Persuading on Paper: Written Advocacy to the FTC’s Bureau of Competition
The Front Office of the FTC’s Bureau of Competition receives a great deal of advocacy from the bar. Virtually every day, parties and their counsel make arguments and present evidence to us regarding the various merger and conduct matters handled by the Bureau’s various Divisions. Some of this advocacy is conducted in person, but much of it takes place on paper, in the memoranda universally known as “white papers.” In some ways, white papers can...