CHAPTER XI MERGER SIMULATION A. Introduction to Merger Simulation Merger simulation is a potentially useful way to generate a quantitative prediction of the likely unilateral price effects of a proposed merger.1 The basic idea is to combine what can be easily observed, such as prices and shares, with reasonable assumptions about behavior of market participants, in a manner that allows the calculation of the implied unilateral effects. Merger simulation can illuminate what matters in determining the unilateral effects of a merger, how it matters, and how much it matters. This chapter discusses the strengths and weaknesses of merger simulation generally, and of specific models used in merger simulation. Merger simulation has been used mainly with differentiated consumer products, and this chapter examines three models of consumer demand that have been used in that context. For non-economists this may be a somewhat technical discussion. The first four sections of this chapter, however, provide non-technical introductions to 1) the concept of merger simulation and its proper use, 2) unilateral merger effects with differentiated consumer products and the role of demand elasticities, 3) three models of consumer demand that have been used in merger simulation with differentiated consumer products, and 4) the pros and cons of these three models in merger simulation. Because tractable economic modeling never fully captures real-world competitive processes, the ultimate test for the reliability of merger simulation is how well it predicts the effects of actual mergers. Regrettably, little is known about that accuracy, nor about the accuracy 1. As explained below, combining the merging firms, and hence internalizing the competition among their merging products, may alter profit incentives and cause the merged firm to raise prices or reduce output without any sort of coordination with competitors. 265 NYDOCS:19868.1 266 ECONOMETRICS of any other method for predicting the competitive effects of mergers. For now, the reliability of merger simulation must be judged on the basis of “fit” between the model and the industry. Merger simulation with differentiated consumer products employs the Bertrand oligopoly model. The Bertrand model assumes competitors interact just once, each maximizing its short-run profit, with price as the sole dimension of competition. Bertrand equilibrium is reached when all competitors are happy with their prices, given rivals’ prices.2 The Bertrand model should be employed in the competitive analysis of mergers only when its proponent is prepared to persuade the trier of fact that the model comports reasonably well with the factual setting of the industry.3 Assessing the “fit” between the Bertrand model and real world economic conditions is largely a matter of evaluating how well it explains the past. One important aspect of fit is the degree to which the predicted price-cost margins, which characterize the intensity of competition, correspond to observed margins. Also important is how well the model would have predicted responses to significant cost changes or new product introductions occurring in the recent past. Finally, it is important to evaluate the role of non-price competition, e.g., advertising and product positioning, as well as the strategic behavior in repeated competitor interaction, all of which are outside the model. Merger simulation holds such things as product characteristics and advertising constant, which can result in misleading predictions, particularly if aspects of marketing strategy interact in important ways with pricing. Merger simulation also examines only the unilateral incentive that may exist for the merged firm to raise price.4 If some form 2. 3. 4. For a discussion of the Bertrand model, see DENNIS W. CARLTON & JEFFREY M. PERLOFF, MODERN INDUSTRIAL ORGANIZATION 166-72 (3d ed. 2000). For further discussion of when the Bertrand model fits the industry well enough to offer useful predictions, see Gregory J. Werden, Luke M. Froeb & David T. Scheffman, A Daubert Discipline for Merger Simulation, ANTITRUST (forthcoming 2004). “Unilateral effects” may occur when products produced by the merging parties are close substitutes in consumption. The merger may create a significant incentive to raise the prices of products that had been sold separately, if a substantial proportion of the sales lost by one merging NYDOCS:19868.1 MERGER SIMULATION 267 of pricing coordination (e.g., overt collusion) is likely exist before the merger, or arise as a result of the merger, merger simulation may not offer any useful insights to the merger’s competitive effects. If the Bertrand model reasonably approximates competitor behavior before and after a merger, simulation may be helpful in gaining insight into likely post-merger price changes. Merger simulation can provide reasonable, if rough, estimates of a differentiated products merger’s price effects. Merger simulation is good tool to have, but it should not always be used, and it is never the only tool required. Significant weight should be placed on the predictions of a merger simulation only if the modeling assumptions and the simulation predictions are consistent with the picture of the competitive landscape painted by the totality of the evidence. Merger simulation can usefully complement a traditional, factintensive analysis of consumers, competitors, and the institutional setting of an industry, but cannot substitute for it. B. Unilateral Effects Analysis and the Role of Demand Elasticities The basic idea of unilateral effects from differentiated products mergers is straightforward: Prior to a proposed merger, the producers of Brands A and B presumably are happy with their prices, given the prices of rival brands. Thus, a small price increase would reduce profits because the revenues lost from the resulting sales reduction would exceed the cost reduction associated with producing less. If Brands A and B compete, and the price of either is raised, some of its customers would switch to the other product. The merger of the producers of Brands A and B would alter the profit-maximization calculus, because some of the sales lost from increasing the price of either brand would be regained by the other merging brand. The merged firm would internalize the competition between Brands A and B and create an incentive to raise prices for both (assuming the merger did not also reduce costs).5 The strength of the incentive to increase prices depends on the intensity of competition between the merging brands, and between those 5. product due to a higher price flow to a product that the merger brings under common ownership. Unilateral competitive effects with differentiated products are explained by Jonathan B. Baker, Unilateral Competitive Effects Theories in Merger Analysis, ANTITRUST, Spring 1997, at 21, 23. NYDOCS:19868.1 268 ECONOMETRICS brands and other products. In a Bertrand model with differentiated products, intensity of competitive interaction is indicated by “own and cross elasticities of demand.” An own elasticity of demand indicates responsiveness to a product’s own price. The own elasticity for Brand A can be defined as the percentage change in A’s quantity demanded resulting from a one percent increase in A’s price. Cross elasticities of demand indicate responsiveness to changes in the other products’ prices. The cross elasticity of demand for Brand A with respect to Brand B’s price can be defined as the percentage change in the quantity demanded for A that would result from a one percent