Antitrust & Competition Policy Blog

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

A Member of the Law Professor Blogs Network

Saturday, September 8, 2012

What Is Regulation?

Posted by D. Daniel Sokol

Barak Orbach (Arizona) asks What Is Regulation?

ABSTRACT: People hold strong views about regulation, but do they know what “regulation” means? National Federation of Independent Business ("NFIB") is a landmark in regulation jurisprudence, yet the NFIB Court was divided over the meaning of the term “to regulate.” During the past century, substantial resources have been invested in the politics and scholarship of regulation. Nonetheless, the term “regulation” has escaped a clear definition. This short essay explores the meaning of the term.

Regulation is a byproduct of our imperfect reality and human limitations. We live in a complex world of finite resources, in which the pursuit of self-interest often fails the individual and causes harm to others. Such imperfections and limitations are the primary motivation for regulation—to promote economic efficiency, environmental sustainability, morality, and the general welfare of the public. The same imperfections and limitations, however, also guarantee the imperfect nature of regulation. Our human flaws allow, for example, the promulgation of excessive and redundant regulations, and enable the adoption of regulations that serve interest groups. Society’s challenge, therefore, is to acknowledge that imperfections and limitations impair decisionmaking, communication, and trade, and to utilize legal institutions to address them. In other words, we should accept the fact that regulation is here to stay, and work to maximize its benefits and minimize its costs.

September 8, 2012 | Permalink | Comments (0) | TrackBack (0)

Friday, September 7, 2012

Upward Pricing Pressure in Two-Sided Markets

Posted by D. Daniel Sokol

Pauline Affeldt (ECA Economics), Lapo Filistrucchi (Tilberg), and Tobias J. Klein (Tilburg) describe Upward Pricing Pressure in Two-Sided Markets.

ABSTRACT: Pricing pressure indices have recently been proposed as alternative screening devices for horizontal mergers involving differentiated products. We extend the concept of Upward Pricing Pressure (UPP) proposed by Farrell and Shapiro (2010) to two-sided markets. Examples of such markets are the newspaper market, where the demand for advertising is related to the number of readers, and the market for online search, where advertising demand depends on the number of users. The formulas we derive are useful for screening mergers among two-sided platforms. Due to the two-sidedness they depend on four sets of diversion ratios that can either be estimated using market-level demand data or elicited in surveys. In an application, we evaluate a hypothetical merger in the Dutch daily newspaper market. Our results indicate that it is important to take the two-sidedness of the market into account when evaluating UPP.

September 7, 2012 | Permalink | Comments (1) | TrackBack (0)

Power market structure and performance

Posted by D. Daniel Sokol

Maria Vagliasindi (World Bank) describes Power market structure and performance.

ABSTRACT: Unbundling power generation, transmission, and distribution is not an end itself, but rather a means to achieve better performance. The key objective of the analytical framework of this paper is to explore the links between alternative market structures and performance (in terms of access, price, quality, and technical and financial performance). The results are crucial for providing policy advice, by offering alternative options to policy makers based on the lessons learned from the taxonomy of different market structures, tailored to different national contexts. The analysis is based on unique data, including a panel of 22 countries for the period beginning in 1989 and extending through 2009. The results of the analysis carried out for this study confirm the following conclusions for policy guidance on power market restructuring for developing countries. First, unbundling delivers results in terms of several performance indicators when used as an entry point to implement broader reforms, particularly introducing a sound regulatory framework, reducing the degree of concentration of the generation and distribution segments of the market by attracting public and private players and private sector participation. Second, there seems to be a credible empirical basis for selecting a threshold power system size and per capita income level below which unbundling of the power supply chain is not expected to be worthwhile. Finally, partial forms of vertical unbundling do not appear to drive improvements, probably because the owner was able to continue exercising control over the affairs of the sector and hinder the development of competitive pressure within the power market.

September 7, 2012 | Permalink | Comments (0) | TrackBack (0)

Thursday, September 6, 2012

Replacing the Libor with a Transparent and Reliable Index of Interbank Borrowing

Posted by D. Daniel Sokol

Rosa M. Abrantes-Metz, Global Economics Group, LLC; New York University - Leonard N. Stern School of Business - Department of Economics and David S. Evans, University of Chicago Law School; University College London; Global Economics Group argue for Replacing the Libor with a Transparent and Reliable Index of Interbank Borrowing.

