+--------+----------------+-----------+-------------+-----------------+
| **     |                |           |             |                 |
| Number |                |           |             |                 |
| range  |                |           |             |                 |
| CHAP   |                |           |             |                 |
| TERFTC |                |           |             |                 |
| Merger |                |           |             |                 |
| Enfor  |                |           |             |                 |
| cement |                |           |             |                 |
| A      |                |           |             |                 |
| ctions |                |           |             |                 |
| in the |                |           |             |                 |
| Pet    |                |           |             |                 |
| roleum |                |           |             |                 |
| Indu   |                |           |             |                 |
| stry** |                |           |             |                 |
|        |                |           |             |                 |
| *      |                |           |             |                 |
| *Since |                |           |             |                 |
| 1981** |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **F    | **Markets      | **Theory  | **Co        | **FTC           |
| irms** | Affected**     | of        | ncentration | Enforcement     |
|        |                | Anti-co   | (HHI)**     | Action**        |
| **(Yea |                | mpetitive |             |                 |
| r)\*** |                | Effects** |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| *      | 1\. Natural    | U         | Post-merger | Divestiture of  |
| *Enter | gas            | nilateral | \> 3600     | either party's  |
| prise/ | transportation | /         | (inferred)  | natural gas     |
| Gul    | from West      | Co        | Change \>   | pipeline        |
| fTerra | Central        | ordinated | 50          | interests       |
| **[^1] | Deepwater area |           | (inferred)  |                 |
| **(2   | of the Gulf of | Co        |             | Divestiture of  |
| 004)** | Mexico.        | ordinated | Post-merger | some of         |
|        |                |           | \> 2809     | Enterprise's    |
|        | 2\. Propane    |           |             | propane storage |
|        | storage and    |           | Change \>   | interests       |
|        | terminaling    |           | 50          |                 |
|        | services in    |           | (inferred)  |                 |
|        | the            |           |             |                 |
|        | Hattiesburg,   |           |             |                 |
|        | Mississippi    |           |             |                 |
|        | area.          |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Mag  | Terminaling of | Co        | Post-merger | Divestiture of  |
| ellan/ | light products | ordinated | \> 4300     | Shell's         |
| Shell  | in the         |           | Change \>   | Oklahoma City   |
| **[^2] | Oklahoma City  |           | 1200        | terminal assets |
| **(2   | area.          |           |             |                 |
| 004)** |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Sh   | Refining and   | U         | Post-merger | Divestiture of  |
| ell/Pe | marketing of   | nilateral | \>2300      | Pennzoil        |
| nnzoil | paraffinic     | /         |             | interest in     |
| Quaker | base oil in    | Co        | Change      | lube oil joint  |
| State  | U.S. and       | ordinated | \>700       | venture;        |
| **[^3] | Canada         |           |             | Pennzoil        |
|        |                |           |             | sourcing of     |
| **(2   |                |           |             | lube oil from   |
| 002)** |                |           |             | third party     |
|        |                |           |             | lube oil        |
|        |                |           |             | refiner frozen  |
|        |                |           |             | at current      |
|        |                |           |             | level           |
+--------+----------------+-----------+-------------+-----------------+
| *      | 1\. Bulk       | Co        | Post-merger | Divestiture of  |
| *Phill | supply (via    | ordinated | \> 2600     | Conoco refinery |
| ips/** | refining or    |           |             | in Denver and   |
|        | pipeline) of   |           | Change \>   | all of Phillips |
| **     | light          |           | 500         | marketing       |
| Conoco | petroleum      |           |             | assets in       |
| **[^4] | products in    |           |             | eastern         |
|        | eastern        |           |             | Colorado        |
| **(2   | Colorado       |           |             |                 |
| 002)** |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Bulk       | Co        | Post-merger | Divestiture of  |
|        | supply of      | ordinated | \> 2100     | Phillips        |
|        | light          |           |             | refinery in     |
|        | petroleum      |           | Change \>   | Salt Lake City  |
|        | products in    |           | 300         | and all of      |
|        | northern Utah  |           |             | Phillips        |
|        |                |           |             | marketing       |
|        |                |           |             | assets in       |
|        |                |           |             | northern Utah   |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\.            | U         | Post-merger | Divestiture of  |
|        | Terminaling    | nilateral | 5000        | Phillips'       |
|        | services in    | /         |             | terminal at     |
|        | the Spokane,   | Co        | Change \>   | Spokane         |
|        | Washington     | ordinated | 1600        |                 |
|        | area           |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\.            | U         | Post-merger | Terminal        |
|        | Terminaling    | nilateral | \> 3600     | throughput      |
|        | services for   | /         |             | agreement with  |
|        | light products | Co        | Change \>   | option to buy   |
|        | in the         | ordinated | 750         | 50% undivided   |
|        | Wichita,       |           |             | interest in     |
|        | Kansas area    |           |             | Phillips        |
|        |                |           |             | terminal        |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Bulk       | U         | Post-merger | Divestiture of  |
|        | supply of      | nilateral | 3700        | Phillips'       |
|        | propane in     | /         |             | propane         |
|        | southern       | Co        | Change \>   | business at     |
|        | Missouri       | ordinated | 1200        | Jefferson City  |
|        |                |           |             | and E. St.      |
|        |                |           |             | Louis;          |
|        |                |           |             | contracts       |
|        |                |           |             | giving buyer    |
|        |                |           |             | no              |
|        |                |           |             | ndiscriminatory |
|        |                |           |             | access to       |
|        |                |           |             | market at       |
|        |                |           |             | Conway, KS      |
+--------+----------------+-----------+-------------+-----------------+
|        | 6\. Bulk       | U         | Post-merger | As above        |
|        | supply of      | nilateral | \> 7700     |                 |
|        | propane in St. | /         |             |                 |
|        | Louis          | Co        | Change \>   |                 |
|        |                | ordinated | 1000        |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 7\. Bulk       | U         | Post-merger | As above        |
|        | supply of      | nilateral | \> 7700     |                 |
|        | propane in     | /         |             |                 |
|        | southern       | Co        | Change \>   |                 |
|        | Illinois       | ordinated | 1000        |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 8\. Natural    | Unila     | Not         | Divestiture of  |
|        | gas gathering  | teral[^5] | publicly    | Conoco's gas    |
|        | by pipeline in |           | available   | gathering       |
|        | certain parts  |           |             | assets in each  |
|        | of western     |           |             | area            |
