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Jennifer Fauver on Antitrust Enforcement by State AGs

Jennifer Fauver on Antitrust Enforcement by State AGs

Sarah:

Hi, and welcome back to Two Think Minimum. Today is Wednesday, June 1st, 2022. I’m Sarah Oh Lam, a senior fellow at the Technology Policy Institute. I’m here with my co-hosts, TPI president and senior fellow Scott Wallsten and TPI senior fellow and president emeritus Tom Lenard. Today, we’re delighted to have as our guest, Jennifer Fauver. Jen is a third-year law student at George Mason’s Antonin Scalia Law School— actually, graduate now, with more than 20 years of experience in law and economics, having worked for NERA Economic Consulting, and having testified and conducted economic analyses related to antitrust litigation. She’s headed off to private practice after the summer, but she’s here today to discuss her new article entitled, “Putting a Number on the Debate: An Empirical Assessment of the U.S. Federal Antitrust Enforcement by State Attorneys General.” It’s available on SSRN. Her article focuses on state attorneys general and what they do in practice. She’s compiled a newly constructed database of state AG enforcement, and we’re going to hear a little bit more from her about her research. Thanks Jen, for joining us.

Jen:

Thanks, Sarah. Thanks for having me. I appreciate it.

Sarah:

Could you tell us a little bit about your paper, about the research that you did, the database you put together, and some of the motivation for why you thought this was an important topic?

Jen:

Sure. So, you know, through the years, you hear a lot of debate about what it is that state AGs should do, you know. And back 22 years ago now, in the Microsoft case, I think a large debate occurred—or at least started there, and perhaps motivated by Judge Posner’s, I think, sort of, salty disposition regarding his failed mediation attempts with the state attorneys generals in the Microsoft case—but there’s been a debate about what state AGs should have the power to do under federal antitrust laws, one, and two, even with respect to their own state antitrust laws, and how that aligns with, sort of the federal lay of the land on antitrust enforcement. And there [were] a lot of anecdotal sort of discussions, you know. Microsoft was one, and there were some others through time… State AGs make decisions, not based on, you know, what conduct is anti-competitive, but they’re motivated by other things, you know. They’re elected, their constituents are looking for jobs, and maybe that’s not the purpose of antitrust laws, but that might be a motivating reason why a state AG brings an antitrust enforcement action.

And what I found lacking was actual information in any sort of systematic manner about what a state AG is actually doing, how are they using, you know, just even federal antitrust laws—forget their own state antitrust laws for the time being—but even just federal antitrust laws. Because I think if we’re going to have a debate, or at least a credible debate, about what state AGs should and shouldn’t do, we actually have to know what it is they’re doing now and what that looks like. Not just, oh, we’re bringing a bunch of cases, which I think we all can say, yeah, that’s true. We can read the popular trade press and say, yeah, state AGs are active [and] put a check mark next to that, but we don’t know exactly what it looks like. What’s the breakdown in terms of the types of cases they’re bringing? Are they keeping true to their promise many years ago to continue to take on vertical cases? Especially when, I guess you could say the law wasn’t particularly favorable, particularly on, you know, predatory pricing and a variety of other things, [such as] resale price maintenance.

And so— but no one could really answer that question. And there was no sort of source of information. And I thought, well, if we’re going to have a debate, we need to get the data. And so, I decided, well, no one else seems to be doing it, so I think I’ll spend some time trying to see if I can build the data. Now, NAAG has, sort of, given a little bit of a head start in that they have a multi-state database that, that they publish. And they publish limited information, but it’s not meant to be systematic. You know, they don’t have every case, and I think the state AGs contribute the information to the database. And so, it was good to have the cross reference, but it wasn’t going to get me all of the enforcement that I needed to get. And so, it was a matter of building from dockets and case law, and then, you know, comparing it with NAAG’s and pulling out all of the relevant information.

It was a— it was a long process. It was a better part of a year to even get the data built. And then of course, time after that to really look at the data and say, does, you know, does it make sense? You know, what am I seeing? Do I need to go back to the sources and pull out additional information to make sense of what it is that that I’m seeing? So that’s kind of how I got to where I am, and sort of the process I went through, and why I even bothered to do it in the first place.