change in the price of B. Any pair of products has two cross elasticities, indicating the responsiveness of the demand of each to changes in the price of the other.6 Cross elasticities between substitutes are positive, indicating there is a sales gain from an increase in the price of a substitute, while own elasticities are negative, indicating that a product’s own sales fall as its price is increased.7 Holding all else constant, the larger the cross elasticities of demand between two brands, the stronger the incentive to increase prices after the brands are merged, because the greater will be the recapture by one brand of sales lost by the other. Own elasticities of demand affect the incentive for price increases less directly. They indicate the pre-merger price-cost margins, and those margins determine the increment to profit from gaining a unit of sales. Because the relevant demand elasticities can never be known with certainly, merger simulation always should consider a substantial range of elasticities and explore sensitivity to other factors affecting the unilateral effects of a merger. A differentiated products merger also might produce coordinated effects, yet there is no 6. 7. The diversion ratios between pairs of products combine own and cross elasticities of demand. The diversion ratio from Brand A to Brand B measures the proportion of sales lost by A when its price is raised that are captured by Brand B. See generally Carl Shapiro, Mergers with Differentiated Products, ANTITRUST, Spring 1996, at 23, 23–30. Cross elasticities can be negative, as with complementary goods. Estimated cross elasticities sometimes come out negative even for substitutes. This can be simply due to statistical variation, but sometimes suggests a problem with the data or the model of consumer demand used in the estimation. NYDOCS:19868.1 MERGER SIMULATION 269 straightforward relationship between the relevant demand elasticities and such effects. C. Introduction to Three Demand Models for Merger Simulation This chapter presents three models of consumer demand that have been used in merger simulation. The Almost Ideal Demand System (“AIDS”) imposes the weakest assumptions of the three and offers the greatest flexibility. Each of the relevant elasticities, at the consumer level, can be independently determined by the data with an AIDS model, subject only to restrictions that may be imposed on the basis of economic theory. But estimating an AIDS model for differentiated consumer products is only feasible when data is available over a wide range of prices and a relatively long time period. Such data were only occasionally available prior to the mid-1980s.8 Retail scanner data is now used to estimate brand-specific demand elasticities at the consumer level, but there are difficult issues in that estimation.9 Aggregation across observational units (e.g., retailers) and across time may distort price-quantity relationships. Retailer promotional activity and consumer inventory behavior may require additional complexities be built into the econometric model. Moreover, a host of standard, but potentially vexing, econometric issues arise and must be dealt with. Finally, demand elasticities at the consumer level can never be a sufficient basis for predicting the effects of a merger at the manufacturing level. It is also essential to model retailer behavior and retailer-manufacturer interaction, which can substantially affect the retail-price effects of a manufacturing merger. 8. 9. Prior to the mid-1980’s, the available aggregate-level data (i.e., data aggregated over individuals to the level of a city or region) typically allowed the estimation of demand elasticities for only broad categories of goods, i.e., food, clothing, etc. The lack of aggregate-level data on the individual products within these broad categories generally prevented the estimation of demand elasticities for these products (i.e., individual brands of bread or soap). The most important exception was data on individual decisions derived through surveys. Using such data, demand was estimated for modes of transportation and recreational sites. See Appendix IV for a discussion of the difficulties that arise when using scanner data. NYDOCS:19868.1 270 ECONOMETRICS The antitrust logit model (“ALM”) focuses on a set of goods called the “inside” goods, which do not necessarily coincide with the relevant market in the antitrust sense.10 The data requirements for the ALM are only 1) the prices of the inside goods, 2) the shares of the inside goods, 3) the aggregate elasticity of demand for the inside goods, and 4) a price coefficient indicating the degree of substitutability among the inside goods. This coefficient can be estimated from the sort of data used to estimate an AIDS model, and it also can be inferred from less systematic evidence of consumer responses to changes in prices, as well as from price-cost margins. There is a single price coefficient in the ALM as a result of the assumption that consumer choice exhibits a property known as the Independence of Irrelevant Alternatives, or IIA. What this means as a practical matter is that substitution away from any inside good is distributed to the other inside goods in proportion to their shares.11 As a result of the IIA property, changing the set of inside goods affects only the aggregate elasticity of demand for the inside goods. This is helpful because it means that it is not necessary to settle on a relevant market in order to determine the inside good shares, or otherwise to simulate a merger. Omissions from the set of inside goods affect the simulation only because the prices of outside goods are held constant, while the prices of inside goods are affected by the merger. The IIA property, however, is the principle drawback of the model, since it forces all inside goods to be equally close substitutes for each other, which may not accurately characterize consumer demand. Like ALM, PCAIDS (proportionately calibrated AIDS) assumes that consumer choice is characterized by the IIA property. The two models differ, however, in that the ALM assumes this property always holds, while PCAIDS assumes that it holds only in the pre-merger equilibrium. 10. 11. ALM also offers the choice of the “outside” good. For example, if the inside goods were flights for a particular route, the outside good would be the choice of not flying. The ALM differs from a conventional logit model with respect to how the outside choice is incorporated into the model. In the ALM, the outside choice is reflected in an aggregate elasticity of demand for the inside goods. If inside goods A, B, and C have respective shares of 10%, 30%, and 60%, and the price of C is increased, the substitution to B must be three times the substitution to A. NYDOCS:19868.1 MERGER SIMULATION 271 The data requirements for PCAIDS are just market shares, the aggregate elasticity of demand for the product group as a whole, and the own elasticity of demand for any one product. Unlike ALM, PCAIDS does not require price information. With both the ALM and PCAIDS, the IIA assumption can be modified to include “nests.” Nests contain groups of products that are particularly close substitutes. For example in estimating automobile demand, nests might be created for luxury cars, economy cars, and possibly several other categories of automobiles. D. The Choice of a Demand Model for Merger Simulation Successful estimation of an AIDS model obviates the need for strong and untestable assumptions required by the ALM or PCAIDS. Thus, it is always worthwhile