CONSPIRACY AND COMPETITOR COLLABORATIONS
OUR SERVICES
We practice federal competition law, have provided Canadian competition law advice to clients across Canada and internationally and provide a full range of competition law and foreign investment law services including in relation to the criminal conspiracy, merger, abuse of dominance, misleading advertising and deceptive marketing provisions of the federal Competition Act. Our competition law services in relation to criminal conspiracies include:
- Application of the criminal conspiracy offences to commercial activities.
- Application of the new civil rules under the Competition Act amendments.
- Structuring commercial agreements, joint ventures and strategic alliances.
- Competition law compliance programs for companies and trade associations.
- Guidelines for meetings and information exchanges.
- Application of the Competition Bureau’s immunity and leniency programs.
- Applications for binding competition law advisory opinions.
OVERVIEW OF CONSPIRACY LAW IN CANADA
As a result of the recent sweeping amendments to the Competition Act (the “Act”), the criminal conspiracy provisions of the Act, considered to a “cornerstone” of the Act and Canadian competition law, have been amended. Effective March 12, 2010, Canada will now have a dual-track criminal conspiracy regime with “per se” criminal offences for three forms of “hard core” criminal agreements (i.e., with no requirement to show any adverse market effects on a relevant market(s)) and a second civil reviewable matters provision under which other non-hard core agreements may be subject to review.
This new U.S.-style criminal conspiracy regime is meant to make the enforcement of hard-core criminal cartel activity easier (by removing the former competitive effects test) while at the same time allowing non-hard core agreements, such as joint venture and other agreements where a more detailed analysis of the potential effects on a market may be warranted, to be subject to more detailed scrutiny.
The enforcement of the criminal conspiracy provisions, which can apply to a wide range of commercial agreements and arrangements (e.g., joint venture, franchise, dual distribution and license agreements – in short any commercial arrangement between competitors or potential competitors), remains a top enforcement priority for the Bureau. Moreover, in the past fifteen years there have been more than eighty convictions for cartel offences in Canada with total fines of approximately $250 million.
Some of the key impacts of the new conspiracy provisions on Canadian and international firms include: (i) substantially increasing the risk associated with “hard core” cartel agreements (i.e., bare price fixing, market division or supply restriction agreements), as a result of the lower legal burden and higher penalties, (ii) altering the review of many common forms of commercial agreements (e.g., franchise, license, dual distribution and joint venture agreements), (iii) increasing the importance for trade associations and companies to review existing (or adopt new) competition compliance programs and (iv) enhancing the importance of reviewing and controlling dealings with competitors (e.g., information exchanges, etc.).
Canada’s new criminal conspiracy regime, which is part of Canada’s new competition law, is discussed in more detail below.
Criminal Offences - Section 45
Under the new conspiracy provisions of the Act, three categories of agreements are now “per se” criminal offences (i.e., with no requirement to establish any negative effect on a relevant market or markets). All other forms of agreements among competitors will be potentially subject to review under a second and separate non-criminal reviewable matters provision.
The following three types of agreements will be per se illegal: (i) agreements to fix, maintain, increase or control the price for the supply of a product (price fixing agreements); (ii) agreements to allocate sales, territories, customers or markets for the production or supply of a product (market division/allocation agreements); and (iii) agreements to fix, maintain, control, prevent, lessen or eliminate the production or supply of a product (supply restriction agreements). Interestingly, the new provisions omits any express reference to group boycotts which, together with bid rigging, has traditionally completed the group of so-called “hard core” anti-competitive forms of agreements both in Canada and internationally (though the language of the new supply restriction offence is broad enough to likely cover group boycotts).
“Competitor” is defined broadly to include potential competitors (i.e., “a person who it is reasonable to believe would be likely to compete with respect to a product in the absence of a conspiracy, agreement or arrangement”). As such, agreements and arrangements between parties that are not actual competitors may also potentially be caught (e.g., in a franchise arrangement, where a franchisor does not currently but could compete with its franchisees).
It is also worth noting that while the previous conspiracy provisions applied to both vertical and horizontal agreements (e.g., supplier-distributor-consumer and competitor-competitor agreements), the new criminal provisions are restricted to horizontal agreements between competitors (and potential competitors). In this regard, the ambit of the new conspiracy provisions has been narrowed. Moreover, it is likely that the majority of allegedly anti-competitive vertical arrangements and agreements will be reviewed under the new civil provision or other reviewable matters provisions, such as the civil abuse of dominance provisions of the Act.
