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, 20.7.2018  
C(2018 ) 4953 final   
  
 
 
 
 
To the notifying party : 
 
 
Subject : Case M. 8837 - Blackstone / Thomson Re uters Financial and Risk 
Business  
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 or Madam,  
(1) On 15 June 2018 , the European Commission received notification of a proposed 
concentration pursuant to Article 4 of the Merger Regulation by which  The 
Blackstone  Group ("Blackstone")  will acquire  within the meaning of Arti cle 
3(1)(b) of the Merger Regulation sole control over Thomson Reuters Financial 
and Risk Business ("Thomson Reuters F&R" or "the Target")  (the 
"Transaction")3. Blackstone is referred to as "the Notifying Party" and Blackstone 
and the Target together as "t he Parties".  
1. THE PARTIES  
(2) Blackstone is a global asset manager  and provider of financial advisory services , 
headquartered in the US.  
(3) The Target  is a data and financial technology platform that provides information 
and data analytics, enables financial tra nsactions, and connects communities of 
                                                 
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 'Union' 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').  
3  Publication in the Official Journal of the European Union No C 228 , 29.06.2018 , p. 33.  PUBLIC VERSION  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omitted has been replaced by ranges of figures or a 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.  
2 trading, investment, financial, corporate, strategy, treasure and risk professionals. 
It also provides regulatory and risk management solutions to help customers 
anticipate and manage risk and compliance.  
2. THE OPERATI ON 
(4) For the purpose of the Transaction, private equity funds controlled by Blackstone 
have formed King (Cayman) Holdings Ltd. ("HoldCo") . Canada Pension Plan 
Investment Board ( "CPPIB ") and Suzuka Investment Pte Ltd., an affiliate of GIC 
Private Limited ( "GIC") will invest alongside Blackstone for the Transaction. 
CPPIB and GIC are together referred to as the Co -investors. Blackstone, CPPIB 
and GIC are together referred to as the Consortium. The Consortium will acquire 
a 55% stake in the Target through owne rship by the Equity Investor Vehicle4 
(formed pursuant to Sections 2, 3 and 21 of the Equity Funding Arrangement 
Letters of the Transaction) of 55% of the common shares of HoldCo . Post-
Transaction, Thomson Reuters will retain a 45% interest in the Target t hrough 
ownership of 45% of the common shares of HoldCo.  HoldCo will acquire all of 
the Target's assets.  
(5) Blackstone will solely control the Target within the meaning of Article 3(1)(b) of 
the EU Merger Regulation.  
3. EU DIMENSION  
(6) The undertakings concerned ha ve a combined aggregate world -wide turnover of 
more than EUR 5 000 million5 (Blackstone [Confidential ] in 2016 and the Target 
[Confidential ] in 2017) . Each of them has a n EU-wide turnover in excess of EUR 
250 million  (Blackstone [Confidential ] in 2016 and the Target [Confidential ] in 
2017) , but they do not achieve more than two -thirds of their aggregate EU-wide 
turnover within one and the same Member State. The notified operation therefore 
has an EU dimension.  
4. COMPETITIVE ASSESSMEN T 
(7) The Target provides a br oad range of financial information products to financial 
market professionals, including real -time and non -real-time data services.  
(8) Blackstone is active in the same markets as the Target  only via Ipreo LLC 
("Ipreo"),  a portfolio company it controls jointly together with the Goldman Sachs 
group Inc. Ipreo provides software, data and market intelligence products to 
companies that are active in capital markets. Ipreo's and the Target's activities 
give rise to horizontal overlaps.6  
                                                 
4  [Confidential] . Neither CPPIB nor GIC will obtain any rights in the Target which r ise to the level of 
control as defined by the Merger Regulation.  
5  Turnover calculated in accordance with Article 5 of the Merger Regulation.  
6  In May 2018, Blackstone agreed to sell Ipreo to IHS Markit  Ltd. This transaction is expected to close 
in the second half of 2018, effectively removing all horizontal overlaps between the Parties.  However, 
by the time the Commission had to adopt a decision on the Transaction, the IHS Markit/Ipreo deal was 
 
3 (9) The Transaction also gives rise to limited vertical overlaps between the activities 
of Target and Blackstone (and its controlled portfolio companies).  
4.1. Relevant Markets  
4.1.1.  Discrete Content Sets, Desktop Services, and Non -Real Time Data Feeds  
4.1.1.1.  Intro duction  
(10) The Transaction relates to the financial information industry, namely, the 
provision of financial information, analytics, and trading capabilities.  According 
to the Notifying Party, the main users of the Parties' products are customers in the 
financial service industry, such as banks, traders, funds, and corporate customers.   
(11) Financial information can be categorized in real -time and non -real time market 
data.  Real -time data consists of indicative or tradable prices for various types of 
financial instruments such as equities, corporate and government bonds, currency 
and traded commodities.  Real -time data changes rapidly during the day and it is 
updated every millisecond.  It is required by security dealers, foreign exchange 
dealers, and investment  advisers for immediate consumption.  Non -real time data 
is more general financial or economic information which may vary between days 
and parts of a day, but not every second.  It does not satisfy real -time demands 
and is primarily adapted to research and  customer awareness demands.   
(12) In the financial information business, there are different methods for the supply of 
financial information products to customers:  
a) Financial information can be delivered by suppliers to customers as 
"datafeeds" through an app lication programming interface (API), where the 
customers obtain their content in a direct or "raw" data format, from which 
they build their own internal applications or portals; and  
b) Financial information can also be integrated into "desktop solutions", na mely, 
retail products, which contain a "front -end" window that enables the user to 
access the content and functionalities contained in the product on the screen.  
Such front -end windows can take the form of either a web -delivered solution 
or a deployed/phy sical solution.7   
(13) According to the Notifying Party, the vast majority of suppliers, including the 
Target, supply their content using both methods (directly to end -users as a 
datafeed and as a desktop solution).  
 