ABSTRACT: We propose an alternative to the LIBOR based on three pillars. 1) Banks that participate in the rate setting process would have to submit bid and ask quotes for interbank lending and commit that they would conduct transactions within that range. If they traded outside of those ranges they would have to justify and face a penalty. This leads to the CLIBOR—for “committed” LIBOR. (2) All large banks would have to submit interbank transactions including rates to a data-clearing house. The data-clearing house would use the actual transactions to verify the commitment of the banks to the submitted rates. It would also report aggregate transaction data, keeping the actual identities of the trading parties anonymous, with a necessary time delay. (3) A governing body would be established from the CLIBOR participating banks, representatives of CLIBOR users, and other independent parties such as academics. That governing body would enter into a long-term contract, based on competitive solicitation, with a private sector entity to supervise the CLIBOR, operate the data-clearing house, and disseminate information.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Competition Advocacy in Mexico: Lessons From the Past Decade

Posted by D. Daniel Sokol

Angel Lopez Hoher (Mexican Federal Competition Commission) explores Competition Advocacy in Mexico: Lessons From the Past Decade.

ABSTRACT: Competition advocacy is sometimes treated like enforcement's poor cousin; academic debate, practitioners' attention, and agency priorities tend to be geared towards enforcement across the world. And rightly so, to some degree: advocacy is much more variable in its methods and ethereal in its outcomes. Even worse, it sometimes borders suspiciously on mushy public relations, instead of the solid analytical terrain of enforcement.

But nonetheless, advocacy is an essential part of a competition agency's toolkit, especially in jurisdictions where markets still have shallow roots and competition is a newfangled concept struggling to hold its own against state intervention and rent seeking. The Mexican case is a good example, for several reasons: First, in spite of the past two decades' far-reaching economic liberalization, the Mexican economy still suffers under the legacy of the state-led, corporatist economic policy that held sway for at least sixty years before that, and which lingers in vast pockets of anticompetitive regulation and all too frequent distrust of market mechanisms in Government, Congress, the Judiciary, and the general public. Second, these conditions tend to be concentrated in services that have a horizontal impact on the rest of the economy, such as telecommunications, transport, energy, and financial services. Trade liberalization in the 80s and 90s brought market discipline to those sectors of the Mexican economy where competition from abroad was a factor; but in non-tradable sectors-for example the services mentioned above-this impulse to modernize regulation and adapt to market conditions was absent, thus yielding a dual economy that holds back competitiveness and harms consumers in downstream markets (i.e., most of the economy).

Third, advocacy, when it is successful (for example through the removal of artificial barriers to entry or market distortions), allows structural changes to competitive dynamics, shifting incentives permanently and across the board, instead of relying on the case-by case threat of competition enforcement. For an agency that is one of the smallest in the world relative to the size of the economy it regulates, this makes it especially attractive to devote some of its scarce resources to advocacy efforts.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Best Damn Amicus Antitrust Brief Ever

Posted by D. Daniel Sokol

See the attachment, which to conform to the page limits was written as a cartoon for the Ebooks case. Download Apple

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Newspaper and Internet Display Advertising – Co-Existence or Substitution?

Posted by D. Daniel Sokol

Nadine Lindstadt (Department of Environmental and Business Economics, University of Southern Denmark) and Oliver Budzinski (Department of Environmental and Business Economics, University of Southern Denmark) ask Newspaper and Internet Display Advertising – Co-Existence or Substitution?