Sarah:

One of the impressive things about your paper, which is kind of why I wanted to invite you on, is because you have so many nice charts and graphs, and you’re really tracking what the state AGs have been doing for the last 20 years across the 50 states. And so, it’s not anecdotal, it’s quantified. Could you explain what NAAG is and how maybe they weren’t doing that and where a researcher can come in and you filled that hole?

Jen:

Yeah, sure. So, NAAG stands to mean [YL1] the National Association of Attorneys General. They are the group of attorneys generals. They represent sort of all the, the attorney generals and they were, they’ve been around for quite some time. They’ve been involved in antitrust for quite some time. And there is a way for various attorneys generals to come together to make enforcement decisions, to learn about their role, to seek help in bringing enforcement actions. And part of what they did several years ago is, they began to construct this multi-state database. As I said, it doesn’t have everything. It has—and it’s a mix, it’s—a mix of cases brought under federal law and a mix of cases brought under state law.

And my question was really about federal law. And so, I think that, in terms of scope, there was something lacking. I think also the types of information that they, you know, pull out is not comprehensive. So, you may know that a case settled, but you don’t know what that means. You don’t know, was there a federal settlement and a state AG settlement? Was it one settlement? What were the terms of that settlement? If there were two settlements—one for the state, one for the federal agency—what are the terms look like comparatively? Are they the same terms, different terms? So, [it] was limited in terms of a), it doesn’t have all the cases, but b), it doesn’t have all the areas of inquiry and all the data variables that I think a researcher would want to actually start studying this question of what the appropriate role for state AGs are in antitrust enforcement.

Scott:

You talk about how to go from the positive of what they are doing to the normative of what they, what they should do and how you can do that better with the database. Can you tell us maybe your highest-level takeaways from what you, what you saw in the data?

Jen:

Yeah, so I think there were a few things that stood out to me in the data. One is, I think—particularly on the merger side—the amount of federal and state AG combined participation there was. There’s very little being done by states alone in that area. And I think to me, I was expecting to see, maybe, a little more of, sort of, the states stepping up without federal enforcers. And typically, you just, you don’t see that. I mean, virtually all of it is with federal enforcers, and that’s not necessarily to say that they’re both plaintiffs on the complaint, or they’re both listed on the settlement. Sometimes the state [has] separate settlements, but what’s interesting about that, which is sort of the second takeaway, is you either have a lot of the same terms, right? With the exception of, the states are allowed to get reasonable attorney fees, and, and costs and things like that. Okay, fine. That’s their state statute. That’s what they can do.

But you also have when they don’t match, you have these additional terms that are not in the federal consent that are not necessarily directed at solving the competitive issue. Now, I acknowledge, and that I’m in a little bit of a bubble in the sense that I have to read a consent and make some determination about whether the remedy actually addresses the harm, right? I don’t have all the deal documents. I don’t, I’m not able to look at everything. But what I think I can say is, when the consent contains information about price controls and jobs and employment, that seems to be a little bit outside of the wheelhouse of antitrust generally, and typically what federal enforcers are going to use as consent terms. So, I think for me, those were the two sort of, two of the things that really kind of jumped out as a result. And I think [it’s] where a lot more work can be done.

Sarah:

When I was reading your paper too, I noticed that enforcement actions jumped up after the Hart–Scott–Rodino Act passed in the seventies. And so, maybe that is similar to federal enforcement, that it increased after the seventies. And then I also wondered—and I asked you this once before—the composition of cases, like, you know, federal antitrust enforcers seem to be focused on tech lately. Do you see that in the state data as well?

Jen:

Yeah. So, I guess two things there. So, you’re absolutely right. I mean, the data shows that after the HSR Act passed, state AGs became more active in federal antitrust enforcement. I think largely— this is kind of a little bit of where the debate comes in, because you’re right there at the cusp of the Reagan administration and everyone argues the Reagan administration [was] pretty lax on antitrust. And so, depending on what school of thought you had, you have this idea that state AGs would say, well, we came in, you know, there was a demand for antitrust enforcement and we filled that unmet demand because antitrust enforcers weren’t actually enforcing. Now I have some data that says, you know, look, maybe on the vertical side, that was maybe true. Clearly, it wasn’t true with respect to, you know, multi-firm conduct price fixing, and things like that. And on the merger side, I think it’s a bit of a mixed bag. But, [the] takeaway [is,] since the HSR Act, they have been very, very active and they show no sign of abating in terms of their activities.