4.1.1.2.  Relevant Product Market  
(14) In Thomson/Reuters , the Commission's market investigation indicated that for 
financial information " discrete content sets represent the appropriate antitrust 
                                                                                                                                                 
not com pleted.  For the purposes of the competitive assessment of the Transaction, Ipreo is considered 
as part of Blackstone.  
7  M.4726, Thomson Corporation / Reuters Group , paras. 25 -28.   
4 markets for assessing the impact " of the transaction that was under review.8  The 
investigation in that case suggest ed that the value of the products in the financial 
information business lies in their functionalities and content.9  The majority of 
both customers and competitors considered in that case that "individual content 
sets are not substitutable for one another" .10  The Commission therefore 
identified separate relevant markets for each type of data content sets.11  
Regarding non -real time content, the Commission identified separate markets for 
fundamentals  content sets , deals  content sets , ownership  content sets , and other 
types of content.12  The Commission clarified that each of the  discrete content set s 
may be sold/delivered in various modalities: as standalone products (e.g., as 
databases or datafeeds) or as part of a desktop service .13   
(15) In the present case, the Notifying Party disagrees with the market delineation in 
Thomson/Reuters .  It submit s that relevant markets for financial information 
products should not be sub -segmented based on  discrete content sets  because the 
competitive lands cape and the market dynamics have continued to evolve 
significantly in the 10 years since the Thomson/Reuters  decision .  According to 
the Notifying Party,  financial information suppliers (including the Target) moved 
towards packaged solutions (desktop serv ices and datafeeds).  For such packaged 
solutions, competition takes place at the level of the comprehensive packaged 
desktop or datafeed rather than at the level of discrete content sets or 
functionalities.  
(16) In light of the above, the Notifying Party proposed relevant product markets for 
(i) desktop services , (ii) non -real-time datafeed services  and (iii) real -time 
datafeed services. However, for the purpose of this transaction real -time datafeed 
services are not a relevant market as the Parties activities  do not overlap for real -
time datafeed services :  
a) Desktop service s.  Desktop services include comprehensive integrated 
desktops, more narrowly focused integrated desktops (a.k.a., workstations or 
terminals) and content/functionality sold for individual use  which can be 
incorporated or used in/alongside an integrated desktop.  The Notifying Party 
submitted that f inancial information suppliers typically provide desktop 
services that comprise multiple sources of different types of financial data.  
According to  the Notifying Party, t he various content sets and functionalities 
in these solutions are not priced separately and cannot be accessed outside of 
the comprehensive packaged desktop product.     
  
                                                 
8  M.4726, Thomson Corporation / Reuters Group , para. 43.  
9  M.4726, Thomson Corporation / Reuters Group , para. 43.  
10  M.4726, Thomson Corporation / Reuters Group , paras. 44 -46.   
11  M.4726, Thomson Corporation / Reuters Group, para. 61ff.   
12  M.4726, Thomson Corporation / Reuters Group, paras. 74ff.,  in particular, 82ff., 88, and 89.  
13  M.4726, Thomson Corporation / Reuters Group , para. 50.   
5 b) Non-real time datafeeds .  Non-real time datafeeds combine various  types of 
general financial or economic (historical or archival) information .  According 
to the Notifying Party, n on-real time datafeeds do not belong in the same 
market as  real time datafeeds.  The characteristics of  the two types of 
datafeeds are very different.  For real time datafeeds, timeliness is the most 
important feature, while for non -real time datafeeds the focus is on 
completeness and reliability of the information.  Real-time datafeeds and non -
real time datafeeds also address different t ypes of demand as explained in 
Section 4.1.1.1  above.  The Commission has confirmed in its decisional 
practice that real time datafeeds belong to relevant markets s eparate from non -
real time datafeeds.14   
(17) The market i nvestigation did not support the view of the Notifying Party that 
customers typically only purchase financial information as part of packaged 
solutions.  The vast majority of customers stated that they c ontinue to buy 
financial information in the form of discrete content sets and not only in packaged 
solutions.15  All of the respondents confirmed that when purchasing financial 
information, they compare the offering of discrete content sets and packaged 
solutions.16  Many respondents admitted that packaged solutions lead to cost 
savings and allow users to be more efficient.17  But customers also highlighted 
that they sometimes need to source discrete content sets from different suppliers, 
for example " to obtain the maximum data coverage and in order to ensure data 
comparisons for data quality processes " or " if a packaged solution does not 
contain the data [the customer] need[s] ".18  
(18) In any event, for the purposes of the present case, the exact market defini tion can 
be left open, as  no serious doubts arise under any plausible product  market 
definition  (discrete content sets or packaged solutions).   
4.1.1.3.  Relevant Geographic Market  
(19) The Notifying Party submitted that the relevant geographic scope for desktop 
servic es is worldwide or at least EEA -wide as both customers and competitors are 
active globally or at least regionally and the core offering remains the same 
throughout the world and/or the region.  The market investigation confirmed 
this.19   
(20) The Notifying Part y submitted that the relevant geographic scope for non -real-
time datafeeds is worldwide or at least EEA -wide.  The market investigation did 
not bring any element to the Commi ssion's attention which would suggest  that the 
market is narrower than EEA -wide.   
                                                 
