Joseph V. Coniglio hosts the third episode of a new antitrust speaker series and interviews longtime antitrust scholar and retired DOJ economist Greg Werden.​ They discuss Werden’s path from chemistry to economics and his four-decade career at DOJ, discussing both constants and changes in antitrust enforcement.

Publications Mentioned

• Werden, Gregory J. The Foundations of Antitrust. Cambridge, MA: Harvard University Press, 2020.
• Werden, Gregory J. “The Competitive Process Standard.” Antitrust Law Journal (2024).
• Areeda, Phillip E., and Herbert Hovenkamp. Antitrust Law: An Analysis of Antitrust Principles and Their Application. Boston: Little, Brown and Company, 1978–.
• Bork, Robert H. The Antitrust Paradox: A Policy at War with Itself. New York: Basic Books, 1978.

Cases Mentioned​

• United States v. Microsoft Corp.
• United States v. IBM Corp.
• United States v. AT&T Co.
• United States v. Philadelphia National Bank
• Standard Oil Co. of New Jersey v. United States
• Chicago Board of Trade v. United States

Auto-Transcript

Joseph V. Coniglio: Thank you for joining us. My name is Joseph Coniglio. I'm the director of antitrust and innovation at the Schumpeter Project on Competition Policy here at the Information Technology and Innovation Foundation, and I'm so glad to be here with you for the third installment of our new antitrust speaker series, Creative Discussion. We're channeling Schumpeter's idea of creative destruction, will be having wide ranging and in-depth discussions with antitrust's greatest luminaries to discuss cutting edge issues in antitrust, tech, economics and beyond, as well as get to know a little bit more about the people who have been very influential within the US antitrust community over the past few decades.

With that, I'm very glad to announce this week's featured speaker for our episode. Greg Werden, who, of course, is a long time antitrust scholar and now retired DOJ economist, having spent over four decades at the agency. And the only antitrust division employee to ever be awarded the very prestigious DOJ Mary C. Lawton Lifetime Service Award.

Greg's time at DOJ span numerous sets of enforcement guidelines and over a hundred briefs in appellate courts or the Supreme Court. And after leaving DOJ, Greg was also a visiting scholar at the Mercatus Center, where he continued his scholarly work with a number of great pieces on antitrust which includes, over his corpus, a really great and authoritative book on antitrust published just a few years ago, that I know we're going to discuss. Greg, thank you for joining us.

Could you tell us first, before we get into all these big antitrust issues, a little bit about your life and how you got into antitrust? Take us back to the days where it was cool to wear ascots. I'm trying to bring it back, but we'll see how that goes.

Greg Werden: I'm afraid I don't go back that far, as old as I am. I think ascots were already in the United States when I was born in 1952 in Cincinnati, and I attended the University of Cincinnati. I started out to be a chemist, but I pretty quickly switched to economics after developing an interest in antitrust. And I realized that I could get a degree in economics in three years, but it would take four in chemistry, because problem scheduling the labs.

So I went for the three year program. It was the same number of courses, same number of credit hours, but I could do it in three years by taking as many as nine classes at a time. Then to pursue antitrust, I got a PhD in Industrial Organization Economics at the University of Wisconsin. I also did that one in three years. I naturally took a job at the antitrust division at the US Department of Justice. Where else would you go?

And at the time I thought I would work in the government for a few years, then go into academia, which is a good career path, but I never left the government.

You've had such an amazing career at DOJ, over 40 years, and talk to us a little bit about the changes you've seen. Both good and bad. I should say, I still remember when I was a paralegal over there, I used to go up to the EAG floor for lunch over at the balcony, and I think remember walking past your really amazing office like, you're literally overseeing the division over there.

Joseph V. Coniglio: You had a bird's eye view of it all.

Greg Werden: I had a bird's eye view of the Capitol. That was a nice view, 24 feet of floor to ceiling windows. So let me first note two things that haven't changed, although people would think that they had.

Believe it or not, since the 1940s, the antitrust division's budget has remained roughly constant as a fraction of the GDP. It is one millionth the GDP. Thurman Arnold headed the division between 1938 and 1943, and under him, the division's budget increased fivefold and the staff grew to nearly 600. It went down at the end of his tenure because people were leaving to join the war effort, faster than they could be recruited.

