Revised Jurisdictional Thresholds for Section 8 of the Clayton Act, 3813 [2014-01284]
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Federal Register / Vol. 79, No. 15 / Thursday, January 23, 2014 / Notices
from a study of how customers react to
different disclosures. However, given
the likelihood that the average benefit of
more disclosure to unaffected customers
is less than the benefit to affected
customers who are likely to be
customers closer to the margin, I am
inclined to believe that Apple has more
than enough incentive to disclose.40
sroberts on DSK5SPTVN1PROD with NOTICES
C. Other Considerations When
Examining the Costs and Benefits of
Platforms and Other Multi-Attribute
Products
Unfairness analysis also requires the
Commission to consider the impact of
contemplated remedies or changes in
the incentives to innovate new product
features upon consumers and
competition.41 I close by discussing
some additional dimensions of an
economic analysis of the costs and
benefits of product disclosures in the
context of complicated products and
platforms with many attributes, like
Apple’s platform, where such
disclosures are a critical component of
the user experience and have
considerable impact upon the value
consumers derive from the product.
For complicated products—for
example, a web-based platform for
purchasing and interacting with
potentially millions of items using a
mobile device—there are many things
that can negatively impact user
experience. The number of potential
issues for products that involve
hardware, software, and a human
interface is large. This is the nature of
technology. When designing a complex
product, it is prohibitively costly to try
to anticipate all the things that might go
wrong. Indeed, it is very likely
impossible. Even when potential
problems are found, it is sometimes
hard to come up with solutions that one
can be confident will fix the problem.
Sometimes proposed solutions make it
worse. In deciding how to allocate its
scarce resources, the creator of a
40 This argument does not, as Chairwoman
Ramirez and Commissioner Brill suggest,
‘‘presuppose that a sufficient number of Apple
customers will respond to the lack of adequate
information by leaving Apple for other companies.’’
Statement of Chairwoman Ramirez and
Commissioner Brill at 5–6. Nor does the economic
logic require any belief about the magnitude of
switching costs. Rather, the analysis relies only
upon the standard economic assumption that Apple
chooses disclosure to maximize shareholder value,
weighing how customers react to different
disclosure policies. If Apple behaves this way, the
average benefit of more disclosure to unaffected
customers is less than the benefit to affected
customers, and affected customers are more likely
to be on the margin than unaffected customers, then
economic theory implies that Apple is likely to
have more than enough incentive to disclose.
41 Unfairness Statement, supra note 7, at 1073–
74.
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complex product weighs the tradeoffs
between (i) researching and testing to
identify and determine whether to fix
potential problems in advance, versus
(ii) waiting to see what problems arise
after the product hits the marketplace
and issuing desirable fixes on an
ongoing basis. We observe the latter
strategy in action for virtually all
software.
The relevant analysis of benefits and
costs for allegedly unfair omissions
requires weighing of the benefits and
costs of discovering and fixing the issue
that arose in advance versus the benefits
and costs of finding the problem and
fixing it ex post. These considerations
fit comfortably within the unfairness
framework laid out by the
Commission.42 The Commission also
takes account of the various costs that
a remedy would entail. These include
not only the costs to the parties directly
before the agency, but also the burdens
on society in general in the form of
increased regulatory burdens on the
flow of information, reduced incentives
to innovate and invest capital, and other
social costs.43
Here, Apple did not anticipate the
problems customers would have with
children making in-app purchases that
parents did not expect. When the
problem arose in late 2010, press reports
indicate that Apple developed a strategy
for addressing the problem in a way that
it believed made sense, and it also
refunded customers that reported
unintended purchases.44 This is
precisely the efficient strategy described
above when complex products like
Apple’s platform develop problems that
are difficult to anticipate and fix in
advance. Establishing that it is ‘‘unfair’’
unless a firm anticipates and fixes such
problems in advance—precisely what
the Commission’s complaint and
consent order establishes today—is
likely to impose significant costs in the
context of complicated products with
countless product attributes. These costs
will be passed on to consumers and
threaten consumer harm that is likely to
dwarf the magnitude of consumer injury
contemplated by the complaint.
