On Sept. 3, the Antitrust Division of the Department of Justice (DOJ) released the Merger Remedies Manual (the manual), which provides guidance on how the agency currently intends to approach the structure and implementation of remedies in merger cases. See Antitrust Div., U. S. Department of Justice, “Merger Remedies Manual” (2020). Assistant Attorney General Makan Delrahim, the head of the Antitrust Division, said that the new manual reflects the DOJ’s “renewed focus on enforcing obligations in consent decrees and reaffirms the Division’s commitment to effective structural relief.” Press Release, Office of Pub. Affairs, Department of Justice, “Justice Department Issues Modernized Merger Remedies Manual” Sept. 3, 2020). The manual is the first updating of the policy in nearly a decade—the

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