Antitrust & Competition Policy Blog

Editor: D. Daniel Sokol
University of Florida
Levin College of Law

A Member of the Law Professor Blogs Network

Saturday, May 19, 2012

Antitrust Federalism in the EU and the US

Posted by D. Daniel Sokol

Firat Cengiz, Tilburg Law School has authored the very interesting book Antitrust Federalism in the EU and the US.

BOOK ABSTRACT: The EU and the US are the preeminent examples of multi-level polities and both have highly developed competition policies. Despite these similarities however, recent developments suggest that they are moving in different directions in the area of antitrust federalism. This book examines multi-level governance in competition policy from a comparative perspective. The book analyses how competition laws and authorities of different levels - the federal and the state levels in the US and the national and the supranational levels in the EU - interact with each other. Inspired by the increasingly divergent policy developments taking place on both sides of the Atlantic, the author asks whether the EU and the US can draw policy lessons from each other’s experiences in antitrust federalism. Antitrust Federalism in the EU and the US reveals the similarities and differences between the European and American models of antitrust federalism whilst employing policy network models in its comparative analysis of issues such as opacity and accountability in networks. The book is essentially multidisciplinary in its effort to initiate dialogue between the Law and Political Science literatures in this field.

May 19, 2012 | Permalink | Comments (0) | TrackBack (0)

Friday, May 18, 2012

Consumer Behavioural Biases in Competition: A Survey

Posted by D. Daniel Sokol

Steffen Huck (University College London) and Jidong Zhou (University College London) wrote a report Consumer Behavioural Biases in Competition: A Survey . Highly recommended.

ABSTRACT: Consumer behavioural biases imply that consumers may not behave in the fully rational way that many economic models presume. What impact do these biases have on competition? Specifically, how does competition and pricing change when consumers are biased? Can inefficiencies that arise from consumer behavioural biases be mitigated by lowering barriers to entry? Do biased consumers make rational ones better or worse off? And will biased consumer behaviour be overcome through learning or education?

This report reviews the empirical and theoretical behavioural economic literature to answer these questions. It looks at the key implications for consumer and competition policy in particular to understand how and when competitive equilibrium may change for the worse. It also contributes to our understanding of when, why, and how we should intervene.

May 18, 2012 | Permalink | Comments (0) | TrackBack (0)

Dynamic Quality Signaling with Moral Hazard

Posted by D. Daniel Sokol

Francesc Dilme (Department of Economics, University of Pennsylvania) explores Dynamic Quality Signaling with Moral Hazard.

ABSTRACT: Asymmetric information is an important source of inefficiency when assets (like firms) are transacted. The two main sources of this asymmetry are unobserved idiosyncratic characteristics of the asset (for example, quality) and unobserved idiosyncratic choices (actions done by the current owners). We introduce moral hazard in a dynamic signaling model where heterogeneous sellers exert effort to affect the distribution of a stochastic signal (for example sales or profits) of their firms. Buyers observe the signal history and make price offers to the sellers. High-quality sellers try to separate themselves from the less quality ones in order to receive high price offers, while the latter try to pool with the first group to avoid receiving a low price. We characterize the competitive equilibria of the model, and we propose an adaptation of existing refinements to the incorporation of moral hazard in dynamic signaling that implies uniqueness of equilibria. We find that similar individual characteristics across types of sellers make everyone worse off, since competition increases signaling waste. Also, due to the new intensive margin (effort), non-trivial signaling will take place even when the cost of signaling is large. In particular cases, we find analytical solutions, that allow transparent comparative statics analysis. The model can be applied to education where grades depend not only on the students’ skills, but also on their effort.

May 18, 2012 | Permalink | Comments (0) | TrackBack (0)

Price Competition with Consumer Confusion

Posted by D. Daniel Sokol

Ioana Chioveanuy (Brunel University) and Jidong Zhou (NYU Stern School) have posted Price Competition with Consumer Confusion.

ABSTRACT: This paper proposes a model in which identical sellers of a homogenous product compete in both prices and price frames (i.e., ways to present price information). Frame choices a¤ect the comparability of price o¤ers, and may lead to consumer confusion. In the symmetric equilibrium price and price frame dispersion coexist and …rms make positive pro…ts. Moreover, the nature of equilibrium depends on whether frame di¤erentiation or frame complexity is more confusing, and an increase in the number of …rms can raise industry pro…ts and harm consumers.