Another thing that hasn't changed: priorities. Every new AG has some differences in priorities, but the main priority since the 1950s have been merger and cartel enforcement. That has never varied.

During my time, two changes seem notable. One is that the size of the front office grew from time to time. This I think was a bad thing because the staff got more isolated from the assistant attorney general.

The other thing was the pay gap with the private sector grew ever larger. My pay rose as high as the law allowed. I was the absolute top at the salary schedule for a career person in Washington, DC, and I was paid less than a fresh law school graduate working at a Washington law firm. So, that's something that ought to be addressed. It ought to be the highest priority, but it's not gonna happen.

Joseph V. Coniglio: Fair enough. Those first year associates, they do have it pretty good in some ways. They also work their tails off to be fair, having been one of them. But let me ask about the Merger Guidelines because you noted mergers have been a really a priority at the DOJ since you've been there.

And I actually want to quote our last guest speaker, Alden Abbott, who actually described you as the leading expert on the history and technical analysis of modern Merger Guidelines, having worked on the 1982, 1984, 1992, 1997, and 2010 versions as a senior DOJ economist.

I would just love to get your sense on just the progression of the Merger Guidelines over the years, and in particular, what you think of the new 2023 Merger Guidelines that were issued after you left, which I know you nonetheless filed a very extensive comment discussing.

Greg Werden: Okay. To Alden's list, you can add the 2019 vertical merger guide guidelines. I did a lot of work on that before I left. In what, I guess early 1981, I learned that there was this project to produce new Merger Guidelines and I wangled my way into it. It had already been staffed before I found out about it, but they added me.

The people who were assigned to it didn't really want to work on it anyway the economists that is. So I ended up after a while being the only economist, staff economist, not counting management, working on the guidelines. And, I didn't have a lot of preconceived notions about how guidelines should work except for the hypothetical monopolist test.

People assume that it was invented in 1981 as part of writing the Merger Guidelines, but it wasn't. In a sense it was invented about the time I was born. 'Cause that's when the first mention of something that appears in a law review type article. And I got the idea from someone who claims not to know where he got the idea, which would've been in 1977. And then developed it in 1978, and it actually appears in a government report in 1978.

So there's no question that it existed in 1978. Getting it into the Merger Guidelines was a struggle because the lead drafting person didn't like the idea very much. In the 1982 guidelines, it was only in a footnote. But it was the only really innovative thing in the Merger Guidelines, and it was promoted to the text in 1984.

There are a couple of other things I contributed to the 1982 Merger Guidelines. Some of which have ceased to be things like, there was something called the leading firm proviso, which is a simple market share rule. If the acquiring firm is bigger than a certain size and it acquires a non-trivial, horizontal competitor, then that exceeds the threshold and the presumption kicks in. Which, is very close, in fact to what Philadelphia National Bank says. It just focuses more on the fact that the concern here is that the leading firm in the market is making the acquisition and is growing ever larger.

But that, that went by the boards. The other thing that really goes with the hypothetical monopolist test, and people took too little notice of, is that market definition became only about demand side substitution. It had been about both supply side and demand side. 1982 Merger Guidelines made it just about demand side substitution, and that more or less was accepted. Not one hundred percent, but more or less, and it makes a big difference. And although not immediately by any means, the hypothetical monopolist test became well accepted until the Biden administration.

Joseph V. Coniglio: Yeah, those two things. The HMT, the idea of demand side, consumer focus, move the supply considerations to the entry analysis. Those were two fundamental things that really have continued, at least up until the 2023 Merger Guidelines. Sort of the priority of quantitative economic analysis of market definition that we use for merger analysis.

And I guess I would just ask you as an economist, that has to be something that's also changed over the last 40 years, the role of economists, practically, in doing merger analysis and other economic analysis. It's not just the salaries of law firm associates that have went up. I think the economics in antitrust worlds really changed a lot over the last 40 years. What would you say?

Greg Werden: That is but again, is not quite what people think. I think the big breakthrough was in the seventies. That's when the economists became part of the investigative team.

The economics matters most where it's least visible and simplest. The stuff you're talking about is a step up in technical complication. It's important, but it's not as important as the most basic stuff. 'Cause economics is used to understand the evidence and to weave together a narrative of how competition works, and that undergirds all of the analysis. And when the economists work, day in, day out with the lawyers, they get on the same page about all of these things, and they don't at all when they don't work together. The lawyers build up a narrative of little bits and pieces, fragments that economists generally don't think have any meaning at all. And they run with it.

