Elgar Encyclopedia of Comparative Law, Second Edition
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Elgar Encyclopedia of Comparative Law, Second Edition

Edited by Jan M. Smits

Written by leading authorities in their respective fields, the contributions in this accessible book cover and combine not only questions regarding the methodology of comparative law, but also specific areas of law (such as administrative law and criminal law) and specific topics (such as accident compensation and consideration). In addition, the Encyclopedia contains reports on a selected set of countries’ legal systems and, as a whole, presents an overview of the current state of affairs.
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Chapter 16: Competition law*

Damien Geradin


There is a wide body of literature in the field of comparative competition law. The vast majority of this literature, however, seeks to offer comparative insights into US antitrust law and EC competition law. Some books have, nevertheless, attempted to compare the competition law regimes of several industrialized countries (see, e.g., Doern and Wilks, 1996, comparing the six ‘model’ policy regimes of the USA, Germany, Japan, the United Kingdom, Canada and the European Union). Other books have attempted to compare an even wider set of competition law regimes, including regimes from emerging economies (see Geradin, 2004a; Chao et al., 2001; De Leon, 2001; Rosenthal and Green, 1996). Europeans have been looking to the US antitrust law system since the end of World War II. At the time of the elaboration of the EC Treaty, the Sherman Act represented the legislation of reference in the area of competition law and it certainly had an influence on the drafting of the competition law provisions included in the EC Treaty. (US lawyers also played a significant role in the drafting of the competition law provisions inserted in the European Coal and Steel Community Treaty, which preceded the EC Treaty. See Gerber, 1998, p. 338.) But even after the signature of the EC Treaty, European competition law scholars and practitioners continued to look to US antitrust law as a source of inspiration (see, e.g., the two pioneering books by Joliet, 1967, 1970).

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