Comment from Alexandros Kazimirov (Former Research Fellow at the American Antitrust Institute)
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Summary: Alexandros Kazimirov, an academic/scholar, supports the revision of the Collaborations Guidelines to address "quasi-mergers" and "acquihiring" in AI markets. He argues that the guidelines should be updated to prioritize substance over form, allowing agencies to challenge agreements that effectively displace nascent competitors despite preserving nominal independence.
This comment consists of a brief proposal of recommendations addressing some gaps in the 2000 Collaboration Guidelines, and a law review article delving into greater depth on certain novel types of acquihiring in artificial intelligence markets. If the staff are willing to further inquire about the comment’s suggestions, I’m happy to answer any questions.
Disclosure: I have no conflicts to report. All writing is my own and no AI tools were used in writing this comment. The comment is not legal advice.