14  See AT.39654 – Reuters Instrument Codes , para. 29 and M.4726, Thomson Corporation / Reuters 
Group , paras. 65ff. which define markets for consolidated real -time datafeeds and direct real -time 
datafeeds.   
15  See Questionnaire Q1 – Customers, Q3 and Q10.  
16  See Questionnaire Q1 – Customers, Q3.4.  
17  See Questionnaire Q1 – Customers, Q3.2.  
18  See Questionnaire Q1 – Customers, Q3.1.  
19  See Questionnaire Q1 – Customers, Q8.1.  
6 (21) The Notifying Party recalled that in Thomson/Reuters , the Commission 
considered that the relevant geographic scope for discrete content sets was EEA -
wide or potentially global in scope.  The market investigation in the present case 
confirmed this.20  
(22) In an y event, for the purposes of the present case, the exact market definition can 
be left open, as  no serious doubts arise under any plausible geographic  market 
definition  (EEA -wide or worldwide).   
4.1.2.  Consolidated Real Time Dataf eeds  
(23) A real time datafeed is a virtual pipeline that supplies continually updated market 
information.  Real -time data feeds can be used in applications developed by banks 
and financial institutions, for example to allow for electronic or algorithmic 
trading.21  There are two types of rea l time datafeeds: consolidated  and direct .  
Consolidated real time datafeeds involve the aggregation of feeds from various 
sources into a single source.  Direct real time datafeeds involve a more direct 
connection from an individual exchange to a customer.22  In Reuters Instrument 
Codes , the Commission found that consolidated real time datafeeds and direct real 
time datafeeds belong to different product markets.23  The Notifying Party 
submits that it is not necessary to define conclusively the relevant product market.  
(24) In Reuters Instrument Codes , the Commission defined the market for 
consolidated real time datafeeds as worldwide.24   The Notifying Party submits 
that it is not necessary to define conclusively the relevant geographic market.  
(25) For the purpose s of the present case, the Commission considers that there is a 
separate relevant market for consolidated real time datafeeds, which is worldwide 
in scope.  
4.1.3.  Market  Data Platform Services  
(26) Market data platform services ( "MDP s") are "middleware" that receive datafeeds 
from multiple sources (including real time datafeeds and other sources) as inputs 
and distribute this information to terminals, applications, wireless devices and the 
internet.25,  In its decisional practice , the Commission defined a separate mark et 
for MDPs .26  The Notifying Party submits that for the purpose of the present case 
it is not necessary to define conclusively the relevant product market.  
(27) In previous decisions , the Commission has considered the geographic market for 
MDP to be at least EEA -wide or worldwide, but left the geographic scope open.27  
                                                 
20  See Questionnaire Q1 – Customers, Q14.  
21  AT.39654, Reuters Instrument Codes , para. 24.  
22  M.4726, Thomson Corporation / Reuters Group , para. 66.  
23  M.4726, Thomson Corporation / Reuters Group , para. 29.  
24  AT.39654, Reuters Instrument Codes , para. 31.  
25  M.4726, Thomson Corporation / Reuters Group , para. 68.  
26  M.4726, Thomson Corporation / Reuters Group , para s. 62 and 69 and M.3692, Reuters/Telerate , para. 
13.  
27  M.3692, Reuters/Telerate , para 16 and M.4726, Thomson Corporation / Reu ters Group , para 111.  
7 The Notifying Party submits that for the purpose of the present case it is not 
necessary to define conclusively the relevant geographic market.  
(28) For the purposes of the present case, the Commissi on considers that there is a 
separate relevant product market for MDPs.  The exact geographic scope of the 
market can be left open, as  no serious doubts arise under an EEA -wide or  a 
worldwide  market definition .   
4.1.4.  Life Insurance  
(29) In its decisional practice, the Commission has made a distinction between three 
broad categories of insurance products, namely (i) life insurance; (ii) non -life 
insurance; and (iii) reinsurance.  With respect to the life insurance market, the 
Commission has distinguished between (i) pure protection products; (ii) pension 
products; and (iii) investment products, but also considered pension and 
investment products together as part of the same product market.28 Additionally, 
the Commission has considered distinguishing between life insura nce for 
individuals and group customers, or  between products  based on the type of risk 
covered. Ultimately, the product market definition has been left open.29  The 
Notifying Party submits that for the purpose of the present case it is not necessary 
to defi ne conclusively the relevant product market.   
(30) In previous cases , the Commission considered that the market for Life Insurance 
is national.30  The Notifying Party submits that for the purpose of the present case 
it is not necessary to define conclusively the  relevant geographic market.    
(31) In any event, for the purposes of the present case, the exact market definition can 
be left open, as  no serious doubts arise under any plausible product or geographic  
market definition . 
4.1.5.  Bulk Annuity Insurance Transactions  
(32) Bulk annuity insurance transactions are de-risking transaction s that are common  
in the insurance business, especially in relation to Defined Benefit pension 
schemes.  In a bulk a nnuity insurance transaction, all of the risk associated with 
the pension liab ilities is transferred to a third party.  In its decisional practice, the 
Commission considered that a separate market exists for bulk annuity insurance 
transactions.31 The Commission has also considered a further distinction in the 
bulk annuity insurance t ransactions market between buy -in and buy -out 
transactions, but ultimately left the product market open32.  The Notifying Party 
submits that for the purpose of the present case it is not necessary to define 
conclusively the relevant product market.  
                                                 
