---
title: "Submission to the Australian Competition and Consumer Commission’s Digital  Platforms Inquiry"
author: "Berg, C.; Hurwitz, G."
date: "2019-02-14"
url: "https://chrisberg.org/2019/02/submission-to-the-australian-competition-and-consumer-commissions-digital-platforms-inquiry/"
type: "Submissions and reports"
published_in: "International Center for Law & Economics"
pdf: "https://chrisberg.org/wp-content/uploads/2019/02/ICLE-submission-to-ACCC-digital-platforms-inquiry.pdf"
topics: "Competition policy, Digital platforms"
---

# Submission to the Australian Competition and Consumer Commission’s Digital  Platforms Inquiry

*With Gus Hurwitz.*

**Executive summary:** The analysis in the Australian Competition and Consumer Commission’s Preliminary Report for the Digital Platforms Inquiry is inadequate in several ways, most notably:

- It mischaracterises the relationship between changes in the economics of media advertising and the rise of digital platforms such as Facebook and Google.
- Its analysis of the dynamics of media diversity is misguided.
- Its competition analysis assumes its results and makes unsupportable claims about the division of advertising markets.
- It is recklessly unconcerned with the freedom of speech consequences of its recommendations.
- It fails to recognise, and proposes to supplant, the ongoing social negotiation over data privacy.
- It provides a poor analytic base on which to make policy recommendations, as it applies a static, rather than dynamic, approach to its analysis.

There is a real danger that if the policy recommendations outlined in the preliminary report were to be adopted, Australian consumers would be severely harmed.

[Available here.](https://chrisberg.org/wp-content/uploads/2019/02/ICLE-submission-to-ACCC-digital-platforms-inquiry.pdf)