Some of the impacts of the new conspiracy provisions include a lower burden to establish criminal conspiracies in Canada, an increased risk for parties engaged in “hard core” anti-competitive agreements (e.g., price fixing or market allocation agreements) and altering the framework for the analysis of non-hard core commercial agreements (e.g., franchise, license, dual distribution and joint venture agreements).
Defences
The recent amendments have also introduced a new ancillary restraints defense that will apply where it can be shown that: (i) the agreement is ancillary to a broader or separate agreement that includes the same parties; (ii) the agreement is directly related to, and reasonably necessary for giving effect to, the objective of the broader or separate agreement; and (iii) the broader or separate agreement does not itself constitute an offence under section 45. Other pre-existing exceptions, including for agreements between affiliates, will still apply.
In addition, the new civil provision (section 90.1) will include an efficiencies defense that will apply where an agreement has resulted in (or is likely to result in) efficiency gains that are greater than, and will offset, the adverse effects of the agreement (i.e., any prevention or lessening of competition that will result or is likely to result from the agreement). In this regard, the new civil provision dealing with non-criminal anti-competitive agreements will be more closely aligned with the existing merger provisions of the Act.
Civil Section – Section 90.1
Under the amended Act, agreements among competitors that are not caught by the three new per se criminal offences will be potentially reviewable under the new civil reviewable matters provision.
Such agreements may include, for example, non-compete agreements, research and development agreements, joint purchasing agreements, joint production agreements, joint selling and commercialization agreements and information sharing agreements (i.e., vertical agreements involving competitors or potential competitors that are not “hard core” anti-competitive agreements caught under section 45).
The Tribunal will be able to, on an application by the Commissioner, make remedial orders where it is established that the agreement prevents or lessens (or is likely to prevent or lessen) competition in a relevant market. The Tribunal may make an order: (i) prohibiting any person (whether or not a party to the agreement) from doing anything under the agreement or (ii) requiring any person, with their consent, to take any other action. Unlike the criminal conspiracy provisions, the Tribunal will not have any power to impose monetary penalties and private parties will not have any right to commence private actions.
Enforcement
The Bureau has broad powers of investigation under the Act in relation to conspiracies. These include the power to obtain search warrants (including for computer searches), orders to compel testimony, to compel written returns under oath and wiretaps.
In Canada, prosecution of criminal conspiracies is the responsibility of the Public Prosecution Service of Canada (the “PPSC”), which is headed by the DPP. Criminal matters are referred to the PPSC by the Bureau, which has the authority to determine whether to commence criminal proceedings. Criminal prosecutions are brought in Canadian criminal courts and, while the DPP has official responsibility for criminal competition matters, the Bureau will typically work alongside the DPP during the course of a prosecution.
Penalties
Under the new legislation, the penalties for contravention of the criminal conspiracy provisions have been increased to include fines of up to $25 million (per count) and/or imprisonment for up to 14 years (increased from the previous $10 million per count and 5 years). Canadian courts may also issue “prohibition orders” prohibiting the continuation or repetition of an offence and order a party to take certain steps to avoid future offences and comply with the law (e.g., to implement a corporate compliance program).
In reality, however, most penalties in Canada for violations of the criminal conspiracy provisions arise as a result of plea negotiations between the Bureau and accused.
Competition Bureau Immunity Program
The Bureau has a formal immunity program that is intended to encourage participants in criminal cartels to disclose their illegal conduct to potentially receive immunity from prosecution. The Bureau’s immunity program is set out in a Bureau Information Bulletin. Immunity applications are made to the Bureau, which will determine whether to recommend to the DPP that the request be granted. In general, a party may receive immunity where they are the first to approach the Bureau with evidence of a cartel offence that the Bureau is unaware of or, alternatively, of which the Bureau is aware but has insufficient proof to refer the matter to the DPP.
Other requirements that a party must satisfy in order to obtain immunity include immediately taking steps to stop its involvement in the illegal conduct, it cannot have coerced unwilling parties to participate in the conspiracy, it must give full, frank and truthful disclosure of all evidence and information it knows (or is available to it), it must disclose all offences under the Act in which it may be involved (i.e., not limited only to conspiracy offences) and must agree to provide full, timely and continuous cooperation during the Bureau’s investigation.
Private Damages Actions
Under section 36 of the Act any person that has suffered loss or damage as a result of a contravention of the criminal provisions of the Act, including the criminal conspiracy provisions, may commence a damages action. Class actions are also possible for violations of the criminal provisions of the Act in some cases.
