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 -MERGER -REGISTRY@ec.europa.eu .  EUROPEAN COMMISSION  
Brussels, 09.11.2021  
C(2021 ) 8204 final  
PUBLIC VERSION  
        
Genstar Capital partners, LLC  
Four Embarcadero Center  
Suite 1900  
San Francisco, CA 94111 -4191  
USA  
 
TA Associates Management, L.P.  
56th Floor  
200 Clarendon Street  
Boston, MA 02116  
USA   
Subject : Case M. 10385 – Genstar Capital / TA Associates / 20 -20 / Compusoft  
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  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’).  

 
 
2 (1) On 1 October 2021, the European Commission received notification of a proposed 
concentration pursuant to Article 4 of Council Regulation (EC) No 139/2004, by 
which Genstar Capital Partn ers, LLC (“Genstar Capital”) and TA Associates 
Management, L.P. (“TA Associates”) will indirectly acquire, within the meaning of 
Article 3(1)(b) and 3(4) of the Merger Regulation, joint control over the combination 
of 20 -20 Technologies, Inc. (“20 -20”), cu rrently solely controlled by Genstar 
Capital, and Compusoft AS (“Compusoft”), currently solely controlled by TA 
Associates (the “Transaction”) .3 Genstar Capital and TA Associates are hereinafter 
collectively referred to as the “Notifying Parties”, and toge ther with 20 -20 and 
Compusoft as the “Parties”.  
1. THE  PARTIE S  
(2) Genstar Capital is a private equity investment company focused on middle market 
businesses in financial services, healthcare, industrial technology and software 
industries.  
(3) TA Associates is a priv ate equity investment company focused on businesses active 
in selected industries, including business services, consumer, financial services, 
healthcare and technology.  
(4) 20-20 provides software for professional designers, retailers and manufacturers in 
the interior design and furniture industries with applications allowing their customers 
to create, design, visualise, price and sell kitchens, bathrooms, closets and 
commercial offices to end -consumers.  
(5) Compusoft offers integrated software solutions that allow  customers to provide 
services to end -consumers from design to installation of consumer/residential space 
and design projects.  
2. THE  OPE RATION  
(6) The Transaction concerns the proposed acquisition by affiliates of Genstar Capital of 
all shares in Compusoft, the subsequent combination of Compusoft with 20 -20 
(resulting in the “Combined Entity”), and a re -investment into the Combined Entity 
by TA Associates.  
(7) More specifically, the Transaction will be implemented through the acquisition of all 
shares in, and contro l over, Soft Topco AS (“Soft Topco”), that indirectly solely 
controls Compusoft, by Consilio Midco Limited, a private limited company 
incorporated under the laws of England and Wales (“Consilio Midco”) that currently 
controls 20 -20. Consilio Midco is curre ntly indirectly wholly -owned and controlled 
by Consilio Topco Limited (“Consilio Topco”), currently directly controlled by 
Consilio Investment Holdings L.P. (the “Consilio LP” and, together with its 
subsidiaries, the “Purchaser Group”) which is currently i n turn indirectly controlled 
by funds managed and advised by affiliates of Genstar Capital.  
                                                 
3  Publication in the Official Journal of the European Union No C 406, 08.10.2021 , p. 6. 
 
 
 
3 (8) Part of the consideration for the Transaction will be settled by affiliates of TA 
Associates, which will also provide new equity funding to the Purchaser Group. In  
addition, certain members of the Compusoft management team will receive 
securities in the purchaser acquisition entities. Upon completion of the above, the 
Transaction will result in (i) certain members of the Compusoft management holding 
shares in Consil io Topco; and (ii) affiliates of TA Associates holding partnership 
interests in the Consilio LP.  
3. THE  CONCE NTRATION  
(9) Upon completion of the Transaction, each of Genstar Capital and TA Associates will 
indirectly hold approximately 44% of Consilio LP, and will  jointly control  (via 
Consilio LP)  the Combined Entity for the following main reasons:  
(a) affiliates of Genstar Capital and TA Associates can each appoint three 
members to the board of directors of Consilio LP, which will in total have 
seven members, includi ng the CEO of Consilio Topco;  
(b) affiliates of Genstar Capital and TA Associates will have the right , via 
Consilio LP,  to veto key matters relating to the Combined Entity’s activities, 
including the adoption of the annual budget and any material employment -
related decisions concerning senior management.   
(10) Consequently, affiliates of Genstar Capital and TA Associates will have joint control 
within the meaning of Article 3(1)(b) and 3(4) of the EU Merger Regulation.  
(11) The Combined Entity will perform, on a lastin g basis, all the functions of an 
autonomous economic entity and will constitute a full -function joint venture within 
the meaning of Article 3(4) of the Merger Regulation for the following main reasons:  
(a) the Combined Entity will supply visual CPQ software to ols4, performing the 
functions normally carried out by competing undertakings operating in that 
same segment;  
(b) the Combined Entity is intended to operate on a lasting basis, pursuant to an 
agreed term sheet that will be the basis of the yet to be completed 
shareholders agreement between the affiliates of Genstar Capital, TA 
Associates and certain members of the 20 -20 and Compusoft management 
teams;  
(c) the current management of 20 -20 and Compusoft will jointly – as to be 
determined – run the Combined Entity on a  day-to-day basis;  
(d) the management will have access to sufficient resources including finance, 
staff, and assets (tangible and intangible) as demonstrated by the current 
operations of both 20 -20 and Compusoft and will thereby be able to conduct 
                                                 
4  As described in more detail in Section 5.1 below, CPQ stands for “configure, price, quote”. Visual CPQ 
software enables the entire sale s process of a given item (e.g. a kitchen) from visualisation of the desired 
product to providing an exact quotation of the cost to consumers . 
 
 
4 on a lasting  basis its business independently of Genstar Capital and TA 
Associates;  
(e) the Combined Entity will continue to have its own access to and presence on 
the market, in which 20 -20 and Compusoft operate now, and will continue to 
provide products to their third p arty customers.  
(12) Therefore, the Combined Entity will constitute a full -function joint venture within 
the meaning of Article 3(4) of the Merger Regulation.  
4. UNION  DIME NSION  
(13) The undertakings concerned have a combined aggregate worldwide turnover of mo re 
than E UR 5 000 million (EUR […]  million). Each of Genstar Capital (including 20 -
20) and TA Associates (including Compusoft) have an EU -wide turnover of more 
than EUR 250 million (Genstar Capital: EUR […] million, TA Associates: EUR […] 
million).  
(14) None of Genstar  Capital (including 20 -20) and TA Associates (including 
Compusoft) achieved more than two -thirds of their Union -wide turnover within one 
and the same Member State.  
(15) Therefore, the Transaction has a Union dimension pursuant to Article 1(2) of the 
Merger Regu lation.  
5. RE LE VANT MARKE TS  
5.1. Introduction  
(16) 20-20 is active global ly in the provision  of computer -aided design ( “CAD ”), visual  
configure, price, quote  (“CPQ”) software and enterprise solutions dedicated to 
interior design, space planning and furniture manufacturing .5 20-20 is primarily 
active in the US.6 
(17) Compusoft is active in the provision of visual CPQ  solutions for several retail and 
manufacturing industries .7 Compusoft is primarily active in the EEA.8 
(18) Core CAD software is focused on the visualisation elements of design and offers 
technical drawing and modelling applications.  
                                                 
