Authors

Alden Abbott

Alden Abbott is a senior research fellow with the Mercatus Center and a former general counsel of the Federal Trade Commission.

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Brian Albrecht

Brian Albrecht is Chief Economist of the International Center for Law & Economics (ICLE).

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Dirk Auer

Dirk Auer is director of competition policy at the International Center for Law & Economics.

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Mikolaj Barczentewicz

Mikolaj Barczentewicz is an associate professor in law at the University of Surrey in Guildford, England and a senior scholar at the International Center for Law & Economics.

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Jonathan M. Barnett

Jonathan M. Barnett is the Torrey H. Webb Professor of Law and director of the Media, Entertainment and Technology Law Program at the University of Southern California Gould School of Law.

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Eric Fruits

Eric Fruits is a senior scholar at the International Center for Law & Economics and an adjunct professor of economics at Portland State University.

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Daniel J. Gilman

Daniel J. Gilman is a senior scholar of competition policy with the International Center for Law & Economics (ICLE).

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Gus Hurwitz

Justin (Gus) Hurwitz is the director of law & economics programs at the International Center for Law & Economics (ICLE) and a senior fellow and academic director of the Center for Technology, Innovation, and Competition at the University of Pennsylvania Carey Law School.

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Thomas A. Lambert

Thomas A. Lambert is the Wall Chair in Corporate Law and Governance and professor of law at the University of Missouri School of Law.

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Geoffrey A. Manne

Geoffrey A. Manne is president and founder of the International Center for Law and Economics (ICLE) and a distinguished fellow at Northwestern University’s Center on Law, Business, and Economics.

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Julian Morris

Julian Morris is a Senior Scholar at the International Center for Law & Economics.

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Lazar Radic

Lazar Radic is a senior scholar for competition policy at the International Center for Law & Economics (ICLE), and an assistant professor of law at IE University.

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Joanna Shepherd

Joanna Shepherd is the Thomas Simmons Professor of Law at Emory Law.

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Ben Sperry

Ben Sperry is senior scholar of innovation policy at the International Center for Law & Economics.

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Kristian Stout

Kristian Stout is director of innovation policy at the International Center for Law & Economics (ICLE).

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Michael E. Sykuta

Michael E. Sykuta is an associate professor at the University of Missouri’s Division of Applied Social Sciences and executive director of the Financial Research Institute.

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Guest Contributors

Asheesh Agarwal

Asheesh Agarwal is president of Agarwal Strategies LLC.

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Pinar Akman

Pinar Akman is Professor of Law at the University of Leeds and a judge at the U.K.’s Competition Appeal Tribunal.

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Andrew Albanese

Andrew Albanese is executive editor and deals columnist for Publishers Weekly.

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Reiko Aoki

Reiko Aoki is a commissioner of the Japan Fair Trade Commission.

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Onyeka Aralu

Onyeka Aralu is a research assistant with the International Center for Law & Economics (ICLE).

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Gustavo Augusto

Gustavo Augusto Freitas de Lima is a commissioner for Brazil’s Conselho Administrativo de Defesa Econômica (CADE).

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Hans Bader

Hans Bader practices law in Washington, D.C.

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Stephen M. Bainbridge

Stephen Bainbridge is the William D. Warren Distinguished Professor of Law at UCLA School of Law.

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Jonathan Baker

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David Balto

David Balto is an attorney with the Law Offices of David Balto.

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Corbin K. Barthold

Corbin K. Barthold is internet policy counsel and director of appellate litigation with TechFreedom.

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Benjamin Barton

Benjamin H. Barton is the Helen and Charles Lockett Distinguished Professor of Law at the University of Tennessee College of Law.

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Roger Bate

Roger Bate is a senior scholar with the International Center for Law & Economics (ICLE). He researches international and domestic health policy, with a special interest in medicines. He has a PhD in applied economics from Cambridge University.

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Michael Baye

Michael Baye is the Bert Elwert Professor of Business at Indiana University’s Kelley School of Business.

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Joshua Benson

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Chris Berg

Chris Berg is a professor of economics at RMIT University in Melbourne, Australia.

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Andrew L. Black

Andrew L. Black is an associate in White & Case\’s global competition and commercial litigation practice groups.

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Jarod M. Bona

Jarod M. Bona is the founder and CEO of Bona Law PC.

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Oscar Borgogno

Oscar Borgogno is a legal research officer with Banca d’Italia and a senior fellow with the GW Competition & Innovation Lab.

