ABSTRACT
In this chapter, relations between the competition authorities in the US and EU are analysed from a comparative perspective and in the light of network models discussed in the second chapter of this book. Thus, this chapter provides the second and final pillar of the comparative analysis of antitrust federalism that this book aims to achieve. The chapter opens with a brief comparison of the general characteristics of competition authorities in the US and the EU. In this section, it is shown that the EU and the US rely on essentially different institutional designs and enforcement methods that, nevertheless, do not render the comparison implausible from the perspective of comparative methodology. Afterwards, the chapter continues with the analyses of the origins, designs and management experiences of networks in the US and the EU. These analyses are accompanied with comparative sections where differences and similarities between the US and the EU regimes are summarized. Readers will immediately notice that the analyses of US network are supported with ample empirical data, whereas the same is not the case for the European Competition Network (ECN). The reason for this asymmetric empirical intensity is twofold: first, lack of formalism in the design of US network renders empirical analysis inevitable to understand the dynamics of this network. Second, the opacity in the management of ECN – that will be discussed in this chapter at length – renders the collection of empirical data with regard to the operation of this network extremely difficult.