May 18, 2012 | Permalink | Comments (0) | TrackBack (0)

Thursday, May 17, 2012

China Releases Judicial Interpretation for Hearing Civil Anti-Monopoly Actions

Posted by D. Daniel Sokol

John Ren (T&D) notes that China Releases Judicial Interpretation for Hearing Civil Anti-Monopoly Actions.

ABSTRACT: On May 8, 2012, China’s Supreme People’s Court ("SPC") released the Judicial Interpretation ("JI") on Anti-Monopoly Law ("AML") in Beijing. The JI, widely recognized as a milestone of private enforcement of the AML, would further shape the developments of antimonopoly law in China. (Download the English version of the JI.) SPC had made preparations for AML civil trials for a long time. On July 28, 2008, the eve of the effective date of the AML, SPC issued the “Notice on Earnestly Study and Implement the AML” to People’s Courts of all levels; SPC indicated clearly in the Notice that all civil cases should be heard by the Intellectual Property Divisions of the People’s Courts. On September 8, 2008, an anonymous high-level judge of SPC's Intellectual Property Division told the People’s Courts (SPC’s official Newspaper) that the administrative procedure shall not be made as a precondition for an anti-monopoly civil lawsuit. The judge also said that SPC had established the special AML Tribunal in the Intellectual Property Division to hear future AML civil lawsuits. No efforts have been spared to make the outcome of the AML JI possible. In April 2011, SPC released an AML JI draft for public comment, which produced two internal versions in September 2011 and January 2012, respectively. Furthermore, some symposiums and workshops were hosted or sponsored by SPC to discuss the draft, including the “2011 Forum on Anti-Monopoly Civil Litigation in China” held in June 2011 and “Antitrust Civil Litigation Forum: Issues, incentives, and evidence” in April 2012, co-organized by T&D Associates.

May 17, 2012 | Permalink | Comments (0) | TrackBack (0)

The Assessment of Market Power of Airports

Posted by D. Daniel Sokol

Andreas Polk, Berlin School of Economics and Law and Volodymyr Bilotkach, Newcastle Business School address The Assessment of Market Power of Airports.

ABSTRACT: Airport regulation regimes are under revision in many countries. The decision about the extent of airport regulation is usually based on an economic analysis of market power, which is done in two steps. The first step involves defining the relevant markets the airport is operating on. This is based on an economic analysis of the particular circumstances of the airport, and must be compatible with the competition law. The second step consists of the evaluation of the airport's competitive position in all identified markets. Due to industry particularities, many diverse issues must be taken into account in this process, such as questions of upstream and downstream market interaction, airport congestion, peak-load pricing, or offsetting bargaining power. Many of these questions have been theoretically analyzed in the industrial organization literature, but have only rarely been applied in practical competition analysis. This paper builds a bridge between the theoretical insights and their practical application to airport regulation policy. We derive the principles for a sound economic analysis of the market power of airports, given the time and data constraints encountered in practice by the regulatory authorities and other involved parties.

May 17, 2012 | Permalink | Comments (0) | TrackBack (0)

PRIVATE ENFORCEMENT AND JUDICIAL DISCRETION IN THE EVOLUTION OF ANTITRUST IN THE UNITED STATES

Posted by D. Daniel Sokol

Reza Rajabiun (Ryerson University) analyzes PRIVATE ENFORCEMENT AND JUDICIAL DISCRETION IN THE EVOLUTION OF ANTITRUST IN THE UNITED STATES.

ABSTRACT: The role of private enforcers in the implementation of laws against anticompetitive practices remains a subject of considerable controversy. The economic approach to the analysis of crime and punishment suggests that private rights of action can complement the information and incentives of public agents in the identification and deterrence of costly market behavior. This article studies the complementarities between public and private enforcement mechanisms. Long-term data on case filings, administrative resources, and judicial outcomes from the United States reveal that mixed regimes allow for the specialization of tasks between public and private enforcers: competition authorities focus on the regulation of dominance, while private litigants tend to identify collusion in contractual relations. The analysis further documents how judicial discretion under the rule-of-reason approach to substantive interpretation limits the predictability and credibility of legal constraints against anticompetitive practices.

