The Digital Markets, Competition and Consumers Bill seeks to create a new regulatory framework for firms with ‘strategic market status’ (SMS). The Digital Markets Unit (DMU), which will be part of the Competition and Markets Authority (CMA), will have the power to designate tech firms such as Google and Apple as having SMS for certain activities. It will be able to impose wide-ranging conduct requirements on those firms and will also have the power to make pro-competitive interventions. These are powerful tools. The DMU will be able to make significant changes to the SMS firms’ business models with the objective of opening up their ecosystems and levelling the playing field for challenger firms. This article considers the standard of review that should apply in determining challenges to decisions of the DMU under this regime. In particular, we consider arguments that have been made against the use of the proposed ‘judicial review’ standard and in favour of an ‘on the merits’ appeal. As part of our analysis we consider consistency with analogous CMA regimes, forward looking assessments and the need for speed, expert opinions and consistency across different jurisdictions.
{"title":"In defence of judicial review: the established UK appeal standard is the best approach for a dynamic digital economy","authors":"Tom Smith, David Gallagher","doi":"10.4337/clj.2023.02.03","DOIUrl":"https://doi.org/10.4337/clj.2023.02.03","url":null,"abstract":"The Digital Markets, Competition and Consumers Bill seeks to create a new regulatory framework for firms with ‘strategic market status’ (SMS). The Digital Markets Unit (DMU), which will be part of the Competition and Markets Authority (CMA), will have the power to designate tech firms such as Google and Apple as having SMS for certain activities. It will be able to impose wide-ranging conduct requirements on those firms and will also have the power to make pro-competitive interventions. These are powerful tools. The DMU will be able to make significant changes to the SMS firms’ business models with the objective of opening up their ecosystems and levelling the playing field for challenger firms. This article considers the standard of review that should apply in determining challenges to decisions of the DMU under this regime. In particular, we consider arguments that have been made against the use of the proposed ‘judicial review’ standard and in favour of an ‘on the merits’ appeal. As part of our analysis we consider consistency with analogous CMA regimes, forward looking assessments and the need for speed, expert opinions and consistency across different jurisdictions.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":"51 2","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136233912","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Vassilena Karadakova, K. Fountoukakos, André Pretorius
Gone are the days when merger control risk assessments were only rarely a feature of private equity deal planning. Competition authorities around the world have recently turned their attention to creeping consolidation in particular sectors, including across private equity portfolios, and are finding new ways of using their existing toolkits to review so-called ‘roll-up’ strategies pursuant to which a private equity investor acquires multiple small companies in the same sector. This article considers the mechanisms through which private equity ‘roll-up’ transactions may be subject to merger review in the EU and the UK and the potentially far-reaching implications for PE firms and those advising them.
{"title":"Merger review of creeping private equity consolidation: a new use for Article 22 EUMR and beyond?","authors":"Vassilena Karadakova, K. Fountoukakos, André Pretorius","doi":"10.4337/clj.2023.01.02","DOIUrl":"https://doi.org/10.4337/clj.2023.01.02","url":null,"abstract":"Gone are the days when merger control risk assessments were only rarely a feature of private equity deal planning. Competition authorities around the world have recently turned their attention to creeping consolidation in particular sectors, including across private equity portfolios, and are finding new ways of using their existing toolkits to review so-called ‘roll-up’ strategies pursuant to which a private equity investor acquires multiple small companies in the same sector. This article considers the mechanisms through which private equity ‘roll-up’ transactions may be subject to merger review in the EU and the UK and the potentially far-reaching implications for PE firms and those advising them.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"45093294","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
A. Knight, Carolina Ricciardi, Matteo Alchini, Steven Pantling
The UK has a voluntary, non-suspensory merger control regime, such that mergers, acquisitions and other transactions can be, and routinely are, completed before they are investigated by the CMA. However, the CMA can, and often does, investigate mergers, acquisitions and other transactions that have not been notified to it. It has powers to prevent further integration between the merging parties’ businesses, and to require existing integration to be unwound, pending the conclusion of its investigation. Where the CMA identifies competition concerns, whether at Phase 1 or Phase 2, the fact that a merger, acquisition or other transaction has been completed can give rise to difficulties in identifying, implementing and ensuring the effectiveness of a remedy. This article discusses the CMA’s powers to impose interim measures and its approach to remedies in completed transactions. It also discusses the lessons that the CMA has learned from implementing remedies in merger investigations into completed transactions.
