WHITE PAPER see PDF document basically the solution to our case here is a summary

The White Paper explains that a US Airways-American combination would occur against an industry
backdrop marked by a dwindling fringe of low-cost carriers and increasing questions about whether
Southwest any longer exerts significant competitive discipline. The report notes that a DOJ investigation
into the proposed merger would be informed by lessons from the effects of previous legacy mega-mergers
(e.g., Delta-Northwest and United Continental) on fares, service, and choice.
The White Paper flags a number of key issues for investigation, including the potential effect of the merger
on enhancing the buying power of US Airways-American and the oneworld alliance to which it would likely
belong. BTCs Mitchell noted, DOJ might also focus on the potential adverse effect of the proposed
merger on the carriers incentives to disclose ancillary service fee information. The report recommends
that any claimed cost savings from the merger be carefully scrutinized. The pandemic of integration
problems in other mergers is a warning sign for this transaction, concluded AAIs Diana Moss.
PDF: Why American Airlines and U.S. Airways Tied the Knot
Arguments against merger
reduced competition
less choice
higher prices
Previous large airline mergers in the United States were approved on the grounds that there was
overcapacity in the industry, resulting in constant price wars and an inability for higher cost, long
established legacy carriers to make money.
US Airways recently posted record profits and American Airlines, although still in bankruptcy, is
successfully restructuring. These facts, he suggests, indicate that both airlines are capable of surviving
and even thriving as separate companies
Kevin Mitchell, chairman of the advocacy organization the Business Travel Coalition, argues that the
proposed merger could substantially lessen competition in the airline industry. He notes that there are
clear warning signs from previous legacy carrier mergers regarding post-merger fares and service to
smaller communities.
The nonprofit group, American Antitrust Institute, has already called on the Justice Department to
investigate the merger. They argue that reduced competition leads to less choice and higher prices for the
public. They published a study together with the Business Travel Coalition that concluded ticket prices
rose 20 percent on some key Delta routes and 30 percent on several United-Continental routes after their
mergers.

US AIRWAYS ANGLES FOR A MERGER WITH AMERICAN _ BUSINESSWEEK

If the union with US Airways were consummated,

the new airline would have about 104,000
employees and 950 planes and operate 6,500
daily flights from nine major hubs, with estimated
sales of $39 billion.
COMPETITORS: DELTA, UNITED and SOUTHWEST
US Airways CEO Doug Parker has long supported airline consolidation as a way to stabilize the
fragmented industry and gain more power over pricing.
After his America West Holdings merged in 2005 with then-bankrupt US Airways (and took its name), he
tried unsuccessfully to strike deals to combine with United Airlines parent UAL in both 2008 and 2010. He
also made a hostile takeover bid for then-bankrupt Delta Air Lines (DAL) in 2006, only to withdraw it the
following year. A combination of US Airways, the fifth-biggest U.S. carrier, and American would fly past

current No. 1 United Continental

Holdings (UAL), based on passenger traffic. The marriage would also shrink the number of major U.S. fullservice carriers to three from seven in 2005.
American had 2011 revenues of $21.3 billion and has about 73,000 employees worldwide. Parkers US
Airways had revenue of $9.99 billion, has about 32,000 workers, and no service to fast-growing Asia. As
measured in miles flown by paying passengers, traffic at Americans main jet operations was more than
twice US Airways last year.
PDF: TRAVELERS UNITED 12 REASONS etc...
Previous merger cases are not comparable to this giant
merger. To begin with, this is the biggest airline merger ever
attempted and each of the prior mergers changed the aviation
landscape.
1. Not as many airlines.
This means more loss of competition
Each of the previous mergers were approved during a period
of time when there were more legacy carriers. Basing a legal
case on approving mergers because earlier mergers were
approved is absurd. At some point the industry arrives at a
point where there are no more companies to be merged.
2. Growth of airline fees
Previous airline mergers were all approved prior to the days of
ancillary fees. These ancillary fees have clearly demonstrated
that there is already too little competition between legacy
carriers. Low-cost-carriers pitch to a different market.
Otherwise, larger network carriers such as American, Delta,
United and USAirways could not charge the baggage fees and
Change fees that they charge if competition was healthy and effective from Southwest Airlines and
JetBlue who have different fee structures.
3. Loss of customer service
Previous mergers were approved during a period where
customer service was still a competitive element across
airlines. The current environment is focused only on extracting
as much money as possible from passengers while providing
the least possible service. Allowing even more market power
to airlines detracts from competition via customer service.
4. Both airlines are making money hand over fist
Last year, US Airways reported their highest profits on record.
AA has reported record-breaking profits for the past two
quarters. Plus, AA has just announced a recall of pilots. Hardly
a signal of weakness. Neither airline is failing or flailing.
5. Its the economy stupid
The previous mergers were approved and hearings were held
during a period when the US economy was suffering. The
specter of having a major airline go bankrupt (Chapter 7) and
the resulting damage to the economy and the increase in
unemployment rates affected how the mergers were seen by
legislators and regulators. DOJs complaint against the AA/US
merger shows signs of remorse about previous mergers.
6. Too big to fail