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Chelsea Boyd

Chelsea Boyd is a resident research fellow of harm reduction with the R Street Institute.

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Timothy J. Brennan

Timothy J. Brennan is professor emeritus of public policy and economics at the University of Maryland, Baltimore County.

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Christopher J. Buccafusco

Christopher J. Buccafusco is the Edward & Ellen Schwarzman Professor of Law at Duke University School of Law.

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Michael Calabrese

Michael Calabrese is director of the Wireless Future Project, which is part of New America’s Open Technology Institute.

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Dan Caprio

Dan Caprio is CEO and president of DC Strategies and co-founder and chairman of The Providence Group.

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Michael A. Carrier

Michael A. Carrier is Board of Governors Professor of Law at Rutgers Law School.

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Steven J Cernak

Steven J. Cernak is a partner with BonaLaw in Detroit, Michigan, where he serves in the firm’s antitrust and competition practice.

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Giuseppe Colangelo

Giuseppe Colangelo is the Jean Monnet Professor of EU Innovation Policy and an associate professor of law and economics at the University of Basilicata.

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Mary Coleman

Mary Coleman is an Executive Vice President at Compass Lexecon.

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James C. Cooper

James C. Cooper is professor of law and director of the Program on Economics & Privacy at George Mason University’s Antonin Scalia Law School

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Peter Craddock

Peter Craddock is a partner in the Brussels office of Keller & Heckman LLP, where he head the EU Data/Cyber/Tech Law team.

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Robert W. Crandall

Robert W. Crandall is an adjunct senior fellow at the Technology Policy Institute.

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Daniel A. Crane

Daniel A. Crane is the Richard W. Pogue Professor of Law at the University of Michigan.

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Dennis D. Crouch

Dennis Crouch is the Judge C.A. Leedy Professor of Law and director of the Center for Intellectual Property and Entrepreneurship at the University of Missouri School of Law.

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Chris DeMuth Jr.

Chris DeMuth Jr. is a partner with Rangeley Capital LLC.

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Paul Denis

Paul Denis is a retired partner from Dechert’s Washington, D.C. office.

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Stephen Dnes

Stephen Dnes is an Associate Professor in Law at Northeastern University London.

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Michael J. Doane

Michael J. Doane is a founding member and director at Competition Economics LLC.

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Susan Dudley

Susan Dudley is director of the George Washington University Regulatory Studies Center.

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Tirzah Duren

Tirzah Duren is vice president of policy and research at the American Consumer Institute.

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Richard A. Epstein

Richard A. Epstein, the Peter and Kirsten Bedford Senior Fellow at the Hoover Institution, is the Laurence A. Tisch Professor of Law at New York University Law School, and a senior lecturer at the University of Chicago.

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David S. Evans

David S. Evans is the founder and publisher of Competition Policy International.

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Jay Ezrielev

Jay Ezrielev is founder and managing principal of Elevecon LLC.

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Allan Fels

Allan Fels is professorial fellow at the University of Melbourne Law School and was chairman of the Australian Competition and Consumer Commission.

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John Fingleton

John Fingleton is chair of the advisory firm Fingleton and former CEO of the UK Office of Fair Trading.

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Miranda Fleischer

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David D. Friedman

David D. Friedman is professor emeritus at Santa Clara University School of Law.

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Brett Frischmann

Brett Frischmann is the Charles Widger Endowed University Professor in Law, Business and Economics at Villanova University.

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Luke M. Froeb

Luke Froeb is the William C. Oehmig Associate Professor in Entrepreneurship and Free Enterprise at Vanderbilt University’s Owen Graduate School of Management.

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Joshua Gans

Joshua Gans is the Jeffrey S. Skoll Chair of Technical Innovation and Entrepreneurship at the University of Toronto Rotman School of Management.

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Svetlana S. Gans

Svetlana S. Gans is a partner in the Washington, D.C. office of Gibson, Dunn, & Crutcher.

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Nuno Garoupa

Nuno Garoupa is a professor of law and the faculty director of graduate studies at George Mason University’s Antonin Scalia Law School.

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Theodore A. Gebhard

Theodore A. Gebhard is a retired economist and attorney.

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Allen Gibby

Allen Gibby is legal counsel at Asurion and a former ICLE senior fellow.

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Michael Giberson

Michael Giberson is an economist now retired from Texas Tech University.