ABSTRACT: Newspapers have been experiencing declining circulation figures and diminishing advertising revenues for several years – both effects might pose a threat to the continuing existence of (print) newspapers. In an earlier paper, Lindstadt & Budzinski (2011) argued from a theoretical viewpoint that industry-specific patterns exist that determine substitution or complementation effects between internet and newspaper advertising. It was argued that retail advertising, in particular, may offer a niche for regional/local newspapers that can be expected to present a sustainable segment of complementarity along with the otherwise mostly substitutional advertising markets. This paper empirically tests these hypotheses by analyzing advertising spending data for newspaper and internet display advertising of 13 different industries in the U.S. from 2001-2010. We find evidence for some of the hypotheses. Whereas some industries showed clear substitution effects between internet display and newspaper advertising, the majority of our hypotheses could be only partly rejected: newspaper substi-tution effects could be observed, however, in the direction to traditional media platforms instead of internet display advertising. For two retail-sub-industries, the hypotheses could not be rejected for the analyzed period.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

On welfare losses due to imperfect competition

Posted by D. Daniel Sokol

Robert Ritz (Cambridge) has thoughts On welfare losses due to imperfect competition.

ABSTRACT: Corporate managers and executive compensation in many industries place significant emphasis on measures of firm size, such as sales revenue or market share. Such objectives have an important - yet thus far unquantifed - impact on market performance. With n symmetric firms, equilibrium welfare losses are of order 1/n4, and thus vanish extremely quickly. Welfare losses are less than 5% for many empirically relevant market structures, despite significant firm asymmetry and industry concentration. They can be estimated using only basic information on market shares. These results also apply to oligopsonistic competition (e.g., for retail bank deposits) and strategic forward trading (e.g., in restructured electricity markets).

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Competition between Managed Care Organizations and Indemnity Plans in Health Insurance Markets

Posted by D. Daniel Sokol

Edmond Baranes (Montpilier) and David Bardey (Universidad de los Andes) describe Competition between Managed Care Organizations and Indemnity Plans in Health Insurance Markets.

ABSTRACT: This paper examines a model of competition between two types of health insurers: Managed Care Organizations (MCOs) and “Conventional Insurers”. MCOs vertically integrate health care providers and pay them at a competitive price, while conventional insurers work as indemnity plans and pay the health care providers that are freely chosen by their policyholders at a wholesale price. This first difference is called input price effect. Moreover, we assume that policyholders put a positive value on providers. diversity supplied by their health insurance plan and that this value increases with their probability of disease. Due to the restricted choice of health care providers in MCOs, a risk segmentation occurs: policyholders who choose conventional insurers are characterized by a higher risk. Surprisingly, our results point out that the effects of this input price and risk segmentation can be countervailing and do not nece! ssarily work in the same direction. More precisely, we show that vertical integration in health insurance markets can create an anti-raise rivals’ cost effect. Consequently, our results reveal that the penetration of vertical integration may decrease conventional insurers’ premiums, which is a sufficient condition to be Pareto-improving. After more than three decades of vertical integration waves, our model may also explain why we observe an interior equilibrium in which conventional insurers have survived.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Endogenous Market Structures and Welfare

Posted by D. Daniel Sokol

Federico Etro (Department of Economics, University Of Venice Ca Foscari) addresses Endogenous Market Structures and Welfare.

ABSTRACT: I characterize microfounded endogenous market structures with Bertrand and Cournot competition and perform welfare analysis generalizing the Mankiw-Whinston condition for excess entry. The impact of market leaders on welfare is reconsidered, with a number of policy implications about strategic investments, vertical contracts, bundling, mergers and more. The neutrality of consumer surplus holds only when utility is homothetic. Under quantity competition, aggressive (accommodating) leaders increase consumer surplus if the elasticity of utility is decreasing (increasing) in consumption. This provides general rules to evaluate mergers and abuse of dominance issues in antitrust policy.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Sedona 14th Annual Conference on Antitrust Law and Litigation: “Strategic & Tactical Considerations in the Trial of an Antitrust Case”, October 24 – 25 2012

Posted by D. Daniel Sokol

 

Overview

When:
October 25, 2012 - October 26, 2012
Where:
Del Mar, CA

The 14th Annual Sedona Conference® on Antitrust Law & Litigation features a stellar faculty of trial lawyers who have tried antitrust cases in court and before agencies, both to juries and to the bench, and the federal judge who just presided over one of the government’s most important criminal antitrust cases in years. In a series of seven different panels, the faculty will discuss the strategic and tactical considerations in trying different kinds of antitrust cases in different contexts. The conference is designed for senior lawyers and in-house attorneys with experience in complex antitrust litigation and an interest in the adjudicative resolution of antitrust cases.