Consolidating the four US network carriers would create three

too-big-to-fail airlines
with approximately 20+ percent of the airline economy in the
hands each airline. The failure of one of these airlines would
be catastrophic for the economy and the possibility of a strike
at one of the airlines would be untenable for the US economy.
7. More overlapping connecting routes
According to the GAO study on this merger, the AA/US system
of overlapping connecting routes is 30 percent greater than
similar overlapping connecting routes that existed with the
UA/CO merger. These overlapping connecting routes
demonstrate the nationwide loss of competition and the
increased likelihood of the merged carrier reducing service in
rationalizing their route structures.
8. More loss of non-hub service
Every other major merger has resulted in losses of service as
airlines right-size their service. In fact, much of the savings
from mergers comes from elimination of redundant service
between existing hubs and spoke routes. For instance, AA has
4 connecting flights between Seattle and Austin and US Air
has the same number. However, AA flights connect in Dallas
and US flights connect in Phoenix. Right-sizing the route may
mean eliminating one or more of the flights since the new
combined airline may have excess capacity.
9. Probable loss of hub service
Every recent airline merger has resulted in former hubs being
downsized or eliminated. Delta has eliminated Cincinnati and
Memphis as hubs. USAir shut down its big operation in
Pittsburgh. Continental was forced to sign an agreement with
Cleveland guaranteeing certain levels of service. With this
merger, Phoenix will probably see a downsizing as Los Angeles
and Dallas pick up the originating traffic and connecting traffic
once served by Phoenix. The story is yet to be written in terms
of Charlotte and Miami. Both can serve as hubs, but both are not necessary. Will Philadelphia continue to
be the main European gateway as it is for US Airways; or, will those flights shift to JFK? These final hub
configuration are fraught with questions.
10. History of price increases
DOJ which approved previous mergers based on airline executive promises and airlineprovided studies
noticed that such
statements and studies did not bear out after mergers were
complete. Hubs were closed or downsized. Service was cut back.
Staff was laid off. Prices on routes with less competition were
increased. And, deceptive fees became a staple of airline cash
flow.
Since the Delta merger fares have increased 33 percent
according to the Wall Street Journal. United flights between
former United and Continental hubs have seen an increase of
35 percent according to United itself. Some airfares on those
routes increased by 66 percent. [Chart from WSJ.]
11. Airline collusion

As fees grew in importance legacy airlines introduced new fees

in unison. This did not allow consumers vote with their
wallets. Airfares were raised uniformly via signaling. The process whenthere were more airlines was
deemed acceptable; there wereenough competing airlines to maintain pricing discipline. With only three
network carriers, such practices would become oligopolistic price matching. Each reduction in the number
of carriers increases carriers incentives to proceed with increases, and reduces carriers incentives to
offer lower prices and lower fees.
Plus, competition does not only come in the form of airfares,
but also in the form of ancillary fees where most airlines did
not even claim competition and moved fees in concert. And,
capacity discipline became another anticonsumer action
where the legacy carriers would refrain from raising capacity
since it would harm joint industry pricing power. The DOJ
complaint specifically called out this anticompetitive
environment with its citing of emails between airline
executives.
12. Loss of the legacy carriers low cost leader
Unlike other mergers, this merger involves the one airline that
lead on the low-cost front US Airways. The DOJ complaint
pointed directly to low fares that would disappear. Consumers
would lose the only airline that consistently bucked the other
legacy carrier fare structures with special pricing on
connecting routes.

PDF: Testemony concerning Antitrust Analysis..

