1 00:00:00,120 --> 00:00:04,240 Speaker 1: More than one billion dollars was spent on advertising in 2 00:00:04,280 --> 00:00:08,239 Speaker 1: the US last year. Yet advertising is less regularly than 3 00:00:08,320 --> 00:00:12,520 Speaker 1: some other media businesses, with trade bodies rather than government agencies, 4 00:00:12,560 --> 00:00:15,720 Speaker 1: doing much of the oversight. But now the US Justice 5 00:00:15,760 --> 00:00:20,400 Speaker 1: Department is investigating the industry, specifically possible bid rigging in 6 00:00:20,560 --> 00:00:25,919 Speaker 1: video advertising production. WPP, the world's largest advertising company, is 7 00:00:25,960 --> 00:00:29,240 Speaker 1: the fourth of the Big six ad agency holding companies 8 00:00:29,440 --> 00:00:33,280 Speaker 1: to admit its subsidiaries have been subpoenaed by the Justice Department. 9 00:00:33,760 --> 00:00:37,240 Speaker 1: The Antitrust Division of the Justice Department is investigating whether 10 00:00:37,280 --> 00:00:41,640 Speaker 1: ad agencies manipulated bids for making TV commercials in order 11 00:00:41,640 --> 00:00:44,400 Speaker 1: to steer business to their own units. According to people 12 00:00:44,440 --> 00:00:47,640 Speaker 1: briefed on the matter, our guests are Jennifer Ree, senior 13 00:00:47,640 --> 00:00:51,720 Speaker 1: litigation analyst for Bloomberg Intelligence, and Daniel Crane, professor at 14 00:00:51,720 --> 00:00:55,040 Speaker 1: the University of Michigan Law School. Jan there have been 15 00:00:55,320 --> 00:00:59,440 Speaker 1: years of tensions between big advertisers and their ad agencies. 16 00:01:00,120 --> 00:01:03,760 Speaker 1: Was this investigation by Justice propelled in any way by 17 00:01:03,800 --> 00:01:08,800 Speaker 1: a June study commissioned by the Association of National Advertisers. Well, June, 18 00:01:08,800 --> 00:01:11,120 Speaker 1: thanks for having me first, and before I answer that, 19 00:01:11,200 --> 00:01:13,280 Speaker 1: I do need to disclose that My husband works for 20 00:01:13,360 --> 00:01:16,399 Speaker 1: j W JW T, which is an ad agency that 21 00:01:16,520 --> 00:01:19,479 Speaker 1: falls under w PP, the agency you were just talking about, 22 00:01:19,520 --> 00:01:21,880 Speaker 1: and he does hold stock options. So before I get in, 23 00:01:21,959 --> 00:01:25,360 Speaker 1: I just have to disclose that. UM. Now, what's been reported, 24 00:01:25,360 --> 00:01:28,640 Speaker 1: at least we think, is that a report by this UM, 25 00:01:29,160 --> 00:01:32,520 Speaker 1: this company K two, that was commissioned by the Association 26 00:01:32,520 --> 00:01:35,680 Speaker 1: of National Advertisers. This is a trade association that represents 27 00:01:35,880 --> 00:01:40,200 Speaker 1: the brand companies or the advertisers. UM suggested that there 28 00:01:40,319 --> 00:01:43,240 Speaker 1: was a lot of non transparent activity going on in 29 00:01:43,280 --> 00:01:45,920 Speaker 1: these ad agencies that wasn't really working out to the 30 00:01:45,959 --> 00:01:48,800 Speaker 1: benefit of the advertisers, but working out to the benefit 31 00:01:48,840 --> 00:01:51,400 Speaker 1: of the agencies. And it seems that they mostly were 32 00:01:51,440 --> 00:01:55,320 Speaker 1: focusing on media companies media suppliers, but and not so 33 00:01:55,440 --> 00:01:57,680 Speaker 1: much production, which is what the d OJ is looking 34 00:01:57,720 --> 00:02:00,280 Speaker 1: at here, but that they did have some finds that 35 00:02:00,400 --> 00:02:03,960 Speaker 1: might not have fallen into their final report that suggested 36 00:02:04,120 --> 00:02:07,520 Speaker 1: there may be this kind of bid rigging activity going 37 00:02:07,600 --> 00:02:10,600 Speaker 1: on in which the ad agencies agree with some of 38 00:02:10,639 --> 00:02:14,680 Speaker 1: these outside production companies not to compete essentially UM and 39 00:02:14,760 --> 00:02:17,120 Speaker 1: try to get the business in house because they own 40 00:02:17,480 --> 00:02:20,240 Speaker 1: some of their own production facilities in house. They want 41 00:02:20,280 --> 00:02:23,440 Speaker 1: to give the advertisers several bids. Looks like they're competing. 