5  Affiliates of Genstar Capital do not control any other company that offers core CPQ software but do 
control po rtfolio companies that to a certain degree are active in the broader segment of Cu stomer 
Relationship Management  software, of which CPQ software is a sub -segment  ([Genstar Capital’s portfolio 
companies]). None of these companies compete with 20 -20 or Compu soft.  
6  Form CO, paragraph 123.  
7  A handful of TA  Associates -controlled companies ([TA Associates’ portfolio compan ies]) are broadly 
active in the provision of Product Life Management  software, but of these, the only compan y that 
compete s, in the US, with 20 -20 and Compusoft  is Revalize . 
8  Form CO, paragraph 123.  
 
 
5 (19) Core CPQ software enables customers to search for, and select, products and 
services to sell, configure product options and featu res, automate pricing of chosen 
products and services, negotiate terms and generate proposals.  
(20) Visual CPQ software is distinct from core CAD and core CPQ software because it 
enables the entire sales process from visualisation of the desired product to prov iding 
an exact quotation of the cost to consumers . Indeed, e ach of core CAD and CPQ 
software respectively only address one part of the process. For example, CAD 
software is focused on the visualisation elements of design, but lacks the ability to 
configure , price and quote different products. By contrast, core CPQ lacks a visual 
component.  
(21) In particular, the Parties’ software solutions enable retailers and manufacturers to:  
- visualise  certain products (such as kitchen and bathroom fittings and furniture) 
within a given space;  
- configure  output and volumes based on catalogues of individual products;  
- price the cost of a range of products and volumes and automate discounts and 
price adjustments in order to produce a customer quotation;  
- quote an accurate price to  customers based on a bill of materials or a range of 
product categories.  
(22) While 20 -20 and Compusoft offer some CPQ functionalities such as pricing 
alongside their main functionalities, neither one of them provides so -called core 
CPQ functionalities.  
(23) Visual  CPQ software solutions for interior design  are utilised by a wide range of 
retail, manufacturing and design & planning customers in connection with: (i) 
residential  interior design (i.e., the design of parts of homes such as kitchen, 
bathrooms, furniture) ; and (ii) commercial  interior design (e.g., office furniture 
including pantries, professional kitchens and dining spaces, retail shops and other 
common areas).  
(24) Within the visual CPQ software provision, 20 -20 and Compusoft are active, to 
varying degrees, i n a number of markets/segments related to interior design and 
planning of residential and commercial spaces such as the following industry 
verticals: (i) Kitchen & Bathrooms, (ii) Windows & Doors, and (iii) Furniture .  
5.2. Visual CPQ software  
5.2.1.  Product market de finition  
5.2.1.1.  The Commission’s precedents  
(25) The Commission has not yet considered, from a product market definition 
perspective, the provision of visual CPQ software  and its possible sub -segments.  
 
 
6 (26) In previous decisions, the Commission defined several distinct markets within the 
broad category of Enterprise Application Software (“EAS”). In particular, the 
Commission considered9 that the market for EAS solutions can be divided according 
to functionality with broadly similar purposes, including, among others: (i) 
Enterprise Resource Planning (“ERP”) software; (ii) Customer Relationship 
Management (“CRM”) software; and (iii) Product Lifecycle Management (“PLM”) 
software.  
(27) ERP software encompasses applications that manage the optimal use of enterprise 
resources such a s employees, assets and finances. CRM encompasses applications 
that automate customer -facing business functions (i.e., sales, marketing, customer 
service and support, call centres and all the processes relating to the automation of 
sales). PLM software enc ompasses business software applications that support the 
end-user in managing the life cycle of its products.  
(28) In a number of cases, the Commission left open whether the  market for  CRM 
software could be further segmented by: (i) functionality of the softwar e;10 (ii) 
industry sector in which the customer is active;11 (iii) mode of deployment 
(installation on premises versus SaaS host -based deployment)12; and (iv) 
customisation (i.e., custom -build solutions as opposed to standardised software).13 
(29) In previous merge r decisions14, the Commission left the product market definition 
for PLM software  open but indicated that it might be appropriate to segment such 
market into specific segments for individual applications, in particular: (i) Digital 
Product Development (that  comprises CAD software ); (ii) Digital Manufacturing; 
and (iii) Product Data Management.  
(30) Finally, the Commission considered an additional distinction within PLM software 
between high -end and low -end solutions, but ultimately left this possible 
segmentation  open.15 
5.2.1.2.  The Notifying Parties’ view  
(31) The Notifying Parties submit , in line with  Gartner16, that core CPQ software is 
generally seen  as a sub -segment of the CRM market.17 The Notifying Parties add 
that CAD is generally seen  as a sub -segment of the PLM software market.  
                                                 
9  Case COMP/M.4944 – Oracle/Peoplesoft, paragraph. 18.  
10  Cases COMP/M.4944 – SAP/Business Objects, para graph  16; COMP/M.4987 – IBM/Cognos, para graph  
14; COMP/M.5904 – SAP/Sybase, para graph  28; COMP/M. 7334 – Oracle/Micros, para graph  14; 
COMP/M.7337 – IMS/Cegedim Business, para graph  105. 
11  In Case M.8124 - Microsoft / LinkedIn (2016) , the Commission concluded that, “ it appears that a 
segmentation of CRM software solutions on the basis of the  customer’s size or industry sector is not 
relevant, given that, while there may be some differences in terms of demand, most customers have the 
same requirements and needs (irrespective of their size and industry), and all CRM providers appear 
capable to offer CRM software solutions to all types of customers ”. 
12  Case COMP/ M.3978 – Oracle/Siebel, paragraph 16.  
13  Case COMP/M.3978 – Oracle/Siebel , paragraph  16. 
14  Cases COMP/M.4608 – Siemens/UGS Corporation , paragraph. 10; COMP/M.5763 – Dassault 
Systèmes/IB M DS PLM Software Business, paragraph 16.  
15  Case COMP/M.5763 – Dassault Systemes/IBM DS PLM Software Business, paragraph 17.  
 