|        | Texas and      |           |             |                 |
|        | southeastern   |           |             |                 |
|        | New Mexico     |           |             |                 |
|        | (Permian       |           |             |                 |
|        | Basin)         |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 9\.            | U         | Not         | Prohibitions on |
|        | Fractionation  | nilateral | publicly    | transfers of    |
|        | of natural gas | /         | available   | competitive     |
|        | liquids at     | Coordi    |             | information;    |
|        | Mont Belvieu,  | nated[^6] |             | voting          |
|        | Texas          |           |             | requirements    |
|        |                |           |             | for capacity    |
|        |                |           |             | expansion       |
+--------+----------------+-----------+-------------+-----------------+
| **Vale | 1\. Refining   | U         | Post-merger | Divestiture of  |
| ro/UDS | and Bulk       | nilateral | \> 2700     | UDS's refinery  |
| **[^7] | Supply of CARB | /         |             | at Avon, CA,    |
|        | 2 gasoline for | Co        | Change \>   | bulk gasoline   |
| **(2   | northern       | ordinated | 750         | supply          |
| 001)** | California     |           |             | contracts, and  |
|        |                |           |             | 70 owned and    |
|        |                |           |             | operated retail |
|        |                |           |             | outlets         |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Refining   | U         | Post-merger | As above        |
|        | and Bulk       | nilateral | \> 3050     |                 |
|        | Supply of CARB | /         |             |                 |
|        | 3 gasoline for | Co        | Change      |                 |
|        | northern       | ordinated | \>1050      |                 |
|        | California     |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Refining   | Co        | Post-merger | As above        |
|        | and Bulk       | ordinated | \> 1750     |                 |
|        | Supply of CARB |           |             |                 |
|        | 2 gasoline for |           | Change \>   |                 |
|        | state of       |           | 325         |                 |
|        | California     |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Refining   | Co        | Post-merger | As above        |
|        | and Bulk       | ordinated | \>1850      |                 |
|        | Supply of CARB |           |             |                 |
|        | 3 gasoline for |           | Change \>   |                 |
|        | state of       |           | 390         |                 |
|        | California     |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Chev | 1\. Gasoline   | Co        | Post-merger | Divestiture (to |
| ron/** | marketing in   | ordinated | range from  | Shell, the      |
|        | numerous       |           | 1000-1800   | other owner of  |
| **     | separate       |           |             | Equilon) of     |
| Texaco | markets in 23  |           | Change      | Texaco's        |
| **[^8] | western and    |           | \>100 to    | interests in    |
|        | southern       |           |             | the Equilon and |
| **(2   | states         |           | Post merger | Motiva joint    |
| 001)** |                |           | \>1800      | ventures        |
|        |                |           |             | (including      |
|        |                |           | Change \>50 | Equilon's       |
|        |                |           |             | interests in    |
|        |                |           | (all        | the Explorer    |
|        |                |           | inferred)   | and Delta       |
|        |                |           |             | Pipelines)      |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Marketing  | U         | Post-merger | As above        |
|        | of CARB        | nilateral | range       |                 |
|        | gasoline in    | /         | \>2000      |                 |
|        | California     | Co        |             |                 |
|        |                | ordinated | Change \>50 |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Refining   | U         | Post-merger | As above        |
|        | and bulk       | nilateral | 2000        |                 |
|        | supply of CARB | /         |             |                 |
|        | gasoline for   | Co        | Change 500  |                 |
|        | California     | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Refining   | Co        | Post-merger | As above        |
|        | and bulk       | ordinated | \> 2000     |                 |
|        | supply of      |           |             |                 |
|        | gasoline and   |           | Change \>   |                 |
|        | jet fuel in    |           | 600         |                 |
|        | the Pacific    |           |             |                 |
|        | Northwest      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Refining   | Coordi    | Post-merger | As above        |
|        | and bulk       | nated[^9] | \> 5000     |                 |
|        | supply of RFG  |           |             |                 |
|        | II gasoline    |           | Change \>   |                 |
|        | for the St.    |           | 1600        |                 |
|        | Louis          |           |             |                 |
|        | metropolitan   |           |             |                 |
|        | area           |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 6\.            | U         | Post-merger | As above        |
|        | Terminaling of | nilateral | range       |                 |
|        | gasoline and   | /         | \>2000      |                 |
|        | other light    | Co        |             |                 |
|        | products in    | ordinated | Change      |                 |
|        | various        |           | \>300       |                 |
|        | geographic     |           |             |                 |
|        | markets in     |           |             |                 |
|        | California,    |           |             |                 |
|        | Arizona,       |           |             |                 |
|        | Hawaii,        |           |             |                 |
|        | Mississippi,   |           |             |                 |
|        | and Texas      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 7\. Crude oil  | Co        | Post-merger | As above        |
|        | transportation | ordinated | \> 3300     |                 |
|        | via pipeline   |           |             |                 |
|        | from           |           | Change      |                 |
|        | California's   |           | \>800       |                 |
|        | San Joaquin    |           |             |                 |
|        | Valley         |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 8\. Crude oil  | Unilat    | Post-merger | As above        |
|        | transportation | eral[^10] | \>1800      |                 |
|        | from the       |           |             |                 |
|        | offshore       |           | (inferred)  |                 |
|        | Eastern Gulf   |           |             |                 |
|        | of Mexico      |           | Change \>50 |                 |
|        |                |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 9\. Natural    | U         | Post-merger | Divestiture of  |
|        | gas            | nilateral | \>1800      | Texaco's 33%    |
|        | transportation | /         |             | interest in the |
|        | from certain   | Coordin   | (inferred)  | Discovery Gas   |
|        | parts of the   | ated[^11] |             | Transmission    |
|        | Central Gulf   |           | Change \>50 | System          |
|        | of Mexico      |           |             |                 |
|        | offshore area  |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 10\.           | U         | Not         | Divestiture of  |
|        | Fractionation  | nilateral | publicly    | Texaco's        |
|        | of natural gas | /         | available   | minority        |
|        | liquids at     | Coordin   |             | interest in the |
|        | Mont Belvieu,  | ated[^12] |             | Enterprise      |
|        | Texas          |           |             | fractionator    |
+--------+----------------+-----------+-------------+-----------------+
|        | 11\. Marketing | U         | Post-merger | Divestiture of  |
|        | of aviation    | nilateral | \> 1900     | Texaco's        |
