CFA submitted the following comments in response to the Department of Justice’s (DOJ’s) proposed Final Judgment in the case of United States of America v. Bayer AG, Monsanto Company and BASF SE. The comments criticize the adequacy of the proposed merger conditions, particularly with respect to their approach to addressing abuse of supply chain chokepoints, or so-called vertical market power abuse. If finalized, the Bayer-Monsanto merger would further erode competition in an already highly concentrated, the market for seeds, traits and agricultural chemicals. That outcome does not bode well for consumers.