 
7 (32) The Notifying Parties argue that: (i) core CAD solutions can be distinguished from 
visual CPQ software applications  because core CAD solutions  do not offer pricing 
and quoting capabilities ; and (ii) core CPQ solutions are different from visual CPQ 
software applications because core CPQ solutions do not offer visualisation tools.18 
(33) The remainder of this section summarises the Notifying Parties’ view on the relevant 
product market definition for visual CPQ software.  
(A) Segmentation of a relevant product market for visual CPQ software based 
on product characteristics  
(34) The Notifying Partie s consider that the areas where competitors seek to distinguish 
themselves are the visualisation/ CAD element of the software , usability, overall 
functionality and service levels . However, the Notifying Parties consider that most 
players competing for the c ustomers serviced by Compusoft and 20 -20 have reached 
similar standard s in relation to these characteristics. Although different approaches  
and features exist across the vaious software solutions, they do not  warrant a 
segmentation into high -end and low -end visual CPQ software.19 Additionally, the 
Notifying Parties indicate that the prices of the solutions offered by the various 
competitors are in a similar range, which further undermines a distinction between 
high-end/low -end offerings .20 
(35) As a result, the No tifying Parties  consider that it is not appropriate to distinguish 
visual CPQ software solutions by high -end and low -end offerings, which they submit 
is in any event not a distinction that is recognised by the industry more generally.21 
(B) Segmentation  of a re levant pro duct market for visual CPQ software based 
on according to industry verticals  
(36) The Notifying Parties submit that visual CPQ software can be used to design 
numerous items across v arious industry verticals, from machine and automotive parts 
to biotec h and furniture or kitchen and bathroom components.22  . 
                                                                                                                                                      
16  See Market Shares: All Software Markets, Worldwide, 2019, Gartner Market Statistics. Gartner, Inc, 
officially known as Gartner, is a technology research and consulting company providing services such as 
research,  consulting, and conferences  in the area of market b enchmarks , rankings, and business metrics 
(see www.gartner.com ). 
17  Form CO, paragraph 95.  
18  Form CO, paragraph 88.  
19  Form CO, paragraph 101.  
20  Form CO, paragraphs 102 – 102.  
21  Form CO, paragraph 104.  
22  The Notifying Parties  further argue that certain market players offer their visual CPQ software across a 
wide range of verticals. For instance, KB Max and Experlogix advertise their software solution to provide 
visual CPQ or CAD with CPQ functionality, inter alia for biotech, building supplies, manufacturing (i.e., 
machinery), kitchen & bathroom and furniture, heavy equipment, modular building, retail space, 
architecture and planning and automotive applications. Similarly, the Notifying  Parties indicate that 
multiple software p roviders, including Compusoft, KB Max, Atlatl and Threekit have in the last few years 
started to refer to these software solutions applicable across the described wide range of industry verticals 
as visual CPQ.  
 
 
8 (37) According to the Notifying Parties, visual CPQ software solutions are fairly 
standardized, as the core functionality required by visual CPQ software solutions is 
the same regardless of the industry vertical in  which the software is used.23 
(38) Furthermore, customers across the various verticals have similar requirements, i.e. a 
software with broad design functionality that can provide configuration, quotation and 
pricing.24  
(39) At the same time, the Notifying Parties note that,  even if some competitors market 
their solutions for a broad spectrum of verticals (e.g. KBMax, Threekit, Experlogix ), 
some software providers , like Compusoft and 20 -20, focus on specific industry 
verticals , to which they direct their mar keting efforts ..25 
(40) In any case, the Notifying Parties maintain that their software solutions can be used 
across the various industry verticals, as well as across the different spaces within 
residential  design  applications, because the functionality of the s oftware does not 
differ significantly. The Notifying Parties note that what differs for the design of 
different products is the respective catalogue content, which can be accessed easily by 
software providers given that the relevant suppliers make their ca talogues available 
for as many software solutions as possible.26  
(41) As a result, the Notifying Parties take the view that a relevant product market for 
visual CPQ software should not be sub -segmented based on the industry verticals  in 
which software solutions are used.  
(B.i) Visual CPQ software for residential interior design applications  
(42) However , considering  in more detail visual CPQ software for residential design 
applications,  the Notifying Parties consider that , within such space,  a dist inction 
could  be made between (i) kitchens, bathrooms and  (other)  furniture and  (ii) 
windows and doors. This is because windows and doors are typically chosen at a 
different stage in a residential design project . The  focus  at that time  is often more on 
architectural features and the exterior design of a building  rather  than on 
configuration of windows and doors based on the design of interiors.  Thus, the 
customers for visual CPQ software relating to windows and doors tend to be 
differen t from the customers for visual CPQ software for kitchen, bathroom and 
furniture.27  
(43) As a result, the Notifying Parties do not seem to disagree with a segmen tation  of 
visual CPQ software  for residential design  between (i) residential interior  design  
applica tions ( including bathrooms and f urniture but not windows and doors) ; and (ii) 
residential exterior design applications  (including  windows and doors) . 
                                                 
23  Form CO, paragraph 100.  
24  Form CO, paragr aph 105.  
25  Form CO, paragraph 107.  
26  Form CO, paragraph 109.  
27  Form CO, paragraph 112.  
 
 
9 (B.ii) Visual CPQ software for kitchen s and b athroom s  
(44) Within visual CPQ software for residential interior design applications, the Notifying 
Parties submit that kitchen and bathroom ( “K&B ”) furniture , rather than (other) 
furniture, has traditionally been the Parties’ focus, as K&B items are generally the 
most customi sable and represent the highest cost in a project. Consequently, the 
demand for visual CPQ software for K&B is greatest among retailers in order to assist 
customers in purchasing decisions.28 
(45) However, the Notifying Parties submit that visual CPQ sof tware for K&B 
applications does not constitute a separate relevant market and instead it belongs to 
the broader relevant market for visual CPQ software for  residential interior design 
space. The Notifying Parties consider that, from a supply -side perspecti ve, there is 
very little differentiation between visual CPQ software for different interior design 
items. Moreover, on the demand side, the product offerings of retailers using the same 
visual CPQ software may comprise not only kitchen s and  bathroom s, but also 
furniture items.29   
(46) As a result, the Notifying Parties take the view that a relevant product market for 
visual CPQ software for residential interior design applications does not need to be 
sub-segmented further and that no separate market exists for visual CPQ software for 
K&B.  
5.2.1.3.  The Commission’s assessment  
(47) The Commission considers that, for the purpose of this decision, visual CPQ software 
constitutes a separate market from core CAD and core CPQ software. As indicated in 
Section 5.1 above, visual CPQ software combines elements that are typical of core 
CAD and core CPQ software. By virtue of such combination, visual CPQ software 
can offer functionalities that go be yond those of core CAD and core CPQ software, 
allowing customers to manage  the entire sales process from visualisation of the 
desired product to providing an exact quotation of the cost to consumers . Therefore, 
the Commission considers that , for the purpos e of this decision,  visual CPQ software 
is a distinct product from core CAD and core CPQ software.  
(48) As regards a possible segmentation of  the relevant market for  visual CPQ software 
based on product characteristics , the results of the market investigation suggest ed that, 
although functionalities can vary from one solution to another, the identification of 
separate relevant markets for high -end and low -end software is not warranted.30 More 
specifically, competitors suggested that  the level of complexity of fu nctionalities and 
visualization requirements in the software depends on the customer’s profile and 
needs, but there is no clear -cut distinction between high -end and low -end visual CPQ 
software solutions.31 Therefore, the Commission considers that, for the p urpose of this 
decision and in line with the Notifying Parties ’ view, it is not necessary to  sub-
segment the relevant market for visual CPQ software based on product characteristics . 
                                                 
28  Form CO, paragraph 114.  
29  Form CO, paragraph 114.  
30  Q1 – questionnaire to visual CPQ software competitors, replies to question 7 and Q2 – questionnaire to 
visual CPQ software customers, replies to question 6.  
31  Q1 – questionnaire to visual CPQ software competitors, replies to question 7.1.1.  
 
