In response to the growing global integration of economies and commerce, and the necessary desire for predictability and certainty in international laws governing rules of business conduct, legislatures, parliaments and courts have developed procedural devices to provide access to justice in matters involving collective wrongs, including anticompetitive conduct affecting a multitude of direct and indirect customers. The experiences in the United States (“the US”), Canada, and the United Kingdom (“the UK”) illustrate these efforts. Although the underlying policies behind the reforms in these three jurisdictions are very similar, the procedures and practical outcomes in collective competition cases have differed.
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