28 M.5075,  Vienna Insurance Group / EBV ; M.5728, Crédit Agricole / Société Générale Asset 
Management ; M.5384, BNP Paribas / Fortis . 
29  M.6883, Canada Life / Irish Life , M.6521, Tal anx International / Meiji Yasuda Life Insurance / Warta , 
M.4701, Generali / PPF Insurance Business , M.4047, Aviva / Ark Life , M.1453 AXA / GRE.  
30  M.6521,  Talanx International / Meiji Yasuda Life Insurance / Warta ; M.5075,  Vienna Insurance 
Group / EBV  and M.5057,  Aviva / UBI Vita , M.6883,  Canada Life/ Irish Life 
31  M.8257 , NN Group / Delta Lloyd , para 88; M.7204, Rothesay Life / Metlife Assurance . 
32  M.8257 , NN Group / Delta Lloyd , para 88  
8 (33) In previ ous cases , the Commission considered that the market for bulk annuity 
contracts is national in scope.33  The Notifying Party submits that for the purpose 
of the present case it is not necessary to define conclusively the relevant 
geographic market.  
(34) In any e vent, for the purposes of the present case, the exact market definition can 
be left open, as  no serious doubts arise under any plausible product or geographic  
market definition . 
4.1.6.  Asset management  
(35) In its decisional practice , the Commission  described asset ma nagement as  the 
provision and potential implementation of investment advice .34  It also  considered 
that asset management may include the creation and managing of mutual funds 
which are then marketed on an “off -the-shelf” basis, including to retail customers , 
the provision of portfolio management services to institutional investors (pension 
funds, institutions and international organisations), and the provision of custody 
services related to asset management. The Commission also considered the 
possibility of there being a relevant product market for asset management, which 
would include the creation and management of mutual funds for retail clients and 
tailor -made funds for corporate and institutional customers, and portfolio 
management for private investors, pension funds and institutions.35 The 
Commission further considered the possible existence of separate relevant 
product markets for each of the types of products mentioned above,36 but 
ultimately left the product market open.   The Notifying Party submits that for the 
purpose of the present case it is not necessary to define conclusively the relevant 
product market.  
(36) In previous cases , the Commission considered that the market for asset 
management is national or EEA -wide in scope .37  The Notifying Party submits 
that for the purpose of the present case it is not necessary to define conclusively 
the relevant geographic market.  
(37) In any event, for the purposes of the present case, the exact market definition can 
be left open, as  no ser ious doubts arise under any plausible product or geographic  
market definition . 
4.1.7.  Investment banking  
(38) Investment banking includes services such as advice on the financial aspects of 
mergers and acquisitions, initial public offerings and arranging new issues of  
stocks and bonds, excluding the underwriting of such operations.  In its decisional 
practice, the Commission analysed the market for investment banking as a whole, 
while identifying the following possible market segments : (i) merger and 
acquisition advice ; (ii) capital markets business such as Initial Public Offering 
and share issues advice ; and (iii) Services relating to arranging new issues as 
                                                 
33  M.8257, NN Group/Delta Lloyd , para. 91 and M.7204,  Rothesay Life / Metlife Assurance , para. 28.  
34  M.8257, NN Group / Delta Lloyd , para. 108.  
35  M.6812 , SFPI / Dexia , M.3894 Unicredito/HVB , M.8257, NN Group / Delta Lloyd . 
36  M.8257, NN Group/Delta Lloyd , para. 110.  
37  M.8257, NN Group / Delta Lloyd , para. 110.  
9 stocks and bonds .38  The Commission ultimately left the product market open.  
The Notifying Party  submit s that fo r the purpose of the present case it is not 
necessary to define conclusively the relevant product market.  
(39) In previous cases, t he Commission has considered the relevant geographic market 
to be national or international (EEA -wide or global), but ultimately left the 
geographic market open.39  The Notifying Party submits that for the purpose of 
the present case it is not necessary to define conclusively the relevant geographic 
market.  
(40) In any event, for the purposes of the present case, the exact market definit ion can 
be left open, as  no serious doubts arise under any plausible product or geographic  
market definition . 
4.1.8.  Financial market services  
(41) Financial market services are provided to institutional investors, corporate clients , 
and professional traders who lack direct access to financial markets or otherwise 
value the intermediary services provided by a bank.  In its decisional practice, the 
Commission distinguished within the market for financial market services 
between  the following sub -segments: (i) t rading in  securities, bonds and 
derivatives, (ii) foreign exchange trading, (iii) money market operations and (iv) 
trading of other asset classes40, but ultimately left the product market open.  The 
Notifying Party  submit s that for the purpose of the present case it is not necessary 
to define conclusively the relevant product market.  
(42) The Commission has considered the relevant geographic market to be national or 
wider (EEA or global)41, but ultimately left the geographic mar ket open.  The 
Notifying Party submits that for the purpose of the present case it is not necessary 
to define conclusively the relevant geographic market.  
(43) In any event, for the purposes of the present case, the exact market definition can 
be left open, as  no serious doubts arise under any plausible product or geographic  
market definition . 
4.1.9.  Private equity investment  
(44) Private equity investment is the investment of equity in unquoted companies (i.e. , 
companies whose shares are not quoted on any public exchange) .  The supply of 
funds for equity investment can comprise equity and debt finance.  In its 
decisional practice, the Commission considered a further distinction between the 
supply of debt and equity finance.42  The Commission has also considered private 
equity as a segment of the corporate finance market or asset management 
                                                 