May 17, 2012 | Permalink | Comments (0) | TrackBack (0)

Search Engine Competition with Network Externalities

Posted by D. Daniel Sokol

Cedric Argenton (Tilburg) and Jens Prufer (Tilburg) analyze Search Engine Competition with Network Externalities.

ABSTRACT: The market for Internet search is not only economically and socially important, it is also highly concentrated. Is this a problem? We study the question of whether “competition is only a free click away.” We argue that the market for Internet search is characterized by indirect network externalities and construct a simple model of search engine competition, which produces a market share development that fits well the empirically observed developments since 2003. We find that there is a strong tendency toward market tipping and, subsequently, monopolization, with negative consequences on economic welfare. Therefore, we propose to require search engines to share their data on previous searches. We compare the resulting “competitive oligopoly” market structure with the less-competitive current situation and show that our proposal would spur innovation, search quality, consumer surplus, and total welfare. We also discuss the practical feasibility of our policy proposal and sketch the legal issues involved.

May 17, 2012 | Permalink | Comments (0) | TrackBack (0)

THE FTC, IP, AND SSOs: GOVERNMENT HOLD-UP REPLACING PRIVATE COORDINATION

Posted by D. Daniel Sokol

Richard A. Epstein (University of Chicago/NYU), F. Scott Kieff (GW), and Daniel F. Spulber (Northwestern) discuss THE FTC, IP, AND SSOs: GOVERNMENT HOLD-UP REPLACING PRIVATE COORDINATION.

ABSTRACT: In its recent report entitled, “The Evolving IP Marketplace,” the Federal Trade Commission (FTC) proposes a far-reaching regulatory approach (Proposal) that is likely to interfere with the intellectual property (IP) marketplace, decreasing both the innovation and commercialization of new technologies. The FTC Proposal relies on non-standard and misguided definitions of economic terms of art such as “ex ante” and “hold-up,” and advocates new inefficient rules for calculating damages for patent infringement. The Proposal would so reduce the costs of infringement that the rate of infringement would increase as potential infringers find it in their interest to abandon the voluntary market in favor of judicial pricing. As the number of nonmarket transactions increases, courts will play an ever larger role in deciding the terms on which the patented technologies of one party may be used by another party. That will do more than reduce the incentives for innovation; it will upset the current set of well-functioning private coordination activities in the IP marketplace that are needed to accomplish the commercialization of new technologies. And that would seriously undermine capital formation, job growth, competition, and the consumer welfare the FTC seeks to promote. Like the FTC Proposal, we focus here within the context of standard-setting organizations (SSOs), whose activities are key to bringing standardized technologies to market. If the FTC's proposed definitions of “reasonable royalties” and “incremental damages” become the rules for calculating patent damages the FTC and private actors will be well poised to attack, after the fact, all standard pricing methods through some combination of antitrust litigation or direct regulation on the ground that even time-honored voluntary royalty arrangements result from some purportedly undue power of IP. The FTC's Proposal may encourage potential licensees to adopt the very holdout strategies the FTC purports to address and that well-organized SSOs routinely counteract today. The FTC's proposal for regulating IP by limiting the freedom of SSOs to set their own terms would replace private coordination with government hold-up. We conclude that the FTC should abandon its Proposal and support the current set of licensing tools that have fueled effective innovation and dissemination in the IP marketplace. FTC forbearance will improve bargaining incentives, reduce administrative costs, and remove unnecessary elements of legal uncertainty in the IP system, thereby advancing consumer welfare.

May 17, 2012 | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 16, 2012

C.D. Howe Institute Competition Policy Council Report is now Out

Posted by D. Daniel Sokol

C.D. Howe Institute Competition Policy Council Report is now Out

The Competition Bureau should clarify how it will apply its powers under the Competition Act in seeking administrative monetary penalties for abuse of dominance. This is the consensus of the C.D. Howe Institute’s Competition Policy Council, which held its third meeting on May 7, 2012.

The Competition Policy Council comprises top-ranked academics and practitioners active in the field of competition policy. Chaired by Finn Poschmann, Vice President, Research at the C.D. Howe Institute, the Council provides analysis of emerging competition policy issues. The Council, whose members participate in their personal capacities, convenes a neutral forum to test competing visions of competition policy and share views with practitioners, policymakers and the public.

