#389 What Should Directors Be Asking? Antitrust in the Boardroom

Speaker A: Welcome to our Cureus Amalgam, the weekly podcast brought to you by the Antitrust Law section of the American Bar Association. Our curious amalgam explores the fascinating and increasingly overlapping world of competition, consumer protection, data protection and privacy law. Each week we bring you leading global experts on the most compelling issues of the day. Enjoy the show.

Speaker B: Hello and welcome to our curious Amalgam, the podcast from the American Bar association and address Los Angeles. My name is Anora Won. Today's topic is what should directors be asking antitrust in the boardroom? Joining me today is my co host, Jenny Mayer. Hi Jenny.

Speaker C: Hey Anora, how are you?

Speaker B: Good. Would you please do the honor to introduce our guest today?

Speaker C: Absolutely. This is going to be a really good one. Our guest today is Julie Goshorn, who has spent more than two decades advising companies and government agencies on some of the most complicated antitrust issues across across the intersection of technology regulation and government enforcement. Julie's background spans both private practice at Arnold and Porter, as well as senior roles at the DOJ Antitrust Division and the ftc, and most recently as a senior managing counsel at Visa, uh, where she built the company's global competition compliance program, as well as leading global antitrust litigation and competition strategy. Today, Julie brings a really unique perspective on a corporate director's role, focusing not necessarily on how to practice antitrust law, but how boards and individual directors should oversee competition risk as part of their broader fiduciary responsibilities. So, really looking forward to this discussion. So welcome, Julie.

Speaker D: Thank you, Jenny. Thank you, Anora. Looking forward to the discussion.

Speaker B: Julie, let's get to the point. It appears that most antitrust advice that's out there is written for either the in house lawyers and business people doing the work, but not really for directors like the board directors overseeing things. Why is there such a gap and why does it matter now to you?

Speaker D: Thanks, Sonora. You're right. Almost everything written about antitrust is written for the people doing the work, the in house and outside lawyers and the deal teams. Almost nothing is written for people who oversee them. And that's the gap I'm seeing. And it matters now because competition risk has grown up. It used to be just a legal question. You hand it to the DC and today it's an enterprise risk question that boards exercising their oversight role need to think about because it moves strategy, growth and value. That's the piece the board feels instinctively banana trust lawyers tend to miss. Risk and opportunity are, uh, two sides of the same coin. This is the thing boards think about, boards think about risk and opportunity. Boards Think about competing hard, taking a market position, doing deals. Each one carries antitrust exposure and balancing against a real upside. The board's job isn't to run that math. It's to sit at 30,000ft and make sure management is pricing both sides, right? The opportunity and the risk and the exposure. That's how I approach it from m. An oversight seat rather than an operator seat. Boards don't manage antitrust cases. You'll hear this quite a bit from me in the coming minutes. Boards manage enterprise risk.

Speaker C: So, Julie, when we were speaking before getting ready for this podcast, you used a phrase that I thought was really apt. You describe the board's role as nose in, fingers out. What do you see that meaning sort of in practice and, uh, especially when it comes to antitrust risk.

Speaker D: Thanks, Jenny. I think it is a really good way to think about board of directors roles, not just in antitrust. And I cannot take credit for that phrase. I learned it from someone else. Very smart on a board. But if you. As I think about it, I think about that there are a couple of ways a board can fail at, uh, in its oversight duties. One is this is a little bit antitrust specific, right? One is a director who takes over and starts doing the GC's job. A director starts running the HSR analysis, starts directing how a CID should be handled, how a discovery request should be responded to. That is a fingers in position. The other side is when a board goes passive and rubber stamps a decision. Oversight on the board lives between these two poles, right? It's fingers out of the work, right? It's not overseeing the cid, it's not overseeing the hsr, nose in on whether the work is happening. So I'm not writing the compliance policy, but I'm making sure a real system exists to measure how the program is going. It keeps evolving as the business and the law change and that the program has a competent owner in the business that has real resources and would put a competition problem in front of me in time to act, right? Not after it's public. I don't want to find out about a competition problem when it hits the front page of the Wall Street Journal. The board's contribution is better questions here, not knowing better answers. And that's the antitrust fluency, where antitrust fluency on a board earns its keep. Not to run the analysis, but to know which questions it should be asking and to catch a competition problem turning serious before it becomes a crisis. If a board never asks about competition risk in its major decisions, it isn't really exercising its oversight role.

