Comments:

Ladies and Gentlemen, I am pleased to submit my comments in the above-referenced proceeding on the analysis of product tying arrangements under Section 2. I have attached my statement Untying the Knot: The Case for Overruling Jefferson Parish. My conclusion is that Jefferson Parish should be overruled and that tying arrangements should be analyzed under a structured rule of reason approach. Part of this submission are four papers that I have previously (co-)written on this topic. As it is not possible to attach more than one document to this online submission form, I will send these papers to section2hearings2@ftc.gov. Any questions about my statement would be welcome. Regards, David S. Evans Chairman, eSapience, Ltd., Cambridge, MA Jevons Institute for Competition Law and Economics and Visiting Professor, University College London, London, UK