Now, in terms of the composition of cases, you’re right. Tech is right now front and center. But if you look at sort of the composition of cases that they’ve brought over the last 20 years, you don’t see a lot of tech, right? Obviously, now you do. And it’s interesting, I think, when you look at what the state AGs are doing in terms of the tech complaints—particularly on the Google side—I think this speaks to why, you know, these data are important and additional research is important, because the state AGs seem to be doing their own thing. And you have groups of state AGs doing their own thing. And so now, we have an even greater potential for there to be dichotomy in terms of results. And while we may have more antitrust enforcement as a result, is more actually better? Is it the right answer from the consumer welfare perspective or, or any perspective really?

Scott:

That’s actually a, I think a good segue. One of the things that stood out to me in the results, which maybe, is not surprising, but that elected attorneys general are much more likely to pursue enforcement actions than non-elected [AGs]. And, you know, that’s the objective finding. How do you interpret that? Do you— does it seem like they’re playing politics, or they are doing more of, more good?

Jen:

Yeah. So, it’s a good question. Some of it is a little bit of a numbers game, I think. So, there are just more elected officials than there are unelected attorneys general.

Scott:

That’s true. But these were averages, right?

Jen:

These were averages, that’s right. But you do have some unelected that are doing more than some elected. But it’s obviously the case—and I think this is probably one of the things that I would’ve been more surprised if I didn’t see this result than the fact that I did—they have a job to do. They’re elected to do a job and they have to do the job and they’re going to be judged by how well they do that job, both in terms of reelection to that position, or in terms of using that position as a steppingstone— as is commonly done, particularly in the state of New York, you know, it’s, it’s sort of the feeding ground to, to the governor’s house. And so, I guess, you know, from my perspective, I think it’s not inconsistent with what you expect an elected official to do. I think what’s more interesting is, sort of when you look at the political breakdown, when you look at sort of the political affiliations of the attorneys general, and then you look at the political affiliation of the executive, and you look and you see how do they behave when they have the same political affiliation or different political affiliation.

And I think what you see a little bit is that, you know, people seem a lot more active during— or state AGs seem a lot more active during Republican administrations, regardless of the state AG’s own political affiliation. And so, what does that potentially tell you about the message state AGs are sending about Republican administrations and their views on antitrust enforcement? There may be nothing there. I’m not saying that there’s a “there” there, so I don’t want people want people to walk away and be like, “she said this,” but I think it’s interesting that, that wasn’t exactly— I expected party lines. I expected there to be sort of more alignment between those two things [and] there wasn’t.

Scott:

I think you can see this in the data— not sure, but the non-elected ones who seem just generally less active, what are they doing? Are they doing something else other than enforcement actions or are they, you know, sitting with their feet up on their desks [Fauver: Laughs] with notes?

Jen:

I mean, that’s, that’s a good question. The answer is, I don’t know.[Wallsten: Mhm.] It’s not something I can see in the data I have. The other constraint—and one that, that I don’t track in the data, that is actually very difficult to track systematically—is just resources. And so, there may be a connection between the availability of resources to do antitrust enforcement in the elected versus the unelected world of states attorneys general. And so, you know, are they sitting there with their feet up on the desk? No, not necessarily, but it does mean they may have a resource constraint that prohibits them from engaging as much as some of their elected colleagues.

Scott:

Right. No, that’s a, that’s a really interesting point because the elected versus non-elected might proxy for lots of other things, like you said. Like resources are a whole different institutional framework.

Sarah:

So, your paper is pretty unique in that a lot of people talk about state AG antitrust enforcement compared to federal—or there’s been talk lately that the federal antitrust enforcers aren’t active enough—but there’s also concurrently 50 state AGs that are pursuing antitrust cases. What other topics or research agendas can come out of your paper? It seems like— why aren’t there more researchers looking at state AGs?

Jen:

Yeah. So, I think this sort of— there’s, there’s a threshold issue just with the, with the whole research agenda. And that’s just the federalism, I think, component. And I think it’s one that a lot of people fall back on in these discussions, which is, well, they can do what it is they’re doing. They can have, you know, state laws and they can enforce the federal laws that’s in the statute. They’re doing what they can do. And any other discussion other than that gets us into this area of preemption. And everyone’s afraid to go there. Everyone doesn’t want to go there. Right. Because especially in the current climate, because it’s all about more and more, more, more antitrust. And the way we get more antitrust, one way at least, is we have 50 state AGs plus the District of Columbia and all the territories and the federal government enforcing antitrust.