Speaker B: So many things that the board has oversight over. Right. Like, it's fair to say antitrust is probably not one of the top however many things they're thinking about most of the time. Right. It's probably fair to say that many corporate boards now have only thought about antitrust when there is a major, um, merger and acquisition kind of transaction that's going through that they have to approve. But that's obviously not comprehensive enough. Right. Like, how has the competition risk landscape really changed over the past decade? That makes only thinking about antitrust when there's major ma sort of like an issue.

Speaker D: Yep, you're absolutely right. For a long time, probably even longer than I've been a lawyer, a board only saw antitrust at, uh, deal time. Just as you say, Anora, the company did wanted to do a big acquisition. You worried about clearance in the US clearance in the EU and then the rest of the year, uh, it wasn't on your radar at all. That world is gone. It has evolved. It widened. It went from antitrust, went from episodic like a deal to always on. And here's what I mean by that. Competition risk now runs, is a through line in a lot of different ways. It runs through digital and platform markets. It runs through data algorithms and AI, through labor markets, and through vertical deals, not just market share and occasional acquisition. Even privacy sits inside it. Right. A firm with market power can degrade data protection the way it could raise price, and that's more competition on quality. Antitrust also widened in reach. If you think about this from a global perspective, many companies, almost all companies operate globally today. A company operating globally can face review in several places at once. So there's all kinds of timing considerations you have to think about. You have to think about whether the laws are changing, whether they are likely to change. And then even here in the US it's no longer just DOJ and FTC doing merger clearances. We think about states now a lot more than we used to think about states a decade ago. States of states have built and are continuing to build real antitrust muscle and will act on their own on deals and on conduct. As of this recording, for example, a coalition of state attorneys general is trying to block the Paramount Warner Brothers deal even after DOJ decided not to challenge the deal. And a, uh, court has paused, has entered a TRO here in San Francisco on the deal while it considers evidence. And I think that, I think the TRO is set to expire in a couple of weeks. And so we'll see what happens there. But to me that says the Fed's passing on a deal isn't the finish line it used to be. Right. So a board's mental model has to move with all of this. Antitrust is a standing condition of how the company competes. Uh, that makes it much, much more than the occasional deal question.

Speaker C: So you explained how antitrust is now definitely broader than M and A. And there are more different types of areas in which we're seeing antitrust pop up on the radar of corporate boards. And I think one other area that some members of boards, especially for larger sophisticated companies, appreciate that antitrust is really a mission critical risk. But it's not just for very large global companies, it's almost any business. How is the degree of importance of antitrust evolved today versus a decade ago?

Speaker D: Yeah, thanks Jenny. I absolutely agree with that. It's the bigger exposure, as you point out, isn't necessarily a merger challenge or a government investigation into a merger. The other exposures, and these run straight across large companies, privately owned companies, small companies. It's the conduct stuff, right? It's conduct baked into ordinary operations at every company. How you price, how you bid, how you hire, how you collaborate with competitors, and what your people say to a competitor in the hallway at uh, a trade association meeting, uh, that's where a lot of antitrust exposure lives. Sometimes it's criminal, sometimes it's just civil. And uh, so price fixing, bid rigging, wage fixing, no poach. It doesn't care whether you're a public company, a private company, a three year old startup. Monopoly and merger risk may scale with size of a company, but conduct matters. Don't care about size of company. Conduct risk is close to universal. And what's different today is that it reached, has reached everyday functions. Hiring became a real antitrust question in the last couple of years in a way it wasn't a decade ago. But here's the reassuring point. For a board, this is the same oversight muscle boards already use on cybersecurity and financial controls. It's the oversight muscle. Antitrust has just joined the list of the parts that you need to exercise oversight over. So the posture of a board shouldn't be reactive, waiting for a subpoena to make antitrust matter to it. The real question is whether the company runs a proactive program before anyone comes knocking with a subpoena.

Speaker B: So in our title we ask, what should a board be asking? Right? Like so the word should indicates there's some sort of an obligation that's coming from the law. There is a string of Delaware cases that aren't really anatrus cases. Right. Like including Caremark, Marchand, Boeing and McDonald's that have important lessons for individuals who are serving on the board. Can you, um, unpack those cases for us just a little bit? And particularly what should directors take away from those cases in relation to managing antitrust risks?

