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International competition law: extraterritoriality matters, conflicts of decisions

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  1. Extraterritoriality matters
    1. In the USA
    2. In Europe
  2. Conflicts of decisions

One criterion in Europe: effect doctrine.
Competition rules exist on the European scale, but we don't have a worldwide competition law.
In the past, the WTO tried to set up a worldwide code with antitrust rules: the Munich Group.
It was hard to reach an agreement between countries, mostly for the US and African countries.

The first problem for the US to refuse:
- the American rules are supposed to be the best one in regards competition law. (Sherman Act 1890 vs our treaty 1957).
- WTO would be a way for smaller countries to coordinate against the USA.

African refused: Behavior of smaller countries, African countries: would be a way for bigger countries to penetrate their local economies (there are great barriers of entry in those countries).

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