 
10 (49) As regards a possible segmentation of the relevant market for visual CPQ software 
based on industry vertical s (e.g. building products, medical devices and equipment, 
mechanical equipment, food  service equipment, specialty vehicles , commercial  
design  or residential exterior or interior design ), the results of the mark et 
investigation were inconclusive . On the one hand, the majority of customers and a 
slight majority of competitors confirmed that the same visual CPQ software can be 
used by customers to design a broad range of different items and spaces.32 However, 
almost  all competitors indicated that a supplier of visual CPQ software speciali sed in 
one industry vertical would not be able to start offering visual CPQ software for 
another industry vertical in a timely manner and at no significant costs.33 In this 
regard, co mpetitors pointed out that requirements are different and solutions for a 
given industry vertical can be very specific, for instance in terms of design and type 
of content that needs to be made available on the software.34 In any case, for the 
purpose of th e present decision, the Commission considers that it can be left open 
whether there is a relevant market for all visual CPQ software  or separate markets 
for visual CPQ software  based on industry verticals.  Under both these plausible 
relevant market definit ions, the proposed Transaction does not rise to serious doubts 
as to its compatibility with the internal market.   
(50) Residential interior design is one of the industries where visual CPQ software can be 
used.  Both 20 -20 and Compusoft offer visual CPQ softwa re for residential interior 
design applications. The Commission has examined whether within visual CPQ 
software for interior design applications, a separate relevant market exists for visual 
CPQ software for K&B. During the market investigation, customers submitted that 
the same visual CPQ solution can be used to design different residential interior items 
including  kitchens, bathrooms and  other  furniture.35 On the supply side, one 
competitor noted  that visual CPQ software providers usually speciali se on only one or 
two residential interior items, e.g., kitchens .36 However  almost all competitors 
submitted that a supplier of visual CPQ solutions speciali sed on specific items within 
the residential interior design space (e.g. , K&B) could start offering such software for 
other items (e.g. , furniture) timely and at no significant costs37 even if one competitor 
pointed out that K&B furniture is “ usually more complex, therefore more expensive” 
compared to other furniture “ which needs less functionalities”.38 
(51) In that context , some competitors also pointed out that such switch between industry 
verticals may require some efforts  as they considered that getting access to the 
relevant catalogue content for the new residential interior items  is an important 
necessary step . However, no consistent and precise quantification of such efforts was 
provided.  
                                                 
32  Q1 – questionnaire to visual CPQ software competitors, replies to question 3 and Q2 – questionnaire to 
visual CPQ software customers, replies to question 4.  
33  Q1 – questionnaire to visual CPQ software competitors, replies to question 4.  
34  Q1 – questionnaire to visual CPQ software competitors, replies to question 4.1.  
35  Q2 – questionnaire to visual CPQ software cus tomers, replies to question 5.  
36  Q1 – questionnaire to visual CPQ software competitors, replies to question 5.1.  
37  Q1 – questionnaire to visual CPQ software competitors, replies to question 5.  
38  Q1 – questionnaire to visual CPQ software competitors, re ply to question 7.1.1.  
 
 
11 (52) In light of the above, the Commission considers that , for the purposes of this decision, 
it can be left open whether there is a relevant marke t for visual CPQ software for 
interior design applications or a separate market for visual CPQ software for K&B.  
Under both these plausible relevant market definitions, the proposed Transaction does 
not give rise to serious doubts as to its compatibility with the internal market.  
5.2.1.4.  Conclusion  
(53) In conclusion, for the purpose of the present decision, the Commission considers that  
it is not necessary to draw a distinction within visual CPQ so ftware based on product 
characteristics . As regards the other possible segmentations, the Commission 
considers that, for the purpose of this decision, the product market definition in 
relation to the provision of visual CPQ software solutions  can be left open, as the 
Transaction does not give rise to serious doubts as to its compatibility with the 
internal market regardless of whether there is an overall market for visual CPQ 
software applications , a market for visual CPQ software applications per industry 
verticals or a market for visual CPQ software applications for K&B.  
5.2.2.  Geographic market definition  
5.2.2.1.  Commission’s precedents  
(54) In previous decisions,  the Commission has never considered the  geographic scope of 
a relevant market for the  provision of visual CPQ software and its possible sub -
segments. The Commission , however , has foun d that the relevant  market s for EAS, 
for CRM and  for PLM software solutions  are at least EEA -wide in scope. This is 
because there are no significant differences in sourcing patterns or product 
requirements for customers in the EEA and the rest of the world. Customers are 
equally able to procure CRM and PLM software in the EEA as in the rest of the 
world.39    
5.2.2.2.  The Notifying Parties’ view  
(55) The Notifying Parties submit that , in line with the Commission’s previous decisions 
on the CRM and PLM markets, the ma rket for visual CPQ software and its various 
plausible sub -segmentations is worldwide or at least E EA-wide.40 
(56) First, the Notifying Parties consider that customer demand and software products 
themselves do not vary substantially across different regions.41  
(57) Second, language differences do not generally pose an issue, as translating the 
relevant part of a software into an additional language does not require significant 
time. Likewise, including a sufficient amount of regional content through catalogues 
of the relevant regional manufacturers typically takes  less than six months.42 
                                                 
39  See for example: Cases COMP7M.3978 – Oracle/Siebel and COMP/M.4944 – SAP/Business Objects.  
40  Form CO, paragraph 126.  
41  Form CO, paragraph 119.  
42  Form CO, paragraphs 120 – 121.  
 
