and
accomplishments you are most proud of from your time at DOJ?
The level of coordination and communication with
competition authorities internationally was tremendous. The
Division has extraordinarily close relations with a number
of international antitrust authorities, as is evidenced by the
references to such in many public statements and speeches by
the leaders of those organizations. In particular, I am proud
of the Memorandum of Understanding (MOU) that the DOJ
and FTC signed with the China’s antitrust agencies. It was a
challenge, given that China has three antitrust agencies, and
Concurrences N° 4-2012 I Interview
There has been an effort to increase cooperation among
the antitrust authorities both in merger review and cartel
enforcement. Has that been achieved? Is there further to go?
I think we achieved what we sought out to do. The Division
has done a lot to increase cooperation and communication
with International competition authorities. Rachel
3
S. A. Pozen: An insiders candid views of competition issues past and future
Ce document est protégé au titre du droit d'auteur par les conventions internationales en vigueur et le Code de la propriété intellectuelle du 1er juillet 1992. Toute utilisation non autorisée constitue une contrefaçon, délit pénalement sanctionné jusqu'à 3 ans d'emprisonnement et 300 000 € d'amende
(art. L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
non-reportable investigation. They met with Division staff
on a Friday, once again not bringing the relevant documents
and information requested, and then proceeded to close
the transaction, without telling us, over that weekend. On
Monday they told us that the deal was closed, and we sued
on Tuesday because we believed the transaction substantially
reduced competition. We eventually worked out a solution to
resolve our concerns, but not without a lot of resources being
expended on both sides, including for a court appearance.
I would put that in the category of misguided. Government
attorneys have long memories and do not forget such events.
Ce document est protégé au titre du droit d'auteur par les conventions internationales en vigueur et le Code de la propriété intellectuelle du 1er juillet 1992. Toute utilisation non autorisée constitue une contrefaçon, délit pénalement sanctionné jusqu'à 3 ans d'emprisonnement et 300 000 € d'amende
(art. L. 335-2 CPI). L’utilisation personnelle est strictement autorisée dans les limites de l’article L. 122 5 CPI et des mesures techniques de protection pouvant accompagner ce document. This document is protected by copyright laws and international copyright treaties. Non-authorised use of this document
constitutes a violation of the publisher's rights and may be punished by up to 3 years imprisonment and up to a € 300 000 fine (Art. L. 335-2 Code de la Propriété Intellectuelle). Personal use of this document is authorised within the limits of Art. L 122-5 Code de la Propriété Intellectuelle and DRM protection.
Brandenburger agreed to join the Antitrust Division as
Special Advisor, International and she played a key role in
promoting communication and transparency. That said,
this is an area where there is always more you can do and
there will need to be conscious ongoing efforts to make it
successful. While at the Division we interacted with many
experienced international competition authorities, and we
learned from other jurisdiction’s experiences as much as they
learned from ours.
We are seeing an increase in the number of private damage
actions in the US. What role do you believe agencies should
play in promoting those? Will the increase hurt leniency
programs?
The agencies have a fine line to walk. The agencies are not
directly involved in these actions. However, these actions
can impact, for example, leniency programs. A key issue
that has emerged in Europe recently is whether the private
claimants can access leniency documents. The fundamental
issue is whether the leniency applicant can be worse off
with the private damage claimants because they choose
to seek leniency. The U.S. has Antitrust Criminal Penalty
Enforcement and Reform Act that allows leniency applicants
to cooperate with claimants in exchange for a limit of single
civil damages. So the incentives start to align in the U.S. for a
leniency applicant to cooperate with the DOJ and claimants,
and benefit from it. While agencies desire restitution for the
victims of antitrust violations, the greatest detection and
deterrence tool can be the leniency program. Therefore,
international competition authorities should continue to be
mindful of protecting the success of their leniency programs
and maintaining the appropriate incentives to attract
leniency applicants. In this vein, the European Commission
has recently expressed their intent to propose EU-wide
legislation to give leniency applicants predictability.
Any predictions on what we’ll likely see from the antitrust
agencies in the coming year?
DOJ is headed on the right track, with a strong team in
place under Joe Wayland’s leadership. If Obama wins,
which I believe he will do, then Bill Baer, the White House’s
nominee, hopefully will be quickly confirmed as Assistant
Attorney General. I think Bill will continue on the same
track. You’ll have another steady hand at the Department
of Justice.
At the FTC, the White House has named Professor Wright
as its nominee to replace Commissioner Rosch. We will
all watch that confirmation process with interest and if
confirmed, see Professor Wright’s antirust expertise brought
to the Commission.
And there’s no question both agencies will continue to
vigorously enforce the antitrust laws.
n
Concurrences N° 4-2012 I Interview
4
S. A. Pozen: An insiders candid views of competition issues past and future
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