|        | fuels to       | /         |             | general         |
|        | general        | Co        | Change \>   | aviation        |
|        | aviation in    | ordinated | 250         | business to an  |
|        | the Southeast  |           |             | up-front buyer  |
|        | U.S.           |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 12\. Marketing | U         | Post-merger | As above        |
|        | of aviation    | nilateral | \> 3400     |                 |
|        | fuels to       | /         |             |                 |
|        | general        | Co        | Change \>   |                 |
|        | aviation in    | ordinated | 1600        |                 |
|        | the western    |           |             |                 |
|        | U.S.           |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **BP   | 1\. Production | Unilat    | Post-merger | FTC filed in    |
| /ARCO* | and sale of    | eral[^14] | \>5476      | federal         |
| *[^13] | Alaska North   |           |             | District Court, |
|        | Slope ("ANS")  |           | Change 2640 | then reached    |
| **(2   | crude oil      |           |             | consent;        |
| 000)** |                |           |             | divestiture of  |
|        |                |           |             | all of ARCO's   |
|        |                |           |             | Alaska          |
|        |                |           |             | assets[^15]     |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Bidding    | Unilat    | Post-merger | As above        |
|        | for ANS crude  | eral[^16] | \>1800      |                 |
|        | oil            |           |             |                 |
|        | exploration    |           | (inferred)  |                 |
|        | rights in      |           |             |                 |
|        | Alaska         |           | Change \>50 |                 |
|        |                |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\.            | U         | Post-merger | As above        |
|        | Transportation | nilateral | \>5600      |                 |
|        | of ANS crude   | /         |             |                 |
|        | oil on the     | Coordin   | Change 2200 |                 |
|        | Trans-Alaska   | ated[^17] |             |                 |
|        | Pipeline       |           |             |                 |
|        | System         |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Future     | U         | Not         | As above        |
|        | com            | nilateral | applicable  |                 |
|        | mercialization | /         |             |                 |
|        | of ANS natural | Coordin   |             |                 |
|        | gas (potential | ated[^18] |             |                 |
|        | competition)   |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Crude oil  | Unilat    | Post-merger | Divestiture of  |
|        | transportation | eral[^19] |             | all of ARCO's   |
|        | and storage    |           | \>1849 for  | pipeline        |
|        | services at    |           | storage     | interests and   |
|        | Cushing,       |           |             | storage assets  |
|        | Oklahoma       |           | \>2401 for  | related to      |
|        |                |           | pipelines   | Cushing         |
|        |                |           |             |                 |
|        |                |           | \>9025 for  |                 |
|        |                |           |             |                 |
|        |                |           | trading     |                 |
|        |                |           | services    |                 |
|        |                |           |             |                 |
|        |                |           | Changes     |                 |
|        |                |           | \>50        |                 |
|        |                |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Ex   | 1\. Gasoline   | U         | Post-merger | Divestiture of  |
| xon/** | marketing in   | nilateral | range from  | all Exxon       |
|        | at least 39    | /         | 1000-1800   | (Mobil) owned   |
| **     | metro areas in | Co        |             | outlets and     |
| Mobil* | the Northeast  | ordinated | Change      | assignment of   |
| *[^20] | (Maine to New  |           | \>100 to    | agreements in   |
|        | York) and      |           | Post-merger | the Northeast   |
| **(1   | Mid-Atlantic   |           | \>1800      | (Mid-Atlantic)  |
| 999)** | (New Jersey to |           |             | region          |
|        | Virginia)      |           | Change \>50 |                 |
|        | regions of the |           |             |                 |
|        | U.S.           |           | (all        |                 |
|        |                |           | inferred)   |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Gasoline   | U         | Post-merger | Divestiture of  |
|        | marketing in   | nilateral | range from  | Mobil's retail  |
|        | five metro     | /         | 1000-1800   | outlets and     |
|        | areas of Texas | Co        |             | supply          |
|        |                | ordinated | Change      | agreements      |
|        |                |           | \>100 to    |                 |
|        |                |           | Post-merger |                 |
|        |                |           | \>1800      |                 |
|        |                |           |             |                 |
|        |                |           | Change \>50 |                 |
|        |                |           |             |                 |
|        |                |           | (all        |                 |
|        |                |           | inferred)   |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Gasoline   | Co        | Not         | Termination of  |
|        | marketing in   | ordinated | applicable  | Exxon's option  |
|        | Arizona        |           |             | to repurchase   |
|        | (potential     |           |             | retail outlets  |
|        | competition)   |           |             | previously sold |
|        |                |           |             | to Tosco        |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Refining   | U         | Post-merger | Divestiture of  |
|        | and marketing  | nilateral | 1699        | Exxon's         |
|        | of "CARB"      | /         |             | refinery at     |
|        | gasoline in    | Co        | Change 171  | Benicia, CA,    |
|        | California     | ordinated |             | and all of      |
|        |                |           | (measured   | Exxon's         |
|        |                |           | by refining | marketing       |
|        |                |           | capacity)   | assets in CA,   |
|        |                |           |             | including       |
|        |                |           |             | assignment to   |
|        |                |           |             | the refinery    |
|        |                |           |             | buyer of supply |
|        |                |           |             | agreements for  |
|        |                |           |             | 275 outlets     |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Refining   | U         | Post merger | As above        |
|        | of Navy jet    | nilateral | \>1800      |                 |
|        | fuel on the    | /         |             |                 |
|        | west coast     | Co        | (inferred)  |                 |
|        |                | ordinated |             |                 |
|        |                |           | Change \>50 |                 |
|        |                |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 6\.            | U         | Post merger | Divestiture of  |
|        | Terminaling of | nilateral | \>1800      | a Mobil         |
|        | light products | /         |             | terminal in     |
|        | in Boston, MA  | Co        | (inferred)  | each area       |
|        | and            | ordinated |             |                 |
|        | Washington, DC |           | Change \>50 |                 |
|        | areas          |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 7\.            | U         | Post merger | Continuation of |
|        | Terminaling of | nilateral | \>1800      | competitor      |
|        | light products | /         |             | access to wharf |
|        | in Norfolk, VA | Co        | (inferred)  |                 |
|        | area.          | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 8\.            | Coordin   | Post-merger | Divestiture of  |
|        | Transportation | ated[^21] |             | either party's  |