 
12 (58) Third, it is not necessary for a visual CPQ software supplier to be physically present 
in a region in order to offer its software . The software  can be downloaded from 
anywhere in the wo rld and service support is typically provided online or via phone.43 
In any case, establishing a new team in a new geography does not require significant 
time and costs.44 In that respect, the Notifying Parties explain that differences in the 
geographic foot print of software providers are mostly a matter of marketing and sales 
focus . These differences do not constitute evidence of  barriers that  would  prevent 
players from offering visual CPQ software in different geographies .45 
(59) In any case, the Notifying Partie s submit that the relevant geographic market 
definition can be left open, because the Transaction does not give rise to competition 
concerns  regardless of the precise geographic market delineation . 46 
5.2.2.3.  The Commission’s assessment  
(60) The result s of the market investigation confirmed that the geographic market 
definition for visual CPQ software, including for residential interior design and K&B 
applications, is worldwide  or at least EEA -wide.47 The majority of competitors 
submitted that there are no specific lang uage nor regulatory barriers preventing a 
visual CPQ software provider from supplying such software in a different region, 
although some competitors pointed out that access to the relevant  local catalogue 
content is key in this regard .48 
5.2.2.4.  Conclusion  
(61) For the purpose of this decision, the Commission considers  that the relevant 
geographic market for the provision of visual CPQ software, including for residential 
interior design and K&B applications, is at least EEA -wide.  The Commission 
considers that the exact g eographic market definition can be left open , as the 
Transaction does not give rise to serious doubts as to its compatibility with the 
internal market regardless of whether the market is EEA -wide or worldwide . 
6. COMPE TITIVE ASSE SSME N T 
6.1. Analytical framework  
(62) Under Article 2(2) and (3) of the Merger Regulation, the Commission must assess 
whether a proposed concentration would significantly impede effective competition in 
the internal market or in a substantial part of it, in particular through the creation or 
strengthening of a dominant position.  
                                                 
43  Form CO, paragraph 122.  
44  Form CO, paragraph  124. The Notifying Parties estimate the initial costs to amount to less than EUR 150 
000 per year.  
45  Form CO, paragraph 123.  
46  Form CO, paragraph 127.  
47  Q1 – questionnaire to visual CPQ software competitors, replies to question 8 and Q2 – questionnaire  to 
visual CPQ software customers, replies to question 7.  
48  Q1 – questionnaire to visual CPQ software competitors, replies to questions 9 and 9.1.  
 
 
13 (63) In this respect, a merger may entail horizontal and/or non -horizontal effects. 
Horizontal effects are those deriving from a concentration where the undertakings 
concerned are actual or potential competitors of each other  in one or more of the 
relevant markets concerned. Non -horizontal effects are those deriving from a 
concentration where the undertakings concerned are active on different relevant 
markets.  
(64)  The Commission appraises horizontal effects in accordance with the  guidance set out 
in the Horizontal Merger Guidelines49 while non -horizontal effects are appraised in 
accordance with the guidance set out in the Non -Horizontal Merger Guidelines.50  
(65) A merger between companies that are potential or actual competitors may 
significantly impede effective competition , in particular  as a result of the creation or 
strengthening of a dominant position. The concept of dominance is defined as “ a 
situation where one or more undertakings wield economic power which would enable 
them to prevent effective competition from being maintained in the relevant market by 
giving them the opportunity to act to a considerable extent independently of their 
competitors, their customers and, ultimately, of consumers ”51 and t here are two main 
ways in whi ch the creation or strengthening of a dominant position  may significantly 
impede effective competition: (i) by eliminating important competitive constraints on 
one or more firms, which consequently would have increased market power (non -
coordinated effects ); (ii) by changing the nature of competition in such a way that 
firms that previously were not coordinating their behaviour, are now significantly 
more likely to coordinate and raise prices or otherwise harm effective competition, or 
by making coordinatio n easier (coordinated effe cts).52  
(66) Non-coordinated effects may arise if a merger removes competition between the 
merging firms, who consequently have increased market power. Non -merging firms 
in the same market can also benefit from the reduction of competi tive pressure, since 
the merging firms' price increase may switch some demand to the rival firms, which, 
in turn, may find it profitable to increase their prices. The reduction in these 
competitive constraints could lead to significant price increases in t he relevant 
market.53  
(67) In order to assess whether significant non -coordinated effects are likely to arise from 
a merger, the Commission takes into consideration a number of factors, that include 
the merging firms’ market shares, whether or not they are clos e competitors, the 
customers’ possibilities to switch supplier, the ability of competitors to increase 
supply and to expand post -transaction and whether the merger eliminates an important 
competitive force.  
(68) When assessing horizontal mergers, the Commission  also considers to which extent 
customers will be in a position to counter the increase in market power of the merged 
                                                 
49  Guidelines on the assessment of horizontal mergers under the Council Regulation on the control of 
concen trations between undertakings ("Horizontal Merger Guidelines"), OJ C 31, 05.02.2004.  
50  Guidelines on the assessment of non -horizontal mergers under the Council Regulation on the control of 
concentrations between undertakings ("Non -Horizontal Merger Guidel ines"), OJ C 265, 18.10.2008.  
 
51  Horizontal Merger Guidelines, paragraph 2.  
52  Horizontal Merger Guidelines, paragraph 22.  
53  Horizontal Merger Guidelines, paragraph 24 . 



 
 
17 leading to combined market s share of less than 30% in the EEA  in both possible 
markets . As a result, the Notifying Parties note that the Transaction does not 
significantly change the structure of the market.62  
(77) Second, the Notifying Parties  consider that , in the affected markets, software 
providers only fac e low barriers to entry or expansion .  T here are no legal or 
regulatory requirements that must be met, nor product certification procedures or IP 
rights t hat suppliers must  have in order to start supplying visual CPQ software.63  In 
particular, the Notifyin g Parties submit that (i) CAD software providers and visual 
CPQ software providers for other industry verticals could swiftly and at modest costs 
start supplying visual CPQ software for K&B applications , and (ii) p ure CAD 
software providers can offer add-ons which enable users to add CPQ functionalities to 
the CAD solution  and consequently compete w ith visual CPQ software providers.64   
(78) To effectively enter into the visual CPQ software segment for residential interior 
design as well as K&B applications, a new entrant would need to include content to 
be used within the software tool, namely the relevant manufacturers’ catalogues . The 
Notif ying Parties submit that although obtaining and converting such catalogues  
would require some investments in terms of working hours, most manufacturers of 
interior design products make their catalogues  available freely and on a non -exclusive 
basis across Europe . According to the Notifying Parties, new entrants would not need 
to invest significant time and resources to collect and convert from scratch a 
sufficiently large catalogue of customizable residential interior furniture  whether for 
K&B or other appli cations .65  According to the Parties, this situation would be 
confirmed by the fact that there have been recent new entrants in the visual CPQ 
segment , in particular  for K&B applications, especially from the CAD space.66   
(79) Third, the Notifying Parties submit  that customers have buyer power that  would allow 
them to resist any attempts of price increase by the Combined Entity . In particular, 
20-20 and Compusoft generate most of their revenues from large manufacturers such 
as [Customers] , who exert significant p ressure on the Parties during negotiations. In 
addition, retailers and dealers are often members of buying groups or franchise 
networks who also have  considerable negotiating power.67 
(80) Fourth, the Notifying Parties argue that in the affected markets, it is e asy for 
customers to switch software suppliers . The Notifying Parties note that competitors of 
the Combined Entity market their products widely and offer training to support 
customers switching.    
6.4.2.  The Commission’s assessment  
(81) The Commission considers that the Transaction does not give rise to serious doubts as 
to its compatibility with the internal market in relation to the horizontal overlaps 
between the activities of 20-20 and Compusoft in the potential markets for (i) visual 
CPQ software for residential interior design applications  in the EEA , and (ii) visual 
                                                 
62  Form CO, paragraphs 148 – 149 and 152 – 154. 
63  Notifying Parties’ response to the Commission’s RFI No 1, reply to question 16.  
64  Form CO, paragraphs 151 and 158.  
65  Notifying Parties’ response to the Commission’s RFI No 1, reply to question 16.  
66  Notifying Parties’ response to the Commission’s RFI No 2, reply to question 11.  
67  Form C O, paragraph 155.  
 