It still ceases to amaze me that a phrase in an email from a chain that you haven't seen can become a smoking gun in a trial, and I'm sitting there saying, I have no idea what he meant.

Joseph V. Coniglio: So true, right? And it really is a wonderful interplay. Having been on the private side and also as I said, a little bit of government, the interplay between the lawyers and the economists, fusing the documentary evidence and the depositions with the data, it really is an amazing practice that has developed.

And, Greg, I have to ask you, you've done so much at DOJ. It's impossible to discuss it all on this podcast, but one thing I think I have to ask you about is the Microsoft case. Because that was such a huge part of antitrust enforcement, over the last 40 years or so, and you played an integral role in that case.

So could you talk a little bit about what that was like and really what the impact and significance is of Microsoft from your perspective, and also maybe some misconceptions that people might have about the case.

Greg Werden: Okay. I was around the periphery of the case before and during the trial. I did a few odd jobs here and there. I was involved with expert work, the depositions, the written direct testimony a little bit. Mock, I mock crossed one of the experts. I'm good at that. I love mock cross.

But then I was deeply involved in the appeal which was quite a thing. The appeal briefs 150 pages. I haven't seen an antitrust brief over a hundred pages since then. This was special. Everything was bigger. The brief was initially drafted by four people in the antitrust division, and then it was redrafted by two people in the office of the solicitor general. And then the six of us met for a total of 36 hours over two days to work out the final wording of the brief. And then the argument took two full days.

With the two people from the Solicitor General's office arguing for the government along with John Roberts. He was in private practice and was hired by the states and did one little, to me, relatively uninteresting piece of the case. Judge Jackson had running conversations with reporters during the trial, which is a major no-no. And Jackson knew it was a major no-no, and he did it anyway. So John Roberts had to stand there and get berated, which is one of the things lawyers have to do from time to time. And they needed to learn how to do that.

Joseph V. Coniglio: I think it's safe to say his career turned out okay though, so.

Greg Werden: Really, it didn't hurt him a bit. I, since I knew you were gonna ask about Microsoft I brought a souvenir.

Joseph V. Coniglio: Ah!

Greg Werden: This

Joseph V. Coniglio: Yeah.

Greg Werden: Is the pass that got me a seat at the argument.

Joseph V. Coniglio: Wow.

Greg Werden: There are probably only about 50 of these and I bet there are only half a dozen left. So the, the lesson of the Microsoft case is a lesson that's learned every generation and then forgotten, sadly. Us old people don't forget, but we keep getting new people who know nothing.

So the lesson that was learned very early in my career from the IBM and AT&T cases was you have to figure out what the remedy is before you file a case. And surely this is a lesson that ought to have been learned by every lawyer in law school because it, it ought to be one of the first principles of equity. It's only about the remedy. There's nothing else that you're there for, except the remedy.

But this lesson was forgotten by the time the Microsoft case was filed, and then it was forgotten again by the time the Google search case was filed. Then they really hit the ball by bifurcating the case. The way a civil action ought to work is that the judge is constantly saying, now what are you asking me to do? And why? And you don't do that when you bifurcate the remedy phase.

And one of the consequences is he didn't make the findings he needed to make to support the remedy that the government then asked for. And the government said, I think you did make the findings, or if you didn't let, why don't you just make some more? It's okay. Do whatever you want. You ask about misconceptions. The great misconception is the government backed off of the remedy it was seeking when the Republican administration came in 2001.

That didn't happen. I was there, wasn't involved in all the discussions, but I didn't see any evidence of that. The court of appeals had made it reasonably clear that there was not going to be a breakup. And Judge Kollar-Kotelly pressured the parties to work out a settlement. That's what judges do, and they did work out a settlement. Consensus now seems to be it did some good. At the time, there were a lot of doubters. A related misconception is that a drastic remedy was justified, wasn't even close.

And the court of appeals explained that. What Microsoft did was fairly labeled as anti-competitive and it was proved that it had some marketplace impact. That was enough to justify a remedy. But it didn't justify a drastic remedy, not a breakup, and there couldn't be any punishment. It was a civil case.

You cannot have punishment in a civil antitrust case. Public doesn't get this, and the press doesn't get it either, and doesn't explain it in the stories. The press didn't get it in Microsoft. Press didn't get it this time in Google and they didn't get it back in the Standard Oil case in 1911.