to explore the availability of data for use in demand estimation. However, estimation of an AIDS model is apt to be time consuming and expensive, and the data may prove inadequate to the formidable task of estimating the large number of independent elasticities in an AIDS model. Moreover, the estimation cannot be worthwhile unless the Bertrand model is a good fit for the industry. Estimating an AIDS model imposes considerable data demands because of the potentially large number of separate demand elasticities that are estimated. With three products, there are three own elasticities and six cross elasticities, for a total of nine elasticities to be estimated. With four products that total increases to sixteen, and in general, the number of elasticities estimated in an AIDS model is the square of the number of products. The desirable flexibility of the AIDS model, thus, comes at a potentially significant cost. When a large number of separate own and cross elasticities are estimated, it is difficult to estimate them precisely, leading to a high variance12 in the estimates. Imposing restrictions on the elasticities, like the IIA property, reduces the variance 12. When a regression coefficient is estimated econometrically, the estimate is properly viewed as a random variable with an associated variance that measures its spread or dispersion. The higher the variance, the less precise is the estimate, or in other words, the less the data say about the “true” value of the coefficient. NYDOCS:19868.1 272 ECONOMETRICS in their estimates, but this may introduce bias.13 This variance-bias tradeoff is discussed further in the chapter. The greater the number of separate elasticities to be estimated, the greater the amount of data needed to attain reliable estimates. Thus, the choice of which model to use may revolve around the amount and quality of data available. With a significant amount of data, reflecting a relatively wide variance in prices, it may be possible to let the data “speak for itself” by estimating all of the relevant demand elasticities econometrically, as with the AIDS model. With very little data is available, no estimation may be possible, but merger simulation is nevertheless possible if strong restrictions are placed on the form of demand, as with the ALM and PCAIDS. In both the ALM and PCAIDS models, the imposition of the IIA property means that all of the relevant demand elasticities are determined by just two independent demand parameters, and there are straightforward ways to infer likely values of both from very little data and without resort to econometrics. This makes merger simulation using the ALM or PCAIDS well suited for use in the initial evaluation of a merger designed to see whether it plausibly would yield significant price increases (e.g., increases not easily eliminated by modest cost savings). On final consideration in the choice among demand models is the inherent “curvature” properties of any particular model. While the AIDS model allows each separate demand elasticity to be determined by the data, how those elasticities change with changes in prices is preordained by the model. This is no less true of any other conventional model of demand, and PCAIDS imposes the same curvature properties as AIDS. Other demand models, including the ALM, impose different curvature properties with different implications. The ALM may result in substantially lower price increase predictions than AIDS or PCAIDS as a consequence of the differing curvature properties.14 13. 14. A biased estimate differs systematically from the “true” value, rather than departs from the true value only because of sampling error. Two other demand models are 1) linear demand, in which demand for each product is a straight-line function of each price, and 2) isoelastic demand, in which all the own and cross elasticities of demand are assumed to be invariant to prices. The price increase predictions with isoelastic demand are apt to be greater than those with AIDS demand, NYDOCS:19868.1 MERGER SIMULATION 273 E. Alternative Models for Merger Simulation 1. Logit Model a. Introduction The logit model is a relatively simple demand model used to estimate demand elasticities and simulate the effects of mergers in differentiated products industries.15 It has relatively few parameters, which facilitates their econometric estimation or their direct calibration from industry data. This makes the logit model ideal for quick, preliminary analyses of potential price effects of mergers based on very little information. The logit model, however, is highly restrictive regarding the pattern of substitution among goods, which has been the source of criticism from economists. Nevertheless, these restrictions provide a useful base case that focuses a merger investigation or trial and generalizations of the model can ease these restrictions. Each demand model has inherent properties that distinguish it from others in ways that substantially affect the magnitude of the predicted price effects from mergers. Properties of the logit model cause it to yield relatively conservative (i.e., low) price increase predictions. b. Choice Models of Consumer Demand Economists modeling consumer demand commonly employ “choice models,” in which each consumer makes a single choice from a “choice set” of goods. Since a consumer makes a single choice, each good in the choice set is a substitute for all the others. The goods of primary interest are referred to as the “inside goods.” The choice set may be limited to those goods but usually includes a “none of the above” choice, referred to as the “outside good.” The outside good is an aggregate incorporating all other alternatives to which the consumer could allocate income. 15. while the price increase predictions with linear demand are apt to be lower than those with the ALM. Although a variety of models are properly termed “logit models,” “the logit model” generally refers to the simplest of logit models, and this chapter is principally concerned with that model. NYDOCS:19868.1 274 ECONOMETRICS Which goods are considered “inside goods” is more modeling art than science. In modeling the choice of a new car, the inside goods could be all of the various models of cars and the outside good could be not purchasing a new car. However, if the focus were on just luxury cars, the modeler might limit the inside goods to cars selling for more than a specific dollar amount, while all other cars would be part of the outside good. While similar in concept, the inside goods may be more or less inclusive than a relevant antitrust market. Choice models directly apply the economic theory of consumer behavior,16 positing that each consumer selects the single product from the choice set which yields the greatest utility. Utility is specified as a function of product characteristics, including price. The own and cross elasticities of demand of the inside goods are determined by their choice probabilities and the coefficient on price in the utility function. In addition to price, choice models normally specify that utility is a function of observed product characteristics and a choice-specific constant that captures utility differences among goods as perceived by the average consumer. This constant reflects brand preference and any goods’ characteristics that are not separately included in the model. The greater the value of the choice-specific constant for a good, or the lower its price, the greater the utility each consumer derives from that good. Choice models are normally “random utility models,” meaning one determinant of utility is specified as a random variable.17 This does not imply that consumers base their purchase decisions on a roll of the dice. Instead, it is a way of allowing different consumers to have different 16. 