 
18 CPQ software for K&B applications  worldwide or in the EEA for the reasons 
explained in the remainder of this Section . As the relevant arguments equally apply to 
all affected markets, the Commission h as focused its assessment on the narrowest 
possible markets , namely the one for visual CPQ software  for K&B applications.    
(82) First, as indicated in Section 6.2 above, the Parties’ combined market shares will 
remain below 30%  ([20-30%]  worldwide and [20-30%]  in the EEA ) in the narrowest 
possible market for visual CPQ software for K&B applications . Those market shares 
have been stable over time as they respectively stood at [20-30%] for 2019 and [20-
30%] for 2018  (worldwide ) and [20-30%] for 2019 and [20-30%] for 2018  (in the 
EEA) .  
(83) Second, the increment contributed by 20 -20 was [5-10%] in visual CPQ software for 
K&B applications  in the EEA in 2020 . 20-20’s market share has been stable over the 
recent past in the EEA as it stood at [5-10%] in 2019 and [5-10%] in 2018 .68 
(84) Third, the Parties are not close competitors  in the affected markets because they have 
different geographic footprints  Compusoft has focuse d primarily on developing its 
activities in Europe while 20-20 has primarily been focused on the Americas .69 
Indeed, 20-20 is a US -based business  that ge nerated more than [70-80%] of its overall 
revenue in 2020 from customers in North America and , through its recent acquisition 
of Promob70 (from Brazil), e xpanded into South America, where it generated a further 
[10-20%] of its revenues. While 20-20 offers its full suite of software solutions for 
commercial and professional space planning  in the US, i n Europe, where 20 -20 
started its activities through the acquisition71 in 2008  of Planit Fusion , it continues to 
mostly offer the software solutions that it acquired  i.e., visual CPQ softw are for 
residential interior design applications . 
(85) Fourth, the Combined Entity will continue to face strong competition  both at 
worldwide level and  in the EEA in particular, but not only, from SHD72 and Carat73, 
their closest competitors both large and well established74 players from Germany , as 
well as from a series of other smaller but internationally active competitors like, 
                                                 
68  In the potential market for virtual CPQ software for K&B applications, 20 -20’s market share is higher 
([10-20%] in 2020; [10 -20%] in 2019; and [10 -20%] in 2018).  This is because of 20 -20’s larger presence 
in the Americas.  However, the combined market  share of the Parties in virtual CPQ software for K&B 
applications would be limited to [20 -30%]  in 2020 (down from [20 -30%] in 2019 and [20 -30%] in 2018).  
69  Form CO, paragraph 210.  
70  Promob is a leading provider of software solutions in  Latin America with interior space planning 
applications, solutions and content tailored for designers, architects, retailers and manufacturers. Promob 
operates and has offices in multiple countries, including , among others,  Argentina, Colombia, Peru, 
Mexico  and South Africa . 
71  Planit Fusion was the retail design business of the United Kingdom -based Planit Holdings Limited. Planit 
Fusion offers interior design programs that combine design features with essential sales manage ment tools 
to provide total support for businesses, including kitchens, baths and bedrooms.  
72  The Notifying Parties estimate SHD’s  market share to be between [10 -20%] (worldwide market/segment 
for vCPQ software for residential interior design applications) and [20 -30%] (EEA market/segment for 
vCPQ software for K&B applications) depending on the segment and on the geography considered.  
73  The Notifying Parties estimate Carat’s market share to be between [5 -10%] (worldwide market/segment 
for vCPQ  software for residential interior design applications) and [10 -20%] (EEA market/segment for 
vCPQ software for K&B applications) depending on the segment and on the geography considered.   
74  SHD describes itself as “ the leading provider of IT solutions an d services for the furniture and kitchen 
industry for 35 years ”, see https://www.shd.de/shd/ .  
 
 
19 among others75, Dassault Systèmes from France (with their Hom eByMe software) , 
Imos AG from Germany  and SIMSA from Spain (with their Teo win software 
application).76 
(86) SHD with its daughter companies (SHD KPS in Germany, SIMAR in the BeNeLux, 
Transtechnology in France and Spain, and TESY in Italy ) has been active in the 
industry for over 25 years  and d escribes itself as “ one of the leading Eur opean 
supplier for Visual CPQ Software selling their different solutions directly to kitchen 
and furniture retailers as well as to manufacturers with own retail chains ”.77 
(87) As regards Carat, it describes its activities as “ very comparable to those of 20 -20 and 
Compusoft ” and explains that Carat applications offer “ 3D design capabilities, 
business transactions and workflow support for many related processes ” to 
“approximately 6.500 customers worldwide ” in “ 15 different languages ”.78 
(88) Dassault Systèmes  is listed  on the Paris Euronext Stock Exchange, employs more than 
20,000 employees across its various subsidiaries, generates over EUR 4 billion in 
annual turnover and provides, on pan -European basis, the Home ByMe software for 
which they have a strong focus on deve loping 3D technology and capabilities.79  In 
addition, Inspi, another product initially developed by Dassault Systèmes and now a 
partner of HomeByMe, is also focused on the kitchen, bath and furniture segments 
with a complete solution including 500 digital catalogues and 65,000 3D models 
across 60 manufacturers.80 
(89) Imos AG develops “specialist software solutions for the furniture and interiors 
industry supplying companies worldwide (currently 90 countries) with CAD, CAM 
and POS software to aid their design, ma nufacturing and distribution processes ”. 
Imos’ users include small and medium -sized companies that manufacture highly 
bespoke items as well as leading mass producers in the industry.81 
(90) SIMSA, with their Teowin software solution (which is a 3D software speci alised in 
interior design, with a focus on K&B), started in Spain but has an international 
presence through its dealer network such as in Spain, Portugal and France with 
software available in Spanish, English, French and Portuguese. It also has developed a  
presence in Latin America (Mexico, Argentina and Colombia) and in Tunisia.82  
                                                 
75  Configura from Sweden is another smaller competitor that “ sell[s] into all countries of the EEA ”, see Q1 – 
questionnai re to com petitors – replies to question 1.  
76  Notifying Parties’ response to the Commission’s RFI No 3, Annex 1.  
77  Q1 – questionnaire to competitors – replies to question 1 . 
78  Q1 – questionnaire to competitors – replies to question 1 . 
79  Dassault Systèmes describes itself as “ a world leader in 3D -model and engineering software ” (see 
https://www.3ds.com ). 
80  See https://www. inspi3d.com/en/solutions/inspi -online -space -planning/ . 
81  Q1 – questionnaire to com petitors – replies to question 1. 
82  See https://teowin.com/en/dealers/ .  
 