Standard Oil was broken into 37 pieces. It's now considered to be the greatest victory in antitrust history, but William Howard Taft got trounced in the 1912 election because the public was completely dissatisfied.

Joseph V. Coniglio: I want to get into the history now, and obviously you have a great book. Still relatively new, came out I think in 2020, discussing really, it's a tour de force of antitrust law. I have a copy here and I would, again, recommended it to all of our listeners. The way I would analogize it is if you're a lawyer, the Areeda-Hovenkamp Treatise is your textbook, so to speak.

But this is a horn book, to use the law school analogy that you definitely want to have on your desk. So let me just ask, why did you write this book and who is it for?

Greg Werden: I work with a lot of people who took the antitrust class in law school and didn't seem to know any antitrust. So I tried to figure out why is that and I came to the conclusion that it's being taught wrong and it's always been taught wrong. I researched the history of the teaching of law and antitrust in particular, and the case method, which, because you went to law school, was invented shortly before antitrust was invented.

Antitrust has always been taught using the case method. I, in fact, have some materials from 1900 to 1905 that were used to teach antitrust, and the teaching of antitrust has always been organized around categories of conduct. But categories really ought not to matter much, and for the most part they don't. It's not like we have separate rules for every category of conduct.

What we have are overarching principles. And to understand those principles, you have to be focused on the principles and where they come from and what they're trying to accomplish. And to do that you need to study background events, ideas, and doctrines. And that's what my book does.

Joseph V. Coniglio: So the first part of the book's really, I think, focused on antitrust history, which you started to get into. And one of the things I like about it, Greg, is you have some very contrarian moments there really challenging the conventional wisdom. You talk about Ida Tarbell, Teddy Roosevelt, and even have something sympathetic to say about Brandeis Chicago Board of Trade decision.

So I guess I would just ask we hear the early period of antitrust glorified a lot. What are some misconceptions that people have about the passage of the antitrust laws, the formative era, how the courts initially handled it, that could be helpful when we're thinking about antitrust policy today.

Greg Werden: Well, practically anything people have said about where antitrust comes from is overreading the history, a lot. It was a populist movement. They had some idea what things in particular the big companies were doing that they didn't like, but mostly they didn't like the big companies. And mostly they didn't like Standard Oil, which was doing a lot of stuff that might have been the stuff they wanted to prohibit. Presumably it was what they were trying to prohibit. But there's not a lot about it in the legislative history and there's no reports as such on the Sherman Act.

There's no inside scoop on what Sherman was really trying to accomplish. He was against the trusts. There's a story that he was bribed, no evidence to back it up, and I'm not sure what he was bribed to do exactly. The truth is that very little in the Sherman Act was what Sherman proposed. He didn't write Section One or Section Two. They were written by George Edmonds, the chairman of the Judiciary Committee.

And the Supreme Court got right, what he was trying to accomplish. He was trying to use ideas that were already established in the common law to craft general prohibitions that would prevent the bad stuff that the trusts were doing.

What were the trusts? That's a good question. That was one of the things that, that I started to research in writing my book. Where does the word come from? It comes from the narrow legal meaning of a trust, 'cause that's what Standard Oil was. A bunch of companies had all or most of their stock put in a trust and a board of 12 trustees ran all of the companies jointly. I actually own one of the share certificates issued to one of the original 12 trustees. It's the wallpaper on my computer.

So this was a little bit cartel and a little bit merger. It was something new and the only reason it happened is because they couldn't merge. It wasn't possible under the corporate laws of 1882, which is when the Standard Oil trust was created. So this was their next best thing. It's said to be a cartel, and a little bit it is, but it was, they were trying to be a merger, and they did merge later, after the Sherman Act was passed.

Joseph V. Coniglio: And it's interesting 'cause I know there are a lot of criticisms of whether the Standard Oil decision was correct. There's this idea that the breakup wasn't even, wasn't actually led to increased prices and, perhaps if Standard Oil didn't even need to predatory price because it could have done other ways of consolidating. So it's such a fascinating case.