38  M.5384, BNP Paribas / Fortis , M.6168, RBI / EFG EUROBANK / JV, M.4692, Barclays / ABN 
AMRO , M.3894, Unicredito / HVB . 
39  M.5726, Deutsche Bank / SAL Oppenheim , M.5384, BNP Partibas / Fortis , M.7044, Blackstone / 
Goldman Sachs / Rothesay . 
40  M.3894, Unicredito / HVB , M.4692, Barclays / ABN AMRO , M.5384, BNP Parib as / Fortis , M.5726, 
Deutsche Bank / SAL Oppenheim , and M.6168, RBI/EFG Eurobank / JV . 
41  M.3894, Unicredito / HVB , M.4692, Barclays / ABN AMRO , M.5384, BNP Paribas / Fortis , M.5726, 
Deutsche Bank / SAL Oppenheim ; and M.6168, RBI / EFG Eurobank / JV . 
42  M.2577 , GE Capital / Heller Financial . 
10 services, but ultimately left the market definition open .43  The Notifying Party  
submit s that for the purpose of the present case it is not necessary to define 
conclusively the relevant pro duct market.  
(45) In previous decisions, the Commission considered the market  for private equity 
investment  could be considered either national or wider, but ultimately left the 
geographic market open .44  The Notifying Party submits that for the purpose of 
the p resent case it is not necessary to define conclusively the relevant geographic 
market.  
(46) In any event, for the purposes of the present case, the exact market definition can 
be left open, as no serious doubts arise under any plausible product or geographic 
market definition.  
4.1.10.  Mortgages  
(47) As described in recital  (46), the Commission has in previous decisions 
distinguished three segments within the banking market, namely  retail banking ; 
corporate banking ; and financial market services.  The Commission also  
considered mortgages as a potential market sub -segment within the retail banking 
market .  The exact product market definition has been left open.45  The Notifying 
Party submits that for the purpose of the present case it is not necessary to define 
conclusi vely the relevant product market.  
(48) In previous decisions , the Commission considered the market for retail banking 
services (including mortgages) to be national in scope, but ultimately left the 
market open.46  The Notifying Party submits that for the purpose  of the present 
case it is not necessary to define conclusively the relevant geographic market.  
(49) In any event, for the purposes of the present case, the exact market definition can 
be left open, as  no serious doubts arise under any plausible product or geo graphic  
market definition . 
4.2. Competitive Assessment  
4.2.1.  Horizontal Analysis  
(50) In the market segments that the Notifying Party proposed as horizontally 
overlapping (i.e., desktop services and non -real time data feeds), the Transaction 
does not give rise to affected markets worldwide or in the EEA.  The combined 
entity would hold [10-20%] in desktop services in the EEA and [10-20%] 
worldwide  and the share increment co ntributed by Ipreo would be minimal 
(below [0-5%]).  The combined entity  would have a share of [10-20%] in non -
real-time data feeds in  the EEA and [10-20%] worldwide and the share increment 
contributed by Ipreo would be minimal (below [0-5%]).  In both the  proposed 
                                                 
43  M.6738, Goldman Sachs / KKR / QMH , M.6832 , Goldman Sachs / TPG Lundy / Ainscough , M.6841 , 
Goldman Sachs / TPG Lundy / Tulloch Homes Group Limited . 
44  M.2577, GE Capital / Heller Financial . 
45  M.5384, BNP Paribas / Fortis , M.4844, Fortis / ABN Amro assets , M.8553, Ba nco Santander / Banco 
Popular , M.6405, Banco Santander / Rainbow . 
46  M.5384 BNP Paribas / Fortis , M.4844 Fortis/ABN Amro assets , M.8553 Banco Santander/Banco 
Popular , M.6405 Banco Santander/Rainbow.  

12 4.2.1.1.  Deals  Content Sets  
(53) In deals content sets , post -Transaction  the Parties will have a combined market 
share of [20-30%] post-Transaction  globally and in the EEA.  The share 
increment contributed by Ipreo is less than [0-5%] (i.e., less than [0-5%] in the 
EEA and less than [0-5%] worldwide).  The HHI increment is minimal.  Post-
Transaction, the combined entity will continue to face significant constraints from 
at least five players, i.e., Dealogic, Bloomberg, Acuris, S&P, and FactSet.   
(54) Moreover, according to the Parties, the Target and Ipreo are not close 
competitors .  The Target is a "Tier 1"51 player in t his space (alongside Dealogic) 
while Ipreo has very limited presence.   
(55) Finally, during the market investigation, the vast majority of market respondents 
did not identify any impact of  this Transaction on competition  in the market for 
deals content sets in the EEA or worldwide.52   
(56) In view of the above, the Commission concludes that no serious doubts as to the 
compatibility of the Transaction with the internal market arise for deals content 
sets in the EEA or worldwide . 
4.2.1.2.  Fundam entals  Content Sets  
(57) In fundamental  content sets, the Transaction gives rise to an affected market only 
at worldwide level (where the combine d share of the Parties is [15-25%]).  The 
market is not affected at EEA level.  At global level, the share increment 
contributed by Ipreo is [0-5%].  The HHI increment is minimal .  Post-
Transaction, the combined entity will continue to face significant constraints from 
at least eleven comp etitors, including major players like Bloomberg, FactSet, and 
S&P Global , as well as other smaller rivals, such as Morningstar, Zacks, Edgar 
Online, Toyo Keizai, Fitch, Value Line, World'Vest Base, and Mergent.    
(58) Moreover, according to the Parties, the Ta rget and Ipreo are not close 
competitors.  The Target is a "Tier 1 " player in t his space while Ipreo has very 
limited presence.  Ipreo does not collect or own its own fundamentals database.  It 
is simply a re -distributor of FactSet fundamentals (and estima tes) content.53   
(59) Finally, during the market investigation, the vast majority of market respondents 
did not identify any impact of  this Transaction on competition in the market for 
fundamentals content sets worldwide.54   
(60) In view of the above, the Commission  concludes that no serious doubts as to the 
compatibility of the Transaction with the internal market arise for fundamentals 
content sets worldwide . 
                                                 