 
20 (91) Fifth, various players have either entered or expanded into, in particular, the possible 
market for K&B applications  such as Marxent83 (US), Houzz84 (US), Kozikaza85 
(France) and AiHous e86 (China) . While multiple companies have expanded into the 
affected visual CPQ markets , new entrants have developed as a result of the easier 
collection and inclusion of manufacturers’ catalogues over the last few years.  
(92) Sixth, customers’ costs for  switching v isual CPQ providers are limited and will 
remain unaffected by the Transaction . In the Commission’s market investigation 
customers generally submitted that the time and cost required for customers to switch 
to a different supplier of visual CPQ software depends on the size of the business 
concerned , the size of the catalogues in the software  and the user interface  but that, on 
average,  it take s 6 month to one year . In terms of the outlays, customers indicated that 
they can amount to a few thousan ds EUR per sales associate87 to several millions 
overall in the case of large companies with tens or hundreds of retail outlets.88  
Several  competitors also confirmed that customers could switch to an alternative 
supplier in a timely manner and at no signifi cant costs .89 
(93) A number of respondents  to the Commission’s market investigation  raised concerns 
indicating that the Combined Entity would enjoy market shares, which , according to 
their own estimation, would exceed 50% in the EEA.90  The Commission undertook a 
market reconstruction exercise by asking the Parties’ main competitors for their own 
revenue figures. The Commission conclude s that it cannot exclude that the Notifying 
Parties overestimated91 the market shares of their various la rgest competitors  in the 
                                                 
83  While Marxent has historically focused on 3D visualisation solutions for large US -retailers  with focus on 
furniture. More recently, it has entered Europe by partnering with  companies such as John Lewis and 
Kingfisher and now operates offices in London,  Paris and Leipzig. Apart from opening offices an d 
partnering with larger European  retailers, Marxent also developed its software tools to cover all products 
offered by its  partners, i.e. including kitchens and bathrooms.  Marxe nt describes itself as the “#1 3D 
visual configuration solution for designing and selling entire rooms online ” with “ proven solutions for 
kitchen, bath, furniture, and outdoor ” (see https://www marxentlabs.com/international -offices/ ).  
84  Houzz is already available i n Denmark, Germany, Spain, France, Ireland, Italy, the Netherlands and 
Sweden. Houzz has raised over USD 650 million in funding since its start in 2009 and is now preparing 
for an IPO, which will provide additional resources for its expansion plans (see 
https://www.proremodeler.com/big -plans -houzz -company -preps -ipo). 
85  Kozikaza describes its services as “ an architecture software that helps easily design 3D home plans for 
free, i n a few minutes, from any computer and for any type of project such as kitchens, bathrooms, etc. ” 
(see https://www kozikaza.com/en/3d -home -design -software ).  
86  AiHouse is a Chinese -based 3D online design software business claiming to have 2,000 employees, of 
which, over 1,000 are developers dedicated to creating their offering. AiHouse’s offering is supported by a 
large customer base (over 1 million users) and deep content database (over 3 0 million 3D 
products/images/items). AiHouse is also positioning itself as a designer tool and claims to have more than 
2.5 million interior designers using their tool  of which already 4% in France. AiHouse’s website is already 
available in English, Spanis h and French  (see https://www.aihouse.com/news/2020 -AiHouse -Review -22). 
87  Such outlays include, among others, equipment upgrade costs as well as sales and support teams training 
costs.  
88  Q2 – questionnaire to customers – replies to question 10 . 
89  Q1 – questionnaire to competitors – replies to question 11.  
90  Q1 – questionnaire to competitors – replies to question 15.1.  
91  In that respect, the Notifying Parties explain that “TA Associates and Compusoft had engaged a third -
party consultant, [consultant]  to undertake market research […]. [The consultant’s]  findings were based 
on public information as well as information gathered during interviews with various market players. As 
with any industry reports, [The consultant]  was not able to gather and present a n absolute and accurate 
reflection of the market and subsequently undertook further work to improve on its data estimates ” 
(Notifying Parties’ response to the Commission’s RFI No 4, reply to question 2) .  
 
 
21 affected markets.  However, even based on the market reconstruction exercise of the 
Commission, the Parties’ combined share would remain below 40% in the affected 
markets and several rivals would continue to exert competitive const raints on the 
Combined Entity post -Transaction including the  same  alternative suppliers described 
in paragraphs (85) to (90)  with SHD and Carat leading the front . 
(94) Some respondents  further argued that b arriers to entry/expansion would be high in the 
affected markets.  These respondents noted that significant time and investments are 
required for software suppliers to get access to catalogue content of furniture 
manufacturers described by those respondents as an essential input to compete on the 
market .92  The results of the Commission’s investigation revealed that the 
developments that have taken place in the market over the last few years  have 
facilitated the access  to catalogue content for v isual CPQ software providers for the 
following main reasons . 
(95) In the first place, a  large part of raw catalogue/content data is provided in a 
standardized format known as “IDM” which stands for “Integrated Data Model”. 
Most German manufacturers and a number of manufacturers from other Member 
States93 publish their IDM files (including their updates) on their respective websites 
or via a data platf orm called Cat@web .94 These IDM files contain details about 
products offered along with their respective configurations of each manufacturer.95 
Industry participants who wish to gain access to IDM catalogues can do so by 
registering through the Cat@web porta l which contains all relevant information about 
the IDM catalogues, the data distributors, and the software companies registered to 
use that data.  
(96) Once registered, the member will indicate its wishes to register with a number of 
manufacturers and will be introduced to these manufacturers who can then decide to 
allow the registered member to access their data. Anyone who has successfully 
registered with a manufacturer can download the relevant data and use it to create the 
respective manufacturer catalogue.  This applies whether the applicant is a new entrant 
or an established player.96 The registration process is free of charge and all IDM 
catalogues can be downloaded at no cost.97 
                                                 
92  Q1 – questionnaire to competitors – replies to q uestion 14.1. and Q2 – questionnaire to customers – 
replies to questions 12.1 and 13.1.  
93  As the German manufacturers are Europe’s largest and most important kitchen and bathroom 
manufacturers, with significant exports outside of Germany, their use of the  IDM format has led to a 
wider adoption by manufacturers internationally and has now become Europe’s most us ed data format in 
the industry, also by some of the biggest manufacturers in other European countries (e.g., Santos who is 
the second largest manufa cturer in Spain, Arrital and Valcucine from Italy) who all use the IDM format 
for their catalogue data across Europe.  
94  See https://www.catatweb.de . 
95  Notifying Parties’ response to the Commission’s RFI No 4, reply  to question 2.  
96  The access is usually granted within a day, sometimes within hours. The application process is highly 
standardized and legitimate users do not need to establish a business relationship with the manufacturers 
to obtain access to the manuf acturers’ IDM files through this platform.  
97  New entrants are not subject to stringent selection criteria, they merely need to demonstrate that they i) are 
a bona fide company with applications for interior design of residential spaces like K&B, and ii) have a 
footprint of design applications available in the market where the manufacturer’s products are available 
for sale.  
 
