Commission européenne, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229 -91111. Fax: +32 229 -64301. E -mail: COMP -MERG ER-REGISTRY@ec.europa.eu . 
 EUROPEAN COMMISSION  
 
 
 
 
 
Brussels, 17.12.2018  
C(2018 ) 9046 final  
  
 
 
To the notifying party  
 
 
Subject : Case M.9152 – BC Partners / United Group  
Commission decision pursuant to Article 6(1)(b) of Council 
Regulation No  139/20041 and Article 57 of the Agreement on the 
European Economic Area2 
Dear  Sir, 
(1) On 16 November 2018, the European Commission received notification of a 
proposed concentration pursuant to Article 4 of the Merger Regulation by which 
BC European Capital X ("BCEC X"), ultimately controlled by BC Partners LLP 
("BC Partners", United K ingdom), acquires within the meaning of Article 3(1)(b) 
of the Merger Regulation sole control of United Group BV ("United Group", the 
Netherlands), by way of purchase of shares (the "Transaction").i BC Partners is 
referred to as the "Notifying Party". BC P artners and United Group are 
collectively referred to as "Parties".  
1. THE PARTIES  
(2) BC Partners is a private equity firm, specialising in buyouts and acquisitions 
financing in Europe and the United States. BCEC X is one of the funds advised 
                                                 
1  OJ L 24, 29.1.2004, p. 1 (the 'Merger Regulation'). With effect from 1 December 2009,  the Treaty on 
the Functioning of the European Union ('TFEU') has introduced certain changes, such as the 
replacement of 'Community' by 'U nion' and 'common market' by 'internal market'. The terminology of 
the TFEU will be used throughout this decision.  
2  OJ L 1, 3.1.1994, p. 3 (the 'EEA Agreement').  In the published version of this decision, some 
information has been omitted pursuant to Article 
17(2) of Council Regulation (EC) No 139/2004  
concerning non -disclosure of business secrets and 
other confidential information. The omissions are 
shown thus […]. Where possible the information 
omitted has been replaced by ranges of figures or a 
general description.  PUBLIC VERSION  
2 by BC Partners. BCE C X holds a controlling interest in […] portfolio companies, 
among which Intelsat SA ("Intelsat"), which is active in the provision of global 
voice, data, video and wholesale Internet communications services via satellites.  
(3) United Group is active in the pr ovision of telecommunications and media services 
in South East Europe. In the EEA, United Group is active primarily in Slovenia 
and, to a lesser extent, Croatia.  
2. THE OPERATION  
(4) The Transaction relates to the acquisition of sole control within the meaning of  
Article 3(1)(b) of the EUMR of United Group by BC Partners.  
(5) The Transaction will be implemented in accordance with a share purchase 
agreement of 27 September 2018 (the "SPA") between Adria Luxco as seller and 
BidCo BV ("BidCo") as buyer. BidCo is a newly set up special purpose vehicle 
ultimately controlled by BC Partners. Pursuant to the SPA, BidCo will acquire all 
outstanding shares in Adria TopCo BV ("Adria TopCo"), which in turns holds 
100 % of the shares of United Group.  
(6) As a result of the Transaction,  BC Partners will have indirect sole control over 
United Group. In fact, BC Partners will indirectly hold […]% of the shares in 
Adria TopCo and, pursuant to a separate Equity Wrapper, will have the ability to 
appoint a majority of the board. The remaining shareholders of Adria TopCo will 
not have negative control over it, as none will be able to veto any strategic 
decision.  
3. EU DIMENSION  
(7) The undertakings concerned have a combined aggregate world -wide turnover of 
more than EUR 5 000 millionii (BC Partners: EUR  […] million; United Group: 
EUR […] million). Each of them has an EU -wide turnover in excess of EUR 
250 million (BC Partners: EUR […] million; United Group: EUR […] million), 
but they do not achieve more than two -thirds of their aggregate EU -wide turnover 
within one and the same Member State.  
(8) The Transaction therefore has an EU dimension pursuant to Article 1(2) of the 
Merger Regulation.  
4. RELEVANT MARKETS  
4.1. Provision of Satellite Transponder Capacity  
(9) Satellite transmissions are used for the distribution of TV signals, telephony, and 
other communications. For the provision of their satellite TV services, 
broadcasters and retail TV distributors like United Group utilise satellite 
transponder services offered by companies like Intelsat: the television content is 
generally fed into an uplink antenna, which in turn is beamed up to a 
geostationary satellite; the signal is then beamed from the satellite down into the 
receiving customers’ antennae.  
3 4.1.1.  Product market definition  
(10) The Notifying Party submits that the relevant market would be the market for the 
supply of satellite transponder capacity for the provision of direct -to-home 
(“DTH”) satellite TV  services.  
(11) In its past decisional practice, the Commission identified a possible market for the 
provision of satellite trans ponder capacity used for distribution of TV signals, 
telephony and other communication services3. The Commission considered 
whether such market may include the provision of uplink services (transmission 
to the satellite), encoding, and various other techni cal services.  
(12) The information gathered during the market investigation indicated that, although 
video content is the main application of s atellite transponder capacity , such 
capacity is also used for a broad variety of other services including notably 
gove rnment services, private networks, mobile services, aeronautical and 
maritime services.4 
(13) In light of the above, the Commission considers that there is no reason to depart 
from its previous approach, and that the relevant product market is the market for 
the supply of satellite transponder capacity, irrespective of the services they are 
provided for. However, the precise product market definition can be left open, as 
this would not change the outcome of the competitive assessment in this case.  
4.1.2.  Geographic mar ket definition  
(14) The Notifying Party submits that the geographic scope of the market coincides 
with, at least, the footprint of a given satellite. Therefore, the Notifying Party 
submits that the scope of the market is at least Central and Eastern Europe, but  
could be wider (i.e., the whole Europe).  
(15) In the past, the Commission concluded that the geographic scope of the market 
for satellite transponder capacity only  encompassed the Nordic countries, and not 
the EEA as a whole.5 
(16) The information gathered during t he market investigation confirmed the regional 
scope of the supply  of satellite transponder capacity. Indeed, the satellites 
covering Slovenia and Croatia have a supranational footprint, which also covers 
neighbouring states of Central and Eastern Europe. Their position is stronger or 
weaker as per territory, depending on the strength of the beam and on the number 
of dishes pointed towards them.6 
(17) In any event, the Commission considers that, for the purpose of this decision, the 
relevant geographic market fo r the supply of transponder capacity can be left 
                                                 