42 00:02:23,720 --> 00:02:26,040 Speaker 1: You know, here are three bids. We've come in lower 43 00:02:26,040 --> 00:02:27,800 Speaker 1: than these other two bids, which at the end of 44 00:02:27,800 --> 00:02:30,239 Speaker 1: the day all of them were artificially high. At least, 45 00:02:30,280 --> 00:02:33,639 Speaker 1: this is what you know, looks like what they're investigating. Um, 46 00:02:33,680 --> 00:02:36,720 Speaker 1: and it gives legitimacy to the ad agency's bid because 47 00:02:36,720 --> 00:02:38,480 Speaker 1: it comes in lower than the others. But they've all 48 00:02:38,520 --> 00:02:42,000 Speaker 1: agreed to put in these artificially high bids. Daniel Crane, 49 00:02:42,240 --> 00:02:44,200 Speaker 1: I'll make a confession, I didn't know all that much 50 00:02:44,200 --> 00:02:47,280 Speaker 1: about the advertising business before this morning. Some if I 51 00:02:47,320 --> 00:02:50,560 Speaker 1: understand this correctly, is the idea that there are separate 52 00:02:50,600 --> 00:02:55,240 Speaker 1: markets for the advertising contracts UH in general and for 53 00:02:55,320 --> 00:02:58,320 Speaker 1: the video productions, so that if an ad agency gets 54 00:02:58,320 --> 00:03:02,240 Speaker 1: a contract, it can't necessarily use its own production facilities. 55 00:03:02,360 --> 00:03:04,960 Speaker 1: Is that the idea right? So, the idea is that 56 00:03:05,280 --> 00:03:08,480 Speaker 1: there is a separate market for the production of advertisements, 57 00:03:08,560 --> 00:03:12,200 Speaker 1: and that can be done by the vertically integrated shop 58 00:03:12,360 --> 00:03:15,400 Speaker 1: of an ad agency or could be done outside by 59 00:03:15,400 --> 00:03:19,000 Speaker 1: an independent video production company. As I understand it from 60 00:03:19,000 --> 00:03:23,200 Speaker 1: media reports, the investigation is centering on allegations that the 61 00:03:23,240 --> 00:03:27,000 Speaker 1: ad agencies, which already we're dealing with clients to sell advertising. 62 00:03:27,400 --> 00:03:30,960 Speaker 1: Uh In Media had some sort of a kickback or 63 00:03:31,000 --> 00:03:35,240 Speaker 1: collusive agreement with independent video production companies that the video 64 00:03:35,240 --> 00:03:40,040 Speaker 1: production companies would submit bogus bids to the client and 65 00:03:40,120 --> 00:03:42,200 Speaker 1: that the ad agency would therefore be able to come 66 00:03:42,240 --> 00:03:45,600 Speaker 1: in and win the business for its own in house 67 00:03:45,960 --> 00:03:50,040 Speaker 1: video production shop, but doing so at inflated prices. Jen, 68 00:03:50,280 --> 00:03:54,040 Speaker 1: we know that four of the big six ad agencies 69 00:03:54,040 --> 00:03:57,760 Speaker 1: have been subpoenaed. More might have been what stage are 70 00:03:57,800 --> 00:04:00,520 Speaker 1: we at here, Well, you know, this is very early on. 71 00:04:00,600 --> 00:04:03,680 Speaker 1: These things take time. Um. This subpoenas really mean that 72 00:04:03,680 --> 00:04:06,320 Speaker 1: they're they're collecting documents, they're collecting evidence at the d 73 00:04:06,560 --> 00:04:09,400 Speaker 1: J that is is collecting evidence and information now and 74 00:04:09,440 --> 00:04:12,280 Speaker 1: these things can take several years. You know. By way 75 00:04:12,280 --> 00:04:15,000 Speaker 1: of example, we know that there have been some recent 76 00:04:15,360 --> 00:04:18,559 Speaker 1: informations issued by the DJ in the generic drug world 77 00:04:18,640 --> 00:04:22,919 Speaker 1: that's like an indictment um um that two people have 78 00:04:23,000 --> 00:04:25,719 Speaker 1: been involved in price fixing for generic drugs. And this 79 00:04:25,800 --> 00:04:27,720 Speaker 1: is what shook out of subpoenas that were issued back 80 00:04:27,760 --> 00:04:29,919 Speaker 1: in two thousand fourteen, and we're just hearing about some 81 00:04:29,960 --> 00:04:32,360 Speaker 1: of the results of that investigation now, So that and 82 00:04:32,360 --> 00:04:35,000 Speaker 1: and there's also something similar happening with auto parts that 83 00:04:35,000 --> 00:04:37,320 Speaker 1: took many, many years to conclude. So this is at 84 00:04:37,320 --> 00:04:39,200 Speaker 1: the beginning, and it's going to be a while before 85 00:04:39,240 --> 00:04:44,320 Speaker 1: we understand what's happening here Dan Beyond what we've discussed, 86 00:04:44,839 --> 00:04:46,919 Speaker 1: are there other things you you might think that the 87 00:04:47,000 --> 00:04:50,480 Speaker 1: Justice Department might be looking into? Or is it primarily 88 00:04:50,520 --> 00:04:55,520 Speaker 1: that issue of these these uh potentially uh uh I 89 00:04:55,560 --> 00:04:58,880 Speaker 1: guess fake are are are inflated uh bids that are 90 00:04:58,920 --> 00:05:02,320 Speaker 1: being genda. So my understanding is that would be the 91 00:05:02,320 --> 00:05:05,440 Speaker 1: focus of this particular investigation. Obviously, as as the lead 92 00:05:05,680 --> 00:05:09,440 Speaker 1: comment on the show made clear, there's been lots of 93 00:05:09,080 --> 00:05:12,680 Speaker 1: of of concern in the advertising business about, for example, 94 00:05:12,800 --> 00:05:18,120 Speaker 1: kickbacks from from media companies or to to ad agencies 95 00:05:18,160 --> 00:05:21,160 Speaker 1: that were not passed on to consumers, or to two 96 00:05:21,160 --> 00:05:24,520 Speaker 1: companies buying ads. That would probably will not raise an 97 00:05:24,520 --> 00:05:27,800 Speaker 1: antitrust issue. It also wouldn't necessarily raise an anti trust 98 00:05:27,880 --> 00:05:31,920 Speaker 1: issue for a vertically integrated ad agency simply to steer 99 00:05:31,960 --> 00:05:34,279 Speaker 1: business to its own video production unit, as long as 100 00:05:34,320 --> 00:05:38,480 Speaker 1: they don't collude with competitors. So, as I understand this investigation, 101 00:05:38,480 --> 00:05:42,440 Speaker 1: it's really centered on allegations of horizontal collusion between competitors 102 00:05:42,480 --> 00:05:45,680 Speaker 1: for video production, and that would be a serious antitrust 103 00:05:45,800 --> 00:05:49,400 Speaker 1: violation if that were shown to be true. Jen explain 104 00:05:49,440 --> 00:05:53,200 Speaker 1: the difference between vertical and horizontal. Oh, sure, So in 105 00:05:53,200 --> 00:05:56,480 Speaker 1: the horizontal you're basically competing at the same level of distribution. 106 00:05:56,760 --> 00:05:59,120 Speaker 1: The same service or same product is provided, and you're 107 00:05:59,160 --> 00:06:02,400 Speaker 1: competing to provide that service or product. Vertical would be 108 00:06:02,520 --> 00:06:04,640 Speaker 1: at a different level of the chain of distribution. You 109 00:06:04,720 --> 00:06:07,279 Speaker 1: might be an input maker, um, and you don't compete, 110 00:06:07,360 --> 00:06:09,520 Speaker 1: let's say, with the manufacturer of the final product that 111 00:06:09,600 --> 00:06:13,360 Speaker 1: uses that input. So essentially here the ad agencies are 112 00:06:13,440 --> 00:06:15,599 Speaker 1: vertically integrated where they come up with the ad ideas, 113 00:06:15,640 --> 00:06:17,680 Speaker 1: but then they might have their in house production, which is, 114 00:06:17,720 --> 00:06:20,240 Speaker 1: you know, another level of in that chain of the 115 00:06:20,240 --> 00:06:25,400 Speaker 1: final product and and um. So it's in the sense 116 00:06:25,520 --> 00:06:28,000 Speaker 1: they can steer you know, it wouldn't be an antetos violation. 