So, I think one thing we have to do is, I think we have to have a discussion about whether the enforcement at the federal level is meaningful [laughs] with respect to antitrust enforcement, as in terms of national antitrust enforcement. Should state AGs be enforcing federal antitrust laws? If the answer to that is no—which I think these data sort of don’t answer that, but they help lead the next person down the road to sort of pick from this and say, here’s why we should not have them enforcing federal antitrust laws—I think the next question is, “what is the implication for state antitrust laws?” And I think because the logical conclusion is, “well, you know, Jennifer, okay, fine. You take away their ability to enforce federal antitrust laws. And all they do is they have state antitrust laws, and they go to the legislature like, you know, New York is considering very, very aggressive changes to the Donnelly Act.” And so, they just go to their state legislatures, they try to get the law that they need. And then they begin to enforce the law at the state level. So, the outcome is the same, except now you’re in state court for the same case. And now you’re in, you know, federal court for the, for the other case, but it’s the same result.

Tom:

This might seem a naive question, but I mean, if they’re enforcing state antitrust laws versus enforcing the federal, whatever remedy is, is the remedy. If it’s just the state antitrust laws is the remedy nationwide?

Jen:

That’s the other question. So, the question is a), can they even really use state antitrust laws in the same way? That’s a factual question in terms of what statutes they have today, but it’s also another question in terms of what remedy could they get that would not potentially have implications for interstate commerce. And I know the Dormant Commerce Clause is not a particularly jazzy topic, but it is one. I don’t know if you all attended the antitrust spring meetings, but it is one that was sort of being thrown out there by some of the state AGs’ representatives that were on panels in terms of talking about gearing up to say, “Hey, California’s coming at you and we’re coming at you with our own state antitrust laws. And if federal doesn’t want to do it, we’re going to do it. And Dormant Commerce Clause beware.” And so, states are looking for ways to more aggressively use their own laws.

Now California is a horrible example because they’re, you know, obviously their antitrust laws are very progressive, very expansive. They can do a lot with them. But you know, where does that leave another state like Idaho? It’s a good question, Tom. Like, I don’t know that where remedy, they’re going to be able to get a remedy that that’s outside of their, of their state. And so if that does break the question thenm if we do cut off federal antitrust laws from enforcement by state AGs, does that mean they have no other way to enforce the antitrust laws in any material way? I, I don’t know. And I think that’s sort of an area where someone can really dig in and start to look at what the lay of the land is now. What’s possible and not possible now.

Sarah:

And even among the states– like the state antitrust laws, they, they are like state Sherman Act and– they’re just mini-Sherman Acts, mini-Clayton Acts. Are there state antitrust laws that are significantly different than the federal laws?

Jen:

So, I think they’re typically mini-FTC Acts. So, they’re typically pretty broad in how they’re worded. And there, but there isn’t a lot of case law, right? And that’s part of the issue. There’s not a lot of case law in the states, particularly in, in what we’re talking about, you know, merger enforcement and, you know, single-firm conduct, monopolization, attempted monopolization. There’s not necessarily really a lot of law that exists at the state level. They don’t have to develop it. They’re using federal antitrust law. Right?

And so, part of the, the hurdle I think would be not only, do they have the law that would allow them to do the enforcement they think they need to do– if the answer to that is yes, what do they face in the courts? I’m not sure they know. Maybe California is an example– is a poor example, I should say, because they have so, so much enforcement. But I think there are a lot of states that aren’t sure what they’d get, you know, when they showed up in state courts and how a state would interpret their antitrust statute, with respect to mergers, per se.

Tom:

Is there a realistic possibility that the current, you know, current rules about preemption would be changed? That, that all of a sudden, they would preempt the states?

Jen:

Yeah. So, I think there’s, you know, this is a debate about what the data show, what additional research might suggest is the optimal answer, and what is the practical answer. And I think, Tom, you’re sort of, you know, pointing out that— is it really practical to think that this particularly this Congress is going to preempt the states? The answer is no. I, I don’t think that it that’s, that’s actually a practical reality. Might additional research suggest that that’s not a horrible idea? Yes. It very well might. Does it going to have a lot of leverage right now? No. But I think we have to just then acknowledge that.