51  Tier 1 suppliers offer broader and deeper c overage than Tier 2 suppliers for fundamental content sets. 
Examples of Tier 1 suppliers for fundamental content sets are Bloomberg, FactSet, S&P Global and 
The Target. Examples of Tier 2 suppliers are Morningstar, Zacks, Edgar Online, Toyo Keizai, Fitch, 
Value Line; World'Vest Base, Mergent and other smaller suppliers.  
52  See Questionnaire Q1 – Customers, Q20.  
53  See https://ipreo.com/targeting -services/ .  
54  See Questionnaire Q1 – Customers, Q18.  
13 4.2.1.3.  Loans  Content Sets  
(61) In loans  content sets, the Transaction gives rise to an affected market only at 
EEA -wide  level (where the combine d share of the Parties is [10-20%]).  The 
market is not affected at worldwide  level.  At EEA -wide  level, the share 
increment contributed by Ipreo is [0-5%].  The HHI increment is minimal .  Post-
Transaction, the combined entity will  continue to face significant constraints from 
at least five competitors, including major players like IHS Markit, S&P Global 
Market Intelligence (CapIQ), and Bloomberg and other rivals , such as Dealogic, 
Loan Radar, and Moody's (through its recent acquisi tion of Bureau Van Dijk) .    
(62) Finally, during the market investigation, the vast majority of market respondents 
did not identify any impact of  this Transaction on competition in the market for 
loans  content sets in the EEA.55   
(63) In view of the above, the Comm ission concludes that no serious doubts as to the 
compatibility of the Transaction with the internal market arise for loans  content 
sets in the EEA . 
4.2.1.4.  Ownership  Content Sets  
(64) In ownership  content sets, the Parties will have a combined market share of [20-
30%] in the EEA and [20-30%] globally  post-Transaction .  The share increment 
contributed by Ipreo is [0-5%] or less.  Post-Transaction, the combined entity will 
continue to face significant constraints from at least five players, i.e., FactSet, 
Bloomberg, S&P Global Market Intelligence (Cap IQ), Morningstar, and 
Dealogic.  
(65) According to the Notifying Party, Ipreo's and the Targets products do not compete 
closely. The market investigation confirmed this.  The majority of the respondents 
identified FactSet  as the closest competitor to the Target, in terms of scope of the 
data offered , price , after-sales services , and integration possibilities.56 The 
respondents were also asked to rank seven providers of ownership content sets 
(Ipreo, the Target, FactSet, Blo omberg, CapIQ, MorningStar, and Dealogic) from 
strongest to weakest taking into account their sales in the EEA in 2017. The 
majority ranked the Target as the strongest or second strongest and Ipreo  only as 
the weakest or second weakest.57  The Notifying Par ty added that Ipreo's and the 
Target's products do not compete closely because they are delivered to the 
customers through different channels.  Ipreo provides its content either through a 
standalone web -based solution or via a customer relationship managem ent 
("CRM") system.  In contrast, the Target  is not active in the CRM space, but  
provides its ownership content either as part of its flagship comprehensive 
integrated desktop service (Eikon) or as a datafeed which is sold to clients and is 
then integrate d into the client's proprietary software.   
                                                 
55  See Questionnaire Q1 – Customers, Q18.  
56  See Questionnaire Q1 – Customers, Q11.  
57  See Questionnaire Q1 – Customers, Q12.  

