Geradin, Damien --- "Competition Law" [2006] ELECD 166; in Smits, M. Jan (ed), "Elgar Encyclopedia of Comparative Law" (Edward Elgar Publishing, 2006)

Book Title: Elgar Encyclopedia of Comparative Law

Editor(s): Smits, M. Jan

Publisher: Edward Elgar Publishing

ISBN (hard cover): 9781845420130

Section: Chapter 15

Section Title: Competition Law

Author(s): Geradin, Damien

Number of pages: 8

Extract:

15 Competition law
Damien Geradin


There is a wide body of literature in the field of comparative competition
law. The vast majority of this literature, however, seeks to offer compara-
tive insights into US antitrust law and EC competition law.1 Some books
have, nevertheless, attempted to compare the competition law regimes of
several industrialized countries (see, e.g., Doern and Wilks, 1996, compar-
ing the six `model' policy regimes of the USA, Germany, Japan, the United
Kingdom, Canada and the European Union). Other books have attempted
to compare an even wider set of competition law regimes, including regimes
from emerging economies (see Geradin, 2004a; Chao, 2001; De Leon, 2001;
Rosenthal and Green, 1996).
Europeans have been looking to the US antitrust law system since the
end of World War II. At the time of the elaboration of the EC Treaty, the
Sherman Act represented the legislation of reference in the area of compe-
tition law and it certainly had an influence on the drafting of the competi-
tion law provisions included in the EC Treaty. (US lawyers also played a
significant role in the drafting of the competition law provisions inserted in
the European Coal and Steel Community Treaty, which preceded the EC
Treaty. See Gerber, 1998, p. 338.) But even after the signature of the EC
Treaty, European competition law scholars and practitioners continued to
look to US antitrust law as a source of inspiration (see, e.g., the two pion-
eering books by Joliet, 1967, 1970).
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