And I think that’s part of what I’m trying to do here is to say, look, if the data and the research tell you that it should be preemptive and the decision is being made not to preempt, then we have to accept that that is a conscious decision in the face of the data not to preempt. And so, I think that, that sort of where I’m coming from is let’s have these discussions, let’s research, let’s look at the data, let’s do some empirical work, and then let’s see what it tells us and then make a decision and just accept the fact that we might just say, we’re willing to suck it up and deal with the data and deal with, you know, the externalities that this might cause, because we’re just not going to […][YL2] .

Tom:

I mean, there also might be some lessons for—at least as far as, as the FTC is or privacy is concerned—kind of the other side of the FTC house, where in the context of discussions about privacy legislation, people make a distinction between preempting the states, but also allowing state AGs to enforce any privacy law that might be passed at the, at the federal level as kind of a, maybe a middle ground solution.

Jen:

Right. And, and I think that to the extent, you know, without having data on sort of the corresponding state antitrust enforcement, it’s hard for me to say, well, if we took away the state law and we just kind of left with whatever federal law was left, what kind of result would we have? I think, sort of, to Sarah’s initial question, that’s another great area for inquiry, which is how are they using their state antitrust laws now? And then what does that look like relative to how they’re using federal antitrust laws? Are they using them the same, or are they using them for different purposes? And I think that would be really informative of this idea you’re saying, that sort of, well, if we remove one, maybe we’re not really removing much, but we’re forcing sort of it to be more of a national antitrust policy, but I still think there are issues there, right?

You know, I talked a little bit before about the consent agreements that state AGs are signing for the same, you know, cases where federal agencies had a consent and where they’ve got additional terms that don’t necessarily fix the competitive harm. And so that’s still going to be there. And so, the question is, what do we do? What do we want to do? Do we want to do anything with that reality? Or is it just, we have to accept it because, you know, we don’t live in a first-best world. We live in sort of a second-best solution world, so, we’re just going to deal with it.

Sarah:

So, we’ve been talking, I guess, in light of tech cases, but the state AGs do a lot of other cases like healthcare, reverse payments… What is the majority of their time going towards?

Jen: 

So, a majority of their time is divided in two areas. One is going to be primarily mergers, which as you know, it’s across the board. So you’re not going to see healthcare, definitely very popular— hospital mergers. You see a lot of those being challenged, not just at the federal level, but even states will even try to challenge under their own antitrust laws. It’s, you know, sort of that important an issue. On, you know, the multi-firm conduct side—again, because we’re talking about price fixing—it sort of, you know, runs the spectrum. Obviously a ton of cases, particularly California, Florida, kind of leading the charge on the automotive parts price-fixing conspiracy [] that happened back in 2012.So, you’ll see a lot of cases there.

But you see a lot of cases on reverse payments. And I think when you see the cases on reverse payments, what’s interesting is, it’s almost unanimous in terms of how many state AGs are joining those cases. You see a lot of participation by state AGs in reverse payment cases. Again, there’s a, a nexus to the healthcare angle, right? This is really important, affecting consumers in their states— prescription drugs, very important. And also, you know, obviously for the elected attorney general, [it] looks pretty good if these are sort of the cases that you’re going after. The interesting thing that jumps out a little bit on the reverse payments is you don’t always see New Jersey, right. And where’s, where’s home to pharma? New Jersey.

And so, that was interesting to me to go back to sort of Scott’s question, I think, a little earlier, you know, what stood out. The other thing that stood out, I think is when do states not bring cases? When do they sit back? And what you see is, you know, I think the number is something like 60— 68% of the time when you’ve got a defendant located in the state attorney general state, they are not part of that enforcement action. That’s pretty interesting, right? I mean, from my perspective, you know, if there’s a harm, why are you not joining? At least participating? You may not want to lead the enforcement action, but why are you not participating?

Sarah:

So that brings back the political angle and, and even maybe the role of having federalism. Fifty state laboratories. Does that imply anything about our federal enforcers that are they influenced or by, you know, pressures or I guess, administrations, or is there anything to see about enforcement discretion?

Jen:

Yeah. So, I mean, I guess it’s a little hard, you know, theoretically is there administration influence? I mean, I think theoretically, you’d have to say, yeah, probably. Can you get at it from a data perspective? I think that’s a little harder, because I think, you know, you’d have to like, you know, basically look behind the black curtain and see, you know, what discussions were being had and how enforcement decisions were being made and whether they had political influence to them.

