ABSTRACT
This chapter presents a comparative overview of the various competition regimes in the world. For the comparative overview the jurisdictions of the United States (US) and the European Union (EU) were chosen because they have the most deep-rooted and sophisticated competition systems in the world. In the US, the term antitrust law is used while in the EU and other parts of the world the term competition law is more common. An important characteristic of US antitrust law is the fact that it allows the possibility of criminal enforcement. The Robinson-Patman Act covered in great detail price discrimination and the provision of services. The Celler-Kefauver Act dealt with mergers and joint ventures whose effect might be to substantially lessen competition or to create a monopoly. Federal competition laws in the US are enforced predominantly through procedures enacted by the federal courts, by the Department of Justice, by private parties or by attorneys general of the various states.