17. Linear and isoelastic demand functions, which have been used to simulate mergers, are not derived from the economic theory of consumer behavior, so neither can be the true demand functions for an individual consumer. Nevertheless, the aggregate demand for a population of consumers could be well approximated by linear or isoelastic functions. Random utility models were formalized by Charles Manski, The Structure of Random Utility Models, 8 THEORY & DECISION 229 (1977). Comprehensive treatments of the theory are provided by MOSHE BENAKIVA & STEVEN R. LERMAN, DISCRETE CHOICE ANALYSIS: THEORY AND APPLICATION TO TRAVEL DEMAND ch. 3–4 (1985); Daniel McFadden, Econometric Models of Probabilistic Choice, in STRUCTURAL ANALYSIS OF DISCRETE DATA WITH ECONOMETRIC APPLICATIONS 198 (Charles F. Manski & Daniel McFadden eds., 1981). NYDOCS:19868.1 MERGER SIMULATION 275 preferences for the same product characteristics. The model specifies the statistical distribution of the random utility component and differing assumptions about that distribution gives rise to different models. The most common distributional assumption gives rise to the logit model,18 which is discussed below. c. The Basic Logit Model and the IIA Assumption19 The logit model derives its name from the “logistic” functional form of the choice probabilities, which traces out an S-shaped curve. Choice probabilities are closely related to, but different from, market shares. If two goods are both in the relevant market, the ratio of their choice probabilities equals the ratio of their market shares (based on quantity sales). This is true regardless of what the relevant market may be or how the choice set is defined. Choice probabilities can be converted into market shares by re-scaling. The market share of any inside good is its choice probability, divided by the sum of the choice probabilities for all goods not in the relevant market. The own and cross elasticities of demand in a logit model are simple functions of price, choice probabilities, and the price coefficient in the utility function.20 In a logit model, the cross elasticities of demand for all 18. 19. 20. The logit model was formalized by Daniel McFadden, Conditional Logit Analysis of Qualitative Choice Data, in FRONTIERS IN ECONOMETRICS (Paul Zarembka ed., 1974). For another useful derivation of the model, see SIMON P. ANDERSON, ANDRÉ DE PALMA & JACQUES-FRANÇOIS THISSE, DISCRETE CHOICE THEORY OF PRODUCT DIFFERENTIATION 41–42 (1992). For thorough treatments of the model, see BEN-AKIVA & LERMAN, supra note 17, ch. 5; KENNETH TRAIN, QUALITATIVE CHOICE ANALYSIS: THEORY, ECONOMETRICS, AND AN APPLICATION TO AUTOMOBILE DEMAND ch. 2 (1986). See Appendix II to this book for a detailed description of the logit model and the method of maximum likelihood that is used to estimate the model. For a more detailed discussion of the application of the logit model, see Gregory J. Werden, Luke M. Froeb & Timothy J. Tardiff, The Use of the Logit Model in Applied Industrial Organization, 3 INT’L J. ECON. BUS. 83, 85–87 (1996). Denoting the own price coefficient as β, the price of good i as pi , and the probability that the individual will choose good i as π i, the own elasticity NYDOCS:19868.1 276 ECONOMETRICS inside goods, with respect to the price of any one inside good are the same. The cross elasticities only depend on the price and choice probability of the good for which price is changed. This pattern of cross elasticities is a consequence of what economists term the Independence of Irrelevant Alternatives (IIA) property,21 a notable feature of the logit model. Formally, the IIA property means that the ratio of the probabilities of any two choices is independent of the presence or absence of other possible choices. In practical terms, this means that substitution from any good in the choice set to all others in that set is proportionate to their relative market shares. Suppose, for example, that the choice set consists of goods A, B, and C, with respective shares of 60 percent, 30 percent, and 10 percent. If the price of good C is increased, the IIA property says that the substitution to good A must be twice that to B because the share of A is twice that of B. The IIA property is a way to define what it means for all goods in the choice set to be equally close substitutes for each other. In the preceding example, it could be argued that, if many more consumers switched to A than to B when the price of C was increased, A must be the closer substitute for C. However, it can also be argued that, if the substitution away from C is proportionate to the relative shares of A and B, then A and B are equally close substitutes for C. The latter argument makes sense partly because the cross elasticities of demand for A and B with respect to the price of C are exactly the same if the IIA property holds. Most importantly, the IIA property offers a rough approximation for substitution patterns if they have not yet been, or cannot be estimated.22 21. 22. of demand for good i is –βpi(1 – πi). The cross elasticity of demand for any inside good with respect to the price of good i is βpiπi. The logit model was originally developed by R. DUNCAN LUCE, INDIVIDUAL CHOICE BEHAVIOR: THEORETICAL ANALYSIS (1959). Luce was a psychologist and termed the IIA property the “choice axiom.” Robert D. Willig, Merger Analysis, Industrial Organization Theory, and Merger Guidelines, BROOKINGS PAPERS ON ECONOMIC ACTIVITY, MICROECONOMICS 281, 299–305 (1991). Willig argued that the logit model, with its IIA property, is appropriate in the benchmark case in which the merging firms’ products are neither particularly close together nor far apart in characteristics space. He used the logit model to motivate NYDOCS:19868.1 MERGER SIMULATION 277 Without evidence to the contrary, substitution in proportion to shares is seen as the most natural default assumption, which is true even if the IIA property is not viewed as defining equally good substitutes among all goods in the choice set. Of course, the IIA property is even more attractive as a default assumption when viewed as defining equally close substitutes. The IIA property has been both a blessing and a curse. Imposing the IIA property facilitates estimation in a variety of ways, most notably by limiting the number of parameters to be estimated. It also permits inferences that otherwise could not easily be made, such as the impact of adding a hypothetical new product to the choice set. Finally, imposing the IIA property assures that goods known to be substitutes actually have positive estimated cross elasticities of demand. Restricting the pattern of substitution, however, can artificially impose a highly unrealistic pattern of substitution. For example, it can force the substitution from a particular model of luxury car or sports car to go predominantly to a pickup truck or minivan if either is the most popular choice among motor vehicles. There are a variety of ways to address this problem by varying the structure of the logit model. It is reliance on market shares in merger analysis. Willig’s analysis appears to be reflected in U.S. DEPARTMENT OF JUSTICE & FEDERAL TRADE COMMISSION, HORIZONTAL MERGER GUIDELINES § 2.211, reprinted in 4 TRADE REG. REP. (CCH) ¶ 13,104 (April 2, 1992), which state in part: The market concentration