3  Commission decision of 13 October 1999 in case M.1439 Telia / Telenor , recital 266.  
4  Replies to the Questionnaire to Intelsat's competitors, questions 2 and 3.  
5  Commission decision of 13 October 1999 in case M.1439 Telia / Telenor , recital 284.  
6  Replies to the Questionnaire to Intelsat's competitors, question 1; Replies to the Questionna ire to 
United Group's competitors, question 1a and 1b.  
4 open (i.e., covering Central and Eastern Europe, or more broadly, encompassing 
Western, Central and Eastern Europe), as this would not change the outcome of 
the competitive assessment in this case.   
4.2. Retail D istribution of TV services  
4.2.1.  Product market definition  
(18) The Notifying Party submits that the relevant market would be the market for the 
retail provision of Pay TV services encompassing (i) all distribution technologies, 
(ii) linear and non -linear content and  (iii) basic and premium Pay TV.  It further 
submits that the precise definition of the product market could be left open, as the 
Transaction would not give rise to competition concerns irrespective of the 
market definition.  
(19) In its past decisional practice,  the Commission identified separate product 
markets for the retail provision of (i) FTA and (ii) Pay TV services.7 The 
Commission also considered whether retail Pay TV could be segmented further 
according to: (i) linear vs non -linear retail Pay TV services8; (ii) according to 
distribution technologies (e.g., cable, Over -The-Top, DTH satellite, Internet 
Protocol television “IPTV”, or terrestrial)9; and (iii) premium vs basic retail Pay 
TV services.10 In recent cases, the Commission left open the product marke t 
definition with regard to each of these potential sub -segments.11 
(20) The results of the market investigation did not provide reasons to depart from the 
Commission’s previous approach in this case.12 The Commission therefore 
considers that, for the purpose of the present decision, the relevant product market 
is the market for the retail distribution of Pay TV services, and that the question 
whether it should be further segmented can be left open, as this would not change 
the outcome of the competitive assessmen t in this case.  
4.2.2.  Geographic market definition  
(21) The Notifying Party submits that the precise definition of the geographic 
(i.e., national or broader) markets could be left open as the Transaction would not 
give rise to competition concerns irrespective of the  market definition.  
(22) In its past decisional practice, the Commission considered, but ultimately left 
open, that the geographic market for the retail provision of TV services (and its 
                                                 
