Friday, 29 May 2020

General Court annuls European Commission prohibition of Hutchison 3G UK/ Telefonica UK merger


General Court annuls European Commission prohibition of Hutchison 3G UK/ Telefonica UK merger

In a breath-taking judgment, the General Court has upheld an appeal by CK Telecoms UK Investments to challenge the European Commission's 2016 EU Merger Regulation decision prohibiting the proposed acquisition of Telefónica Europe Plc (O2) by Hutchison 3G UK (Three).

The Commission found that the merger would have removed an important competitor on the UK mobile market, reducing the number of operators from four to three.  The merged company would have occupied around 40% of the retail market.

The General Court considered the Commission’s application of the ‘significant impediment to effective competition’ (SIEC) test.  It found that the mere effect of reducing competitive pressure on the remaining players in an oligopolistic market is not of itself sufficient to demonstrate a SIEC based on non-coordinated effects.

The General Court found that the Commission had committed a number of errors in finding that Three was an ‘important competitive force’ on the retail market.  Although the parties were close competitors in some segments of the market this was not sufficient to prove the elimination of important competitive constraints to establish a SIEC.

The General Court also found errors in the Commission’s analysis of the effects of the merger on the network-sharing agreements and infrastructure provision in the UK.

This may well be one of the most significant merger control decisions that the General Court has issued in the last fifteen years.  The Commission will need to take a root and branch look at how it appraises mergers in oligopolistic markets and where it bases its theory of harm on non-coordinated effects falling short of creation or strengthening of a dominant position.  It is expected that the Commission will appeal the judgment given its wide implications.

CK Telecoms UK Investments Ltd v European Commission (T-399/16), ECLI:EU:T:2020:217)

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