measures articulated in Section 1 [of the Guidelines] may help assess the extent of the likely competitive effect from a unilateral price elevation by the merged firm notwithstanding the fact that the affected products are differentiated. The market concentration measures provide a measure of this effect if each product’s market share is reflective of not only its relative appeal as a first choice to consumers of the merging firms products but also its relative appeal as a second choice, and hence as a competitive constraint to the first choice. Where this circumstance holds, market concentration data fall outside the safeharbor regions of Section 1.5, and the merging firms have a combined market share of at least thirty-five percent, the Agency will presume that a significant share of sales in the market are accounted for by consumers who regard the products of the merging firms as their first and second choices. NYDOCS:19868.1 278 ECONOMETRICS always possible to limit the scope of the choice set, for example, to just luxury cars or just sports cars. d. The Antitrust Logit Model The Antitrust Logit Model (ALM) is a reformulation of the conventional logit model designed to make it more useful for antitrust practitioners.23 Unlike conventional logit models, formulated in terms of choice probabilities, the ALM is formulated in terms of “shares” within the set of inside goods. These shares are similar to market shares, although the inside goods not need constitute a relevant market. In merger analysis, conventional logit models have conceptual difficulties because the probability of choosing the outside good is never considered. As an illustration, consider a choice model for airlines on a particular route. To estimate this model, one must consider the probability of not flying at all and identify the number of potential passengers who choose not to fly. Although there are ways to address these issues, the ALM avoids doing so by treating the probability of not flying as a scaling factor determined by the aggregate elasticity of demand for the inside goods. In this illustration, that is the elasticity of demand for commercial air travel on the relevant route.24 If the demand for the inside goods is sufficiently elastic, mergers of inside goods cannot significantly increase prices, because the outside goods (e.g., other modes of transportation) are very close substitutes for the inside goods. The aggregate elasticity of demand for the inside 23. 24. For details, see Gregory J. Werden & Luke M. Froeb, The Antitrust Logit Model for Predicting Unilateral Competitive Effects, 70 ANTITRUST L.J. 257 (2002); Gregory J. Werden & Luke M. Froeb, Simulation as an Alternative to Structural Merger Policy in Differentiated Products Industries, in THE ECONOMICS OF THE ANTITRUST PROCESS 65 (Malcolm B. Coate & Andrew N. Kleit eds., 1996); Werden et al., supra note 19; Gregory J. Werden & Luke M. Froeb, The Effects of Mergers in Differentiated Products Industries: Logit Demand and Merger Policy, 10 J.L. ECON. & ORG. 407 (1994). Denoting the share of good i as si, the average price of all inside goods as p, and the aggregate elasticity for the inside goods as ε, the own elasticity of demand for good i is –[βp(1 – si) + εsi]pi /p, and the cross elasticity of the demand for good i with respect to the price of good j is sj(βp – ε)pj /p. NYDOCS:19868.1 MERGER SIMULATION 279 goods has essentially the same role as market delineation. Given the value of the aggregate elasticity, the price coefficient determines the responsiveness of choices to changes in prices; the greater the value of the price coefficient, the greater the substitutability among the inside goods.25 If the price coefficient is very low, the merger of two inside goods has very little effect on their prices, because the inside goods are such distant substitutes that each is essentially a monopoly unto itself. If the price coefficient is very high, only a merger resulting in a monopoly of the inside goods would have much effect on their prices, because the inside goods are very close substitutes for each other. In the ALM, competitive interaction among inside goods is completely characterized by the shares and prices of those goods, both of which are routinely determined in merger investigations, and two demand parameters. Estimating the aggregate demand elasticity can be challenging, but that challenge is already present in traditional antitrust analysis, because the process of market delineation requires at least intuiting from non-quantitative evidence the value of the inside goods aggregate elasticity.26 The value of the price coefficient can be estimated from aggregate data on prices and quantity of actual transactions, household level data on actual choices, or survey data. It also can be inferred in several ways: This inference can be made from observed patterns of diversion resulting from a natural experiment such as the entry and exit of a brand. Under the conventional assumption—that observed prices and shares are the product of a Bertrand equilibrium in which firms compete on the basis of price—the value of the price coefficient can be inferred from the price-cost margin of any major brand. 25. 26. What matters is the price coefficient times the average price of the inside goods, so references to high and low values of the price coefficient, are really references to high and low values of the coefficient multiplied by the average price of the inside goods. See Gregory J. Werden, Demand Elasticities in Antitrust Analysis, 66 ANTITRUST L.J. 363, 378–91 (1998). Useful experiments are suggested by the relationship between market delineation and the aggregate elasticity. One might assume that a collection of goods constitutes a relevant market, compute the highest demand elasticity consistent with that assumption, and use that as the value of the inside goods aggregate elasticity. NYDOCS:19868.1 280 ECONOMETRICS Since the shares in the ALM are not market shares, it is not necessary to settle on a relevant market in order to ascertain the shares needed to apply the ALM. All that matters in the ALM are the relative shares of inside goods. If A and B are both inside goods, their relative shares are invariant to inclusion or exclusion of other goods from the list of inside goods. The impact of market delineation issues comes in only through the inside goods aggregate elasticity and not through the shares. Simulating a merger using the ALM is straightforward.27 The standard assumptions for differentiated products merger simulations (which can be relaxed) are that: (1) the only strategic competitive variable is price, hence there can be no entry or product repositioning; and (2) the cost of producing each good depends only on the quantity of that good produced, and consists of a constant marginal cost and a fixed cost that does not matter for the purposes of the simulation. Merger simulation using the ALM predicts the price and welfare effects of mergers in three steps. First, the price coefficient and aggregate elasticity are estimated or merely specified. Second, the necessary conditions for pre-merger profit-maximization are solved for the implied marginal costs and the logit probability functions are solved for the implied values of the remaining parameters of the demand system.28 Finally, the necessary conditions for post-merger profit-maximization are solved for prices and outputs to predict the effects of a merger.29 27. 28. 