|        | of light       |           | \>1800      | pipeline        |
|        | products to    |           |             | interest        |
|        | the Inland     |           | (inferred)  |                 |
|        | Southeast      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 9\.            | Coordin   | Post-merger | Divestiture of  |
|        | Transportation | ated[^22] | \>1800      | Mobil's 3%      |
|        | of Crude Oil   |           |             | interest in     |
|        | from the       |           | (inferred)  | TAPS            |
|        | Alaska North   |           |             |                 |
|        | Slope          |           | Change \>50 |                 |
|        |                |           |             |                 |
|        |                |           | (inferred)  |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 10\.           | U         | Post-merger | Divestiture of  |
|        | Terminaling    | nilateral | 7400        | Exxon's         |
|        | and gasoline   | /         |             | terminal and    |
|        | marketing      | Co        | Change 2800 | retail assets   |
|        | assets on Guam | ordinated |             | on the island   |
+--------+----------------+-----------+-------------+-----------------+
|        | 11\.           | U         | Post-merger | Relinquishment  |
|        | Paraffinic     | nilateral | range 1000  | of contractual  |
|        | base oil       | /         | to 1800     | control over    |
|        | refining and   | Co        |             | Valero's base   |
|        | marketing in   | ordinated | (inferred)  | oil production; |
|        | the U.S. and   |           |             | long term       |
|        | Canada         |           | Change      | supply          |
|        |                |           | \>100       | agreements at   |
|        |                |           |             | formula prices  |
|        |                |           | (inferred)  | for volume of   |
|        |                |           |             | base oil equal  |
|        |                |           |             | to Mobil's U.S. |
|        |                |           |             | production      |
+--------+----------------+-----------+-------------+-----------------+
|        | 12\. Refining  | Unilat    | Pre-merger  | Divestiture of  |
|        | and marketing  | eral[^23] | \>5625      | Exxon jet       |
|        | of jet turbine |           |             | turbine oil     |
|        | oil worldwide  |           |             | manufacturing   |
|        |                |           |             | facility at     |
|        |                |           |             | Bayway, NJ,     |
|        |                |           |             | with related    |
|        |                |           |             | patent licenses |
|        |                |           |             | and             |
|        |                |           |             | intellectual    |
|        |                |           |             | property        |
+--------+----------------+-----------+-------------+-----------------+
| *      | 1\.            | Co        | Post-merger | Divestiture of  |
| *BP/** | Terminaling of | ordinated | range       | a terminal in   |
|        | gasoline and   |           | \>1500 -    | each geographic |
| **     | other light    |           | \>3600      | market          |
| Amoco* | products in    |           |             |                 |
| *[^24] | nine separate  |           | Change      |                 |
|        | metropolitan   |           | \>100       |                 |
| **(1   | areas, mostly  |           |             |                 |
| 998)** | in the         |           |             |                 |
|        | Southeast U.S. |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Wholesale  | Co        | Post-merger | Divestiture of  |
|        | sale of        | ordinated | range       | BP's or Amoco's |
|        | gasoline in    |           | \>          | owned retail    |
|        | thirty cities  |           | 1400-\>1800 | outlets in      |
|        | or             |           |             | eight           |
|        | metropolitan   |           | Change      | geographic      |
|        | areas in the   |           | \>100       | areas; in all   |
|        | Southeast U.S. |           |             | 30 areas        |
|        | and parts of   |           |             | jobbers and     |
|        | Ohio and       |           |             | open dealers    |
|        | Pennsylvania   |           |             | given option to |
|        |                |           |             | cancel without  |
|        |                |           |             | penalty         |
+--------+----------------+-----------+-------------+-----------------+
| **S    | 1a. Refining   | U         | Post-merger | Divestiture of  |
| hell/T | of gasoline    | nilateral | 3812        | Shell refinery  |
| exaco* | for the Puget  | /         |             | at Anacortes,   |
| *[^25] | Sound area     | Co        | Change 1318 | WA; Shell       |
|        |                | ordinated |             | jobbers and     |
| **(1   |                |           |             | dealers given   |
| 997)** |                |           |             | option to       |
|        |                |           |             | contract with   |
|        |                |           |             | purchaser       |
+--------+----------------+-----------+-------------+-----------------+
|        | 1b. Refining   | U         | Post-merger | As above        |
|        | of jet fuel    | nilateral | 5248        |                 |
|        | for the Puget  | /         |             |                 |
|        | Sound area     | Co        | Change 481  |                 |
|        |                | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2a. Refining   | U         | Post-merger | As above        |
|        | of gasoline    | nilateral | 2896        |                 |
|        | for the        | /         |             |                 |
|        | Pacific        | Co        | Change 561  |                 |
|        | Northwest      | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2b. Refining   | U         | Post-merger | As above        |
|        | of jet fuel    | nilateral | 2503        |                 |
|        | for the        | /         |             |                 |
|        | Pacific        | Co        | Change 258  |                 |
|        | Northwest      | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Refining   | U         | Post-merger | As above        |
|        | of "CARB"      | nilateral | 1635        |                 |
|        | gasoline for   | /         |             |                 |
|        | California     | Co        | Change 154  |                 |
|        |                | ordinated |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\.            | Unilat    | Not         | Ten year        |
|        | Transportation | eral[^26] | applicable  | extension of    |
|        | of undiluted   |           |             | crude oil       |
|        | heavy crude    |           |             | supply          |
|        | oil to San     |           |             | agreement.      |
|        | Francisco Bay  |           |             |                 |
|        | area for       |           |             |                 |
|        | refining of    |           |             |                 |
|        | asphalt        |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Pipeline   | Coordin   | Pre-merger  | Divestiture of  |
|        | transportation | ated[^27] | \>1800      | either party's  |
|        | of refined     |           |             | pipeline        |
|        | light products |           |             | interest        |
|        | to the inland  |           |             |                 |
|        | Southeast U.S. |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 6\. CARB       | Co        | Post-merger | Divestiture to  |
|        | gasoline       | ordinated | 1815        | a single entity |
|        | marketing in   |           |             | of retail       |
|        | San Diego      |           | Change 250  | outlets with    |
|        | County,        |           |             | specified       |
|        | California     |           |             | individual and  |
|        |                |           |             | combined volume |
+--------+----------------+-----------+-------------+-----------------+
|        | 7\.            | Co        | Post-merger | Divestiture of  |
|        | Terminaling    | ordinated | 2160        | either Shell's  |
|        | and marketing  |           |             | or Texaco's     |
|        | of gasoline    |           | Change 267  | terminal and    |
|        | and diesel     |           |             | associated      |
|        | fuel on the    |           |             | retail outlets  |