7  Commission decision of 21 December 2010 in case M.5932 News Corp/BSkyB , recital 99.  
8  Commission decision of 7 April 2017 in case M.8354 Fox/Sky, recitals 98 and 99 . 
9  Commission decision of 21 December 2010 in case M.5932 News Corp/BSkyB , recital 103.  
10  Commission decision of 24 February 2015 in case M.7194 Liberty Global/Corelio/W&W/De Vijver 
Media , recital 119.  
11  See i.a. Commission decision of 6 February 2018 in case M.8665 Discovery/Scripps , recitals 31 
and 32. 
12  Replies to the Questionnaire to United Group's competitors, question 2.  
5 possible sub -divisions) was either national or, at most, covering linguist ically 
homogeneous areas.13 
(23) The results of the market investigation did not provide reasons to depart from the 
Commission’s previous approach in this case.14 
(24) In particular, one respondent to the market investigation indicated that the 
geographic scope of the  market could cover the Serbo -Croatian linguistic area, 
which encompasses Bosnia and Herzegovina, Croatia, FYROM, Montenegro, 
Serbia and part of Slovenia.  
(25) On the basis of the above, the Commission considers that, for the purpose of the 
present decision, th e relevant geographic market for the retail distribution of Pay 
TV services is national or, at most, covering linguistically homogeneous areas. 
The precise geographic market definition can be left open, as the Transaction 
would not give rise to competition  concerns under any alternative market 
definition.  
5. COMPETITIVE ASSESSMEN T 
5.1. Affected markets  
(26) Intelsat and United Group are active at different levels of the satellite TV value 
chain: (i) Intelsat is a global provider of voice, data, video, and wholesale Internet 
communications services via satellite. Of particular relevance for this case is 
Intels at’s provision of satellite capacity for DTH services. (ii) United Group 
provides telecommunications and media services. In Slovenia, and to a lesser 
extent in Croatia, United Group is active as a retailer of Pay TV services, a 
wholesale distributor of Pay  TV channels, and a producer of TV content. For its 
provision of retail TV services, United Group utilises both cable and satellite 
DTH technologies. Additionally, United Group is active as a provider of retail 
fixed Internet access, fixed telephony, and m obile telecommunications services.  
5.1.1.  Horizontal overlaps  
(27) The Transaction does not lead to any horizontal overlaps between the business 
activities of the portfolio companies of BC Partners and the business activities of 
United Group.  
5.1.2.  Vertical relationships  
(28) The Transaction gives rise to a possible vertical relationship between (i) Intelsat’s 
satellite transponder capacity’s activities and (ii) United Group’s retail provision 
of TV distribution services in Slovenia and in Croatia.  
                                                 
13  Commission decision of 21 December 2010 in case M.5932 News Corp/BSkyB , reci tal 110.  
14  Replies to the Questionnaire to United Group's competitors, question 2.  
6 5.1.2.1.  Vertical relationships in Slo venia  
(29) The Transaction gives rise to vertically affected markets, given that Intelsat is 
active in the upstream provision of satellite transponder capacity, and that United 
Group has a market share in excess of 30  % in the downstream retail market for 
the d istribution of Pay TV services.  
(30) With regard to the upstream market for the provision of satellite transponder 
capacity, Intelsat has a market share of [0-5]% for  2017 in terms of value in 
Cent ral and Eastern Europe, and of [0 -5]% if considering a broader g eographic 
market encompassing Western, Central and Eastern Europe.15 
(31) With regard to the downstream market for the retail provision of Pay TV services 
in Slovenia, United Group has a share of [30-40]% for 2017 in terms of volume.16 
If considering possible sub -markets according to the distribution technology, 
United Group has a market share of [90-100]% of DTH satellite subscribers for 
Q2 2018.17 Other possible sub -markets, including other distribution technologies, 
and linear/non -linear services, are not affect ed by the Transaction.18 
(32) For the provision of its retail DTH satellite TV services in Slovenia, United 
Group currently utilises Eutelsat’s satellite transponder capacity services.  
5.1.2.2.  Vertical relationships in Croatia  
(33) The Transaction does not give rise to verti cally affected markets as regards 
Croatia, because United Group has a de minimis  presence in the downstream 
market for the retail provision of Pay TV services in Croatia (below 5% for 2016 
in terms of value)19 and Intelsat has a de minimis  presence in the u pstream market 
for the provision of satellite transponder capacity (below 5% for 2017 in terms of 
                                                 