COMPETITION BUREAU ISSUES
FINAL COMPETITOR COLLABORATION GUIDELINES
On December 23, 2009, the Competition Bureau (the “Bureau”) issued its final Competitor Collaboration Guidelines (the “Collaboration Guidelines”). The Collaboration Guidelines, which have been issued to coincide with the upcoming coming into force of Canada’s new criminal conspiracy rules and replace the Bureau’s earlier Strategic Alliances Guidelines, set out the Bureau’s enforcement approach to Canada’s new two-track criminal conspiracy regime under sections 45 and 90.1 of the federal Competition Act (the “Act”).
General Analytical Framework
In general, the Bureau states that mergers will be reviewed under the existing merger provisions of the Act and that most vertical agreements will be analyzed under the civil provisions of the Act (e.g., the new civil price maintenance and existing abuse of dominance provisions). Exceptions may include dual distribution agreements (i.e., where a supplier may compete with one or more of its customers).
With respect to determining whether to evaluate agreements under the criminal or civil track, the Bureau indicates that only naked restraints (i.e., bare price fixing, market allocation and output restriction agreements) will be reviewed under the new section 45. With respect to the process for review of agreements under section 45 (hard-core criminal offences), the Bureau indicates that it will take the following approach: (i) determine whether to review the agreement/arrangement under the criminal or civil provisions, (ii) if reviewing an agreement under section 45, determine whether in its view the new ancillary restraints defence applies, (iii) where it determines that the ancillary restraints defence applies, it may still seek a remedy under the civil provision (section 90.1) or (iv) refer the matter to the Director of Public Prosecutions for prosecution.
Given that there will be no existing Canadian jurisprudence to interpret the new ancillary restraints defence when the new criminal cartel provisions come into force in March, 2010, in the first few years after the new provisions are in force American jurisprudence will be important to interpret the new provisions. In this regard, the United States has had a two-track criminal cartel regime for over a century, with hard core agreements reviewed under a per se rule (encompassing for the most part bare price fixing agreements) and non-hard core agreements analyzed under a second separate “rule of reason” approach that considers the pro- and anti-competitive effects of challenged agreements. Unlike Canada’s new regime, however, which has now expressly codified a two-track approach to criminal conspiracies, the United States has over a century of case law that has interpreted Section 1 of the Sherman Act that does not explicitly set out the categories that are proscribed.
Section 45 – Hard Core Anti-competitive Agreements
The Bureau indicates in its new Competitor Collaboration Guidelines that section 45 will be reserved for the review of hard core agreements (i.e., price-fixing, market allocation and output restriction agreements between competitors and potential competitors) while other types of agreements, such as joint venture agreements, will potentially be subject to review under the new civil provisions.
With respect to the existence of an agreement, the Bureau confirms existing jurisprudence (e.g., that there must be a “meeting of minds”, that informal or covert arrangements may be caught, a cartel may be established whether or not the arrangement has been implemented and that an agreement may be established based on only circumstantial evidence). With respect to one of the most difficult and controversial areas of criminal cartels – i.e., “tacit agreements” or “conscious parallelism” – the Bureau takes the position that “parallel conduct coupled with facilitating practices, such as sharing competitively sensitive information … may be sufficient to prove that an agreement was concluded between parties.” With respect to determining whether parties are competitors for the purposes of section 45, the Bureau confirms that the impugned agreement must be in relation to a product in relation to which the parties compete (or are likely to compete).
One of the most challenging issues likely to be faced by competition counsel will be what arguments can be made in situations of common control or where individuals or entities may reasonably be considered to be a single legal entity (and, therefore, that the conspiracy provisions should not apply). Whereas the United States has developed an intra-enterprise doctrine, under which entities that are in fact a single legal entity may be immune from the application of the Sherman Act, it remains to be seen whether a similar doctrine will develop in Canada. This is key considering that the exceptions under section 45, including the pre-existing bright line exception for agreements between affiliates, are relatively narrow and do not provide express exceptions for agreements in other types of commercial arrangements (e.g., for principals and agents, partnerships, etc.). The Bureau does indicate, however, that there may be some latitude for arguing that parties in other types of commercial relationships may, despite the existence of an express exception, nevertheless be considered by the Bureau to be a single economic entity (which was not present in the Bureau’s earlier draft guidelines):
“Parties should note that this exception applies only to companies, and not partnerships, trusts or other non-corporate entities or individuals, although the Bureau will consider the nature of any common control or relationship between the parties when determining whether referral of an agreement for prosecution is appropriate.”