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Paul Gift

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Douglas Ginsburg

Judge Douglas H. Ginsburg has been a judge on the U.S. Circuit Court of Appeals for the D.C. Circuit since 1986.

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Colin Grabow

Colin Grabow is a research fellow at the Cato Institute’s Herbert A. Stiefel Center for Trade Policy Studies.

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Shane Greenstein

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Thomas J. Grennes

Thomas J. Grennes is a professor emeritus of economics at North Carolina State University.

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Gillian Hadfield

Gillian Hadfield is the Schwartz Reisman Chair in Technology and Society, a professor of law, and professor of strategic management at the University of Toronto.

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Philip Hanspach

Philip Hanspach is a PhD researcher in economics at the European University Institute.

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Natalie J. Hausknecht

Natalie Hausknecht is a partner in the Denver office of Gibson, Dunn, & Crutcher.

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Thomas W, Hazlett

Thomas W. Hazlett is the Hugh H. Macaulay Endowed Professor of Economics at Clemson University.

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Bowman Heiden

Bowman Heiden is executive director at the Tusher Strategic Initiative for Technology Leadership at the University of California at Berkeley and co-director of the Center for Intellectual Property.

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William Henderson

William Henderson is the Stephen F. Burns Professor of Law at Indiana University’s Maurer School of Law.

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Joshua Hendrickson

Josh Hendrickson is Chair of the Department of Economics at the University of Mississippi.

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Claire Hill

Claire Hill is the James L. Krusemark Chair in Law at the University of Minnesota Law School.

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Dae Sik Hong

Dae Sik Hong is a professor of law at Sogang University in Seoul, South Korea.

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Steven G. Horwitz

Steven G. Horwitz (1964-2021) was the Distinguished Professor of Free Enterprise and Director of the Institute for the Study of Political Economy at Ball State University’s Miller College of Business.

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Herbert Hovenkamp

Herbert Hovenkamp is James G. Dinan University Professor at the University of Pennsylvania Carey Law School and the Wharton School of the University of Pennsylvania.

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Keith N. Hylton

Keith N. Hylton is the William Fairfield Warren Distinguished Professor of Boston University and professor of law at Boston University School of Law.

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Jonathon Jacobson

Jonathan Jacobson is a retired partner of Wilson Sonsini Goodrich & Rosati.

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Mark Jamison

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Kay Jebelli

Kayvan Hazemi-Jebelli is principal at Evalusion, a consultancy firm focused on digital-competition policy.

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Renee Knake Jefferson

Renee Knake Jefferson holds the Joanne and Larry Doherty Chair in Legal Ethics at the University of Houston Law Center.

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Daniel Martin Katz

Daniel Martin Katz is professor of law and director of the Law Lab at Illinois Tech’s Chicago-Kent College of Law.

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F. Scott Kieff

F. Scott Kieff is the Stevenson Bernard Professor of Law at the George Washington University Law School.

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Bruce H. Kobayashi

Bruce H. Kobayashi is the Paige V. and Henry N. Butler Chair in Law and Economics at George Mason University’s Antonin Scalia Law School.

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William J. Kolasky

William J. Kolasky is a partner in the Washington, D.C., office of Hughes Hubbard & Reed.

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Filippo Lancieri

Filippo Lancieri is a postdoctoral fellow at the ETH Zurich Center for Law & Economics.

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Robert H. Lande

Robert H. Lande is the Venable Professor of Law Emeritus at the University of Baltimore School of Law.

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Angela Landry

Angela Diveley Landry is counsel with Freshfields Bruckhaus Deringer.

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Aaron Lane

Aaron Lane is a senior lecturer in law at RMIT University in Melbourne, Australia, and a senior fellow with George Washington University’s Competition & Innovation Lab.

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Richard Langlois

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Marina Lao

Marina Lao is the Edward S. Hendrickson Professor of Law at Seton Hall University School of Law.

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Sangyun Lee

Sangyun Lee is a postdoctoral researcher at Kyoto University, where he is a Japan Society for the Promotion of Science (JSPS) International Research Fellow.

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George Leef

George Leef is director of editorial content for the James G. Martin Center for Academic Renewal.

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Mark A. Lemley

Mark A. Lemley is the William H. Neukom Professor at Stanford Law School.

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David K. Levine

David K. Levine is joint chair of the Department of Economics and the Robert Schuman Centre for Advanced Studies at the European University Institute.