At Issue: Amendments to the Competition Act in 2009 gave the Competition Bureau the power to seek administrative monetary penalties (AMPs) of up to $15 million from businesses it believes to have contravened the abuse of dominance provisions of the Act, which are non-criminal sections of that legislation. Subsequently, in March this year, the Bureau issued draft Enforcement Guidelines that were silent on the question of AMPs. At the May 7 meeting, the Council addressed the following questions: “Do Administrative Monetary Penalties make good policy? For what infractions? Are they constitutional? What are the costs, benefits, and options?”

There was a range of views among the Council members about whether AMPs for abuse of dominance are ever appropriate. Some members contended that AMPs are appropriate as a deterrence mechanism. Others expressed the view that the possibility of a firm’s being subject to

AMPs would chill efficient arrangements. There was unanimity, however, on the point that the risks of over-deterrence associated with AMPs are real, and that it would be appropriate to know how the Bureau plans to approach the issue of AMPs in particular cases. Accordingly, the Council’s key recommendation is that the Competition Bureau issue guidance and explain the basis on which it will assess the AMPs it seeks.

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

COMPETITION WITHIN FIRMS

Posted by D. Daniel Sokol

Lisa Bruttel and Simeon Schudy, Department of Economics, University of Konstanz address COMPETITION WITHIN FIRMS.

ABSTRACT: We investigate the role of incentives set by a parent firm for competition among its subsidiaries. In a Cournot experiment, four subsidiaries of the same parent operate in the same market. Parents earn a specific share of the joint profit, and can choose how to distribute the remaining surplus (or loss). Results show that parents allocating profits equally among their subsidiaries reach outcomes close to collusion. However, almost half of the parent firms employ a proportional sharing rule instead. These groups end up with profits around the Cournot level.

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

EXIGENCY AND INNOVATION IN COLLUSION

Posted by D. Daniel Sokol

Mark S. LeClair (Professor, Department of Economics, Fairfield University) describes EXIGENCY AND INNOVATION IN COLLUSION.

ABSTRACT: This article examines the evolution of price fixing, and how new means of colluding have been utilized by firms facing financial exigency. The cartel agreement that prevailed in the air freight industry from 1997 to 2005 will be used to illustrate the search for new methods of price fixing. Unlike previous arrangements, the airlines implicated in the scheme did not seek to manage final prices, but rather the fuel, security, and customs surcharges applied to each fare—despite a warning from their own trade association that such a practice was probably illegal. The utilization of common surcharges adds a new dimension to cartel behavior, as this appears to be the first price-fixing agreement that used such a mechanism to manipulate net returns. Unfortunately for the nearly thirty airlines involved, the setting of common surcharges was highly visible to both end users and regulators, leading to complaints filed by both the U.S. Department of Justice and the European Commission. The airlines' willingness to risk punishment fines arose out of financial exigency brought on by escalating fuel prices. Once the cartel began to unravel, initially with a confession by executives from Lufthansa, it became apparent that most of the aviation sector was involved.

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

Online Search Symposium May 21-22

Posted by D. Daniel Sokol

Blog Symposium on Competition in Online Search May 21-22

I am pleased to announce that we will be holding a symposium on the blog the week of May 21st in relation to the Federal Trade Commission’s investigations into Google. The FTC recently announced that it had hired well-known litigator Beth Wikinson of Paul, Weiss, Rifkind, Wharton & Garrison LLP to work on their investigations into Google. A number of commentators have interpreted this as a sign that the FTC is preparing to litigate, but absent from the reporting of this announcement was any elaboration of what the antitrust case against Google actually might be. For our blog symposium, we will hear the views from a number of academics and policy experts who have written about the Google investigations. A number of complaints have been made against Google, including by its competitors Microsoft, Expedia and Yelp who say that Google favors its own content and forecloses the ability of other sites to compete. Google argues that its actions are pro-competitive and are all about providing the best possible experience for the user. Google says it is a guide and not a gatekeeper on the internet. An important question for our symposium is whether antitrust law actually applies to the allegations that have been made against Google.