Speaker D: Yeah, thanks, Anora. You're m absolutely right about, uh, a couple of points. One is they are not antitrust cases, they are governance cases. And two is that we should be paying attention to them. So there are four cases that you mentioned. I'll put them in a couple of buckets. One is the sort of Karamark, Marchand, Boeing cases. And those cases run the spectrum of how a board can be liable if it never builds a system to catch a major risk or consciously ignores a warning it got for decades. It was nearly impossible to win. Caremark, for example, itself called theories like this the hardest theory in corporate law to win on. But then Marshland, which is actually a case study in business school that I did when I was in business school back in the day. It's a listeria case where three people died. And that helped give the theory some teeth. Uh, and Bluebell Marchand paid a lot of money as the judgment in that case, and it made it a risk that can end a company.

Speaker B: Right.

Speaker D: The board, to bring it back to the board, has to actually monitor the risk and make sure bad news reaches the top quickly. Same in the Boeing case. Right. This was a case about the 737 Max where some few people died. The directors settled for hundreds of millions of dollars. The largest oversight settlement in Delaware history. So the enforcement in Delaware is increasing and is something directors need to pay more attention to. Now the second bucket, uh, is the McDonald's case. The McDonald's case is different because it had to do with officers rather than directors. Officers can also be liable for failing to exercise oversight. And ah, it's something you hear about when you're doing boards of directors things is you hear about DNO Insurance. DNO insurance has long been standard in the industry. But the takeaway from the McDonald's case is that officers oversight is real and necessary. The duty exists and it matters most for the risks that can take the company down. Turns on whether information reaches the board goes through senior officers in the company. This is where the officer liability comes in and, and it turns on whether and how quickly information gets to the board. So although there's no antitrust case in Delaware or elsewhere yet, the direction's clear. And unmistakable. And it would be an oversight for boards of directors to think that just because there isn't an antitrust case yet, these cases can't reach antitrust. Because it absolutely can.

Speaker C: Really important to keep in mind. And now perhaps moving from those cases where you're seeing a greater degree of courts pushing for both directors and now officers to have greater oversight over the business's activities. If you are a new director and you just walked into the board meeting for the first time tomorrow, what's the first question that you would be asking management and the general counsel, counsel of the company about managing competition risk?

Speaker D: Yeah, good question. What questions would I ask? I'd open with ownership, right? I'd ask who in the company owns antitrust risk, what is authority they have and does a problem have a fast path to this board. And I don't want every thing the DC is thinking about to reach me as a board member. I want there to be quick decisions and quick path to me for things that are important. That sounds basic, might sound basic, but it's the question everything hangs on.

Speaker B: Right.

Speaker D: A good answer names a competent owner with real resources and a clear line to the board. Ideally not somebody who is the head of the department of no. Risk and opportunity. As I said earlier, opposite sides of the same coin. And a board has to oversee legal risk through a lens of a profit making enterprise. And this is the thing that a lot of operators in a business miss. Right. Need to balance risk and opportunity. And this is what the board does. And therefore the business needs to find a lawful way to compete and not just the reasons it can't. And this is what I mean by the department of no. A bad answer from a, uh, general counsel to me is something like, don't worry, the lawyers have it, outside counsel's working on it, outside counsel will evaluate it. When we do a deal, that tells me that no one really owns it and antitrust is being handled episodically, not overseen. That one question tells you in about five minutes everything you need to know.

Speaker B: I think that's very important to start. And then we already talked about how M and A is a huge piece in terms of antitrust risk management for board. And then from a director's perspective, what are the most important questions that like he or she should be asking before actually approving a transaction?

Speaker D: Good question. And so, uh, the headline question in the Wall Street Journal or you may see as outside counsel is will the deal get approved? Will it get blocked? Will there be remedies from a board seat that's not even the first question. The board is approving a bet, right? Approving a, uh, risk opportunity bet. And so what I want to know first is whether the deal still could work under conditions we'd have to accept to to get it cleared. So what I want to see is a risk spectrum, if you will, sort of this is the riskiest situation, this is the least risky situation, so that I can adequately price the risk. And if what reaches me is conditions, accepting conditions that hamstring the strategy of the company, the deal might not deliver what the thesis has promised even if it closes. So that's the first thing. Second is risk allocation. If it doesn't clear at all, the deal doesn't clear at all who pays how much and how long are we the company tied up and off the market. That's things like reverse termination fee effort, standard divestitures. We pre commit to third. And lastly, and many directors miss this one. What are we a company allowed to do between signing and closing? This is where building guardrails is necessary before a deal. And so what I want to know as a director is do you have the guardrails in place to uh, m not do things like gun jumping, sharing competitively sensitive information in a way that violates antitrust laws, preliminary premature integration. I want to know as a director, do you have the guardrails in place? Is there, is there somebody exercising oversight into that program so that it doesn't happen? You don't have to call me and say, oh, DOJ has launched a gun jumping investigation into this merger because DOJ thinks maybe we're in. We were operating as one company before we closed.