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Steven Levitsky

Steven Levitsky is an antitrust attorney in New York.

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Ioannis Lianos

Ioannis Lianos is a professor and chair of global competition law and public policy at University College London’s Faculty of Laws.

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Scott Lincicome

Scott Lincicome is the vice president of general economics at the Cato Institute and Cato’s Herbert A. Stiefel Center for Trade Policy Studies.

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Tad Lipsky

Tad Lipsky is assistant professor at George Mason University’s Antonin Scalia Law School and director of the Competition Advocacy Program at the Global Antitrust Institute.

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Gerard Llobet

Gerard Llobet is associate professor at the Centro de Estudios Monetarios y Financieros.

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John E. Lopatka

John E. Lopatka is the A. Robert Noll Distinguished Professor of Law at Penn State Law.

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Filip Lubinski

Filip Lubinski is a PhD researcher at the European University Institute.

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Nelson Lund

Nelson Lund is Distinguished University Professor at George Mason University’s Antonin Scalia School of Law.

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Daniel Lyons

Daniel Lyons is a professor, the associate dean of academic affairs, and the Dean’s Distinguished Scholar at Boston College Law School.

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William C. MacLeod

Bill MacLeod is a partner with Kelley Drye & Warren LLP in Washington, D.C., where he chairs the firm’s antitrust and competition practice group.

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Andrew Magloughlin

Andrew Magloughlin is an associate with Steptoe LLP in Washington, D.C.

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Akiva Malamet

Akiva Malamet is a contributing editor at The UnPopulist.

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Henry G. Manne

Henry Manne (1928-2015) was dean emeritus of the George Mason University School of Law and one of the founders of the discipline of Law & Economics.

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Satya Marar

Satya Marar is a visiting postgraduate fellow at the Mercatus Center at George Mason University.

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Philip Marsden

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Antonio Robles Martín-Laborda

Antonio Robles is an associate professor of commercial law at the Universidad Carlos III de Madrid.

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Howard P. Marvel

Howard P. Marvel is professor emeritus of economics at The Ohio State University.

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Kevin A. McCabe

Kevin McCabe is a professor of economics, law, and neuroscience at George Mason University.

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A. Douglas Melamed

A. Douglas Melamed is a visiting fellow at the Stanford Law School and scholar in-residence at the University of Southern California Gould School of Law.

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Jessica Melugin

Jessica Melugin is director of the Center for Technology & Innovation at the Competitive Enterprise Institute.

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Andrew Mercado

Andrew Mercado is an economist and professional staff member with the U.S. House Judiciary Committee.

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Robert Miller

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Thomas D. Morgan

Thomas D. Morgan is the Oppenheim Professor Emeritus of Antitrust and Trade Regulation Law at George Washington University Law School.

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Andy Morriss

Andrew P. Morriss is the dean of Texas A&M University’s School of Innovation and professor at the School of Law and the Bush School of Government and Public Service.

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Diana L. Moss

Diana L. Moss is vice president and director of competition policy at the Progressive Policy Institute.

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Timothy J. Muris

Timothy J. Muris is George Mason University Foundation Professor of Law at George Mason’s Antonin Scalia Law School and a former chairman of the Federal Trade Commission

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Thomas Nachbar

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John Newman

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Aaron Nielson

Aaron Nielson is solicitor-general of the State of Texas and a professor of law at Brigham Young University J. Reuben Clark Law School.

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Erin A. O'Hara O'Connor

Erin O’Hara O’Connor is dean and Donald J. Weidner Chair at Florida State University College of Law.

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Maureen K. Ohlhausen

Maureen K. Ohlhausen is a partner with Baker Botts, and section chair of the firm’s Global Antitrust and Competition practice.

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Dario Oliveira Neto

Dario Oliveira Neto is an LL.M. candidate in international business and economic law (IBEL) at Georgetown University and an ICLE academic affiliate.

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Walter Olson

Walter Olson is a senior fellow at the Cato Institute’s Robert A. Levy Center for Constitutional Studies.

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Jorge Padilla

Jorge Padilla is chair of Compass Lexecon EMEA.

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Ajit Pai

Ajit Pai is a partner at Searchlight Capital Partners and a former chairman of the Federal Communications Commission.

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Richard W. Painter

Richard W. Painter is the S. Walter Richey Professor of Corporate Law at the University of Minnesota.