117 00:06:28,080 --> 00:06:31,120 Speaker 1: Just just try to steer work internally. You're just capturing 118 00:06:31,160 --> 00:06:33,040 Speaker 1: internal work. This is one of the benefits of being 119 00:06:33,120 --> 00:06:37,040 Speaker 1: vertically integrated. But where they have that division, that production 120 00:06:37,080 --> 00:06:40,000 Speaker 1: division that then competes and they're also hired, might be 121 00:06:40,080 --> 00:06:43,279 Speaker 1: hiring some of these outside production companies for some jobs. 122 00:06:43,320 --> 00:06:47,120 Speaker 1: That's where they're also horizontally competing with these production companies, 123 00:06:47,160 --> 00:06:51,200 Speaker 1: and that's where the conspiracy can't take place. We have 124 00:06:51,480 --> 00:06:55,160 Speaker 1: just about thirty seconds left. Is this a good area 125 00:06:55,600 --> 00:07:02,280 Speaker 1: dan for there to be more complying, more regulation. It's 126 00:07:02,360 --> 00:07:06,680 Speaker 1: an advertising is an area where it's sort of looking 127 00:07:06,720 --> 00:07:10,880 Speaker 1: at itself through its own groups. Right. So one thing 128 00:07:10,920 --> 00:07:12,680 Speaker 1: we don't just know right now, though, it's what's going 129 00:07:12,720 --> 00:07:15,760 Speaker 1: to happen when the Trump administration comes in on January 130 00:07:15,800 --> 00:07:17,920 Speaker 1: twenty and so you ask is it a good or 131 00:07:18,000 --> 00:07:20,720 Speaker 1: bad idea just in terms of predicting where things are 132 00:07:20,720 --> 00:07:23,520 Speaker 1: going to go in the next four years UM In 133 00:07:23,560 --> 00:07:27,120 Speaker 1: an ordinary year of transition from a democratic to Republican administration, 134 00:07:27,200 --> 00:07:28,720 Speaker 1: you would expect it to be a high level of 135 00:07:28,760 --> 00:07:32,160 Speaker 1: continuity on issues like collusion. This is anything but an 136 00:07:32,240 --> 00:07:34,480 Speaker 1: ordinar year, though. And one thing we just don't know 137 00:07:34,560 --> 00:07:37,400 Speaker 1: yet is what antitrust enforcement will look like under the 138 00:07:37,400 --> 00:07:42,040 Speaker 1: Trump administration. The business community is guessing about President elect 139 00:07:42,040 --> 00:07:45,320 Speaker 1: Trump's anti trust policy position because it's an area he 140 00:07:45,400 --> 00:07:49,280 Speaker 1: has said very little about. Trump has accused several companies 141 00:07:49,280 --> 00:07:53,240 Speaker 1: of violating antitrust laws and vowed to regulate their conduct. 142 00:07:53,560 --> 00:07:56,520 Speaker 1: For example, the A T and T Time Warner merger 143 00:07:57,560 --> 00:08:01,040 Speaker 1: as an example of the power structure of fire. A 144 00:08:01,200 --> 00:08:03,800 Speaker 1: T and T is buying Time Warner and thus CNN 145 00:08:04,440 --> 00:08:08,320 Speaker 1: a deal we will not approve in my administration because 146 00:08:08,360 --> 00:08:13,520 Speaker 1: it's too much concentration of power in the hands of 147 00:08:13,600 --> 00:08:18,800 Speaker 1: too few. Yet, the people on his transition team advising 148 00:08:18,880 --> 00:08:22,800 Speaker 1: him on anti trust have records of conservatism. We've been 149 00:08:22,800 --> 00:08:26,520 Speaker 1: talking with Jennifer Reese and your litigation analyst for Bloomberg Intelligence, 150 00:08:26,640 --> 00:08:29,840 Speaker 1: and Daniel Crane, professor at the University of Michigan Law School. 