With respect to trade associations, the new Collaboration Guidelines indicate that there may be increased exposure for associations that facilitate anti-competitive agreements. In this regard, the Bureau states that “rules, policies, by-laws or other initiatives enacted and enforced by an association with the approval of members who are competitors, are considered by the Bureau to be agreements between competitors for the purpose of section 45.” The Bureau’s position that trade associations that facilitate anti-competitive agreements may be parties to the agreement is noteworthy for several reasons: first, there is little or no recent Canadian authority for this proposition; and second, it is not clear that many trade associations could be considered to compete (or potentially compete) with their members in order to fall within the horizontal prohibition under the new section 45.
With respect to dual distribution agreements, the Bureau indicates that it will review such agreements (i.e., arrangements where a supplier may compete with one or more of its distributors) under the civil provisions of the Act, not under the new criminal conspiracy provisions.
Finally, the Bureau indicates that it will generally not review the following types of (common commercial) ancillary restraints under the criminal provisions, but rather under the civil provisions: (i) non-compete clauses in employment agreements or asset/share agreements, (ii) agreements not to make material changes to a business prior to completing a merger and (iii) non-compete agreements between joint venture partners (where the restraint relates only to the products, services or territories covered by the joint venture).
Section 90.1 – Non-hard Core Anti-competitive Agreements
With respect to the application of the new civil provision (section 90.1) for non-hard-core anti-competitive agreements, the Bureau states that in general agreements that fall within this new provision will be reviewed in a manner consistent with mergers under the Bureau’s Merger Enforcement Guidelines (the “MEGs”). For example, the Bureau adopts very similar market share safe harbours to those set out for parties to mergers in its MEGs:
“The Commissioner will not challenge an agreement under section 90.1 on the basis of: (i) a concern related to the exercise of market power by the parties to the agreement where the market share held by the parties represents less than 35% of the relevant market; or (ii) a concern related to a coordinated exercise of market power by firms in the relevant market where the share of the four largest firms in the relevant market is less than 65%, or the share of the parties to the agreement is less than 10% of the relevant market.”
Moreover, the Bureau sets out a similar analytical framework to that in the MEGs for mergers for considering whether parties possess market power, with factors including market shares, the likelihood of entry, foreign competition, barriers to entry and innovation. The Bureau indicates that the new civil provision will be used to review six common forms of commercial agreements: (i) commercialization agreements, (ii) information sharing agreements, (iii) research and development agreements, (iv) joint production agreements, (v) joint purchasing agreements and (vi) non-compete agreements. These six forms of agreements generally fall into two categories: (i) non-hard-core horizontal agreements whose effects require closer scrutiny (i.e., agreements other than bare price fixing, market allocation and output restriction agreements) and (ii) agreements that fall entirely outside the language of the new section 45 (e.g., upstream joint purchasing agreements).
As a practical matter, the introduction of a two-track regime for cartels in Canada will demand that both counsel and the Bureau engage in a more economic-based approach to reviewing agreements, particularly those challenged under the new section 90.1.
It will also mean that increased advocacy will be necessary to argue that some agreements, particularly those whose competitive effects may be unclear, fall either within the new ancillary restraints defence or within the new civil provision (as opposed to the criminal provisions).
RECENT CANADIAN TRADE ASSOCIATION, CONSPIRACY & BID-RIGGING CASES
The following are some of the recent publicly reported Canadian trade association, conspiracy and bid-rigging cases that have involved Competition Bureau (the “Bureau”) investigations, penalties, court orders or settlements.
Canadian Real Estate Association Alleged Abuse of Dominance Case (2010)
Market: Residential real estate services.
Overview: Alleged abuse of dominance case. On February 8, 2010 the Bureau filed an abuse of dominance application with the federal Competition Tribunal (the “Tribunal”) alleging that MLS rules adopted by The Canadian Real Estate Association limit choice and prevent innovation in the market for residential real estate services nationally in Canada. In particular, the Bureau is challenging MLS rules that it claims require that certain services be provided as a condition for real estate agents to list properties on local real estate boards’ MLS systems and that it claims limit consumer choice of residential real estate services.
The Bureau’s position is that CREA and its members have used their alleged control of the MLS system and related trademarks to impose exclusionary restrictions impacting the supply of residential real estate brokerage services and as a result have limited alternative real estate services business models in the market.
This case is interesting for a number of reasons, including that, if a decision is issued by the Tribunal, it would be the first Canadian “essential facilities” case to be decided on its merits (i.e., a case dealing with whether and under what terms access to an important asset, or “essential facility”, must be granted).