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Sabrina Pekarovic

Sabrina Pekarovic is an intern with the International Center for Law & Economics (ICLE) and a second-year law student at IE University in Segovia, Spain.

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Nicolas Petit

Nicolas Petit is professor of European Union competition law and head of the law department at European University Institute.

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Noah J. Phillips

Noah Phillips is Co-Chair of the Antitrust Practice at Cravath and previously served as a Commissioner of the Federal Trade Commission.

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Jaclyn Phillips

Jaclyn Phillips is a senior associate in White & Case’s global antitrust/competition practice.

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Randal C. Picker

Randy Picker is James Parker Hall Distinguished Service Professor of Law at the University of Chicago Law School.

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Richard J. Pierce Jr.

Richard Pierce Jr. is the Lyle T. Alverson Professor of Law at George Washington University Law School.

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Aurelien Portuese

Aurelien Portuese is a research professor at George Washington University.

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Sharis Pozen

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Ryan Radia

Ryan Radia is research fellow and regulatory counsel with the Competitive Enterprise Institute.

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Subiksha Ramakrishnan

Subiksha Ramakrishnan is a research assistant with the International Center for Law & Economics.

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Eric Bennett Rasmusen

Eric B. Rasmusen is a retired professor of economics and public policy, previously at Indiana University.

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Morgan Reed

Morgan Reed is president and executive director of ACT – The App Association.

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James F. Rill

James F. Rill is a senior counsel with Baker Botts in Washington, D.C., and the former assistant U.S. attorney general in charge of the U.S. Justice Department (DOJ) Antitrust Division.

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Will Rinehart

Will Rinehart is a senior fellow at the American Enterprise Institute.

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Roberta Romano

Roberta Romano is Sterling Professor of Law and co-director of the Yale Law School Center for the Study of Corporate Law.

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Don Rosenberg

Donald J. Rosenberg is former executive vice president, general counsel, and corporate secretary of Qualcomm Inc.

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Ben Rossen

Ben Rossen is special counsel with Baker Botts and previously served as a senior attorney in the Federal Trade Commission’s Division of Privacy and Identity Protection.

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Michael A. Salinger

Michael A. Salinger is the Jacqueline J. and Arthur S. Bahr Professor of Management and professor of economics at the Boston University School of Management.

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Steve Salop

Steven C. Salop is professor emeritus at Georgetown Law.

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Kerem Cem Sanli

Kerem Cem Sanli is an associate professor in civil law and competition law at Istanbul Bilgi University.

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Thibault Schrepel

Thibault Schrepel is an Associate Professor of Law at the Vrije Universiteit Amsterdam.

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Scott Sher

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Mike Shor

Mike Shor is an associate professor of economics at the University of Connecticut.

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J. Gregory Sidak

J. Gregory Sidak is founder and chairman of Criterion Economics Inc. and founding co-editor of Oxford University Press’ Journal of Competition Law & Economics.

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Joseph J. Simons

Joseph J. Simons is a retired partner with the antitrust group of Paul, Weiss, Rifkind, Wharton & Garrison LLP and the former chairman of the Federal Trade Commission.

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Joe Sims

Joe Sims is a retired partner with Jones Day.

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Hal Singer

Hal Singer is managing director of Econ One, a professor in the economics department at the University of Utah, and the executive director the Utah Project.

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Brent Skorup

Brent Skorup is a research fellow at the Cato Institute’s Levy Center for Constitutional Studies.

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Margaret Slade

Margaret Slade is professor emeritus in the Vancouver School of Economics at the University of British Columbia.

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Lawrence J. Spiwak

Lawrence J. Spiwak is the president of the Phoenix Center for Advanced Legal & Economic Public Policy Studies.

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Christopher Jon Sprigman

Christopher Jon Sprigman is the Murray and Kathleen Bring Professor of Law at New York University School of Law.

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Matthew Starr

Matthew Starr is government affairs director for privacy and AI policy with Motorola Solutions.

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Judd E. Stone

Judd E. Stone is a partner at Stone Hilton in Austin, Texas, and was the State of Texas solicitor general from February 2021 to October 2023.

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Shivanghi Sukumar

Shivanghi Sukumar is a partner with Axiom5 Law Chambers LLP.

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Mary Sullivan

Mary Sullivan is a visiting scholar at the George Washington University Regulatory Studies Center.

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Berin Szoka

Berin Szóka is the president and founder of TechFreedom.