{"title":"Disentangling completed transactions in the UK: experiences and challenges","authors":"A. Knight, Carolina Ricciardi, Matteo Alchini, Steven Pantling","doi":"10.4337/clj.2023.01.05","DOIUrl":"https://doi.org/10.4337/clj.2023.01.05","url":null,"abstract":"The UK has a voluntary, non-suspensory merger control regime, such that mergers, acquisitions and other transactions can be, and routinely are, completed before they are investigated by the CMA. However, the CMA can, and often does, investigate mergers, acquisitions and other transactions that have not been notified to it. It has powers to prevent further integration between the merging parties’ businesses, and to require existing integration to be unwound, pending the conclusion of its investigation. Where the CMA identifies competition concerns, whether at Phase 1 or Phase 2, the fact that a merger, acquisition or other transaction has been completed can give rise to difficulties in identifying, implementing and ensuring the effectiveness of a remedy. This article discusses the CMA’s powers to impose interim measures and its approach to remedies in completed transactions. It also discusses the lessons that the CMA has learned from implementing remedies in merger investigations into completed transactions.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":"1 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42035890","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
For the last ten years, most-favoured-nation clauses (MFNs), also known as price parity clauses, have remained a hotly debated topic in competition policy. The direction of travel has generally been one-way, culminating with the UK and EU vertical block exemption regimes designating wide MFNs as ‘hardcore’ or excluded restrictions respectively. However, the UK Competition Appeal Tribunal’s judgment in BGL (Holdings) Limited v. Competition and Markets Authority injects nuance into the debate. The CAT found that, not only had the Competition and Markets Authority not proved its case on anti-competitive effects, but that it was unlikely that, in this case, wide MFNs had any effect on the key market outcomes of retail prices (i.e. insurance premiums), commissions paid by insurers to CompareTheMarket or increased barriers to entry. The CAT’s judgment and the economic evidence presented throughout the case provide valuable insights into how the competitive effects of wide MFNs should be assessed, why harmful effects may not arise and the role that econometric evidence can play. As explained in this article, at most, MFNs (whether wide or narrow) only directly restrict intra-brand competition and, if coverage and adherence to the MFNs are limited, competitive effects (whether pro-competitive or anti-competitive) may not arise. In this case, there was an opportunity to test empirically for any competitive effects, as CompareTheMarket removed its wide MFNs shortly after the CMA’s investigation opened (and no other price comparison website had them in place). As described by the CAT, ‘such a “before and after” consideration at least prima facie lends itself to econometric analysis’, which can provide a robust comparison to the situation that prevailed when wide MFNs were applied. In contrast, the CAT raised concerns with the qualitative evidence relied on by the CMA and its absence of any quantitative analysis of the competitive effects, if any, of the wide MFNs.