Result: CREA filed its response on March 26, 2010. The case is currently ongoing.
Quebec Street Lights Tender Bid-rigging Case (2010)
Market: Contracting services.
Overview: The defendants in this case were accused of bid-rigging in relation to a call for bids for a street light project.
Result: The corporate defendant was fined $50,000 and two individual defendants were sentenced to a ten year prohibition order.
Quebec Retail Gasoline Price-Fixing Case (2008–2009)
Market: Retail gasoline.
Overview: Price-fixing conspiracy case. In 2008 charges were laid against 13 individuals and 11 companies accused of fixing retail gasoline prices at the pump in Victoriaville, Thetford Mines, Magog and Sherbrooke, Quebec.
Result: As of December, 2009, 10 individuals and six companies pleaded guilty in this case with total fines imposed of more than $2.7 million. Les Pétroles Therrien Inc. and Distributions Pétrolières Therrien Inc. were fined $179,000, Ultramar Ltée was fined $1.85 million and Jacques Ouellet was fined $50,000.
Of the ten individuals that pleaded guilty, 6 were sentenced to terms of imprisonment.
This case is noteworthy in that it involves one of the high priority sectors for the Bureau (retail gasoline) as well as being a recent example of where the sentences involved imprisonment (served in the community).
Air Cargo Price-fixing Case (2009)
Market: Air cargo services.
Overview: International price-fixing case in relation to surcharges for air cargo exported on certain routes from Canada.
Result: On October 30, 2009 the Bureau announced that British Airways Plc (“BA”) had pleaded guilty in the Federal Court and was fined $4.5 million for its participation in an air cargo cartel affecting Canada. In particular, BA admitted to fixing surcharges relating to the sale and supply of international air cargo exported on particular routes from Canada between 2002 and 2006. In this case, each of BA, Air France, KLM, Martinair and Quantas pleaded guilty to fixing surcharges on the sale and supply of international air cargo. The total fines imposed in this case were more than $14.6 million (Air France: $4 million; KLM: $5 million; Martinair: $1 million; Qantas: $155,000; BA: $4.5 million).
This case is noteworthy for the significant penalties imposed as well as highlighting that the investigation of cartels remains a top enforcement priority for the Bureau.
Interac Association Abuse of Dominance Case (1996, 2010)
Market: ATM services.
Overview: Alleged abuse of dominance case (variation of Consent Order).
Result: The Interac Association requested that the Commissioner of Competition (the “Commissioner”) consent to vary a 1996 Consent Order to permit Interac to restructure from a not-for-profit association structure to a for-profit model. The Consent Order in this case included, among other things, terms relating to membership requirements of the Interac Association and fees. The Bureau refused to remove certain “safeguards” in the Consent Order and stated that it did “not agree that the removal of the restriction against for-profit activities by Interac would be pro-competitive, or is necessary to allow Interac to remain competitive.”
This case is interesting in that it involves issues relating to access and terms of use for an “essential facility” (in this case a shared electronic network services network established by the Interac Association).
Saskatchewan Roofing Contractors Association Alleged Bid-riggina and Conspiracy Case (2009)
Market: Roofing contracting services.
Overview: Alleged bid-rigging and conspiracy case.
Result: On June 22, 2009 the Bureau announced that a court order had been issued prohibiting the Saskatchewan Roofing Contractors Association from taking any action directed towards the commission of an offence under the conspiracy or bid-rigging provisions of the Competition Act (the “Act”). The order was a result of allegations that some members of the association had discussed not submitting bids in response to a request for tenders for a roofing project in Saskatchewan. The order also requires the association to educate its members on the relevant provisions of the Act and terms of the order, and requires the association’s members, as a condition of membership, to acknowledge in writing that they will comply with the association’s corporate compliance program.
This case is noteworthy as a recent example of the Bureau’s continued interest in ensuring that Canadian trade and professional associations comply with the Act, as well as indicating that the criminal conspiracy and bid- rigging provisions of the Act remain top enforcement priorities for the Bureau.
Newfoundland School Bus Operators Alleged Price-fixing Case (2009)
Market: School bus services.
Overview: Alleged market division and price-fixing case involving school bus services in and around St. John’s Newfoundland and Labrador. This case involved allegations that the parties had entered into agreements to divide the market and fix prices for school bus services and allegations of bid-rigging activities between 2001 and 2003.
Result: In February, 2009 the Bureau announced that it had obtained two prohibition orders against 14 companies and 18 individuals operating school bus services.