15  Form CO, tables 2  and 3.  
16  Form CO, table 5.  
17  Form CO, table 6.  
18  Other distribution technologies, such as cable TV or IPTV, would not be impacted by the merged 
entity’s hypothetical customer or input foreclosure strategies. This is because IPTV (and generally 
cable) does not rely on satellite technology for the provision of TV services. In any case, as 
explained below, no United Group’s competitor in Slovenia relies on Intelsat’s satellite services. 
The Notifying Party submits it was not able to provide market shares for the possible sub -markets 
for linear and non -linear services. However, the Commission considers that the distinction between 
linear and non -linear ser vices is not relevant in this case, since non -linear services generally cannot 
be provided via DTH satellite technology, and non -linear services represent a small share of the 
total market (only 8% of TV customers subscribe to Video -on-Demand “VOD” service s in 
Slovenia).  
19  Form CO, paragraph 66 and footnote 31. The Notifying Party explains that United Group is 
mainly  active in Croatia as a TV broadcaster (Nova TV). United Group is active at retail level 
via Nova TV's Subscription VOD ("SVOD") service "OY O", which grossed approximately EUR  
[…] in 2016. The Commission considers that no vertically affected markets will arise, 
irrespective of the market definition, because SVOD cannot be provided via satellite DTH, and 
the vertical relationship between Intels at and United Group would be purely hypothetical.       
7 value for both geographic markets encompassing the whole Europe, or Central 
and Eastern Europe only).20 
(34) In any case, the Transaction will not give rise to any anticompetitive effects in the 
Croatian market, for the following reasons: United Group’s retail activities in 
Croatia are limited to non -linear VOD services, which do not rely on satellite 
DTH technology; furthermore, Intelsat […] satellite transponder ca pacity to any 
of United Group’s competitors in Croatia.21   
5.1.2.3.  Conclusion on vertical relationships  
(35) In the following sections, the Commission will analyse whether the Transaction is 
likely to produce anti -competitive effects in Slovenia, as a result of input 
foreclosure or customer foreclosure.22 
5.2. Input foreclosure  
5.2.1. The Notifying Party's view  
(36) The Notifying Party submits that it is unlikely that the merged entity will 
foreclose United Group’s competing providers of Pay TV services in Slovenia by 
refusing to supply Intelsat’s satellite transponder capacity services, or offering 
them at worse conditions.  
(37) The Notifying Party claims that Intelsat does not have the ability to foreclose 
United Group’s competitors, because Intelsat lacks market power on the upstream 
market for satellite transponder capacity, and because alternative providers will 
be active post -transaction in Central and Eastern Europe, namely RSCC, Eutelsat, 
and Gazprom23. Moreover, the Notifying Party affirms that there would not be 
any competitor to foreclose, as competing providers of Pay TV in Slovenia do not 
rely on satellite technology.24 
(38) In addition, the Notifying Party submits that Intelsat would not have the incentive 
to engage in full or partial input foreclosure either, because I ntelsat's only 
                                                 