{"title":"MFNs: the latest turn in the policy debate – key lessons from the CAT’s judgment on CompareTheMarket’s use of wide MFNs in home insurance","authors":"Helen Ralston-Smith, Tamrat Shone","doi":"10.4337/clj.2023.01.06","DOIUrl":"https://doi.org/10.4337/clj.2023.01.06","url":null,"abstract":"For the last ten years, most-favoured-nation clauses (MFNs), also known as price parity clauses, have remained a hotly debated topic in competition policy. The direction of travel has generally been one-way, culminating with the UK and EU vertical block exemption regimes designating wide MFNs as ‘hardcore’ or excluded restrictions respectively. However, the UK Competition Appeal Tribunal’s judgment in BGL (Holdings) Limited v. Competition and Markets Authority injects nuance into the debate. The CAT found that, not only had the Competition and Markets Authority not proved its case on anti-competitive effects, but that it was unlikely that, in this case, wide MFNs had any effect on the key market outcomes of retail prices (i.e. insurance premiums), commissions paid by insurers to CompareTheMarket or increased barriers to entry.\u0000The CAT’s judgment and the economic evidence presented throughout the case provide valuable insights into how the competitive effects of wide MFNs should be assessed, why harmful effects may not arise and the role that econometric evidence can play. As explained in this article, at most, MFNs (whether wide or narrow) only directly restrict intra-brand competition and, if coverage and adherence to the MFNs are limited, competitive effects (whether pro-competitive or anti-competitive) may not arise. In this case, there was an opportunity to test empirically for any competitive effects, as CompareTheMarket removed its wide MFNs shortly after the CMA’s investigation opened (and no other price comparison website had them in place). As described by the CAT, ‘such a “before and after” consideration at least prima facie lends itself to econometric analysis’, which can provide a robust comparison to the situation that prevailed when wide MFNs were applied. In contrast, the CAT raised concerns with the qualitative evidence relied on by the CMA and its absence of any quantitative analysis of the competitive effects, if any, of the wide MFNs.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48173008","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
L. Rigby, Sofie Edwards, Anna Stellardi, Hannah McEwen
2022 was a record year for opt-out collective redress in the UK. The highest number of new collective proceedings claims were filed to date, and a record six claims were granted certification. While some actions were certified by the Competition Appeal Tribunal without challenge from the defendants, other proceedings were appealed to the Court of Appeal. All of this scrutiny saw both the judiciary – and the parties before it – test the boundaries of the certification stage; ultimately providing important guidance for the young regime. This article tracks the key developments in 2022 and analyses their impact on the collective proceedings regime under section 47B of the Competition Act 1998, before looking ahead to potential trends in 2023 and beyond.
{"title":"2022 in review: a look at key developments in opt-out collective redress in the UK","authors":"L. Rigby, Sofie Edwards, Anna Stellardi, Hannah McEwen","doi":"10.4337/clj.2023.01.01","DOIUrl":"https://doi.org/10.4337/clj.2023.01.01","url":null,"abstract":"2022 was a record year for opt-out collective redress in the UK. The highest number of new collective proceedings claims were filed to date, and a record six claims were granted certification.\u0000While some actions were certified by the Competition Appeal Tribunal without challenge from the defendants, other proceedings were appealed to the Court of Appeal. All of this scrutiny saw both the judiciary – and the parties before it – test the boundaries of the certification stage; ultimately providing important guidance for the young regime.\u0000This article tracks the key developments in 2022 and analyses their impact on the collective proceedings regime under section 47B of the Competition Act 1998, before looking ahead to potential trends in 2023 and beyond.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42334885","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This article discusses the EU General Court’s Google Shopping judgment (Case T-612/17), which deals with online self-preferencing. Self-preferencing is a novel abuse of dominant position (Article 102 TFEU), which consists of the prominent display and positioning of the dominant undertaking’s own service (comparison shopping service in this case), and demotion of the competitors’ services, on webpages generated by the dominant undertaking’s general search services. The key-principles in the legal reasoning of the General Court’s ruling were the prohibition of discrimination and coterminous concepts such as ‘equal opportunities to compete’ and ‘competition on the merits’. The differential treatment between Google’s own service and those of its competitors derived from Google’s subjection of its adjustment algorithms only to its competitors and not to its own service. While an approach based on non-discrimination is contentious, on the other hand Google’s conduct was neither efficient nor did it benefit consumers. The article also examines the EU Digital Markets Act’s prohibition of self-preferencing and its relationship with the Google Shopping ruling.
