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Competition law enforcement in the pharmaceutical sector has been vigorous in recent years with regulators focusing on a variety of issues including denigration strategies, lifecycle management patent strategies, pricing rebates, and excessive pricing.

In an article recently published in Concurrences, we examine the case law and enforcement practice in this area and apply it to a particular type of pharmaceutical product: biologic drugs and biosimilars.

The article considers market definition concerning biologic drugs and biosimilars, reviewing European Commission and national case law concerning mergers and abuse of dominance cases involving biologics/biosimilars. It then examines how the existing framework in abuse of dominance cases can be applied in the area of biologics/biosimilars taking the specific characteristics of those products into account.

The article concludes that, although several elements from the existing cases could be implemented in biosimilar cases, various fact-specific differences will likely lead to a more nuanced legal approach both in market definition and in the assessment of potentially anti-competitive conduct.

The full text of the article can be accessed on the Concurrences website here (no subscription required).

This article was written for Concurrences and co-authored by Kyriakos Fountoukakos (Global Head of Competition, Regulation and Trade) and Violetta Meli (previously an Associate (Intern) at Herbert Smith Freehills, currently an Associate at Gowling WLG).

 

Kyriakos Fountoukakos photo

Kyriakos Fountoukakos

Managing Partner, Competition Regulation and Trade, Brussels

Kyriakos Fountoukakos
Peter Rowland photo

Peter Rowland

Of Counsel, Brussels

Peter Rowland
Max Kaufman photo

Max Kaufman

Senior Associate, London

Max Kaufman
Emily Bottle photo

Emily Bottle

Partner, London and Milan

Emily Bottle
Priyanka Madan photo

Priyanka Madan

Senior Associate, London

Priyanka Madan

Key contacts

Kyriakos Fountoukakos photo

Kyriakos Fountoukakos

Managing Partner, Competition Regulation and Trade, Brussels

Kyriakos Fountoukakos
Peter Rowland photo

Peter Rowland

Of Counsel, Brussels

Peter Rowland
Max Kaufman photo

Max Kaufman

Senior Associate, London

Max Kaufman
Emily Bottle photo

Emily Bottle

Partner, London and Milan

Emily Bottle
Priyanka Madan photo

Priyanka Madan

Senior Associate, London

Priyanka Madan
Kyriakos Fountoukakos Peter Rowland Max Kaufman Emily Bottle Priyanka Madan