|        | island of      |           |             |                 |
|        | Oahu, Hawaii   |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **S    | Terminaling    | Co        | Not         | Divestiture of  |
| un/Atl | and marketing  | ordinated | publicly    | terminal and    |
| antic* | of light       |           | available   | associated      |
| *[^28] | products in    |           |             | owned retail    |
|        | Williamsport,  |           |             | outlets in each |
| **(1   | PA and         |           |             | area            |
| 988)** | Binghamton, NY |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **PRI/ | 1\.            | U         | Not         | FTC won         |
| Shell* | Terminaling    | nilateral | publicly    | preliminary     |
| *[^29] | and marketing  | /         | available   | injunction in   |
|        | of light       | Co        |             | U.S. District   |
| **(1   | petroleum      | ordinated |             | Court; prior    |
| 987)** | products on    |           |             | approval        |
|        | the individual |           |             | required for    |
|        | island of      |           |             | future          |
|        | Oahu, HI       |           |             | acquisitions    |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\.            | U         | Not         | As above        |
|        | Terminaling    | nilateral | publicly    |                 |
|        | and marketing  | /         | available   |                 |
|        | of light       | Co        |             |                 |
|        | petroleum      | ordinated |             |                 |
|        | products on    |           |             |                 |
|        | the individual |           |             |                 |
|        | islands of     |           |             |                 |
|        | Maui, Hawaii,  |           |             |                 |
|        | and Kauai in   |           |             |                 |
|        | the state of   |           |             |                 |
|        | Hawaii         |           |             |                 |
|        | (potential     |           |             |                 |
|        | competition)   |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Con  | 1\. Bulk       | Unilat    | Not         | FTC voted to    |
| oco/** | supply (from   | eral[^31] | publicly    | seek            |
|        | refineries and | /         | available   | preliminary     |
| **As   | pipelines) of  | Co        |             | injunction;     |
| amera* | gasoline and   | ordinated |             | parties         |
| *[^30] | other light    |           |             | abandoned the   |
|        | products to    |           |             | transaction     |
| **(1   | eastern        |           |             |                 |
| 986)** | Colorado       |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Purchasing | U         | Not         | As above        |
|        | of crude oil   | nilateral | publicly    |                 |
|        | in the         |           | available   |                 |
|        | De             |           |             |                 |
|        | nver-Julesberg |           |             |                 |
|        | Basin of       |           |             |                 |
|        | northeastern   |           |             |                 |
|        | Colorado       |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Ch   | 1\. Bulk       | Co        | Not         | Divestiture of  |
| evron/ | supply of      | ordinated | publicly    | one of two      |
| Gulf*  | kerosene jet   |           | available   | specified Gulf  |
| *[^32] | fuel in parts  |           |             |                 |
|        | of PADDs I and |           |             | refineries in   |
| **(1   | III and the    |           |             | Texas and       |
| 984)** | West Indies    |           |             | Louisiana.      |
|        | and Caribbean  |           |             |                 |
|        | islands        |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Transport  | Coordin   | Not         | Divestiture of  |
|        | of light       | ated[^33] | publicly    | Gulf's interest |
|        | products to    |           | available   | in the Colonial |
|        | the inland     |           |             | Pipeline        |
|        | Southeast      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Wholesale  | Co        | Not         | Divestiture of  |
|        | distribution   | ordinated | publicly    | all Gulf        |
|        | of gasoline    |           | available   | marketing       |
|        | and middle     |           |             | assets in six   |
|        | distillates in |           |             | states and      |
|        | numerous       |           |             | parts of South  |
|        | markets in     |           |             | Carolina        |
|        | West Virginia  |           |             |                 |
|        | and the South  |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Transport  | U         | Not         | Divestiture of  |
|        | of crude oil   | nilateral | publicly    | Gulf interests  |
|        | from West      | /         | available   | in specified    |
|        | Texas/New      | Coordin   |             | crude oil       |
|        | Mexico         | ated[^34] |             | pipelines,      |
|        |                |           |             | including 51%   |
|        |                |           |             | of Gulf's       |
|        |                |           |             | interest in the |
|        |                |           |             | West Texas Gulf |
|        |                |           |             | Pipeline        |
|        |                |           |             | Company         |
+--------+----------------+-----------+-------------+-----------------+
| **T    | 1\. Refining   | U         | Not         | Divestiture of  |
| exaco/ | of light       | nilateral | publicly    | Texaco refinery |
| Getty* | products in    |           | available   | at Westville,   |
| *[^35] | the            |           |             | NJ              |
|        | Northeast[^36] |           |             |                 |
| **(1   |                |           |             |                 |
| 984)** |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\. Pipeline   | U         | Not         | Texaco required |
|        | transportation | nilateral | publicly    | to support all  |
|        | of light       | /         | available   |                 |
|        | products into  | Coordin   |             | Colonial        |
|        | the Northeast  | ated[^37] |             | pipeline        |
|        |                |           |             | expansions for  |
|        |                |           |             | ten years       |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Pipeline   | U         | Not         | Divestiture of  |
|        | transportation | nilateral | publicly    | either Texaco   |
|        | of light       | /         | available   | pipeline        |
|        | products into  | Coordin   |             | interest or     |
|        | Colorado       | ated[^38] |             | Getty refining  |
|        |                |           |             | interests       |
+--------+----------------+-----------+-------------+-----------------+
|        | 4\. Wholesale  | Co        | Not         | Divestiture of  |
|        | distribution   | ordinated | publicly    | Getty marketing |
|        | of gasoline    |           | available   | assets in the   |
|        | and middle     |           |             | Northeast, and  |
|        | distillates in |           |             | a Texaco        |
|        | various parts  |           |             | terminal in     |
|        | of the         |           |             | Maryland        |
|        | Northeast      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 5\. Sale and   | Unilat    | Not         | Texaco required |
|        | transport of   | eral[^39] | publicly    | to supply crude |
|        | heavy crude    |           | available   | oil and crude   |
|        | oil in         |           |             | pipeline access |
|        | California     |           |             | to former Getty |
|        |                |           |             |                 |
|        |                |           |             | customers under |
|        |                |           |             | specified terms |
+--------+----------------+-----------+-------------+-----------------+
| *      | 1\. Wholesale  | Co        | Not         | Gulf withdrew   |
| *Gulf/ | distribution   | ordinated | publicly    | its tender      |
| Cities | of gasoline in |           | available   | offer after the |