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Sayako Takizawa

Sayako Takizawa is a professor at the University of Tokyo’s Graduate Schools for Law and Politics.

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Eric Talley

Eric Talley is the Isidor and Seville Sulzbacher Professor of Law at Columbia Law School.

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Mariana Tavares de Araujo

Mariana Tavares de Araujo is a partner with Levy & Salomão Advogados’ Antitrust and Compliance Practice Group in Rio de Janeiro, Brazil.

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Amir C. Tayrani

Amir C. Tayrani is a partner in Gibson, Dunn & Crutcher’s Washington, D.C. office.

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David Teece

David J. Teece is the Thomas W. Tusher Professor in Global Business and faculty director of the Tusher Center for The Management of Intellectual Capital at the University of California at Berkeley Haas School of Business.

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Richard H. Thaler

Richard H. Thaler is the Charles R. Walgreen Distinguished Service Professor of Behavioral Science and Economics at the University of Chicago Booth School of Business and the 2017 recipient of the Nobel Memorial Prize in Economic Sciences for his contributions to behavioral economics.

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Chang-hsien (Robert) Tsai

Chang-hsien (Robert) Tsai is a professor of law and business at the Institute of Law for Science and Technology within Taiwan’s National Tsing Hua University College of Technology Management.

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Darren Tucker

Darren is a partner in the antitrust group of Vinson & Elkins.

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Ashwin Varma

Ashwin Varma is a medical student at the University of Texas Health Science Center at San Antonio and a former associate consultant at Boston Consulting Group.

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Cento Veljanovski

Cento Veljanovski is founder and managing partner of Case Associates.

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Carrie Wade

Carrie Wade is senior manager of global scientific engagement with Philip Morris International.

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Phil Weiser

Phil Weiser is the attorney general of the State of Colorado and the Hatfield Professor of Law and Telecommunications at the University of Colorado Law School.

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Gregory J. Werden

Gregory J. Werden retired in 2019 after 42 years in the Antitrust Division of the U.S. Justice Department.

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Lawrence J. White

Lawrence White is Robert Kavesh Professor of Economics at New York University Leonard N. Stern School of Business.

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Christine Wilson

Christine S. Wilson is a senior advisor in the antitrust, competition and trade practice of Freshfields Bruckhaus Deringer and a former commissioner of the Federal Trade Commission (FTC).

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Ramsi Woodcock

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Tim Wu

Timothy Wu is the Julius Silver Professor of Law, Science and Technology at Columbia Law School.

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Aaron Wudrick

Aaron Wudrick is a senior fellow and director of the Domestic Policy Program at the Macdonald-Laurier Institute.

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John M. Yun

John M. Yun is an associate professor of law and an economist at George Mason University’s Antonin Scalia Law School.

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Luigi Zingales

Luigi Zingales is the Robert C. McCormack Distinguished Service Professor of Entrepreneurship and Finance at the University of Chicago Booth School of Business.

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Mario Zúñiga

Mario Zúñiga is a senior scholar of competition policy at ICLE.

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Todd J. Zywicki

Todd J. Zywicki is George Mason University Foundation Professor of Law at George Mason’s Antonin Scalia School of Law.

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Bloggers Emeriti

Sam Bowman

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Todd Henderson

M. Todd Henderson is the Michael J. Marks Professor of Law at the University of Chicago Law School.

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Adam Mossoff

Adam Mossoff is professor of law at George Mason University’s Antonin Scalia Law School.

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Elizabeth Nowicki

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Larry Ribstein

Larry E. Ribstein (1946-2011) was the Mildred Van Voorhis Jones Chair, associate dean for research, and co-director of the Illinois Business Law and Policy Program at the University of Illinois.

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Paul H. Rubin

Paul Rubin is Samuel Candler Dobbs Professor of Economics Emeritus at Emory University.

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Keith Sharfman

Keith Sharfman is a professor of law and director of bankruptcy studies at St. John’s University School of Law.

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Bill Sjostrom

William K. Sjostrom is professor of law at the University of Arizona’s James E. Rogers College of Law.

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Alec Stapp

Alec Stapp is the co-founder and co-CEO of the Institute for Progress.

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J.W. Verret

J.W. Verret is associate professor of law at George Mason University’s Antonin Scalia Law School.

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Joshua D. Wright

Joshua D. Wright is founding partner of Lodestar Law & Economics and a former member of the Federal Trade Commission (FTC).

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