I think people would tell you, everybody has some amount of political influence. And of course, the staff at the agencies are restricted by, you know, the FTC. They’re restricted by the commissioners, and they’re restricted by the assistant attorney general of antitrust at the DOJ. [YL3] And so, you know, those people have agendas and so it, you know, it can go both ways, right? Political influence to bring cases, political influence not to bring cases. It’s a little hard, it’s a little hard to tell just from a data perspective, I’m not quite sure how you would even get there from a data perspective.

Tom:

Probably the, well, let me ask the question is, is your observation that states tend not to be party to suits if the company is in their state? Does that also hold for things like hospitals, hospital mergers?

Jen:

So that is a really good question, Tom. The answer to that is, it does not hold for hospital mergers. So that’s definitely one of the areas where you see aggressive state enforcement, either alone, or in conjunction with the federal agencies. So, I think they’re less likely to, at that point care very much that you are a resident of their state, but in, in the pharma context, just sort of reverse payment wise, it’s not a hospital, [it’s] a little bit different. You might view it through a different lens.

Tom:

Right, yeah. It makes sense to me.

Sarah:

Great. So, I guess just a little bit more about you, to wrap up– you’re heading to private practice. Could you tell us a little bit about what your thoughts are on the current antitrust debates and, and how your research has influenced you and what you’ll be doing next?

Scott:

Well, actually, even before that, if you could go back a little further and we talked about this a little bit, before we were recording– tell us why you made this career change. Well sort of a career change. You sort of went to the other side of the same career. What made you leave our, our noble economist ranks?

Jen:

That’s a very good question, Scott. So, I spent a quite a bit of time, 21 years, doing antitrust economics at all different sort of cases, merger enforcement in front of the agencies. Some criminal work, antitrust litigation, work, civil, you know, both in the sort of the class certification arena and elsewhere. And it was great. It was a lot of fun. It was interesting. I think over time, you know, I became a lot more interested in what the lawyers were doing. I think, as I said, we economists in antitrust, we have our areas that we play in and that’s our wheelhouse and that’s where we stay. But when you bring in antitrust enforcement action of any kind, whether it’s, you know, litigation–civil litigation or criminal litigation, or, or even a merger enforcement action–there’s a lot more going on than just the economics. And so, I was sort of drawn to having an opportunity to use my economics, continue to use my economics, but to be able to do more of the strategic thinking and, and sort of the, the legal work. And since I’m not getting any younger, I thought, well, now is a good time as any to go to law school.

Sarah:

Great. I do think that you’re starting at Wilson Sonsini this fall, is that correct?

Jen:

I am. In the DC antitrust practice. Being in antitrust now is, it’s [a] pretty exciting time. I think there’s a lot of debate, a lot of debate about whether, you know, the Sherman Act needs to be re-envisioned, perhaps is what I say. People say there’s, you know, a crisis in the courts and, and there’s, you know, the agencies can’t win. The burdens are too low. And, you know, I think that a lot we can talk about, I, I think fundamentally, I think the Sherman Act is in good standing. I think that it has for years shown its flexibility and the courts have shown their flexibility and ability to learn. I think there’s economic thinking that can be brought to bear on the question, but I don’t think that means we have to throw the baby out with the, the bath water.

And I think some of this research and state AGs I think are, are sort of meant to continue to foster that discussion, but sort of in the context of the, the existing Sherman Act paradigm, because if we abandon the Sherman Act and we say, yeah, jobs are a part of antitrust enforcement now, so when you have a merger, you have to show that you’re not going to reduce jobs. We’re in a different world at that, at that point, right? And so, people are looking at what I say might be protectionist enforcement by the state AGs, and they’re saying, nope, that’s just, that’s just antitrust enforcement these days. I think overall we do disservice, I think when we start to, I guess, plant seeds that go beyond the contours of the Sherman Act and the consumer welfare standard.

Sarah:

Great. Well, thanks for your time, Jen. And yeah. Well, we look forward to reading more of your writing and if you have more research papers that come off of this one, please share it. And yeah, I thought your paper was really important and interesting and fills a need to, to really know what’s happening at the state AG level in antitrust enforcement. So, thanks Jen.

Jen:

Thank you all. Appreciate it.

Tom:

Thanks.

Scott:

Thanks for joining us.

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