29. For an application to an actual proposed merger, see Gregory J. Werden, Expert Report in United States v. Interstate Bakeries Corp. and Continental Baking Co., 7 INT’L J. ECON. BUS. 139 (2000). Only relative values of the demand parameters matter, so one of them is set to an arbitrary constant and the others are then easily computed from the logit probability functions, given the prices, shares, and demand parameters. For a concise statement of the process of merger simulation, see Gregory J. Werden, Simulating Unilateral Competitive Effects from Differentiated Products Mergers, ANTITRUST, Spring 1997, at 27. More complete statements of the analysis are found in Philip Crooke, Luke M. Froeb, Steven Tschantz & Gregory J. Werden, The Effects of Assumed Demand Form on Simulated Postmerger Equilibria, 15 REV. INDUS. ORG. 205 (1999); Jerry A. Hausman & Gregory K. Leonard, Economic Analysis of Differentiated Products Mergers Using Real World Data, 5 GEO. MASON L. REV. 321 (1997); Gregory J. Werden, Simulating the Effects of Differentiated Products Mergers: A Practical Alternative to Structural NYDOCS:19868.1 MERGER SIMULATION 281 When simulating a merger, the one critical difference in the treatment of inside versus outside goods is that the prices of the inside goods are determined by the competition among them. Mergers affect that competition, which causes changes in the prices of the inside goods. The outside goods are, by assumption, outside this competition. Their prices are taken as given before the prices of the inside goods are set, and their prices are assumed to be unaffected by the merger. The direct effect of narrowing the list of inside goods is to preclude price increases for all goods that are not treated as inside goods. This indirectly affects the prices of goods determined to be inside goods, especially the merging goods, as their prices will increase in response to any increases in the prices of substitutes. Both of these effects tend to be slight unless individual excluded goods, if included, would have very large shares. In the ALM, the prices of all inside goods increase as a result of a merger of any two inside goods, but the magnitudes of the price increases for different brands are different. If the merging brands have significantly different shares, the merger has asymmetric effects on the prices of those brands. The price of the smaller-share brand increases more than that of the larger-share brand. In addition, the prices of the merging brands typically increase much more than the prices of nonmerging brands. The prices of larger-share, non-merging brands increase more than the prices of smaller-share brands. Increased concentration among the non-merging brands increases the price effects of a merger, but the effect is typically fairly weak.30 30. Merger Policy, 5 GEO. MASON L. REV. 363 (1997); Gregory J. Werden, Simulating the Effects of Differentiated Products Mergers: A Practitioners’ Guide, in STRATEGY AND POLICY IN THE FOOD SYSTEM: EMERGING ISSUES 95 (Julie A. Caswell & Ronald W. Cotterill eds., 1997); Gregory J. Werden & Luke M. Froeb, Simulation as an Alternative to Structural Merger Policy in Differentiated Products Industries, in THE ECONOMICS OF THE ANTITRUST PROCESS 65 (Malcolm B. Coate & Andrew N. Kleit eds., 1996). See Gregory J. Werden & Luke M. Froeb, The Effects of Mergers in Differentiated Products Industries: Logit Demand and Merger Policy, 10 J.L. ECON. & ORG. 407 (1994). Luke M. Froeb, Timothy J. Tardiff & Gregory J. Werden, The Demsetz Postulate and the Welfare Effects of Mergers in Differentiated Products Industries, in ECONOMIC INPUTS, LEGAL OUTPUTS: THE ROLE OF ECONOMISTS IN MODERN ANTITRUST 141 (Fred S. McChesney ed., 1998), have shown that a merger may enhance NYDOCS:19868.1 282 e. ECONOMETRICS A Rationale for Use of the ALM Economists have long noted that the IIA property is not likely to hold in the real world. It is usually true that a model that does not impose the IIA property fits a real-world industry better than the ALM. Nevertheless, the ALM is very useful as a starting point in the analysis of differentiated products mergers. Until reliable contrary evidence is discovered, one can start with the assumption that the merging firms’ products are neither especially close nor especially distant substitutes, which means that the IIA property holds.31 Indeed, the ALM provides a screen comparable to that provided by market shares in traditional antitrust analysis;32 however, only the ALM offers quantitative priceincrease predictions. Simple merger simulations, as with the ALM, also permit an explicit tradeoff of efficiencies in the form of synergies that reduce marginal cost. (1) The Variance-Bias Trade-Off and More Flexible Functional Forms 31. 32. total welfare in the ALM without generating synergies, and even though consumer welfare is diminished. Welfare gains can arise because a merger causes a shift in production from merging firms to non-merging firms. If small- or medium-share brands merge, there is a shift in production to larger-share brands. In the ALM, larger-share brands must have lower marginal costs and be preferred by consumers, resulting in an increase in total welfare. Welfare gains also arise because a merger causes a shift in production from one merging brand to the other. The merger of a large-share brand with a smaller-share brand causes a shift in production from the smaller-share brand to the larger-share brand, which has a lower marginal cost and is preferred by consumers, resulting in an increase in total welfare. Whether the IIA property holds between the merging and non-merging brands tends to be unimportant to the price effects of a merger. The IIA assumption can be used to calibrate other models, see Philip Crooke et al., supra note 29 (using the IIA assumption to calibrate AIDS, isoelastic, and linear demand), as it is in the PCAIDS model discussed below. Illustrations are provided in Chapter XIII and Gregory Werden & Luke Froeb, Calibrated Economic Models Add Focus, Accuracy, and Persuasiveness to Merger Analysis, in THE PROS AND CONS OF MERGER CONTROL 63 (Swedish Competition Authority 2002). NYDOCS:19868.1 MERGER SIMULATION 283 Estimating demand presents a tradeoff between variance and bias. The more flexible the assumed demand form, the greater the number of parameters to be estimated, and the more difficult it is to precisely estimate them. Thus, the more flexible the assumed demand form, the greater may be the variance of the estimators. Conversely, the less flexible the assumed demand form, the more likely it is that the functional form significantly restricts substitution patterns in unrealistic ways. Thus, the less flexible the functional form, the greater may be the bias in the estimator. When abundant data present sufficient price variation,33 the choice is clear. Using a flexible functional form allows the data to speak for itself and to indicate how consumers substitute one product for another in response to changes in prices. Having sufficient data eliminates the need to make any difficult decisions. However, in many cases a tradeoff must be considered. Estimating a restricted demand form reduces the number of parameters and, to some extent, imposes a substitution pattern on the data.34 It can preclude the possibility of negative cross elasticities of demand, and in the case of the ALM, it can force substitution to be proportionate to market share. The problem in merger analysis is that the 33. 