But let me ask about the sort of part two of your book. So you get into the history, but then you really get into the intellectual foundations behind antitrust, some of the principles. And one of the things that struck me was your discussion of the Chicago school and how it relates to the Harvard School. 'Cause usually when we think about antitrust, we think about an interplay of those two schools, forming the modern foundation of antitrust. And you mentioned that approach in your book but you suggest that when it came to the economic analysis, the Chicago school really was dominant whereas others might say the Harvard School really became the normative method in the courts.

So how do you see that interplay between the Chicago school and the Harvard School in making antitrust law what it is today?

Greg Werden: Before I answer that question, let me first say that in the early days of antitrust, economics wasn't part of the picture at all because economists didn't think it was a good idea. There was no support from the economic community for antitrust laws in 1890. There, there wasn't any support for antitrust law until roughly, I'd put it at about 1912. So economics comes into the picture when we get the second generation of antitrust.

We got the Clayton Act and the FTC Act in 1914, and John Bates Clark, who was the most influential economist from 1890 to 1915 was a big supporter of legislation. You read all this stuff to find out what stupid ideas they had and what brilliant ideas they had, because they got a lot of stuff right. And one of the things that I cannot find in any earlier references on than John Bates Clark is that dynamic competition is what it's all about. Now, I'm sure you you guys are particularly interested in this idea. The earliest I can trace it back to is 1912, John Bates Clark. And he said it exactly right.

But economists aren't involved in the process of antitrust until the thirties. I tried, I, I could not get enough documentation on this, but economists start working in the agencies in the thirties, and a few of them are pretty influential. But economics is on the sidelines. And even though economists are involved at the Harvard School, Edward S. Mason was an economist and he's considered the founder of the Harvard School, it is not modeling type economics. It is touchy feely, policy-oriented economics.

What Aaron Director did completely differently in the Chicago school was say, now, hold on now. You say this practice is anti-competitive, let's work this out in a simple model. And it's very simple, too simple perhaps, but it's a place to start. The idea of modeling antitrust caught on because of the Chicago school, and the models got a lot more sophisticated around 1980.

That was a period when industrial organization economics was all about game theory. And so all the tools of game theory were applied to all the antitrust questions in an, in increasingly more sophisticated way to prove what you could prove about what was right in Chicago, prove what you could prove about wasn't robust in Chicago's philosophies. And, try to get to what mattered and what didn't matter and what insights we could use to work on cases and make policy. And that wasn't work done by the Chicago school, but I'm not so sure it would've been done had it not been for the Chicago school. It's all very useful.

Joseph V. Coniglio: You need to have Chicago to have Post-Chicago.

Greg Werden: Yeah. So not surprisingly, every simple insight that Chicago had is not quite right. Of course not. But were any of the economic insights of the forties and fifties quite right? No not by today's standards.

Joseph V. Coniglio: Okay.

Yeah, sometimes Chicago is unfairly criticized by the standards of now rather than the time and overlooks the contributions that it did make in improving antitrust, even if it's nothing is perfect.

Greg Werden: And people also treat Chicago as one thing, and it was many things.

Joseph V. Coniglio: Exactly. And I want to move now to part three of your book, because that is in some ways, where you talk about the antitrust doctrine. From my perspective, it's this idea that antitrust is not necessarily about consumer welfare. It's about competition.

And I think that's really profound, Greg, and I think it's something that maybe we have missed a little bit over the past 40 years. Consumer welfare analysis is helpful but maybe there's something more there about the competitive process. So talk to us a bit about that. 'Cause I really think it is a fundamental point that you raise.

Greg Werden: Sure. I come to this slowly and painfully. I would say it took me more than 20 years, maybe more than 30 years of doing antitrust to decide what antitrust was about. Even though it's obvious and should have known from day one because the courts have been saying it all this time, it's about competition.

What does that mean? So there, there's this very important section in the Antitrust Paradox, Robert Bork's famous book, where he says that competition is not a workable basis for antitrust. And he gives, I'm not remembering exactly, but I think seven reasons why that is, and he's wrong about all seven.

But he basically just misses the idea that you can make antitrust be about competition. And his straw man is to say that if it's about competition, then the antitrust ideal is infinitely many infinitesimal competitors, which is impossible and inefficient. It's not what we want. It can't be our ideal. That's a crazy notion of what competition means.

So you shouldn't even start with structure. You should think about conduct. 'Cause that's what antitrust is about. So what does it mean? It means that two competitors can't get together and agree not to compete.

Joseph V. Coniglio: Yep.