Federal Government IT Contracts Alleged Bid-rigging Case (2009)
Market: IT services.
Overview: In February, 2009 the Bureau announced that criminal charges had been laid against 14 individuals and 7 companies accused of rigging bids to obtain Government of Canada contracts for information technology services. The Bureau stated that it had discovered evidence indicating that several IT services companies in the National Capital Region had been secretly coordinating their bids to “defraud the government by winning and dividing contracts, while blocking out honest competitors.”
Result: One individual pleaded guilty to one count of bid-rigging, another individual (the former owner of TRM Technologies Inc.) pleaded guilty and was fined $25,000 and a prohibition order was issued against TRM Technologies Inc.
International Hydrogen Peroxide Price-fixing Case (2008)
Market: Hydrogen peroxide.
Overview: International price-fixing case.
Result: In November, 2008, the Bureau announced that Akzo Nobel Chemicals International BV had pleaded guilty and was ordered to pay a fine of $3.15 million in relation to fixing the price of hydrogen peroxide sold in Canada. The Bureau stated that in its investigation it benefited from the cooperation of an immunity applicant under its formal Immunity Program.
International Rubber and Chemicals Price-fixing Conspiracy (2007)
Market: Rubber and chemicals industry.
Overview: Charges under section 45 of the Act relating to price-fixing conspiracies in the rubber and chemicals industry.
Result: On October 30, 2007, Bayer Group pleaded guilty for its participation in three cross-border price-fixing conspiracies. Bayer AG was fined $2.9 million for its participation in the rubber chemical conspiracy and $400,000 for its participation in the nitrite rubber conspiracy. Bayer corporation was fined $345,000 for the aliphatic polyester polyols conspiracy.
International Graphite Electrodes Price-fixing Case (2007)
Market: Graphite electrodes.
Overview: International price-fixing case.
Result: In November, 2007 the Bureau announced that SEC Carbon Ltd. (“SEC”) pleaded guilty to participating in a conspiracy in the graphite electrodes market and was fined $250,000. SEC was the eighth party to be convicted in Canada in this case where total fines imposed were about $25 million.
Fort McMurray Auto Body Shops Alleged Price-fixing Case (2007)
Market: Auto body services.
Overview: Alleged price-fixing case involving auto body services.
Result: In February, 2007, the Bureau announced that a settlement was reached with six auto body shops in Fort McMurray.
The parties agreed to a binding court order that prohibited the six companies from: (i) engaging in communications relating to pricing or services and (ii) entering into agreements relating to pricing of products or services to customers or insurance companies. The companies were also required to publish a corrective notice outlining key terms of the court order and were required to implement a competition law compliance program.
CANADIAN CONSPIRACY LAW LINKS AND RESOURCES
Competitor Collaboration Guidelines (Enforcement Guidelines)
Immunity from Prosecution (Pamphlet)
Immunity Program Under the Competition Act (Bulletin)
Memorandum of Understanding (Commissioner of Competition and Director of Public Prosecutions)
Reaching an Agreement with Competitors (Pamphlet)
Revised Draft Information Bulletin on Sentencing and Leniency in Cartel Cases (Bulletin)
Sentencing and Leniency in Cartel Cases (Information Bulletin)
Setting Your Own Price (Pamphlet)
Technical Bulletin on “Regulated” Conduct
CANADIAN COMPETITION LAW LINKS
For more information about Canadian competition law or our competition law services visit our: Abuse of Dominance, Advertising and Marketing Law, Bid Rigging, Canadian Competition Law, Canadian Competition Law Compliance, Canadian Competition Law Home, Competition Act Amendments, Competition Bureau Investigations, Competition Law Courses and Conferences, Competition Law Litigation, Competition Law Publications, Competition Law Resources, Competition Law Services, Conferences, Conspiracy and Competitor Collaborations, Conspiracy – FAQs, Global Competition / Antitrust Law Resources, Global Competition Law Updates, Investment Canada Act, Merger Control, Merger Control FAQs, Private Actions, Promotional Contests, Publications, Refusal to Deal, Team, Trade Associations or Trade Association Cases pages or visit our website at www.NortonStewart.com.
CONTACT US
We provide Canadian competition law and consulting services to Canadian and international clients. For more information about our services contact us at steve@nortonstewart.com, info@competitionlawcanada.com or call us on +1 604 687 0555 or +1 778 867 5558. Visit us on the web in Toronto at www.torontocompetitionlawyer.com or www.torontocompetitionlaw.com.