34. To the extent that demand elasticities are identified in the traditional way, from quantity changes in response to price changes, independent price variation in each brand is needed to trace out the separate demand curves of the individual brands throughout the entire relevant range of prices. More recent academic work has also attempted to identify demand elasticities on the basis of consumer responses to changes in available brands or the characteristics of existing brands. In this work, variation in characteristics helps to trace out the separate demand curves of the individual brands throughout the entire relevant range of prices. Estimating a relatively flexible demand form like the AIDS in some cases can yield a relatively high variance due to the large number of parameters being estimated. The problem of high variance can often manifest itself in estimated negative cross elasticities of demand, which imply that the goods are complements, even though they may be known to be substitutes. In merger simulation analysis, high variance also implies wide confidence intervals for predicted price effects that can potentially be so wide that the exercise is useless. NYDOCS:19868.1 284 ECONOMETRICS estimated merger effects may then be determined, to a considerable extent, by the substitution pattern imposed on the data. For example, when substitution is assumed to be proportionate to market shares, mergers of larger-share brands increase price more than mergers of smaller-share brands. The ALM does not allow for the possibility that a merger of two large-share brands would have little effect on their prices because they are very distant substitutes. Additionally, ALM does not allow for the possibility that a merger of two relatively small-share brands could cause a substantial effect on price because those two brands occupy an important niche in product space. In the context of merger analysis, guidance about how and when to trade off bias and variance is provided by an examination of the important determinants of unilateral price effects. The own elasticities of demand of the merging brands and the cross elasticities between them are far more important than any of the other demand elasticities. Thus, it is most important to have flexibility with respect to these few elasticities involving the merging brands. As noted above, the logit model results from making a particular assumption about the statistical distribution of the random component of utility in the choice model. Part of the distributional assumption that gives rise to the logit model is that the random component of utility is independently and identically distributed across consumers. As a practical matter, what this means is that there is no correlation in the way different goods are valued by particular consumers. It is not possible, for example, for some consumers to systematically place a high value on luxury cars while others place a high value on minivans. Correlations in preferences, however, can be introduced through several generalizations of the basic logit model. One such generalization is the “nested” logit model, which places “nests” around brands that are especially close substitutes for one another and for which preferences are correlated.35 An added parameter for each 35. See generally ANDERSON ET AL., supra note 18, at 46–48; BEN-AKIVA & LERMAN, supra note 17, ch. 10. For several applications, see JEFFREY A. DUBIN, STUDIES IN CONSUMER DEMAND—ECONOMETRIC METHODS APPLIED TO MARKET DATA ch. 6–7 (1998). The nested logit model was introduced by Daniel McFadden, Modeling the Choice of Residential Location, in SPATIAL INTERACTION THEORY AND PLANNING MODELS 75 (Anders Karquist et al. eds., 1978). NYDOCS:19868.1 MERGER SIMULATION 285 nest determines both the closeness among the brands in the nest and their distance from other brands, and can be estimated from the data. When the price of a brand in a strong nest increases, nearly all of the substitution is to other brands within its nest. In a nested logit model, a merger may have much larger price effects if the merging brands are in the same nest than if they are in separate nests. Another way to add flexibility to a logit model is to specify “dimensions of differentiation,” similar to adding brand or product characteristics. Brands that share the same characteristics are closer to one another than brands that do not. In this model, the strength of a nest can be estimated from the data and the importance of characteristics in differentiating brands. For example, products may be distinguished on the basis of whether they are major brands and whether they are on the technological frontier.36 If two binary characteristics such as these are used, brands are then classified into one of the four categories corresponding to the four possible combinations of these two characteristics. A merger involving two brands sharing the same classification would produce greater price effects than a merger involving two brands that do not. Another generalization of the logit model, very popular in academic research, is the “mixed” or “random-coefficients” logit model. These models incorporate customer heterogeneity by specifying that the observed demand is a mixture of distinct individual demands for consumers who have different characteristics. Suppose high-income consumers have relatively inelastic demands, while low-income consumers have relatively elastic demands. Observed demand then can be modeled as the weighted average or “mixture” of two logit demands, with the weights being the population proportions of high- and lowincome consumers. Mixed logit models can approximate any underlying choice model, although their estimation can be challenging.37 36. 37. See Timothy F. Bresnahan, Scott Stern & Manuel Trajtenberg, Market Segmentation and the Sources of Rents from Innovation: Personal Computers in the Late 1980s, 28 RAND J. ECON. S17 (1997). See, e.g., Steven T. Berry, James Levinsohn & Ariel Pakes, Automobile Prices in Market Equilibrium, 63 ECONOMETRICA 841 (1995); Aviv Nevo, A Practitioner’s Guide to Estimation of Random Coefficients Logit Models of Demand, 9 J. ECON. & MGMT. STRATEGY 513 (2000). NYDOCS:19868.1 286 ECONOMETRICS (2) Demand Curvature and Assumed Functional Forms A demand form is “flexible to the first order” if it can be fitted precisely into any given set of own and cross elasticities at a particular set of prices and quantities. First-order flexibility is desirable, although a price must be paid for it. Higher-order flexibility is also desirable, but none of the conventional demand forms have higher-order flexibility: All greatly restrict how the own and cross elasticities of demand change as prices change. The most conspicuous example is the isoelastic demand function, which assumes all demand elasticities are invariant to prices. Isoelastic demand is not fundamentally more restrictive than other conventional demand forms, such as linear demand; rather, each demand form imposes a different set of restrictions on the “curvature” of demand and these restrictions are quite important. The different curvature properties of AIDS and isoelastic demand cause those demand forms to yield larger price increase predictions than the linear and logit models.38 For any given set of prices, shares, and demand elasticities, it is not unusual for the price increases predicted using AIDS or isoelastic demand to be several times those predicted using linear or logit demand. The main reason is the differing rates at which an individual product’s demand becomes more elastic as its price increases. The idiosyncratic behavior of cross elasticities is also relevant to these models. An increase in the price of one product may increase, decrease, or not change the cross elasticity of its demand with respect to the price of another product. The properties of these four demand forms cause them to yield very different price effects from mergers, which also cause them to yield very different pass-through rates for marginal cost reductions.39 The pass through rate of marginal cost reductions with AIDS or isoelastic demand is several times that with linear or logit demand. Any conventional demand form has drawbacks. Assuming any demand form, in effect, assumes to a significant extent the effects of the merger under investigation. However, statistical testing can provide a 38. 