| Se     | various areas  |           |             | FTC obtained a  |
| rvice* | in the East    |           |             | temporary       |
| *[^40] | and Southeast  |           |             | restraining     |
|        |                |           |             | order prior to  |
| **(1   |                |           |             | a preliminary   |
| 982)** |                |           |             | injunction      |
|        |                |           |             | hearing         |
+--------+----------------+-----------+-------------+-----------------+
|        | 2\.            | Co        | Not         | As above        |
|        | Manufacture    | ordinated | publicly    |                 |
|        | and sale of    |           | available   |                 |
|        | kerosene jet   |           |             |                 |
|        | fuel in PADDs  |           |             |                 |
|        | I and III and  |           |             |                 |
|        | parts thereof  |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
|        | 3\. Pipeline   | Unilat    | Not         | As above        |
|        | transportation | eral[^41] | publicly    |                 |
|        | of refined     |           | available   |                 |
|        | products into  |           |             |                 |
|        | the Mid        |           |             |                 |
|        | Atlantic and   |           |             |                 |
|        | Northeast      |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| **Mo   | Wholesale      | U         | Not         | FTC sought      |
| bil/** | marketing of   | nilateral | publicly    | preliminary     |
|        | gasoline and   | /         | ava         | injunction, but |
| **Mar  | middle         | Coordin   | ilable[^44] | before hearings |
| athon* | distillates in | ated[^43] |             | were held Mobil |
| *[^42] | various        |           |             | withdrew tender |
|        | markets in the |           |             | offer as a      |
| **(1   | Great Lakes    |           |             | result of       |
| 981)** | area           |           |             | injunction in a |
|        |                |           |             | separate,       |
|        |                |           |             | private         |
|        |                |           |             | litigation      |
+--------+----------------+-----------+-------------+-----------------+
| S      |                |           |             |                 |
| ource: |                |           |             |                 |
| Co     |                |           |             |                 |
| mpiled |                |           |             |                 |
| from   |                |           |             |                 |
| FTC    |                |           |             |                 |
| compl  |                |           |             |                 |
| aints, |                |           |             |                 |
| o      |                |           |             |                 |
| rders, |                |           |             |                 |
| and    |                |           |             |                 |
| an     |                |           |             |                 |
| alyses |                |           |             |                 |
| to aid |                |           |             |                 |
| public |                |           |             |                 |
| co     |                |           |             |                 |
| mment. |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+
| \*     |                |           |             |                 |
| Note:  |                |           |             |                 |
| This   |                |           |             |                 |
| table  |                |           |             |                 |
| lists  |                |           |             |                 |
| enfor  |                |           |             |                 |
| cement |                |           |             |                 |
| a      |                |           |             |                 |
| ctions |                |           |             |                 |
| in     |                |           |             |                 |
| r      |                |           |             |                 |
| everse |                |           |             |                 |
| c      |                |           |             |                 |
| hronol |                |           |             |                 |
| ogical |                |           |             |                 |
| order, |                |           |             |                 |
| beg    |                |           |             |                 |
| inning |                |           |             |                 |
| with   |                |           |             |                 |
| the    |                |           |             |                 |
| FTC's  |                |           |             |                 |
| most   |                |           |             |                 |
| recent |                |           |             |                 |
| cha    |                |           |             |                 |
| llenge |                |           |             |                 |
| of a   |                |           |             |                 |
| major  |                |           |             |                 |
| pet    |                |           |             |                 |
| roleum |                |           |             |                 |
| merger |                |           |             |                 |
| in     |                |           |             |                 |
| 2004.  |                |           |             |                 |
| The    |                |           |             |                 |
| year   |                |           |             |                 |
| cited  |                |           |             |                 |
| is the |                |           |             |                 |
| year   |                |           |             |                 |
| in     |                |           |             |                 |
| which  |                |           |             |                 |
| the    |                |           |             |                 |
| merger |                |           |             |                 |
| was    |                |           |             |                 |
| pr     |                |           |             |                 |
| oposed |                |           |             |                 |
| and    |                |           |             |                 |
| most   |                |           |             |                 |
| of the |                |           |             |                 |
| FTC    |                |           |             |                 |
| ac     |                |           |             |                 |
| tivity |                |           |             |                 |
| occ    |                |           |             |                 |
| urred; |                |           |             |                 |
| in     |                |           |             |                 |
| some   |                |           |             |                 |
| cases, |                |           |             |                 |
| a      |                |           |             |                 |
| c      |                |           |             |                 |
| onsent |                |           |             |                 |
| order  |                |           |             |                 |
| was    |                |           |             |                 |
| not    |                |           |             |                 |
| final  |                |           |             |                 |
| until  |                |           |             |                 |
| a      |                |           |             |                 |
| later  |                |           |             |                 |
| ca     |                |           |             |                 |
| lendar |                |           |             |                 |
| year.  |                |           |             |                 |
|        |                |           |             |                 |
| Number |                |           |             |                 |
| range  |                |           |             |                 |
| C      |                |           |             |                 |
| HAPTER |                |           |             |                 |
+--------+----------------+-----------+-------------+-----------------+

