Over the past several months, there have been a number of statements by politicians and Member State governments regarding the reform of EU competition law. Much of this debate is fundamentally linked to how authorities should define the relevant product and geographic markets that guide their antitrust and merger investigations.
Industries
New Investigative Power for the French Competition Authority to Access Telephone Communications Data
Decree n°2019-1247 of November 28, 2019, published in the Official Journal of the French Republic on November 29, 2019 (the “Decree”), provides the procedural framework for the FCA’s new power to access telephone communications data for the purpose of antitrust investigations under Article L. 450-3-3 of the French Commercial Code. This framework was introduced by the Pacte Law [1] and allows the FCA to request access to technical information regarding the identity of a caller, the telecommunication terminals used, the data, time, and duration of each call, and the phone numbers called. It will be operational as soon as the Data Request Supervisor (“contrôleur des demandes de données de connexion”) is appointed (the Supervisor will be appointed among the judges of the French Administrative or Civil Supreme Court).[2]
Pay-for-Delay Again: Commission Fines Teva and Cephalon €60.5 Million for Delaying Entry of Cheaper Generic Medicine
On November 26, 2020, the Commission fined Teva and Cephalon a total of €60.5 million for entering into a pay-for-delay agreement in relation to a sleep disorder drug. This arrangement is alleged to have helped maintain high prices for several years, to the detriment of patients and healthcare systems.[1]
FCO Conditionally Clears Furniture Merger
On November 25, 2020, after an in-depth investigation, the FCO approved the acquisition by Mann Mobilia Beteiligungs GmbH (part of the XXXLutz Group) of 50% of the shares in Möbel Management Holding GmbH & Co. KG and Roller GmbH & Co. KG (part of the Tessner Group), subject to the divestiture of 23 furniture outlets.[1] The FCO’s clearance only relates to the sales side of the transaction, i.e., the relationship between furniture retailers and consumers, whereas on November 30, 2020, the European Commission unconditionally cleared the transaction with respect to the procurement side, i.e., the relationship between furniture retailers and manufacturers.[2]
The French Supreme Court Reiterates That During Dawn Raids the Legal Privilege Is Only Applicable To Attorney-client Communications Which Concern the Exercise of the Rights of Defence
On November 25, 2020, the French Supreme Court ruled that attorney-client communications could not be seized during dawn raids provided they are related to the exercise of the client’s rights of defence.
The French Competition Authority Finds That Intra- Group Bids to a Tender No Longer Fall Within the Ambit of Competition Law
FCJ Reaffirmed Position on FRAND Defense
On November 20, 2020, at the request of Sisvel International Group (“Sisvel”), the Federal Court of Justice (“FCJ”) granted a preliminary injunction against Chinese mobile phone manufacturer Haier Corporation Group (“Haier”).[1] The injunction is another victory for Sisvel in its patent disputes with Haier following a preliminary injunction issued in May 2020.[2] The FCJ used the recent decision as an opportunity to further elaborate on the obligations of patent holders and potential patentees under the Huawei/ZTE jurisprudence of the Court of Justice of the European Union (“CJEU”).[3]
The General Court Rejects The Essential Facilities Doctrine In Rail Sector
On November 18, 2020, the General Court dismissed an appeal by AB Lietuvos geležinkeliai (“Lithuanian Railways”) against a 2017 Commission decision which found that the company had abused its dominant position on the Lithuanian rail freight market by removing a stretch of track connecting Latvia and Lithuania (the “short route”). The Commission found that the conduct prevented one of Lithuanian Railways’ major customers, the Polish stated-owned oil company AB Orlen Lietuva (“Orlen”), from switching transportation services to rival Latvian Railways.[1] The Commission and Lithuanian Railways discussed potential remedies, but failed to reach an agreement. The Commission therefore imposed a fine of €28 million. The General Court partially upheld the Commission decision, reducing the fine from €28 million to €20 million due to the limited territorial scope of the infringement.[2]
JD Sports Fashion plc v Competition and Markets Authority
On 1 September 2020, JD Sports Fashion and Pentland Group Limited filed an appeal against a CMA decision of 29 July 2020 to impose a penalty of £300,000 on the parties for failing to comply with the requirements of the CMA’s initial enforcement order issued in the context of the completed acquisition by JD Sports of Footasylum plc.
Sector Inquiries Into Consumer Law Issues
The 2017 Amendment of the ARC granted the FCO the competence to conduct sector inquiries into consumer protection issues. The FCO recently published the results of two sector inquiries—into smart TVs and fake user reviews—and announced another sector inquiry into messenger services.