Speaker C: So you, Julie, are a experienced antitrust lawyer and done a lot of M and A related work in your career on many different sides, in house, outside counsel at the government. And as we were talking getting ready for today, you mentioned something along the lines of, um, executives always tend to write the government's case for them. What? From the perspective of members of the board, why should they care? And then how do you get them to care about things like emails, board presentations and other documents that really are meaningful for antitrust review of deals.

Speaker D: Another great question, and it's not hyperbole when I say executives write the government's complaint for them. And we can easily see it in a lot of public cases. Now DOJ's complaints in any number of cases. I'll tell you about one here in a second. Directors should care about this because it goes back to the enterprise risk oversight role, right? Directors are overseeing enterprise risk and pricing it. And when there's one document, it's a bad document. It can sink a deal or lose a case or back the company into an antitrust complaint when it's simply at the investigation phase. So here's my example. Take Meta. FTC did not challenge the Instagram deal when then Facebook at the time it bought it. However, Years later, the FTC built a monopolization case anchored by a 2008 Mark Zuckerberg email that said it's better to buy than compete. Mark Zuckerberg Berg had to sit on the witness stand at the Meta trial just in 2025 and defend the email he wrote in 2008. What I want companies to recognize as a director is the documents don't expire, right? They live on. And letting a deal through is never a permanent pass. Why is why this is a board issue is that in a merger, for example, the deal rationale documents are prepared for the board. They go to the government with filing and so do significantly the deal documents for the other side. So when a company is trying to sell itself to a buyer, you will often see puffery in documents, right? You may see things like we dominate this space, nobody can touch us. That reads to an enforcer as an emission of market power. None of this is the responsibility of the board to draft or excise from drafting. What is the board's responsibility is to make sure the guardrails are in place so that those documents, at least at your own company, don't get drafted in the first place. That's where a robust compliance program matters and where a living compliance program matters because the law is changing all the time. Assume. My advice typically is assume anything we or our counterparty put on paper will be read out loud by an enforcer on the witness stand in a deposition. So write documents that you don't mind defending when you're in a deposition, when your lawyer can't object for you.

Speaker B: Judy, you're right. Compliance is so important. But when asked every company is going to say, yes, we do. We have a compliance program, right? But from the Bohr's perspective, how can you tell the difference between like a, uh, genuinely effective and like being updated and actually functioning compliance program from those that sort of like just condense to like a, uh, book on a shelf that you dust off and then glance over once a year?

Speaker D: This is a little bit of a flip response, but the easy way to tell the difference is to blow on it. And if dust flies, then, then it hasn't moved in a long time. But really what really matters is whether the program does anything. Right? The two look identical on a shelf or realistically in a computer. Right. On a monitor. So I ask three things. I ask things as a director. I ask things like, when did we last test the program and what did the test find? A program that never catches anything is not an effective program.

Speaker C: Right.

Speaker D: It's a, uh, sleeping program. So I want to hear when I want to hear about us catching something. Next question. Does the training reach the people who can actually create exposure? Right. Pricing, sales, procurement, hr, not just the legal departments. And third, can anyone point to something it caught and how, and importantly, how we fixed it? Right, because that ties the two things together. A real program has a track record and it's never done. It keeps evolving. It keeps pace with technology, the law, and the company itself. One that looks the same as it did three years ago isn't a living program. It's quietly stopped working. If those questions get a shrug, you've just got a binder on a shelf.

Speaker C: So when we were talking earlier, towards the beginning of the program, you described all of the new areas that antitrust enforcers and, um, agencies and other private parties around the world are kind of looking at as relates to antitrust. Things like platform, market, AI, data, labor, multiple acquisitions, other things like that. So many different areas in which antitrust is now touching the business. How would you recommend a new board member, or any existing board member to stay current on the wide variety of risk areas without completely getting lost in the weeds?