This investigation began largely
because of complaints that arose when
in-app purchases were first introduced
into the marketplace and Apple had not
had enough experience with the
platform to recognize how parents and
42 The Commission must take ‘‘account of the
various costs that a remedy would entail’’ including
‘‘reduced incentives to innovation and capital
formation, and similar matters.’’ Unfairness
Statement, supra note 7, at 1073–74.
43 Unfairness Statement, supra note 7, at 1073–
74.
44 See Foresman, supra note 13.
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3813
children would use the App Store. In
late 2010, complaints began to emerge.
In March 2011, Apple first altered its
platform to address complaints about
unauthorized in-app purchases. It is not
unreasonable to surmise that as Apple
has modified its policies based on
experience, and customers have learned
more about how to use the platform,
unauthorized in-app purchases by
children have most likely steadily
declined.
The Commission has no foundation
upon which to base a reasonable belief
that consumers would be made better
off if Apple modified its disclosures to
confirm to the parameters of the consent
order. Given the absence of such
evidence, enforcement action here is
neither warranted nor in consumers’
best interest.
[FR Doc. 2014–01197 Filed 1–22–14; 8:45 am]
BILLING CODE 6750–01–P
FEDERAL TRADE COMMISSION
Revised Jurisdictional Thresholds for
Section 8 of the Clayton Act
Federal Trade Commission.
ACTION: Notice.
AGENCY:
The Federal Trade
Commission announces the revised
thresholds for interlocking directorates
required by the 1990 amendment of
Section 8 of the Clayton Act. Section 8
prohibits, with certain exceptions, one
person from serving as a director or
officer of two competing corporations if
two thresholds are met. Competitor
corporations are covered by Section 8 if
each one has capital, surplus, and
undivided profits aggregating more than
$10,000,000, with the exception that no
corporation is covered if the competitive
sales of either corporation are less than
$1,000,000. Section 8(a)(5) requires the
Federal Trade Commission to revise
those thresholds annually, based on the
change in gross national product. The
new thresholds, which take effect
immediately, are $29,945,000 for
Section 8(a)(1), and $2,994,500 for
Section 8(a)(2)(A).
DATES: Effective January 23, 2014.
FOR FURTHER INFORMATION CONTACT:
James F. Mongoven, Bureau of
Competition, Office of Policy and
Coordination, (202) 326–2879.
SUMMARY:
Authority: 15 U.S.C. 19(a)(5).
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2014–01284 Filed 1–22–14; 8:45 am]
BILLING CODE 6750–01–P
E:\FR\FM\23JAN1.SGM
23JAN1
Agencies
[Federal Register Volume 79, Number 15 (Thursday, January 23, 2014)]
[Notices]
[Page 3813]
From the Federal Register Online via the Government Printing Office [www.gpo.gov]
[FR Doc No: 2014-01284]
-----------------------------------------------------------------------
FEDERAL TRADE COMMISSION
Revised Jurisdictional Thresholds for Section 8 of the Clayton
Act
AGENCY: Federal Trade Commission.
ACTION: Notice.
-----------------------------------------------------------------------
SUMMARY: The Federal Trade Commission announces the revised thresholds
for interlocking directorates required by the 1990 amendment of Section
8 of the Clayton Act. Section 8 prohibits, with certain exceptions, one
person from serving as a director or officer of two competing
corporations if two thresholds are met. Competitor corporations are
covered by Section 8 if each one has capital, surplus, and undivided
profits aggregating more than $10,000,000, with the exception that no
corporation is covered if the competitive sales of either corporation
are less than $1,000,000. Section 8(a)(5) requires the Federal Trade
Commission to revise those thresholds annually, based on the change in
gross national product. The new thresholds, which take effect
immediately, are $29,945,000 for Section 8(a)(1), and $2,994,500 for
Section 8(a)(2)(A).
DATES: Effective January 23, 2014.
FOR FURTHER INFORMATION CONTACT: James F. Mongoven, Bureau of
Competition, Office of Policy and Coordination, (202) 326-2879.
Authority: 15 U.S.C. 19(a)(5).
By direction of the Commission.
Donald S. Clark,
Secretary.
[FR Doc. 2014-01284 Filed 1-22-14; 8:45 am]
BILLING CODE 6750-01-P