15 (69) The remainder of this Section examines together the vertical links between the 
same upstream market and the different downstream markets.  This is the case 
because (i) the Target offers the same product  (or product family)  in the upstream 
market to all types of downstream customers and it understands that its rivals do 
the same and (ii) the competitive assessment for each of these v ertical links is 
based on comparable considerations.  
4.2.2.1.  Consolidated real time datafeeds (upstream) and bulk annuity insurance 
transactions, mortgages , asset management, investment banking, financial 
market services, and private equity investment (downstream)  
Input Foreclosure  
(70) The Notifying Party submitted that post -Transaction the combined entity will not 
have the ability or the incentive to foreclose downstream competitors , by 
restricting access to consolidated real time datafeeds  for the following reasons.  
First, the consolidated real time datafeeds are not a necessary input for any of the 
downstream markets where Blackstone and its controlled entities are active.  
Second, any input foreclosure strategy would b e defeated by the T arget's rivals 
who can satisfy demand in the downstream markets.  Third, any potential gains of 
a hypothetical input foreclosure strategy would be very low in view of the limited 
market share of Blackstone and its controlled entities in each of the  downstr eam 
markets, irrespective of their precise delineation.  
The Commission considers that post -Transaction, the combined entity  would not have 
the ability to foreclose its downstream rivals.  Such an ability exists only  when by 
reducing access to its upstream  products, the combined entity negatively affects the 
overall availability of inputs for the downstream market.  This is the case where the 
remaining upstream suppliers are less efficient, offer less preferred alternatives, or lack 
the ability to expand ou tput in response to the supply restriction.59  By contrast, in 
consolidated real time datafeeds, the Target faces competition by several major players , 
e.g., Bloomberg (with a share of [20-30%]) and ICE ( [0-10%]).  These players could 
expand output to suppl y consolidated real time datafeeds for any downstream players that 
the Target might decide to foreclose.   
(71) Nor would the combined entity  have the incentive to foreclose its downstream 
rivals.  The total consolidated real -time datafeed expend iture of Blacks tone and 
all its controlled entities amounts to  USD  [confidential] , which is less than [0-5%] 
of the Targ et's total sales in this market in 2017.  Any input foreclosure strategy 
would likely lead to a loss in consolidated real -time datafeeds  that is not 
commensurate to any possible gain in the downstream markets.     
(72) The respondents in the market investigation did not raise any concern as regards 
the potential input foreclosure in the downstream markets for bulk annuity 
insurance transactions , mortgages, asset management, investment banking, 
financial market services, and private equity investment  by restricting access to 
the Target's consolidated real time datafeeds.   
                                                 
59  Guidelines on the assessment of non -horizontal mergers under the Council Regulation on the control 
of concentrations between undertakings, OJ C 265, 18.10.2008, p. 7 ("Non -Horizontal Merger 
Guidelines"), para. 36.  
16 Customer Foreclosure  
(73) The Notifying Party submitted that post -Transaction the combined entity will not 
have the ability or the incentive to foreclose upstream competitors in consolidated 
real time datafeeds, by restricting access to Blackstone's demand in the 
downstream markets.  First, even if Blackstone and its controlled enti ties were to 
purchase consolidated real -time datafeeds exclusively from the Target, a 
significant and more than sufficient customer base remains available for the 
Target's rivals.  Second, Blackstone portfolio entities will not start purchasing 
consolidate d real time datafeeds exclusively from the Target, unless this is in the 
best interests of each entity's investor base.  According to the Notifying Party, this 
in itself prevents a foreclosure strategy.  
(74) The Commission considers that post -Transaction, Blac kstone would not have the 
ability to foreclose its upstream rivals  in consolidated real time datafeeds .  Post-
Transaction, sufficient economic alternatives will remain in the downstream 
market for upstream rivals to sell their output.  The total expend iture of 
Blackstone and its controlled entities on consolidated real time datafeeds 
represents only [0-5%] of the total worldwide demand for these products in 2017.   
(75) According to the Non -Horizontal Guidelines, an ability to foreclose upstream 
rivals exists on ly where the merger involves a company which is an important 
customer with a significant degree of market power in the downstream market.60  
Blackstone and its controlled entities do not have a significant degree of market 
power in the downstream markets wh ere they are active.  According to the 
Notifying Party, their share never exceeds 30% in any of the downstream 
markets.61  Moreover, in each of these markets, Blackstone and its controlled 
entities face competitive constraints from several large players who  likely 
constitute a significantly large customer base for consolidated real -time datafeeds 
in the future.62  
(76) The respondents in the market investigation did not raise any concern as regards 
the potential customer foreclosure in the upstream market for  consolidated real 
time datafeeds by restricting access to Blackstone's demand for these services.  
Conclusion  
(77) In view of the above and of all the evidence available to the Commission, the 
Commission considers that the Transaction does not raise serious doubts as to its 
compatibility with the internal market with respect to the vertical link between 
                                                 