Merger GUIDELINES US
The Division and the FTC have jointly developed Merger Guidelines that describe the inquiry they will
follow in analyzing mergers. "The unifying theme of the Guidelines is that mergers should not be permitted
to create or enhance market
power or to facilitate its exercise." Merger Guidelines 0.1. As suggested by the language of Section 7 itself,
we usually start by seeking to define the relevant product or service ("line of commerce") and geographic
("section of the country") markets in which the parties to a merger compete and then determine whether
the merger would be likely to lessen competition in those markets.
The purpose of this inquiry is to ascertain whether, with respect to a product or service offered by the
merging parties, there are alternative products and services to which customers could reasonably turn if it
were assumed that the merging parties were the only suppliers of the product or service and sought to
increase prices.
Once relevant markets are defined, we look at various factors in order to determine whether the
transaction is likely to have an anticompetitive effect. In performing this analysis, the Division considers
both the post-merger market concentration and the increase in concentration resulting from the merger.
As a yardstick for concentration, we utilize the Herfindahl-Hirschman Index ("HHI"), which is calculated by
summing the squares of the individual market shares of all the participants. The Division will presume that
mergers in highly concentrated
industries that produce more than a small increase in concentration are likely to create or enhance market
power or facilitate its exercise, unless other factors, such as the prospect of entry by other firms, make
that unlikely.
We apply this basic approach to analysis of air carrier transactions. In this industry, the definition of
product/service market and geographic market converge: relevant airline markets are likely to consist of

scheduled airline service between a point of origin and a point of destination, generally referred to as city
pairs. This market makes intuitive, as well as economic, sense. A passenger desiring to fly from
Washington to San Francisco for a business meeting or a vacation is unlikely to regard a flight from
Washington to Minneapolis as a reasonable alternative in the event the fare from Washington to San
Francisco is increased. Thus, we should be concerned about a transaction that significantly raises
concentration levels in city pair markets.
The relevant market may, however, be narrower than all scheduled airline service in a city pair. Carriers
can serve a city pair market on a connecting basis or a nonstop basis. If the only available service offered
by carriers in a city pair is connecting service, there may be various routes that passengers regard as
reasonable alternatives and from which they will choose based on fare, elapsed travel time, and other
factors. However, there are many city pairs that are served by some carriers
on a nonstop basis and others on a connecting basis, which poses the following question: is a passenger
having the ability to take a nonstop flight likely to regard connecting service as a reasonable alternative,
such that he or she would switch from nonstop service offered by one carrier to connecting service offered
by another carrier if the first carrier raised its fare? Chances are that passengers traveling for leisure -- on
vacation perhaps -- are more likely to consider switching; their demand is said to be more elastic.
However, passengers making business trips are significantly less likely to regard connecting service as a
reasonable alternative - - they are often in a hurry and may place a higher value on getting to their
destination in a hurry -- so that a carrier offering the only nonstop service has power to raise fares without
losing these passengers to another carrier's connecting service.
Thus, there may be circumstances in which a transaction will be competitively problematic because of its
impact on nonstop service in city pair markets, even if other carriers provide service in those markets on a
connecting basis.
Therefore, in considering the antitrust implications of a particular transaction, the Division looks at the
effect in all city pair markets served by both of the carriers involved in terms of (1) nonstop service and (2)
nonstop and connecting service. We have found, not surprisingly given the operation by carriers of hubs in
the postderegulation world, that the transactions most likely to be problematic are those that involve
carriers with hubs at the same airport or at airports in the same metropolitan
area. These carriers are likely to serve many of the same city pairs and, especially in spoke markets, they
may be the only two carriers, or two of a very small number of carriers, providing service.
That is not to suggest, however, that transactions involving carriers that do not have overlapping hubs
may not also present problems. Carriers with hubs in nearby cities are often the dominant carriers -usually on a connecting basis -- for a significant
number of city pairs in their region. And even when carriers' hubs are substantial distances apart, it is
often the case that they are the only two carriers providing nonstop service between their respective hubs.
Once overlapping city pairs have been identified, the Division looks at the number of other carriers serving
each of the markets and at the nature of that service, often by resorting to data that carriers report
periodically to the DOT. This allows the Division to calculate market shares and focus further analysis on
those city pairs in which pre-merger concentration levels suggest post-merger structure conducive to the
creation or enhancement of market power.
As the Merger Guidelines indicate, however, the analysis does not end there. Premerger market shares
are a useful tool for predicting future market shares of the incumbents in a market, but they do not take
account of the possibility of entry by additional competitors. The prospect of potential competition can
constrain the ability of incumbents to raise price or reduce output below a competitive level.
Indeed, the possibility of potential competition was the linchpin for many of the DOT's decisions approving
mergers between carriers. Potential competition, it was said, could be relied upon to discipline carriers,
even those with dominant market shares: if a dominant carrier sought to raise fares above competitive
levels or reduce
service below competitive levels, new carriers could easily enter, especially if they already had some
operations at the affected airports. Airplanes were the quintessential mobile asset, it was said, and ground