[^1]: Enterprise/GulfTerra (2004), Complaint ¶¶ 9-15, Analysis of
    Proposed Consent Order to Aid Public Comment.

[^2]: Magellan/Shell (2004), Complaint ¶¶ 8-15, Analysis of Proposed
    Consent Order to Aid Public Comment.

[^3]: Shell/Pennzoil-Quaker State (2002), Complaint ¶¶ 8-16, Analysis of
    Proposed Consent Order to Aid Public Comment.

[^4]: Phillips/Conoco (2002), Complaint ¶¶ 8-135; Analysis of Proposed
    Consent Order to Aid Public Comment.

[^5]: Phillips owned 30% of Duke Energy Field Services (DEFS); DEFS and
    Conoco were the only gatherers in the Permian Basin. Phillips/Conoco
    (2002), Complaint ¶¶ 69-71.

[^6]: Phillips owned 30% of DEFS, with representation on its Board of
    Directors; DEFS held an interest in two of the four fractionators in
    the market. Conoco partially owned and operated a third, Gulf Coast
    Fractionators. The merger would have given the combined firm veto
    power over significant expansion projects and might have led to the
    sharing of competitively sensitive information. Phillips/Conoco
    (2002), Complaint ¶¶ 76-79.

[^7]: Valero/UDS (2001), Complaint ¶¶ 13-21; Analysis of Proposed
    Consent Order to Aid Public Comment.

[^8]: Chevron/Texaco (2001), Complaint ¶¶ 12-57; Analysis of Proposed
    Consent Order to Aid Public Comment.

[^9]: Chevron held a 17% interest in Explorer Pipeline, and Texaco and
    Equilon (Texaco's joint venture with Shell) together held 36%.
    Explorer is the largest pipeline supplying bulk Phase II
    Reformulated Gasoline (RFG II) to St. Louis; at the time, Equilon
    also had a long-term contract that gave it control of much of the
    output of a local St. Louis area refinery. Chevron/Texaco (2001),
    Analysis of Proposed Consent Order to Aid Public Comment.

[^10]: Equilon owned 100% of Delta, and Chevron owned 50% of Cypress;
    these two pipelines were the only means of transporting crude from
    the Eastern Gulf of Mexico to on-shore terminals. Chevron/Texaco
    (2001), Analysis of Proposed Consent Order to Aid Public Comment.

[^11]: Texaco owned 33% of the Discovery Gas Transmission System;
    Chevron and its affiliate Dynegy together owned 77% of the Venice
    Gathering System, one of only two other pipeline systems for
    transporting natural gas from this area. Chevron/Texaco (2001),
    Analysis of Proposed Consent Order to Aid Public Comment.

[^12]: Chevron owned 26% of Dynegy, which held large interests in two of
    the four fractionators in the market, and had representation on
    Dynegy's Board of Directors; Texaco held a minority interest in a
    third. The merger might have led to the sharing of competitively
    sensitive information and might also have permitted the merged firm
    to exercise unilateral market power. Chevron/Texaco (2001), Analysis
    of Proposed Consent Order to Aid Public Comment.

[^13]: BP/ARCO (2000), Complaint ¶¶ 10-66; Analysis of Proposed Consent
    Order to Aid Public Comment.

[^14]: BP had a 44% share of ANS crude oil production at that time,
    while ARCO had a 30% share, implying that their contribution to the
    HHI was 2,836. Their contribution to the post-merger HHI would have
    been 5476. BP/ARCO (2000), Analysis of Proposed Consent Order to Aid
    Public Comment.

[^15]: The ARCO Alaska assets divested included crude oil exploration
    and production assets, 22% interest in TAPS, and specialized tanker
    ships. BP/ARCO (2000), Analysis of Proposed Consent Order to Aid
    Public Comment.

[^16]: BP and ARCO together won 60% of the Alaska state lease auctions
    during the 1990s, while the top four bidders won 75%. BP/ARCO
    (2000), Analysis of Proposed Consent Order to Aid Public Comment.

[^17]: BP (50%) and ARCO (22%) both held interests in TAPS. Their
    contribution to the HHI would have been 2,984 pre-merger and 5,184
    post-merger. There were five other owners of TAPS; Exxon held 20%
    (*see* note 20 *infra*), and the four others' shares are not
    publicly available; including Exxon and assigning the four other
    firms equal shares yields a lower bound for the HHI of 3,400
    pre-merger or of 5,600 post-merger. BP/ARCO (2000), Analysis of
    Proposed Consent Order to Aid Public Comment.

[^18]: The FTC alleged that BP Amoco, ARCO, and Exxon Mobil were the
    only three companies that held "sufficiently large volumes of gas
    reserves to have the potential to develop those reserves for
    significant commercial use." BP/ARCO (2000), Analysis of Proposed
    Consent Order to Aid Public Comment.

[^19]: BP and ARCO together accounted for 43% of storage capacity, 49%
    of pipeline capacity, and 95% of trading services at Cushing.
    BP/ARCO (2000), Analysis of Proposed Consent Order to Aid Public
    Comment.

[^20]: Exxon/Mobil (1999), Complaint ¶¶ 8-54; Analysis of Proposed
    Consent Order to Aid Public Comment.

[^21]: Exxon owned 49% of Plantation Pipeline and Mobil owned 11% of
    Colonial Pipeline. Exxon/Mobil (1999), Complaint ¶ 13.