 
22 (97) In the s econd  place , software providers can also become members of the Data 
Com petence Center (“DCC”) which is a European industry group open to anyone.98  
As DCC member s, software editors will be able to access IDM data and import it into 
their software .  DCC members are also given access to a software solution that allows 
IDM data processing free of charge.  DCC Members are also entitled to contribute to 
the data changes and additions, and are provided with a forum to introduce 
themselves when they firs t launch software products . 
(98) Based on their prominence in the industry,  German manufacturers ’ turnover 
represents approximately a bit less than half of the K&B furniture market share in 
Europe99 Considering, as already indicated, that 90% of German manufactu rers use 
the IDM file format/DCC as distribution platform, any player who is active in visual 
CPQ software or plans to enter this space has access to catalogue content accounting 
for 40 -45%100 of K&B furniture in Europe without needing to establish a direct 
relationship with any of the furniture manufacturers.101  
(99) In the t hird place , there are many alternative industry groups and platforms which any 
software editor can easily access in order to obtain catalogue/content data such as the 
ARGE Neue Medien102 which i s an alliance of more than 100 brand manufacturers 
from the HVAC (heating, ventilation and air conditioning) industry and which 
organizes the quality management of product data as well as the standardization of 
data standards and formats  for inputs into th e K&B design industry such as all kinds 
of radiators, ventilators, extractors, etc . All their members103 provide their catalogue 
data in a standard  format  which has become one of Europe’s most prevalent data 
formats in the bathroom industry  for instance .104 
(100)  In the f ourth  place , the Commission’s investigation has additionally confirmed that 
manufacturers “ usually seek to make the catalogues available to as many vCPQ 
providers as possible ” given that “ each vCPQ provider services new customers ” the 
manufacturer “ would like to be able to sell their products to ”.105  
                                                 
98  Against a fee and acceptance of the membership by the board of the DCC . 
99  Notifying Parties’ response to the Commission’s RFI No 4 , reply to question 2.  
100  This percentage does not include other K&B furniture manufacturers from Spain and Italy that also make 
their catalogues freely available through the IDM format.  
101  In that respect, the Notifying Parties argue that 20 -20 has built  its business in Europe without always 
accessing manufacturers directly, but via the license agreement with [competitor]  (which included the use 
of [competitor]’s  catalogue content). Since the end of the license agreement with [competitor] , 20-20 was 
able to quickly gain access to the European manufacturer catalogues as a result of its DCC implication and 
through the cat@web platform. As a result of this catalogue access, the Notifying Parties submit that 20 -
20 has been able to maintain its content and rela ted services to its customer base outside of the DACH 
region using these IDM based catalogues.  
102  A list of the members and brands using the format is available at the following website: 
https://www.arge.de/en/arge -en/our -members/ . 
103  The data of numerous non -German European manufacturers (e.g., Vasco and Ideal Standard in Belgium, 
Roca and Salgar in Spain, Catalano and GSI in Italy) is also available . 
104  IGH, a Swiss bathroom catalogue po rtal which provides commercial and graphical (“BIM”) data free of 
charge , is another platform . BIM as a standard is also more and more widely used (especially in the 
building industry) and allows a wider range of systems to use supplier data. BIM is not co nfigurable, but it 
is well integrated into the wider CAD world  (see https://igh.ch/kataloge html ).  
105  Reply of a large German manufacturer to the market investigation.  
 
 
23 (101)  Consequently, in addition to the channels identified above and which make the access 
to raw catalogue/content data easy and efficient with minimum investment required, 
any software editor, whether they ar e a new entrant or small player, can also access 
such data directly from the manufacturers (in a standard format such as IDM or 
unstructured such as Excel or PDF file). They can do so by directly contacting the 
manufacturers who proactively provide their c atalogue data to the software companies 
directly with some manufacturers publishing such data sets on their websites . 
Manufacturers often provide multiple software editors with direct access to their 
catalogue data simultaneously via email or any other for m of electronic 
communication.  
(102)  In the market investigation, some competitors nevertheless submitted that post -
Transaction, the Combined Entity would have a competitive advantage vis -a-vis its 
rivals because it would have access to a large trove of catalog ue content/data from 
various manufacturers.106  However, the competitors of the Combined Entity also 
have access to significant catalogue content and in some cases, earlier than their 
rivals.107     
(103)  Finally, any supplier of visual CPQ software (including new e ntrants)  can create a 
catalogue of a manufacturer with whom they do not have any relationship, since  it is 
possible to download a brochure of the manufacturer from their website and create a n 
up-to-date catalogue  as u pdates are also typically published on the manufacturers’  
website.  
(104)  On the basis of the above, the Commission  considers that  the results of its market 
investigation have confirmed that software providers generally benefit from an ease of 
access to manufacturer s catalogues ’ content in different ways108 and are therefore able 
to enter or expand in any of the affected markets .109  
(105)  For all the above reasons, the Commission concludes that the Transaction does not 
give rise to serious doubts as to its compatibility with the internal market with respect 
to possible non-coordinated horizontal effects on (i) visual CPQ software for 
residential interior design  applications  in the EEA , or (ii) visual CPQ software for 
K&B applications worldwide or in the EEA.  
                                                 
106  Q1 – questionnaire to competitors – replies to question 12.1.  
107  SHD, for instance, indicates that it has “ over 500 records of catalogues in multiple languages ” (see 
https://www.shd.de/planung -visualisierung/produktda ten/?L=632 ). Carat further indicates a “ high degree 
of collaboration with industry ” and that “ catalogues are made available early ”, are “ available in several 
languages ” with “ online updates ” (see https://www.carat -online.com/products/carat -kitchen -design -
software/carat -features/ ).  
108  In that context, the Notifying Parties submitted that approximately 80% of the raw data in Europe is freely 
available for software providers a structured format (e.g., excel, via standardized formats like IDM, 
ARGE, etc .) and the remaining 20% is freely available in an unstructured (e.g., PDF) format.  
109  In that context, i t is worth noting that with respect to actual processing of the catalogue content/data  (once 
accessed) , while this step has been for a long time the only material way in which software editors could 
try to differentiate themselves from one another by devel oping their own proprietary tools and techniques, 
the scope for such differentiation/competitive advantage by software editors has been significantly eroded 
by the growing standardization of most raw manufacturer catalogue data. This standardization means that 
the raw data can be converted to digital format ready for deployment by software editors’ applications 
extremely quickly/easily with limited effort/investment by the software editors.  
 
 
24 7. CONCLUSION  
(106)  For the above reasons, the European Commis sion 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  
Executive Vice-President