Speaker D: Yeah, that's a good question. And it's really hard, particularly as lawyers and as lawyers who grew up in law firms or in the government or even at companies, it's difficult not to get lost in the weeds. And it's an ever present challenge. The way I think about it, the way I try to do it, is I don't track the case law. And so this is why I was merely summarizing the Delaware cases above, because I don't track the case law. I track the risk. And, uh, thinking about risk and opportunity as opposite sides of the coin, I. When I'm tracking the risk, I think about, okay, this is how I'm thinking about the size of the risk. Therefore, there must be a size of the opportunity that follows. Trying to follow every new theory is how exactly how a board gets lost in the week. My job is to keep the, uh, enterprise risk lens. What these shifts, what shifts actually touch our business, and importantly, whether someone competent is watching it. The board doesn't have to be the expert itself. And so something smart that I learned in my board journey was, uh, thinking about bringing in outside advisors to get up to speed on a fast moving area. It is entirely possible, it's likely that there are experts in the company that can help boards figure out new areas, particularly areas where a company is moving. But there are lots of areas where the company is not moving, does not itself have experts. And so outside experts are perfectly viable things for boards to talk to and learn from. And it's amazing because then you get lots of good advice that helps you do your job better as an oversight person. Last thing I'll say about this is once or twice a year, sometimes more, depending on the size of the company, what its risk profile is. I ask management for a short, uh, plain English read, what's changed in the legal environment, what it means for us, the company. And I want two things on that read right. One, the risk map as we talked about earlier is not just DOJ and FTC anymore. Even in the US it's state IDs, it's private plaintiffs, we operate globally. Competition, regulators overseas, abroad. Always evolving. Staying current means watching all of those fronts, not just Washington. Second thing here is it isn't a one way ratchet toward more enforcement. So it's important to remember, even though we sort of live in what I think of as a very enforcee environment right now, technical word, some things are less enforcey. So if you think about the FTC and the Meta case that I mentioned a minute ago, FTC lost that case and so it is on appeal, but who knows how that's going to end. Hsr, new HSR was struck down and we'll see by the end of 2026 what happens with new HSR if there's a new HSR. So I want to know which theories are actually winning, what the status is, not just which cases are being filed, which cases have been thrown away.

Speaker B: It's definitely not easy job to sit on a board. And I think one more thing just to make it even a little bit more complicated and I think one thing you mentioned before while we were prepping is that just by sitting on a board, right, especially if you're sitting on multiple boards, there could be a sort of like an antitrust issue because there are issues what we call interlocks or conflict of interest as subject to Section 8 of the Clayton Act. So what should every board member know about that kind of Section 8 Enitrus risk?

Speaker D: So I uh, know that the podcast has covered section 8 fully incompetently a couple of Times. And so I'm not gonna, I'm not going to belabor the point, but I encourage people to go back and listen to those episodes. Section 8 bars one person from sitting on boards of two competitors. And importantly, after being dormant for a couple of a decade and a half, the agencies have revived it. How that has manifested is couple. About a dozen directors have quietly exited boards. And so to avoid that, one thing every director should do is check their own seats, right? You, I as a director know better than anyone else what seats I have, what is the time frame of those seats, who else sits on those boards. And so I can help protect the company from being in an interlock situation better than anyone else can do that. So that's the first thing. The new wrinkle is deputization. This is something that I have, I personally have not grappled with in my roles. But it's. The agencies have pushed this idea that. And it's a fairly aggressive theory that a fund placing two different people on two competing boards can still trip the, the interlock wire. So it is still kind of a theory, but it is something that people who sit on, on, on boards like that should keep in mind and should be sensitive to. And there are lots of great outside counsel who can provide good advice here. And so I'd recommend just at least interrogating that final thing I'll say here is there's also the company side version of interlocks and it's worth building in a guardrail in the company. So if a company has ventures, investments, and some of its executives hold seats in those venture investment companies, seats that carry different rights, uh, uh, depending on the company, depending on the investments, it's worth monitoring that and having somebody inside the company stay abreast of it. You want to stay abreast of both. What are the venture investment companies that we sit on? And also does our company do anything that competes with those companies? Companies are evolving all the time, including your own company. And so it can be a little difficult to track the overlaps. But there's nobody better to do it than the operators inside the company.