We have a great group of commentators for the symposium, including:

● Mark Jamison, University of Florida, Warrington College of Business
● Adam Thierer, George Mason
● Eric Clemons, Wharton School of the University of Pennsylvania
● Dan Crane, Michigan Law School
● James Grimmelman, New York Law School
● Marina Lao, Seton Hall
● Maurice Stucke, University of Tennessee College of Law
● Bob Litan, Kauffman Foundation
● Eugene Volokh, UCLA
● Marvin Ammori, Center for Internet and Society at Stanford Law School
● Frank Pasquale, Seton Hall

Topics:

● Can there be a market for unpaid search results and could Google be classified as a public utility? (Mark Jamison; Adam Thierer; Eric Clemons)
● Is there a basis in antitrust law for requiring ‘neutral’ search results's (Dan Crane; James Grimmelman; Marina Lao; Maurice Stucke and Allen Grunes together)
● Does the FTC have grounds to pursue a Section 5 case against Google? (Bob Litan)
● Is search protected by the first amendment? (Eugene Volokh)
● Are there practical remedies that wouldn’t involve federal regulation of search results? (Marvin Ammori; Frank Pasquale)

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

The AT&T/T-Mobile Merger: What Might Have Been?

Posted by D. Daniel Sokol

Maurice E. Stucke (Tennessee Law) and Allen P. Grunes (Brownstein Hyatt) ask The AT&T/T-Mobile Merger: What Might Have Been?

ABSTRACT: The case raises issues important in the USA but also in Europe as providers seek to concentrate worldwide to introduce new technology in a context where access to capital has become more difficult. For instance, how will authorities address the likelihood of negative coordinated effects attached to such transactions? Another issue is how they will deal with efficiency claims presented by merging parties.

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

Judicial Reform and Reasonable Delay

Posted by D. Daniel Sokol

Marc van der Woude (Judge, General Court) addresses Judicial Reform and Reasonable Delay.

ABSTRACT: On 28 March 2011 the Court of Justice proposed, on the basis Article 281 of the Treaty on the Functioning of the EU (TFEU), to amend its statute. This proposal deals with all three jurisdictions that constitute the Court of Justice. The proposal concerning the Court of Justice is intended, in essence, to adapt its governance by amending the rules relating to the composition of the Grand Chamber and to establish the office of Vice-President of the Court of Justice.

The proposal concerning the General Court aims to appoint twelve additional judges. The Court of Justice considers that this increase in capacity is required to deal with the increasing work load of the General Court. This work load had lead to a considerable backlog and has increased the average duration of proceedings. This increase has affected in particular State aid and competition cases in which the average duration is, respectively, 42 months and 56 months in cases leading to a final judgment. As the Court ruled in the Grüne Punkt case (C-385/07 P, 2009, ECR I-6155) lengthy proceedings can be incompatible with the principle of reasonable delay as guaranteed by Article 47 of the Charter of Fundamental Rights, but also Article 6(1) of the European Convention of Human Rights and Fundamental Freedoms. As the Court acknowledges, this latter aspect could place the European Union in a delicate position at a time when its accession to that convention is being negotiated.

May 16, 2012 | Permalink | Comments (0) | TrackBack (0)

Tuesday, May 15, 2012

Antitrust Audit in the Context of Transactions: Motives and Key Practical Aspects

Posted by D. Daniel Sokol

Christina Hummer (SCHINDHELM) and Lukas Leitner have published Antitrust Audit in the Context of Transactions: Motives and Key Practical Aspects.

ABSTRACT: Antitrust audits are increasingly essential as well as due diligence in the context of transactions, as a result of rules regarding parental liability and succession at a European level.

They must be conducted in a vast array of circumstances, for example when a firm or its competitors face a change in ownership or management as well as when antitrust investigations are being planned or carried out in the same or a related economic sector.

In addition to European law, national provisions (e.g. data protection) must be taken into account—particularly when planning the execution of an antitrust audit.

May 15, 2012 | Permalink | Comments (0) | TrackBack (0)

Cross-Border Merger Control: Challenges for Developing and Emerging Economies

Posted by D. Daniel Sokol

The OECD has released its report Cross-Border Merger Control: Challenges for Developing and Emerging Economies.

May 15, 2012 | Permalink | Comments (0) | TrackBack (0)

Class Certification in Innovation Rich Spaces - Do 23(b)(3) Classes Need to Get More Innovative?