facilities could be easily leased or subleased. Knowing that noncompetitive behavior would attract entry, it
was claimed that dominant incumbents would price competitively and offer competitive
levels of service. Hence, the DOT reasoned that market shares -- and the
presumptions of market power that accompany them -- were of relatively little use in airline merger
analysis. The airline industry became the poster child for contestable market theory.
READ!!! Finally, the Division will consider and take into account airline-specific business practices and
characteristics that can affect merger analysis, especially those that differ from most other industries.
Airline fare data is available instantaneously not only to consumers, but also to the airlines themselves,
which can act as a disincentive to fare reductions. Airlines frequently propose general or systemwide price
increases, which may be more likely to "stick" as the number of major carriers diminishes. Carriers have
developed loyalty programs that tie passengers and travel
agents to them at their hubs, making entry into those hubs more difficult. And, airlines apply sophisticated
computer modeling techniques and ticketing restrictions to identify passengers to whom they can charge
higher fares, a form of price discrimination. The Division will consider these and other factors, in seeking
to determine whether any proposed transaction threatens substantially to lessen competition.
PDF: Justice Departement files Antitrust lawsuit...
The Department of Justice, six state attorneys general and the District of Columbia filed a civil antitrust
lawsuit today challenging the proposed $11 billion merger between US Airways Group Inc. and American
Airlines parent corporation, AMR Corp. The department said that the merger, which would result in the
creation of the
worlds largest airline, would substantially lessen competition for commercial air travel in local markets
throughout the United States and result in passengers paying higher airfares and receiving less service.
This transaction would result in consumers paying the price in higher airfares, higher fees and fewer
choices.
Last year, business and leisure airline travelers spent more than $70 billion on airfare for travel throughout
the United States. In recent years, major airlines have, in tandem, raised fares, imposed new and higher
fees andreduced service, the department said.
The department sued to block this merger because it would eliminate competition between US
Airways and American and put consumers at risk of higher prices and reduced service, said Bill
Baer, Assistant Attorney General in charge of the Department of Justices Antitrust Division. If
this merger goes forward, even a small increase in the price of airline tickets, checked bags or
flight change fees would result in hundreds of millions of dollars of harm to American consumers.
Both airlines have stated they can succeed on a standalone basis and consumers deserve the
benefit of that continuing competitive dynamic.
American and US Airways compete directly on more than a thousand routes where one or both offer
connecting service, representing tens of billions of dollars in annual revenues. They engage in head-tohead competition with nonstop service on routes worth about $2 billion in annual route-wide revenues.
Eliminating this head-tohead competition would give the merged airline the incentive and ability to raise
airfares, the department said in
its complaint.
According to the departments complaint, the vast majority of domestic airline routes are already highly
concentrated. The merger would create the largest airline in the world and result in four airlines controlling
more than 80 percent of the United States commercial air travel market.
The complaint also describes how, in recent years, the major airlines have succeeded in raising prices,
imposing new fees and reducing service. The complaint quotes several public statements by senior US
Airways executives directly attributing this trend to a reduction in the number of competitors in the U.S.