20  See recital  (30). 
21  See reply to Request for Information No. 1 of 19 October 2018, question 11.  
22  The Commission considers that the input and customer foreclosure analysis for the Slovenian 
market equally applies to the possible market comprising the retail TV provision of Serbo -Croatian 
language content (i.e., encompassing Members States like Croatia and parts of Slovenia, as well as 
non-EU countries like Bosnia and Herzegovina, FYROM, Montenegro and Serbia). As explained at 
paragraph (41) below, Intelsat canno t be considered an important provider of satellite transponder 
capacity, either in Central and Eastern Europe or in the whole Europe. Likewise, United Group as a 
whole cannot be considered an important customer for satellite transponder capacity, as eviden ced 
by United Group’s spend at paragraph  (52). Therefore, the addition of United Group’s South East 
European activities would not make any substantial difference f or the Commission’s assessment.  
23  Form CO, table 3.  
24  Form CO, paragraph 111.  
8 purchaser of satellite transponder capacity in Slovenia is […], a teleport and 
satellite services company that is not a competitor of United Group in the EEA.25 
5.2.2. The Commission's assessment  
(39) According to the Non -Horizontal Merger Guideli nes, input foreclosure occurs 
where a merger is likely to raise the costs of downstream rivals by restricting their 
access to an important input.26 
(40) The Commission considers that Intelsat has no ability to foreclose United Group’s 
competing providers of Pay TV services in Slovenia by refusing to supply 
satellite transponder capacity or by offering them at worse conditions.  
(41) Intelsat has a market share comprised between [0-5]% and [0-5]% for  2017 in 
terms of value, depending on the geographic scope of the upstr eam market.27 The 
Commission considers that, given this low market share, Intelsat has no market 
power in the upstream market for the provision of satellite transponder capacity.  
(42) In addition to its limited market share in the provision of satellite transpo nder 
capacity, Intelsat faces strong competitors in Central and Eastern Europe, such as 
RSCC and Eutelsat with market shares of respectively [20-30]% and [10-20]% 
for 2017 in terms of value.28 
(43) Moreover, the information gathered during the market investigati on confirmed 
that Intelsat is not an indispensable provider of satellite transponder capacity in 
Slovenia, either for the distribution of TV services or the supply of 
telecommunications services.29  
(44) For completeness, during the course of the investigation, one respondent 
submitted that, post -Transaction, Intelsat would have the incentive to engage in 
input foreclosure, by discriminating against United Group's competitors in South 
East Europe. This would raise barriers to competitor's expansion and further 
entrench United Group's dominance.30 However, for the above -mentioned 
reasons —and in particular the minimal market presence of Intelsat, the 
Commission considers that Intelsat has no ability to engage in input foreclosure 
with regard to its provision of satel lite transponder capacity services.  
                                                 
25  Form CO, paragraphs 102 and 112.  
26  Non-Horizontal Merger Guidelines, paragraph 34.  
27  See recital  (30). 
28  Form CO, table 3.  
29  Replies to the Questionnaire to United Group's competitors, question 1.  
30  The Commission also received certain negative comments from non -EEA market players. The 
complainants allege that United Group emplo ys various means in order to evade service of process 
by mail, and thus execution of final and binding decisions of a non -EEA National Competition 
Authority. The complainants ask the Commission to impose certain conditions as part of its final 
decision, in cluding disclosure of one of United Group’s entities’ address, as well as proof of 
compliance with the above non -EEA decisions. The Commission notes that the complaints address 
non merger -specific issues. Therefore, the Commission will not address them fur ther in the present 
decision.  
9 (45) In light of the above, the Commission considers that the Transaction does not give 
rise to serious doubts as to its compatibility with the internal market in relation to 
input foreclosure with regard to the markets for the provision of satellite 
transponder capacity and for the retail distribution of Pay TV services in 
Slovenia, or in the Serbo -Croatian language area.  
5.3. Customer foreclosure  
5.3.1. The Notifying Party's view  
(46) The Notifying Party submits that it is unlik ely that the merged entity will 
foreclose Intelsat’s competitors of satellite transponder capacity, by switching 
United Group's entire spend on satellite capacity to Intelsat.  
(47) The merged entity would not have the ability to engage in customer foreclosure, 
because United Group’s activities do not represent a sufficient customer base. 
Indeed, the Notifying Party submits that providers of satellite transponder 
capacity have a customer base that goes beyond Slovenian customers.31 
(48) In addition, the Notifying Party  submits that the merged entity would not have the 
incentive to engage in customer foreclosure either, because switching United 
Group’s procurement of satellite transponder capacity from Eutelsat to Intelsat 
would be costly for United Group and disruptive for its customers. In fact, United 
Group’s customers would lose access to several channels and incur antennae 
settings costs, which would entail an increase in churn.32 Likewise, United Group 
would have to incur costs for the construction of a new uplink st ation, and for the 
development of new software.33 
5.3.2. The Commission's assessment  
(49) For customer foreclosure to be a concern, it must be the case that the vertical 
merger involves a company that is an important customer with a significant 
degree of market power in the downstream market.34 
(50) During the course of the investigation, one respondent submitted that, because of 
the Transaction, there could be a risk that the merged entity will prevent 
competing satellite services providers from supplying transponder capacity to the 
leading provider of DTH services in South East Europe.35 
                                                 