Posted by D. Daniel Sokol

David Reichenberg (Wilson Sonsini) asks Class Certification in Innovation Rich Spaces - Do 23(b)(3) Classes Need to Get More Innovative?

ABSTRACT: In recent years, the backdrop for antitrust class actions has increasingly been provided by technological innovation. Take the following hypothetical: Plaintiffs allege a conspiracy between providers of cell phone service resulting in the increase of cell phone plan prices over a six-year span, from 2006 to 2012. In 2006, when the conspiracy was alleged to take effect, there were 20 million consumers who had plans with calling and texting features. By 2012, 120 million people had cell phone service with plans that allowed for streaming, social networking, file sharing, internet, video chatting, etc. All 120 million consumers are now intended to be part of a putative 23(b)(3) class, but many of the new 100 million consumers would not have signed up but for the improvements and cost efficiency gains that had been made from 2006 to 2012.

Several conspiracy cases echo this fact pattern, in industries such as flash memory, portable electronics, graphics processing, and home entertainment. In each case, the alleged class period encompasses a time in which a product has gained widespread-acceptance; this usually comes in tandem with improvements in technology and value for the product at issue. There are also cases in which this trend exists with an allegation of unilateral anticompetitive conduct, as opposed to joint conduct. However, it does not appear that any court has delved deeply into one aspect of class certification under 23(b)(3) in this context. Namely: What must a plaintiff show to establish commonality of impact across the entire class, regardless of when an alleged class member became part of the class? Can the 23(b)(3) predominance requirement be met where individualized proof is necessary to assess whether the alleged conduct had a common impact across the entire class? It is generally accepted that in traditional price pricing cases, in which the product at issue remains static over time, predominance is easily met because all of the class members were subject to some overcharge. However, what about cases in which most or many of the purported members of the class would not be in the class at all but for improvements that had been made in the product at issue? In our hypothetical, are there a sizable number of class members who either signed up only for a data plan for internet use, or would not have gotten a cell phone at all but for improvements in service (3G, 4G, etc.)? Or in the case of flash memory, are there class members who would have bought other forms of portable storage had the price per bit for flash memory not declined as it did?

May 15, 2012 | Permalink | Comments (0) | TrackBack (0)

Joint Venture…Subsidiary…What’s the Difference for Cartel Liability and Fines?

Posted by D. Daniel Sokol

Laura Atlee (Steptoe & Johnson) asks Joint Venture…Subsidiary…What’s the Difference for Cartel Liability and Fines?

ABSTRACT: Parent liability in cartel infringement proceedings has been the focus of quite a number of our commentaries. Starting with the Akzo ruling, the EU Courts have tightened the noose around each and every parent company's financial neck. When a parent company has a 100 percent shareholding in a subsidiary it is presumed (although it can in theory be rebutted) that: (i) the parent company has decisive influence over the subsidiary and (ii) the parent company in fact exercises this decisive influence over the subsidiary's conduct. The Commission has expanded the presumption to include shareholdings that are something less than 100 percent, although it is unclear how elastic the presumption will ultimately be.

Why is this "decisive influence" test so important? It means that the two companies are part of the same "undertaking" and that, in turn, means inter alia that the base amount of the fine for infringing Article 101 of the Treaty on the Functioning of the European Union ("TFEU") includes both the parent's and subsidiary's turnovers and that both can be held jointly and severally liable for any fine the European Commission (the "Commission") imposes.

Having been so successful with wholly-owned subsidiaries, the Commission has recently decided to try its luck with joint ventures. Based on Dow and DuPont, it currently appears that parent companies will also be held liable for their joint ventures' transgressions.

May 15, 2012 | Permalink | Comments (0) | TrackBack (0)

Monday, May 14, 2012

I Need Help to Explain Antitrust to My Daughter's First Grade Class - Slides Would be Appreciated

Posted by D. Daniel Sokol

On Thursday I need to come up with something interesting for "cool job day" in my daughter's first grade class. How do you explain antitrust to a class of seven year olds? I am sure I am not the first to do this so if anyone has any tips, or better yet slides, please send me an email.

May 14, 2012 | Permalink | Comments (7) | TrackBack (0)