Important topics to be covered during this year’s invite-only program include:

(1) The Trial of a Merger Case (i) Preliminary Injunctions; (ii) Trial on the Merits; & (iii) Private Merger Litigation;
(2) The Trial of a Criminal Case with a Jury;
(3) The Trial of a Private Antitrust Case with a Jury; Part I – B2B Cases;
(4) The Trial of a Private Antitrust Case with a Jury; Part II – Class Actions;
(5) Bench Trials Other Than Merger Cases;
(6) The Trial of a Part III Administrative Proceeding at the FTC; and
(7) Ex-US Adjudicative Proceedings.

To ensure an intimate environment for meaningful dialogue, registration is limited to 45 persons, and is BY INVITATION ONLY. TO APPLY FOR AN INVITATION, please indicate your experience and reasons for wanting to attend in the box on the right, and click on “add to cart.” Follow the on-screen directions to submit your application. We will notify you as soon as possible if your application has been accepted. You will not be charged unless your application has been accepted. If your application is accepted, you will receive an invitation with instructions on how to complete the registration process, at the email address you use when you applied for an invite. As always, we will be looking for an experienced participant base with diverse viewpoints to contribute to the dialogue leading us to valuable insights and collective wisdom.

We have a Group Rate for lodging at the conference hotel. Hotel reservation information will be provided to invitees upon completion of the registration process. Government employees will receive a $250 discount, please contact our office if you qualify. Financial aid policy is available upon request.

We will be applying for advance MCLE accreditation for 660 minutes of instruction in states requested by those who register.

Agenda

October 25, 2012
Time Session Panelists
7:30 am - 8:30 am Continental Breakfast & Sign-In  
8:30 am - 8:45 am Welcome and Overview
8:45 am - 10:45 am The Trial of a Merger Case – (1) Preliminary Injunctions (2) Trial on the Merits; & (3) Private Merger Litigation
10:45 am - 11:00 am Morning Break  
11:00 am - 12:00 pm The Trial of a Criminal Case with a Jury
12:00 pm - 1:00 pm Lunch (provided)  
1:00 pm - 3:00 pm The Trial of a Private Antitrust Case with a Jury: Part I – B2B Cases
3:00 pm - 3:15 pm Afternoon Break  
3:15 pm - 5:00 pm The Trial of a Private Antitrust Case with a Jury: Part II – Class Actions
5:00 pm - 7:00 pm Reception with the Faculty (guests invited)  
October 26, 2012
Time Session Panelists
7:30 am - 8:30 am Continental Breakfast & Sign-In  
8:30 am - 9:45 am Bench Trials Other Than Merger Cases
9:45 am - 11:15 am The Trial of a Part III Adjudicative Proceeding at the FTC
11:15 am - 11:30 am Morning Break  
11:30 am - 1:00 pm Ex-US Adjudicative Proceedings
1:00 pm - 2:00 pm Grab & Go Lunch (Provided)  
October 25, 2012
Time Session Panelists
7:30 am - 8:30 am Continental Breakfast & Sign-In  
8:30 am - 8:45 am Welcome and Overview
8:45 am - 10:45 am The Trial of a Merger Case – (1) Preliminary Injunctions (2) Trial on the Merits; & (3) Private Merger Litigation
10:45 am - 11:00 am Morning Break  
11:00 am - 12:00 pm The Trial of a Criminal Case with a Jury
12:00 pm - 1:00 pm Lunch (provided)  
1:00 pm - 3:00 pm The Trial of a Private Antitrust Case with a Jury: Part I – B2B Cases
3:00 pm - 3:15 pm Afternoon Break  
3:15 pm - 5:00 pm The Trial of a Private Antitrust Case with a Jury: Part II – Class Actions
5:00 pm - 7:00 pm Reception with the Faculty (guests invited)  
October 26, 2012
Time Session Panelists
7:30 am - 8:30 am Continental Breakfast & Sign-In  
8:30 am - 9:45 am Bench Trials Other Than Merger Cases
9:45 am - 11:15 am The Trial of a Part III Adjudicative Proceeding at the FTC
11:15 am - 11:30 am Morning Break  
11:30 am - 1:00 pm Ex-US Adjudicative Proceedings
1:00 pm - 2:00 pm Grab & Go Lunch (Provided)  
Chair(s): 
Gray Plant Mooty, Minneapolis, MN
Latham & Watkins, LLP, Washington, DC
Panelists: 
Alioto Law Firm, San Francisco, CA
Axinn Veltrop & Harkrider, LLP, Washington, DC
United States Department of Justice, San Francisco, CA
U.S. District Judge, N.D.CA, San Francisco, CA
Boies, Schiller & Flexner LLP, Washington, DC
Sidley Austin LLP, Brussels, Belgium
O’Melveny & Myers LLP, Washington, DC
Simpson Thacher & Bartlett LLP, Washington, DC
Hogan Lovells, Washington, DC
Federal Trade Commission, Washington, DC
McCarthy Tétrault LLP, Vancouver, BC, Canada
Nexsen Pruet, LLC, Columbia, SC