{"title":"Self-preferencing in the EU: a legal and policy analysis of the Google Shopping case and the Digital Markets Act","authors":"C. Petrucci","doi":"10.4337/clj.2023.01.03","DOIUrl":"https://doi.org/10.4337/clj.2023.01.03","url":null,"abstract":"This article discusses the EU General Court’s Google Shopping judgment (Case T-612/17), which deals with online self-preferencing. Self-preferencing is a novel abuse of dominant position (Article 102 TFEU), which consists of the prominent display and positioning of the dominant undertaking’s own service (comparison shopping service in this case), and demotion of the competitors’ services, on webpages generated by the dominant undertaking’s general search services. The key-principles in the legal reasoning of the General Court’s ruling were the prohibition of discrimination and coterminous concepts such as ‘equal opportunities to compete’ and ‘competition on the merits’. The differential treatment between Google’s own service and those of its competitors derived from Google’s subjection of its adjustment algorithms only to its competitors and not to its own service. While an approach based on non-discrimination is contentious, on the other hand Google’s conduct was neither efficient nor did it benefit consumers. The article also examines the EU Digital Markets Act’s prohibition of self-preferencing and its relationship with the Google Shopping ruling.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42156549","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
J. Dunné, C. Livingstone, Craig Watt, Lauren Smith
This article reviews the impact of the recent Civil Litigation (Expenses and Group Proceedings) (Scotland) Act 2018, which introduced a new procedure for bringing collective proceedings in Scotland, on future competition litigation in Scotland.
{"title":"Group proceedings in Scotland: competition between the Court of Session and the Competition Appeal Tribunal?","authors":"J. Dunné, C. Livingstone, Craig Watt, Lauren Smith","doi":"10.4337/clj.2023.01.04","DOIUrl":"https://doi.org/10.4337/clj.2023.01.04","url":null,"abstract":"This article reviews the impact of the recent Civil Litigation (Expenses and Group Proceedings) (Scotland) Act 2018, which introduced a new procedure for bringing collective proceedings in Scotland, on future competition litigation in Scotland.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-06-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44129449","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The Court of Appeal and the Competition Appeal Tribunal have recently handed down guidance in NTN v. Stellantis and O’Higgins and Evans, as to the requirements that must be satisfied to plead a competition law claim or defence, whether the claim is an individual claim or a collective action. This article considers the economic and legal issues that need to be addressed in pleadings, in the light of that guidance. Both judgments make clear that economists must be consulted at the very earliest stage to ensure that the pleadings, whether a claim or defence, or in an individual claim or a collective action, reflect clearly the economic theories relied upon and do so by reference to underlying facts. If a pleading does not comply with this guidance, it risks being struck out.
上诉法院和竞争上诉审裁处最近在NTN v. Stellantis和O 'Higgins and Evans案中就竞争法索赔或抗辩必须满足的要求(无论索赔是个人索赔还是集体诉讼)发布了指导意见。本文根据该指导意见，考虑在诉状中需要处理的经济和法律问题。这两项判决都清楚地表明，必须在最早的阶段咨询经济学家，以确保诉状，无论是索赔还是辩护，无论是个人索赔还是集体诉讼，都能清楚地反映所依赖的经济理论，并通过参考基本事实来做到这一点。如果一项辩护不符合这一指导原则，就有可能被驳回。
{"title":"Pleading competition damages claims and defences: recent guidance from the Court of Appeal and the Competition Appeal Tribunal","authors":"Matt Hughes, Elaine A. Whiteford","doi":"10.4337/clj.2022.04.03","DOIUrl":"https://doi.org/10.4337/clj.2022.04.03","url":null,"abstract":"The Court of Appeal and the Competition Appeal Tribunal have recently handed down guidance in NTN v. Stellantis and O’Higgins and Evans, as to the requirements that must be satisfied to plead a competition law claim or defence, whether the claim is an individual claim or a collective action. This article considers the economic and legal issues that need to be addressed in pleadings, in the light of that guidance. Both judgments make clear that economists must be consulted at the very earliest stage to ensure that the pleadings, whether a claim or defence, or in an individual claim or a collective action, reflect clearly the economic theories relied upon and do so by reference to underlying facts. If a pleading does not comply with this guidance, it risks being struck out.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-04-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46799697","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Agreements on prices by undertakings selling competing products are regarded as one of the most serious competition law infringements. This article considers what happens when government sets the prices at which those competing firms can sell their products. This article firstly examines the extensive use of government price controls in World War II. It then reviews early cases in the Restrictive Practices Court that considered the public interest (if any) in price stability. This article then touches on EU case law on when government involvement in price setting is acceptable or may provide some defence for undertakings and more recent EU legislation imposing price controls. Finally, the article draws the arguments for and against price fixing together to show what we can learn from the history of price controls. Current economic conditions and the range of solutions available to government make such a historical review both valuable and timely.