31  Form CO, paragraph 113.  
32  Form CO, paragraph 115.  
33  Form CO, paragraph 119.  
34  Non-Horizontal Merger Guidelines, paragraph 61.  
35  The same respondent added, without any substantiation, that the Transaction might incentivise 
United Group and Intelsat to access commercially sensitive information of rivals, giving them a 
significant competitive advantage. In particular, it submitted that United Group may be incentivised 
to disclose to Intelsat details of its current commercial relationship with Eutelsat. However, United 
Group confirmed that its current procurement agreements with Eutelsat contain confidentiality 
provisions, prohibiting the disclosure of any confidential information to third parties. Finally, 
Eutelsat itself did not raise such a concern during the market investigation. See, reply of Eutelsat to 
10 (51) The Commission considers that United Group has no ability to foreclose Intelsat’s 
competitors, because United Group cannot be considered an indispensable 
customer for satellite transpo nder capacity, irrespective of the geographic market 
definition.  
(52) While United Group has a share of [30-40]% for 2017 in terms of volume for the 
retail provision of Pay TV services in Slovenia, and a share of [90-100]% in the 
retail provision of Pay TV serv ices via DTH satellite36, the total spend on satellite 
transponder capacity of the entire group represents a negligible share of the 
upstream market's value ( [0-5]% for Central and Eastern Europe in 201737, or [0-
5]% for Western, Central and Eastern Europe)38.  
(53) Moreover, the Commission observes that United Group cannot be considered an 
indispensable customer of Eutelsat (United Group’s current provider of satellite 
transponder capacity) either. United Group's total spend on satellite transponder 
capacity repre sents a minor fraction of Eutelsat’s turnover in either  Central and 
Eastern Europe ([0 -5]% in  2017)39 or Western, Central and Eastern Europe ( [0-
5]% in 2017)40. 
(54) The Commission further notes that alternative customers of satellite transponder 
capacity will remain active in the relevant market. As explained in paragraph 
(12), satellite transponder capacity is used for a large number of usages, which are 
not limited to the distribution of DTH signal, and which include the provision of 
telephony, aeronautical, maritime, and other communications services. For 
example, Eutelsat’s  website lists the following “key clients” for Central and 
Eastern Europe: Antik Telecom, DigitAlb, FreeSat, Hrvatski Telekom, OiV, 
Team:Media, Telekom Austria Group, and Tring Digital.  
(55) Last, the Commission notes that United Group is contractually bound to  Eutelsat 
by a long -term contract that runs until […], which will make it less likely that 
United Group will switch provider in the foreseeable future. In addition, the 
market investigation confirmed that switching provider is logistically costly and 
time consuming, because of the necessity to re -direct the dishes, and often to 
change the dish size and the equipment itself.41 
(56) In light of the above, the Commission considers that the Transaction does not give 
rise to serious doubts as to its compatibility with  the internal market in relation to 
customer foreclosure with regard to the markets for the provision of satellite 
                                                                                                                                                 
the Questionnaire to Intelsat's competitors. Therefore, the Commission considers it unlikely that 
post-transaction Intelsat will get access to commercially sensi tive information of Eutelsat.  
36  See recital (31). 
37  Form CO, tables 3 and 4.  
38  Form CO, tables 2 and 4.  
39  Form CO, tables 3 and 4.  
40  Form CO, tables 2 and 4.  
41  Replies to the Questionnaire to United Group's competitors, question 1c.  
11 transponder capacity and for the retail distribution of Pay TV services in 
Slovenia, or in the Serbo -Croatian language area.  
6. CONCLUSION  
(57) For t he above reasons, the European Commission has decided not to oppose the 
notified operation and to declare it compatible with the internal market and with 
the EEA Agreement. This decision is adopted in application of Article 6(1)(b) of 
the Merger Regulation  and Article 57 of the EEA Agreement.  
For the Commission  
(Signed ) 
 
Margrethe VESTAGER  
Member of the Commission  
 
 
 
                                                 
i  Publication in the Official Journal of the European Union No C 423 , 23.11.2018 , p. 24.  
ii  Turnover calculated in accordance with Article 5 of the Merger Regulation and the C ommission 
Consolidated Jurisdictional Notice (OJ C 95, 16.4.2008, p. 1).