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Does Merger Simulation Work? A "Natural Experiment" in the Swedish Analgesics Market Market

Posted by D. Daniel Sokol

Jonas Bjornerstedt and Frank Verboven ask Does Merger Simulation Work? A "Natural Experiment" in the Swedish Analgesics Market Market.

ABSTRACT: We exploit a natural experiment associated with a large merger in the Swedish market for analgesics (painkillers). We confront the predictions from a merger simulation study, as conducted during the investigation, with the actual merger effects over a two-year comparison window. The merger simulation model is based on a constant expenditures specification for the nested logit model (as an alternative to the typical unit demand specification). The model predicts a large price increase of 34% by the merging firms, because there is strong market segmentation and the merging firms are the only competitors in the largest segment. The actual price increase after the merger is of a similar order of magnitude: +42% in absolute terms and +35% relative to the

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Shearman & Sterling Produces a Comprehensive Sample Antitrust-Related Provisions in M&A Agreements--2012 Expanded Edition

Posted by D. Daniel Sokol

One of the great treasures I picked up from teaching Antitrust Mergers last year was Shearman & Sterling's Antitrust-Related Provisions in M&A Agreements when Dale Collins guest lectured in my class on risk shifting provisions. Shearman has produced a new Sample Antitrust-Related Provisions in M&A Agreements--2012 Expanded Edition.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Towards an Empirical and Theoretical Assessment of Private Antitrust Enforcement

Posted by D. Daniel Sokol

Joshua P. Davis, University of San Francisco - School of Law and Robert H. Lande, University of Baltimore - School of Law move Towards an Empirical and Theoretical Assessment of Private Antitrust Enforcement.

ABSTRACT: The dominant view in the antitrust field is that private enforcement cases, and especially class actions, accomplish little or nothing positive but, on the contrary, are counterproductive. Despite strongly worded convictions, that view has been premised on anecdotal, self-serving and insufficiently substantiated claims. Indeed, the authors' 2008 study of 40 private cases appears to constitute the only systematic effort to gather information about a significant number of private antitrust actions. That study generated a great deal of controversy, including questioning of our conclusions by high officials at the Department of Justice and by Professor Daniel Crane at the University of Michigan Law School.

Given this subject's importance and controversial nature we undertook a supplemental study of 20 additional private antitrust cases. This article analyzes the 20 new cases, compares and contrasts them with that of our earlier group, and draws insights from all 60.

The studies demonstrate that private litigation has provided substantial cash compensation to victims of anticompetitive behavior: at least $33.8 to $35.8 billion. The studies also show that private antitrust enforcement has had an extremely strong deterrent effect. In fact, private enforcement probably deters more anticompetitive behavior than even the appropriately acclaimed anti-cartel program of the U.S. Department of Justice Antitrust Division.

Another purpose of our study was to ascertain important characteristics of private antitrust cases that could help influence the debate over their efficacy. These include whether there were indicia that the cases had underlying merit, the significance of recoveries from foreign violators of U.S. antitrust law, and the sizes of attorney’s fee awards and claims administration expenses.