60  Non-Horizontal Merger Guidelines, para . 61.  
61  See Notifying Party's submission of 18 July 2018, "Addendum to Additional Submission of 18 July 
2018".   
62  According to the Notifying Party, key rivals of Rothesay Life Limited in bulk annuity insurance 
transactions include L&G, PIC, Scottish Wi ndows, Phoenix Live, JRP, Aviva, and Canada Life; key 
rivals of the Northview Group in mortgages (in the UK) include Lloyds Banking Group, Nationwide 
BS, Royal Bank of Scotland, Santander UK, Barclays, HSBC Bank, Coventry BS, Virgin Money, 
Yorkshire BS, an d TSB Bank; key rivals of Blackstone and First Eagle Management in asset 
management include Barclays, Allianz, AXA, and ING; key rivals of Blakcstone in investment 
banking and financial market services include Goldman Sachs, JP Morgan Chase, Morgan Stanley , 
and Credit Suisse; and key rivals of Blackstone in private equity investment include Blackrock, 
Lazard, Citigroup, and Deutsche Bank.  
17 Consolidated re al time datafeeds (upstream) and bulk annuity insurance 
transactions, mortgages, asset management, investment banking, financial market 
services, and private equity investment (downstream).  
4.2.2.2.  MDPs  (upstream) and bulk annuity insurance transactions, mortgage s, life 
insurance,  asset management, investment banking, financial market services, 
and private equity investment (downstream)  
Input Foreclosure  
(78) The Notifying Party submitted that post -Transaction the combined entity will not 
have the ability or the incent ive to foreclose downstream competitors , by 
restricting access to MDPs for the following reasons.  First, MDPs are not a 
necessary input for any of the downstream markets where Blackstone and its 
controlled entities are active.  Second, any input foreclosu re strategy would be 
defeated by the Target's rivals who can satisfy demand in the downstream 
markets.  Third, any potential gains of a hypothetical input foreclosure strategy 
would be very low in view of the limited market share of Blackstone and its 
controlled entities in each of the downstream markets, irrespective of their precise 
delineation.  
(79) The Commission considers that post -Transaction, the combined entity would not 
have the ability to foreclose its downstream rivals.  Indeed, the combined entity 
would not be able to affect the overall availability of MDPs for the downstream 
markets.  The share in t his (upstream ) market barely exceeds 30% and  the Target 
faces competition by several major  MDP  players, e.g., Bloomberg (with a share 
of [30-40%] in the EEA and [30-40%] worldwide), Informatica ( [20-30%] in the 
EEA and [20-30%] worldwide), and Solace Systems ( [0-10%] in the EEA and [0-
10%] worldwide).  These players could expand output to supply MDPs for any 
downstream players that the Target might decide to foreclose.   
(80) Nor would the combined entity have the incentive to f oreclose its downstream 
rivals for two reasons:  
a) The total worldwide MDP expend iture of Blackstone and all its controlled 
entities amounts to [confidential] .  This represents [less than 10%] of the 
Target's total MDP sales worldwide and [20-30]% of the Target's total MDP 
sales in the EEA in 2017.63  Any input foreclosure strategy would likely lead 
to a loss of revenues  in the MDPs  market  that is not commensurate to any 
possible gain in the  downstream markets.   
b) The (fixed) cost of developing and updating MDPs is high , while the marginal 
cost of selling one additional unit is low.  MDP suppliers typically seek to 
spread their fixed costs  over a suffi ciently large base of customers.  The 
comb ined entity has no  incentive to forego this opportunity by restricting 
access of third parties to its MDPs.   
  
                                                 
63  This figure is overstated, as it compares the total worldwide MDP expend iture of Blackstone and its 
controlled entit ies with the total MDP sales of the Target in the EEA.  The total MDP expend iture of 
Blackstone and its controlled entities in the EEA was not available to the Notifying Party.   
18 (81) The respondents in the market investigation did not raise any concern as regards 
the potential input foreclosure in the downstream market for bulk annuity 
insurance transactions, mortgages, life insurance, asset management, investment 
banking, financial market services, and private equity investment  by restricting 
access to the Target's MDPs . 
Customer Foreclosure  
(82) The Notifying Party submitted that post -Transaction the combined entity will not 
have the ability or the incentive to foreclose upstream competitors in MDPs, by 
restricting access to Blackstone's demand in the downstream markets.  First, even 
if Blackstone  and its controlled entities were to purchase MDPs exclusively from 
the Target, a significant and more than sufficient customer base remains available 
for the Target's rivals.  Second, Blackstone portfolio entities will not start 
purchasing MDPs exclusivel y from the Target, unless this is in the best interests 
of each entity's investor base.  According to the Notifying Party, this in itself 
prevents a foreclosure strategy.  
(83) The Commission considers that post -Transaction, Blackstone would not have the 
abilit y to foreclose its upstream rivals in MDPs.  A sufficient number of 
customers will remain in the downstream markets for upstream rivals to sell their 
output.  The total worldwide expend iture of Blackstone and its controlled entities 
on MDPs represents less  than [0-5%] of the total worldwide demand for these 
products in 2017 and less than [5-10%] of the total demand in the EEA.64   
(84) According to the Non -Horizontal Guidelines, an ability to foreclose upstream 
rivals exists only where the merger involves a compa ny which is an important 
customer with a significant degree of market power in the downstream market.65  
Blackstone and its controlled entities do not have a significant degree of market 
power in the downstream markets where the y are active.  According to t he 
Notifying Party, their share never exceeds 30% in any of the downstream 
markets.66  Moreover, in each of these markets, Blackstone and its controlled 
entities face competitive constraints from several large players who likely 
constitute a significantly l arge customer base for MDPs  in the future.67  
(85) The respondents in the market investigation did not raise any concern as regards 
the potential customer foreclosure in the upstream market for market data 
platform services by restricting access to Blackstone's demand for these services.  
  
                                                 
64  This figure is overstated, as it compares the total worldwide MDP expend iture of Blackstone and its 
controlled entities with the total demand for MDP products in the EEA.  The total MDP expend iture of 
Blackstone and its controlled entities in the EEA was not available to the Notifying Party.  
65  Non-Horizontal Merger Guidelines, para. 61.  
66  See Notifying Party's submission of 18 July 2018, "Addendum to Additional Submission of 18 July 
2018".   
67  See fn.  62 above.  According to the No tifying Party, key rivals of The Lombard Group in life 
insurance  (in the UK)  include Cardif , Swiss Life, La Mondiale, Allianz, Generali and AXA.  
19 Conclusion  
(86) In view of the above and of all the evidence available to the Commission, the 
Commission considers that the Transaction does not raise serious doubts as to its 
compatibility with the internal market with respect to the vertical link between 
market data platform services (upstream) and bulk annuity insurance transactions, 
mortgages, life insurance, asset management, investment banking, financial 
market services, and private equity investment (downstream).  
5. CONCLUSION  
(87) For the 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 Regula tion and Article 57 of the EEA Agreement . 
For the Commission  
(Signed)  
Margrethe VESTAGER  
Member of the Commission