151 00:08:30,280 --> 00:08:34,559 Speaker 1: Jen what's your analysis of what the Trump administration policy 152 00:08:34,600 --> 00:08:38,360 Speaker 1: and anti trust might be? Well, I really don't have one, because, 153 00:08:38,640 --> 00:08:41,520 Speaker 1: as you said it, everybody's guessing about this. I mean, 154 00:08:41,800 --> 00:08:43,720 Speaker 1: with the comments that he made on the campaign trail 155 00:08:43,760 --> 00:08:45,360 Speaker 1: about A T and T and also there were some 156 00:08:45,440 --> 00:08:48,720 Speaker 1: about Comcast, an, nbc U, and Amazon. You know, it's 157 00:08:48,800 --> 00:08:51,679 Speaker 1: unclear are these part of his populist message? Is this 158 00:08:52,040 --> 00:08:53,839 Speaker 1: is this what he intends the direction he tends to 159 00:08:53,880 --> 00:08:55,840 Speaker 1: go on anti trust or you know, or is this 160 00:08:55,960 --> 00:08:57,960 Speaker 1: just his anger at the media, you know, and his 161 00:08:58,360 --> 00:09:00,880 Speaker 1: isn't a desire to lash to the media or or 162 00:09:01,080 --> 00:09:05,160 Speaker 1: or scare the media. Um, it's really unclear. And and 163 00:09:05,960 --> 00:09:07,720 Speaker 1: the people he has advin Now we don't know who 164 00:09:07,760 --> 00:09:10,040 Speaker 1: will be appointing at the Department of Justice or Federal 165 00:09:10,080 --> 00:09:12,360 Speaker 1: Trade Commission, but the people advising him on these things 166 00:09:12,360 --> 00:09:15,880 Speaker 1: are two gentlemen. You know, both have records of conservatism. 167 00:09:15,920 --> 00:09:18,800 Speaker 1: One was a former FTC commissioner who all of his 168 00:09:18,880 --> 00:09:22,560 Speaker 1: votes were quite conservative. Another one and worked for the 169 00:09:22,559 --> 00:09:25,280 Speaker 1: Department of Justice under George Bush, you know. And I 170 00:09:25,280 --> 00:09:28,160 Speaker 1: guess i'd say that if you look at their records 171 00:09:28,240 --> 00:09:31,400 Speaker 1: and things they've said publicly, that they're more typical. They 172 00:09:31,440 --> 00:09:34,120 Speaker 1: take a more typical Republican approach, which is generally to 173 00:09:34,200 --> 00:09:37,160 Speaker 1: let businesses regulate themselves, you know, a little bit more 174 00:09:37,200 --> 00:09:40,080 Speaker 1: hands off. I think in some areas that there's really 175 00:09:40,080 --> 00:09:42,640 Speaker 1: been a bipartisan consensus that we need to go after 176 00:09:42,720 --> 00:09:45,880 Speaker 1: the really egregious antitrust activity, like what we were just 177 00:09:45,920 --> 00:09:49,560 Speaker 1: talking about, bid rigging and price fixing. But sometimes these mergers, 178 00:09:49,559 --> 00:09:52,040 Speaker 1: when they're evaluated, you know, they're really difficult. It's a 179 00:09:52,120 --> 00:09:55,880 Speaker 1: very difficult decision. They could be borderline. Sometimes they might 180 00:09:55,920 --> 00:09:58,840 Speaker 1: have the potential to put you know, harmon market to 181 00:09:58,920 --> 00:10:01,760 Speaker 1: some extent, but they also might have some very great 182 00:10:01,880 --> 00:10:04,760 Speaker 1: synergies and pro competitive benefits. And I think when you 183 00:10:04,840 --> 00:10:07,320 Speaker 1: have those sort of on the borderline, there those deals 184 00:10:07,320 --> 00:10:10,040 Speaker 1: that are difficult calls. That's where you might see Democrats 185 00:10:10,040 --> 00:10:12,200 Speaker 1: and Republicans coming out differently. And that's where we have 186 00:10:12,240 --> 00:10:15,040 Speaker 1: a record for, for instance, Josh Right, who's advising on 187 00:10:15,120 --> 00:10:17,960 Speaker 1: the FTC, coming out differently than some of the Democratic commissioners. 