Speaker C: That's a really great point, one in which I think sometimes goes missed in the Section 8 literature. So very great thing to keep in mind. So we had a really wide range of topics that we've covered today. Really interesting for me, it's a new perspective, I think for a lot of us that are outside counsel. But maybe to pivot towards some, um, advice for any of our listeners out there who hope to one day serve on a board from your perspective and experience, what would be the couple of things or, uh, questions that those individuals should be routinely asking management to make sure that antitrust risk is being given the attention that it deserves?

Speaker D: Good question. And I, I would anchor this on one of the first things we talked about, the nose in, fingers out point. And so the three things I'm going to mention here are things you can think about that will help you maintain the nose in, fingers out posture regardless of whether you're on a, uh, public private startup board size, size of the company almost doesn't matter at all. So the questions in steady rotation are things like one, who owns the antitrust risk here and how does a problem reach this board fast? So I've emphasized speed, that it reaches me a couple of times and that anchors on the point about the cases. Right. Cases challenging boards having not gotten the information quickly enough and acted on it quickly enough. Second thing is antitrust on our mission critical risk register. And that's just, are we thinking about antitrust risk in the way we're thinking about cyber risk in the way we're thinking about securities risk? Right. This goes back to the point I mentioned earlier about antitrust is more present and it's not going to become less present anytime in our lifetimes or our careers. So the other thing I want to know there is when did we last test our compliance program or an antitrust program? Right. Because this goes back to the binder on a shelf problem. Right. When is the last time we thought about it? When is the last time we tested it, and what did that reveal? The third question I want to ask is when we're making major strategic decisions, M and A conduct other things, are we actually asking the competition program question or are we interrogating it, or are we assuming the outside lawyers, the GC just have it, they're running it. I want to know how we're asking that question and what the answer is. So those are the three questions. A board that asks those three questions routinely is doing its oversight job. A board that never asks them is not doing it, and they're failing at their oversight obligations.

Speaker B: I think that's a very important, uh, recap and thank you for the great conversation we have throughout. Before we really let you go, Julie, we're not going to miss the opportunity to give our audience a little bit of, like, peek into you as individual. So can you tell us something that people would not know about you if they had only known you or worked with you professionally?

Speaker D: Yeah. So I, I'm a scuba diver. And from the outside, uh, that seems risky, reckless, dangerous. But I'm also a lawyer. I am, um, not reckless. I don't engage in very risky behaviors unless they're managerist. And so there's real exposure. But you're also trained and you're watching everything. And that's what lets you go and see things that most people never get to go and see. And, uh, so there's a lot of planning and monitoring that you have to do when you dive, right? You plan the dive, you dive the plan. You watch your air. You don't want to run out of air 60ft below the ocean. You watch your depth, you watch your time below the surface. And you catch a small problem while it's still a problem, right? You always test your air before you go underwater. You test it as you're descending, because if you catch the fact that you don't have air before you go 60ft down, then you're not going to die. And I've dived lots of places. I've. And I've never died so far. And. But there, there's an analogy here, right, to the work of a board, right, which is a job of a board to catch risk before it comes, before it becomes a lawsuit, right before it shows up on the front page of the Wall Street Journal. Seeing around the corner is the board's job, with cooperation, partnership with the business executives. And when I'm diving, I read the gauges so I don't get surprised. When I'm on a board of directors, I read the gauges from the senior execs in the company so that I don't get surprised.

Speaker B: Do you have a favorite spot for scuba diving?

Speaker D: Well, it's really hard to beat where I first dove, which was in the Caribbean around St Martin because the water is so warm. And however, I will say my most recent dive trip was in the Maldives. It was a week on a dive boat, just constantly going around in search of sharks and other interesting creatures. And so that was amazing because I did not wear shoes for an entire week. Lived on a boat for an entire week. And so that was pretty magical.

Speaker B: We're excited for you about all those adventures. So it has been a great conversation. Thank you, Julie again for joining us. Thank you, Jenny, for being a great, wonderful co host as always. Thank you listeners and viewers.

Speaker A: Until next time, thank you for listening to this week's episode of our Curious Amalgam, a competition, consumer protection, data protection and privacy law podcast. It is produced and shared around the globe by ABA's antitrust law sector. The opinions expressed by the participants in this podcast are their own and do not necessarily represent their employer or other organizations. If you like what you heard or would like to become a member of the American Bar association, please check out what the Antitrust Section has to offer@ambar.org antitrust. You can learn more about our podcast at our curious amalgam.com if you have comments, suggestions or podcasts podcast ideas, please reach out to us@podcastourcurious amalgam.com until next time, thank you for listening.