market:
President Scott Kirby said, Three successful fare increases [we are] able to pass along to customers
because of consolidation.
At an industry conference in 2012, Kirby said, Consolidation has alsoallowed the industry to do things
like ancillary revenues. That is a structural permanent change to the industry and one thats impossible
to overstate the benefit from it.
As US Airways CEO Parker stated in February 2013, combining US Airways and American would be
the last major piece needed to fully rationalize the industry.
A US Airways document said that capacity reductions have enabled fare increases.
The merger of these two important competitors will just make things worse exacerbating current airline
industry trends toward reduced service, increasing fares and increasing passenger fees, added Baer.
As the complaint describes, absent the merger, US Airways and American will continue to provide
important competitive constraints on each other and on other airlines. Today, US Airways competes
vigorously for priceconscious travelers by offering discounts of up to 40 percent for connecting flights on
other airlines nonstop routes under its Advantage Fares program. The other legacy airlines American,
Delta and United routinely
match the nonstop fares where they offer connecting service in order to avoid inciting costly fare wars.
The Advantage Fares strategy has been successful for US Airways because its network is different from
the networks of the larger carriers. If the proposed merger is completed, the combined airlines network
will look more like the existing American, Delta and United networks, and as a result, the Advantage Fares
program will
likely be eliminated, resulting in higher prices and less services for consumers. An internal analysis at
American in October 2012, concluded, The [Advantage Fares] program would have to be eliminated in a
merger with American, as Americans large, nonstop markets would now be susceptible to reactionary
pricing from Delta and
United. And, another American executive said that same month, The industry will force alignment to a
single approachone that aligns with the large legacy carriers as it is revenue maximizing. By ending the
Advantage Fares program, the merger would eliminate lower fares for millions of consumers, the
department said.
The complaint also alleges that the merger is likely to result in higher ancillary fees, such as fees charged
for checked bags and flight changes. In recent years, the airlines have introduced fees for those services,
which were previously included in the price of a ticket.
These fees have become huge profit centers for the airlines. In2012, domestic airlines generated more
than $6 billion in fees from checked bags and flight changes alone. The
legacy carriers often match each other when one introduces or increases a fee, and if others do not match
the 13-909 Antitrust Division initiating carrier tends to withdraw the change. By reducing the number of
airlines, the merger will likely make it easier for the remaining carriers to coordinate fee increases,
resulting in higher fees for consumers.
The department also said that the merger will make coordination easier among the legacy carriers.
Although low-cost carriers such as Southwest and JetBlue offer consumers many benefits, they fly to
fewer locations andare unlikely to be able to constrain the coordinated behavior among those carriers.
The departments complaint describes US Airways executives fear of Americans standalone growth plan
asindustry destabilizing. The complaint states that US Airways worries that Americans growth plan
would causeothers to react with their own enhanced growth plans, and that the resulting effect would
increasecompetitive pressures throughout the industry. The department said the merger will allow US
Airways
management to abandon these aggressive growth plans and continue the industrys current trend toward

higher
prices and less service.

WEBSITE:
http://www.justice.gov/opa/speech/remarks-prepared-delivery-assistant-attorneygeneral-bill-baer-conference-call-regarding
We filed the lawsuit today because we determined that the merger which would create the worlds
largest airline and leave just three legacy carriers remaining in the U.S. would substantially lessen
competition for commercial air travel throughout the United States. Importantly, neither airline needs this
merger to succeed. We simply cannot approve a merger that would result in U.S. consumers paying
higher fares, higher fees and receiving less service.
Americans spent more than $70 billion flying around the country last year. Increases in the price of airline
tickets, checked bags or flight change fees resulting from this merger would result in hundreds of millions
of dollars of harm to American consumers.
If this merger were to go forward, consumers will lose the benefit of head-to-head competition between US
Airways and American on thousands of airline routes across the country in cities big and small. They
will pay more for less service because the remaining three legacy carriers United, Delta and the new
American will have very little incentive to compete on price. Indeed, as our complaint shows, the
management of US Airways, which will run the new airline, sees consolidation as a vehicle to reduce
competition between the airlines and raise fees and fares.
Here is one powerful example. Today, US Airways competes vigorously by offering discounts of up to 40
percent if a consumer takes its one stop instead of another airlines nonstop route. This means that if you
need to catch a flight at the last minute for any reason celebration or emergency you will find it is 40
percent cheaper to take US Airways connecting service than the non-stop fare offered by American, Delta
and United.
The big three airlines American, Delta and United dont like this aggressive price cutting by US
Airways.
For example, for round-trip flights leaving on August 13 and returning on August 14 from Miami to
Cincinnati, you can see the benefits of US Airways discount program. American is the only airline on this
route to offer nonstop service, charging $740. Delta and United dont have offer competition since they
both charge more for their connecting service than American charges for nonstop service. In this instance,
a consumer who bought a US Airways one-stop ticket would save $269 compared to Americans nonstop
service.
You can see the benefits of competition between US Airways and American on hundreds of other
flights. For example, on round-trip flights leaving on August 13 and returning on August 14 from New York
to Houston, US Airways one stop fare is about $870 cheaper than the other legacy carriers nonstop
flights, and even beats JetBlue and AirTran by more than $300.
Although Southwest doesnt participate in the standard online travel sites, a cross-check against the
Southwest website for the same dates demonstrates that US Airways also beats Southwests $887
nonstop fare by more than $300.
If this merger happens, US Airways aggressive discounting called Advantage Fares will
disappear. As a bigger airline with many more hubs, there will be no incentive for the merged company to
offer any of the discounts I just described, resulting in higher prices, less choice and fewer services for the
more than two million travelers who today benefit from the program. How do we know it? We know this
from the internal analyses and the planning documents put together by American in considering the likely
effects of this merger.
The elimination of the Advantage Fares program is just one example. If the merger goes forward,
consumers can also expect to pay higher fees for things like checked bags, flight changes, more legroom
and frequent flyer benefits.
Today, American does not charge if you redeem frequent flyer miles. US Airways charges an average of