Finally, this article responds to criticisms of our analysis and our conclusions. In particular, we explain why the Department of Justice officials are incorrect in challenging our claims about the deterrence effects of private antitrust enforcement and why Professor Crane is similarly mistaken regarding its compensation effects. We explain why our earlier study did indeed demonstrate the truly significant benefits of private antitrust actions — conclusions our new empirical work confirms and strengthens.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Endogenous Market Structures and Welfare

Posted by D. Daniel Sokol

Federico Etro (Department of Economics, University Of Venice Ca Foscari) has written on Endogenous Market Structures and Welfare.

ABSTRACT: I characterize microfounded endogenous market structures with Bertrand and Cournot competition and perform welfare analysis generalizing the Mankiw-Whinston condition for excess entry. The impact of market leaders on welfare is reconsidered, with a number of policy implications about strategic investments, vertical contracts, bundling, mergers and more. The neutrality of consumer surplus holds only when utility is homothetic. Under quantity competition, aggressive (accommodating) leaders increase consumer surplus if the elasticity of utility is decreasing (increasing) in consumption. This provides general rules to evaluate mergers and abuse of dominance issues in antitrust policy.

September 6, 2012 | Permalink | Comments (0) | TrackBack (0)

Wednesday, September 5, 2012

What Goes Up, Doesn’t Come Down: The Absence of the Mitigating-Role Adjustment in Antitrust Sentencing

Posted by D. Daniel Sokol

Mark Rosman and Jeff VanHooreweghe (Wilson Sonsini) discuss What Goes Up, Doesn’t Come Down: The Absence of the Mitigating-Role Adjustment in Antitrust Sentencing.

ABSTRACT: The Sentencing Guidelines permit an upward or downward adjustment to a sentencing calculation based on the extent of the defendant’s participation in the criminal act. Mark Rosman and Jeff VanHooreweghe argue that the Antitrust Division’s non-use of the mitigating-role adjustment is bad policy with unfair results for defendants.

September 5, 2012 | Permalink | Comments (0) | TrackBack (0)

UK: Clarification of the Litigation Privilege that can be Claimed by Parties During an Investigation by a Competition Authority

Posted by D. Daniel Sokol

Dan Burton (Freshfields) describes UK: Clarification of the Litigation Privilege that can be Claimed by Parties During an Investigation by a Competition Authority.

ABSTRACT: Litigation privilege allows firms to withhold material where that material was created, predominantly, for the purpose of actual or contemplated litigation. For the first time, the scope of that privilege has been considered, in the UK, by a court in the context of a competition investigation. The judgment clarifies the extent of the privilege in the context of OFT investigations for breach of UK competition law—and provides insight as to how that rule could be interpreted elsewhere in the European Union.

September 5, 2012 | Permalink | Comments (0) | TrackBack (0)

The Application of EU Competition Law in the Pharmaceutical Sector

Posted by D. Daniel Sokol

David W. Hull (Covington) addresses The Application of EU Competition Law in the Pharmaceutical Sector.

ABSTRACT: If the Court of Justice follows the Advocate General's advice and upholds the General Court's judgment in AstraZeneca, this may result in increased enforcement aimed at various life cycle management strategies. The Commission's current enforcement priority remains combatting practices that slow generic entry, particularly reverse-payment patent settlements. The Commission has shown a renewed interest in parallel trade, particularly dual-pricing arrangements in Spain.

September 5, 2012 | Permalink | Comments (0) | TrackBack (0)

Germany: The Bundeskartellamt's New Merger Guidelines

Posted by D. Daniel Sokol

Andreas Bardong, Bundeskartellamt has written on Germany: The Bundeskartellamt's New Merger Guidelines.

ABSTRACT: Economic concepts play a far greater role, in the updated guidance document on substantive merger control in Germany (2012), in particular in the area of collective dominance. Markets are analysed with a view to constraints within the market (eg competitors), outside the market (eg potential competition), and from the opposite side of the market (countervailing buyer power). Issues raised during the consultation included the role of rebuttable presumptions in the context of information requirements, pre-notification, and standard of review, as well as the upcoming adoption of the SIEC-test in Germany.

September 5, 2012 | Permalink | Comments (0) | TrackBack (0)

Sagers on the Rabbi Cartel

Posted by D. Daniel Sokol

Chris Sagers (Cleveland Marshall) has a post on the Rabbi cartel on his blog.

September 5, 2012 | Permalink | Comments (0) | TrackBack (0)