[^22]: Exxon and Mobil owned 20% and 3%, respectively, of the
    Trans-Alaska Pipeline System (TAPS), the only means of transporting
    Alaskan North Slope (ANS) crude oil to the port facilities at
    Valdez, AK. Exxon/Mobil (1999), Complaint ¶ 14.

[^23]: Exxon and Mobil together accounted for 75% of worldwide sales,
    and 90% of worldwide sales to commercial airlines. Exxon/Mobil
    (1999), Analysis of Proposed Consent Order to Aid Public Comment.

[^24]: BP/Amoco (1998), Complaint ¶¶ 8-21; Analysis of Proposed Consent
    Order to Aid Public Comment.

[^25]: Shell/Texaco (1997), Complaint ¶¶ 10-37; Analysis of Proposed
    Consent Order to Aid Public Comment.

[^26]: The Texaco heated pipeline was the only pipeline supplying
    undiluted heavy crude oil to the San Francisco Bay area, where Shell
    and a competitor refined asphalt. Shell/Texaco (1997), Complaint ¶
    15.

[^27]: Shell owned 24% of Plantation Pipeline and Texaco owned 14% of
    Colonial Pipeline. Shell/Texaco (1997), Complaint ¶ 32.

[^28]: Sun/Atlantic (1988), Complaint and Order.

[^29]: PRI/Shell (1987), Complaint ¶¶ 6-12.

[^30]: Conoco/Asamera (1986), Complaint that the Commission voted to
    pursue.

[^31]: The Preliminary Injunction Complaint in Conoco/Asamera alleged
    that the merger would create a dominant firm in the relevant
    markets. Conoco/Asamera (1986), Complaint that the Commission voted
    to pursue ¶ 15.

[^32]: Chevron/Gulf (1984), Complaint ¶¶ 15-41.

[^33]: Gulf owned the largest share, 16.78%, of Colonial Pipeline, while
    Chevron owned the second largest share, 27.13%, of Plantation
    Pipeline, Colonial's only direct competitor. Chevron/Gulf (1984),
    Complaint ¶¶ 25-26.

[^34]: Chevron owned a proprietary pipeline running from the West
    Texas/New Mexico producing area to El Paso, while Gulf owned the
    largest share of the West Texas Gulf Pipeline running from the
    producing area to the Gulf Coast and the MidValley Pipeline at
    Longview, TX. Chevron/Gulf (1984), Complaint ¶¶ 38-39.

[^35]: Texaco/Getty (1984), Complaint ¶¶ 15-59.

[^36]: At this time pipeline transport from the Gulf Coast was not
    considered to be in the relevant market for "the manufacture of
    refined light products." Texaco/Getty (1984), Complaint ¶¶ 19-21.

[^37]: Texaco owned 14.3% of Colonial Pipeline, "the dominant means of
    transporting additional refined light products into the Northeast
    region, supplying approximately 36.9 percent of total consumption .
    . . in 1982." Getty owned 100% of the Getty Eastern Products
    Pipeline. Texaco/Getty (1984), Complaint ¶¶ 33-35.

[^38]: Texaco owned 40% of the Wyco Pipeline, one of four pipelines
    delivering refined product to Colorado, while Getty owned 50% of the
    Chase Pipeline. Texaco/Getty (1984), Complaint ¶¶ 29-31.

[^39]: Both Texaco and Getty owned refineries and proprietary pipeline
    systems in the relevant market. While Texaco produced less heavy
    crude oil than it could refine, Getty produced more than it could
    refine on the West Coast. The Complaint alleged that the merger was
    "likely to increase Texaco's incentives and ability to deny
    non-integrated refiners heavy crude oil and access to proprietary
    pipelines." Texaco/Getty (1984), Complaint ¶¶ 50-57.

[^40]: Gulf/Cities Service (1982), Complaint for a Temporary Restraining
    Order and Preliminary Injunction Pursuant to Section 13(b) of the
    FTC Act ("Gulf/Cities Service Complaint"), ¶¶ 19-22. 1982 Merger
    Report.

[^41]: Gulf and Cities Service owned 16.78% and 13.98%, respectively, of
    Colonial Pipeline. Since the merged firm's share would exceed 25%,
    it would be able to unilaterally block future pipeline expansion
    under the pipeline's rules. Gulf/Cities Service Complaint ¶ 19.

[^42]: Mobil/Marathon (1981), Memorandum of Points and Authorities in
    Support of the Federal Trade Commission's Complaint for Temporary
    Restraining Order and for Preliminary Injunction ("Mobil/Marathon
    Complaint Memorandum") 6, 26-27. 1982 Merger Report.

[^43]: While the theories of anticompetitive effects were not always
    clearly articulated in the earliest petroleum merger investigations,
    a careful reading of the complaint and accompanying materials
    suggests the type of effects the investigators had in mind. The
    classifications of theories for these early cases listed in this
    table are therefore based in part on the authors' interpretation of
    the complaints, court documents, and staff case memoranda. In the
    case of Mobil and Marathon, the merger would "enhance Mobil's market
    power" in the relevant markets by "doubling and tripling its share,"
    (Mobil/Marathon Complaint Memorandum 26, 29) suggesting a likelihood
    of unilateral anticompetitive effects, and that it would increase
    concentration in already concentrated markets and remove a firm that
    had tended to act as a maverick, pricing aggressively and selling
    large volumes to independent retailers (Mobil/Marathon Complaint
    Memorandum 29-30) -- pointing toward a theory of coordinated
    effects.

[^44]: The Complaint alleged that the firms' combined shares of
    wholesale gasoline sales exceeded 24.5% in eighteen SMSAs, reaching
    44.0% in one city and 49.4% in another. While HHIs were not
    calculated at that time, the parties' contribution to HHI (that is,
    the sum of their squared shares) can be calculated from the market
    share data given (Mobil/Marathon Complaint Memorandum 27, Table 1).
    The parties' pre-merger contribution to HHI ranged between 500 and
    1,000 for ten of the eighteen SMSAs and exceeded 1,000 for another
    three.