$40. If the merger is allowed, US Airways is planning to take this frequent flyer benefit away and make
Americans frequent flyers pay redemption fees. By eliminating this competitive distinction between
American and US Airways, the new airline generates an additional $120 million in revenue. But you pay
the price.
Consumers will also pay more on routes where US Airways and American today offer competing nonstop
service. We know from prior mergers that elimination of head-to-head competition on nonstop routes
results in substantial price increases for consumers.
Expect similar fare increases if this merger is allowed. For example, US Airways and American offer
competing nonstop service between Charlotte, North Carolina and Dallas-Ft. Worth. Consumers will likely
pay more than $3 million more per year for travel on that route alone.
You dont need to go far from this very city to see another worrisome effect from the proposed
merger. Across the Potomac River, the merged airline would dominate Washington Reagan National
Airport, by controlling 69 percent of the take-off and landing slots at DCA.
And, it would have a monopoly on 63 percent of the nonstop routes out of Reagan National.
By allowing one airline to control that many slots, the merger will prevent other airlines, including low-fare
carriers like JetBlue and Southwest from competing at Reagan National.
It would face little or NO competition.
Indeed, this would get worse. Recently JetBlue started service from Reagan National to Boston,
competing with US Airways, and fares dropped by more than 30 percent saving consumers about $50
million a year.
Similarly, consumers saved about $14 million in lower fares between Tampa and Reagan National after
JetBlue started competing against US Airways. But and this is important half of JetBlues slots at
Reagan National are leased from American. If this deal is allowed, new American can terminate that
lease and JetBlues ability to compete will be severely diminished. Consumers will pay the price.
Blocking the merger will preserve current competition and service at Reagan National airport, including
flights that US Airways currently offers to large and small communities around the country.
The complaint also describes other ways in which consumers are at risk if we allow this deal to further
reduce the number of competitors in this industry.
You do not need to take my word for this. High level executives at US Airways have talked about how
consolidation allows for capacity reductions that enable fare increases. One US Airways executive
recently stated that this merger is the last major piece needed to fully rationalize the industry. In the
airline business the word rationalize is a code word for less competition, higher costs for consumers and
fewer choices.
Both US Airways and American have publicly stated that they can do well without this merger. American
has used the bankruptcy process to lower its costs and revitalize its fleet. It has repeatedly said that it can
thrive as a standalone competitor. Just this January, Americans management presented plans that would
increase the destinations and frequency of its flights in the U.S., allowing it to compete independently and
vigorously with plans to grow.
And, executives of US Airways agree about Americans ability to make it on its own. They have noted that
American will be stronger post-bankruptcy and that [t]here is NO question about Americans ability to
survive on a standalone basis.
US Airways also has said that US Airways itself does not need the merger that it can thrive as a
standalone firm.
The lawsuit we filed today to block this deal gives consumers the best possible chance for continued
competition in an important industry that they have come to rely upon.
I want to thank the litigation team from the divisions Transportation, Energy and Agriculture Section, led
by Chief Bill Stallings and Assistant Chief Kathy ONeill, as well as the Economic Analysis Group led by
Bob Majure and Oliver Richard for their hard work on this. And, I want to thank the attorneys general who
have joined this lawsuit and are working with us to protect the consumers of their respective states.