Greg Werden: What could by definition be more anti-competitive than two competitors agreeing not to compete? That's what it's about to focus on competition. You can build an antitrust around competition. And I really didn't do it in my book. I did it later. I did it in a 2024 article in the Antitrust Law Journal, which is titled Competitive Process Standard.

And I wrote it defensively, also collect up my ideas, but defensively, because people were saying like what Bork had said, although not acknowledging that Bork said it first, and not agreeing with anything Bork said for, with most of these people saying that hardly the competitive process is just an empty slogan. It has no meaning. I wrote a 30,000 word article saying, here's what it means, and it does mean something.

Let me explain in just in a nutshell what it means, 'cause it's a 30,000 word article. So it, it means that antitrust cases are about proximate effects. Not ultimate effects. Bork's all about the ultimate effects. He said, look at how this affects welfare or output as a proxy for welfare. And eh, sometimes you maybe can do that, but mostly that's really hard. Might even be absolutely infeasible. But what can you do?

You can look at proximate effects on the ability and incentive to compete. And certainly when you look at agreements among competitors, that's what you look at. Does this affect, ability and incentive to compete in an adverse way? Is there a good reason to do it anyway? Okay, that's the analysis you can do. And to a large extent, that's the analysis we have done. Just call it what it is.

It's a competitive process standard.

It says, don't look down the causal chain. You can't see that far. With tort law, we know we can't see that far. Why should we think we can see that far in antitrust law? We can't. And if plaintiffs have to prove it, they always lose.

Joseph V. Coniglio: Yeah. Yeah. I think it's such a great point because you do have these ideas of either competition and structural terms, which you see again with the neo-Brandeisians and even Adam Smith arguably, and also this idea of competition is neoclassical equilibrium which is the Borkian view, the Chicago view.

There's this other path of competition as a process, certainly as a Schumpeterian, I I would agree. Competition is a process, and the idea is, it, there is this harm to the process that manifests itself through harm to consumers and innovation would, depending on what form that process takes. And, again, it's you do need to show consumer harm, right? But that's not the be all end all right? There has to be some process harm.

Greg Werden: You have to come at it from multiple directions. As a Schumpeterian, that you have a different take on what the process is, a bigger, longer term take on what the process is. And you see all the bits and pieces as being part of this bigger process. And that is a very healthy way to look at many antitrust cases. You have to look at this big picture to understand what is good or bad about particular conduct. If you focus too narrowly, you don't understand why anybody does anything, you don't understand why it's good. You don't understand why it's bad. You miss everything.

T hat's very healthy. The courts have a long ways to go on that.

Coming from an antitrust economist in particular, that's a very high praise for the competitive process standard. And really, I think, illustrates an area of how it operates that many people don't necessarily realize. But Greg, now that we've solved all the problems of the antitrust standards and we've gotten to the core of what antitrust is about before we conclude, I just wanted to ask a question.

Joseph V. Coniglio: Now that you're retired, what does a retired DOJ economist do other than write great antitrust books? How are you enjoying yourself in your retirement?

Greg Werden: I write briefs.

Joseph V. Coniglio: So you're not really retired after all?

Greg Werden: No, I was working on one today. It will be filed next week in the DC circuit. A brief supporting defendants who got summary judgment after, believe it or not, 17 years of litigation.

And it'll be many more years if the summary judgment is reversed, but it shouldn't be 'cause it was correctly granted in 166 page opinion. And, I, someone sent me an amicus brief in support of reversal and said, is this right? And I said, no, because there's economics in it.

And then the person said, Hey do you want to write a brief? I said, yeah. Okay. And it's my sixth amicus brief in the last two years. I've already written a brief in the Google Appeal and it hasn't really started yet, but I could write half of it. At least half. I didn't know how much starting in June and I did, 'cause I had time then. And so it's all ready to go.

Joseph V. Coniglio: So I guess the takeaway is we all love antitrust so much we can never stay away even when we're retired.

Greg Werden: Greg, I want to thank you so much for your time. This has really been an amazingly erudite and fascinating discussion. I would just commend everybody again to read your book the Foundations of Antitrust. Truly one of the best things I think that's come out in recent years on the antitrust laws. And thanks everybody for listening. Please stay tuned for our next episode of Creative Discussion coming up next month, we'll feature another great antitrust luminary. Greg, thanks again very much for joining us.

You're welcome. Thanks for having me.