188 00:10:18,520 --> 00:10:20,720 Speaker 1: What's your take on that, Dan, Are we gonna see 189 00:10:20,760 --> 00:10:25,400 Speaker 1: a typical Republican administration when it comes to antitrust law? Well? 190 00:10:25,400 --> 00:10:27,679 Speaker 1: I think Jennifer is right that to the extent that 191 00:10:27,720 --> 00:10:31,040 Speaker 1: we measure our predictions by the people directly involved in 192 00:10:31,040 --> 00:10:35,400 Speaker 1: the transitional antitrust it'll look like a fairly conservative antitrust regime, 193 00:10:35,480 --> 00:10:38,000 Speaker 1: both at the Federal Trade Commission and the Justice Department. 194 00:10:38,559 --> 00:10:40,000 Speaker 1: The one thing we don't know, of course, is to 195 00:10:40,040 --> 00:10:44,040 Speaker 1: what extent Donald Trump himself would be personally involved in 196 00:10:44,080 --> 00:10:48,400 Speaker 1: making decisions about antitrust enforcement at that the case specific level. 197 00:10:48,559 --> 00:10:50,520 Speaker 1: I mean for the last the thirty or four years, 198 00:10:50,520 --> 00:10:52,760 Speaker 1: that's really been a big no. Now, presidents have stayed 199 00:10:52,840 --> 00:10:56,679 Speaker 1: very much removed from the the the enforcement decisions as 200 00:10:56,720 --> 00:10:58,520 Speaker 1: to particular cases to be brought or not to be 201 00:10:58,559 --> 00:11:01,719 Speaker 1: brought in the that's really a decision made professionally in 202 00:11:01,760 --> 00:11:04,520 Speaker 1: the Justice Department, in the Federal Trade Commission. Um. But 203 00:11:04,600 --> 00:11:06,520 Speaker 1: with you know, with Donald Trump, you just don't know 204 00:11:06,559 --> 00:11:08,839 Speaker 1: what sort of a managerial style he'll have, whether he 205 00:11:09,520 --> 00:11:12,600 Speaker 1: would become much more active in saying here are particular 206 00:11:12,640 --> 00:11:14,760 Speaker 1: cases we should bring or not bring, and at least 207 00:11:14,800 --> 00:11:16,920 Speaker 1: as to the Justice Department. Uh, you know, if he 208 00:11:16,960 --> 00:11:18,760 Speaker 1: has a be in his bonnet about a T and 209 00:11:18,760 --> 00:11:20,760 Speaker 1: T time warner and really wants to communicate to the 210 00:11:20,760 --> 00:11:23,360 Speaker 1: Justice Department that they should put up a fight, uh, 211 00:11:23,400 --> 00:11:25,760 Speaker 1: he might make with President and and and actually give 212 00:11:25,760 --> 00:11:28,480 Speaker 1: that kind of direction. So I think part of the 213 00:11:28,600 --> 00:11:30,680 Speaker 1: just the guessing game here we really don't know is 214 00:11:30,880 --> 00:11:32,800 Speaker 1: not only we don't know who will be in the 215 00:11:32,920 --> 00:11:36,080 Speaker 1: leadership at a d O J and FTC um my 216 00:11:36,080 --> 00:11:38,920 Speaker 1: my working guests, as those will be fairly typical Republicans. 217 00:11:39,400 --> 00:11:41,880 Speaker 1: But the real question is to what extent will will 218 00:11:42,000 --> 00:11:45,440 Speaker 1: will Donald Trump and Jeff Sessions actually take more of 219 00:11:45,440 --> 00:11:48,559 Speaker 1: a personal managerial role with respect to some of these matters, 220 00:11:48,600 --> 00:11:52,000 Speaker 1: And if so, it might might surprise us. All We 221 00:11:52,120 --> 00:11:55,480 Speaker 1: certainly have been surprised by a lot recently. Thank you 222 00:11:55,520 --> 00:11:59,160 Speaker 1: both for being on Bloomberg Law. That's Daniel Crane, Professor 223 00:11:59,200 --> 00:12:01,839 Speaker 1: at the University of Michigan Law School, and Jennifer Ree, 224 00:12:01,920 --> 00:12:05,680 Speaker 1: Senior litigation analyst for Bloomberg Intelligence. And for more of 225 00:12:05,880 --> 00:12:09,520 Speaker 1: Jennifer's antitrust analysis, you can go to be I go 226 00:12:09,840 --> 00:12:11,200 Speaker 1: on the Bloomberg terminal.