{"title":"When government sets prices: what can history teach us?","authors":"The Rt Hon Lady Rose of Colmworth","doi":"10.4337/clj.2022.04.01","DOIUrl":"https://doi.org/10.4337/clj.2022.04.01","url":null,"abstract":"Agreements on prices by undertakings selling competing products are regarded as one of the most serious competition law infringements. This article considers what happens when government sets the prices at which those competing firms can sell their products. This article firstly examines the extensive use of government price controls in World War II. It then reviews early cases in the Restrictive Practices Court that considered the public interest (if any) in price stability. This article then touches on EU case law on when government involvement in price setting is acceptable or may provide some defence for undertakings and more recent EU legislation imposing price controls. Finally, the article draws the arguments for and against price fixing together to show what we can learn from the history of price controls. Current economic conditions and the range of solutions available to government make such a historical review both valuable and timely.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-04-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"44011163","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Leniency policies grant substantial fine reductions to firms that disclose their former participation in a cartel. Such policies may, thereby, destabilize existing cartels and disincentivize the formation of new ones. Alternatively, some argue that they might have the opposite effect of incentivizing collusion by reducing the punishment for former cartel participants, thereby raising the collusive payoff. The overall decline in leniency applications in the European Union since 2014 calls for an analysis of the interplay between the 2006 Leniency Policy and other competition policies, most notably the 2014 Damages Directive. This article discusses the interaction between these two competition policy tools, arguing that the liability of immunity recipients in follow-on damage claims tends to stabilize cartels, and assesses several proposals that aim to ensure that public and private cartel enforcement tools are more in sync.
{"title":"The interplay between leniency programmes and private enforcement: the economist perspective on recent policy proposals","authors":"Roberto Alimonti, Sophie Kümmel, Thomas Nau","doi":"10.4337/clj.2022.04.04","DOIUrl":"https://doi.org/10.4337/clj.2022.04.04","url":null,"abstract":"Leniency policies grant substantial fine reductions to firms that disclose their former participation in a cartel. Such policies may, thereby, destabilize existing cartels and disincentivize the formation of new ones. Alternatively, some argue that they might have the opposite effect of incentivizing collusion by reducing the punishment for former cartel participants, thereby raising the collusive payoff. The overall decline in leniency applications in the European Union since 2014 calls for an analysis of the interplay between the 2006 Leniency Policy and other competition policies, most notably the 2014 Damages Directive. This article discusses the interaction between these two competition policy tools, arguing that the liability of immunity recipients in follow-on damage claims tends to stabilize cartels, and assesses several proposals that aim to ensure that public and private cartel enforcement tools are more in sync.","PeriodicalId":36415,"journal":{"name":"Competition Law Journal","volume":" ","pages":""},"PeriodicalIF":0.0,"publicationDate":"2023-04-28","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"42416409","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
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