39. See Crooke et al., supra note 29. See Gregory J. Werden, Luke M. Froeb & Steven Tschantz, The Effects of Merger Synergies on Consumers of Differentiated Products (unpublished paper 2001). NYDOCS:19868.1 MERGER SIMULATION 287 means to choose between a set of demand forms. Since prices tend to vary over at least some range in the typical dataset, a statistical test can be used to identify the particular demand form that best fits the curvature within the observed range of prices. Alternatively, one can use demand forms with flexible curvature properties. In principle this is possible but very rarely proves a practical solution. Adding flexible curvature properties generally exacerbates the variance problem by trying to estimate too many parameters. In addition, the data normally will not allow a significant determination of curvature outside the range of observed prices.40 A far simpler alternative is to switch to an alternative analysis unaffected by curvature. This is the computation of the marginal cost reductions that exactly offset the price-increasing effects of a merger.41 Because this calculation involves post-merger prices that are the same as pre-merger, the effects of price changes on demand elasticities do not matter. Consequently, these “compensating marginal cost reductions” are the same no matter what the demand form. 2. Flexible Demand Specification—The AIDS Model a. Introduction The use of a “flexible functional form” in the analysis of competition among differentiated products allows all of the own and cross elasticities of demand for those products to be estimated from aggregate-level data, such as retail scanner data. The flexible functional form most commonly used is AIDS, and this section compares the strengths and weaknesses of AIDS relative to other specifications and identifies issues that arise in the estimation of an AIDS model (or other demand system).42 40. 41. 42. Mixed logit models have potential to address the curvature issue in a useful way. They can allow demand curvature to be determined by using empirical distributions of relevant consumer attributes (e.g., income). See Gregory J. Werden, A Robust Test for Consumer Welfare Enhancing Mergers among Sellers of Differentiated Products, 44 J. INDUS. ECON. 409 (1996). Technical details on this model and its estimation are presented in Appendicies II and IV. NYDOCS:19868.1 288 ECONOMETRICS b. Considerations in Choosing a Demand System Specification A less flexible demand specification such as the ALM has fewer parameters to estimate than a flexible demand specification and, as a result, may lead to more precise elasticity estimates than a flexible demand specification. However, this precision may come at a price, namely, a less flexible specification may not fit the data well, which could induce bias into the elasticity estimates.43 During the 1980s, econometricians came to realize the importance of using “flexible functional forms” that place minimal (or no) restrictions on the estimated values of the demand elasticities.44 Unfortunately, estimating a relatively flexible demand form, like AIDS can yield a high variance due to the large number of parameters.45 43. 44. 45. Another consideration, particularly when estimating the price effects of a proposed merger, is the behavior of the demand system as prices move away from the point of approximation. Demand systems that yield the same elasticities at the point of approximation can predict substantially different post-merger price changes. See, e.g., Crooke, et al., supra note 19. Ideally, statistical tests can be used to choose among alternative demand specifications, but traditional tests involving demand parameters (i.e., ttests or F-tests) are often not appropriate. Suppose, for example, that one is choosing between two demand systems that have different structures. In place of a traditional test, one would need to use a, more complex “non-nested” test. For example, the AIDS and log-log specifications discussed below are not nested within one another. For a definition of flexible functional forms, see W.E. Diewert, An Application of the Shephard Duality Theorem: A Generalized Leontief Production Function, 79 J. POL. ECON. 481 (1971); see also Angus Deaton, Demand Analysis, in 3 HANDBOOK OF ECONOMETRICS (Zvi Griliches & Michael D. Intriligator eds., 1986); ROBERT A. POLLAK & TERENCE J. WALES, DEMAND SYSTEM SPECIFICATION & ESTIMATION 63 (1992). For a discussion of the tradeoffs involved in specifying complex demand systems, and the implications for the estimation of demand elasticities, see Daniel Rubinfeld, Market Definition with Differentiated Products: The Post/Nabisco Cereal Merger, 68 ANTITRUST L.J. 163 (2000). NYDOCS:19868.1 MERGER SIMULATION 289 Under the economic theory of consumer choice, a demand system must have a certain properties.46 Some demand specifications allow these properties to be easily imposed and tested, while other specifications do not. Generally, one would want to impose the restrictions implied by these properties because certain calculations (i.e., consumer welfare) would not be valid if the demand system did not satisfy the properties of consumer demand.47 Thus, the ability to both impose and test these properties is a valuable property for a demand system specification. A second important theoretical consideration is whether the demand system specification can be obtained by aggregation over individual consumers.48 The question is whether the demand system and its properties transfer to the aggregate-level data obtained by aggregating over individual consumers. If that is the case, the aggregate-level demand can be treated as the demand of a “representative consumer” and the estimated demand system should exhibit the appropriate properties. c. The Almost Ideal Demand System Under AIDS, the revenue share of a product is the result of three terms.49 The first term is a constant that differs across products, which indicates that, everything else being equal, some products would have higher shares as a result of different consumer preferences. The second term is based on the “real” expenditure devoted to the category. The 46. 47. 48. 49. These properties are: Slutsky symmetry, homogeneity of degree zero in prices and total expenditure, and adding up. Slutsky symmetry requires that the compensated cross price derivative of Brand A with respect to Brand B equals the compensated cross price derivative of Brand B with respect to Brand A. Homogeneity of degree zero in prices and expenditure requires that demand for all products be unchanged if the prices of the products and total expenditure all increase by the same percentage. Finally, adding up requires that the sum of expenditures on the individual products equals total expenditure. However, empirical demand studies have found that the properties of consumer demand are often rejected by statistical tests. ANGUS DEATON & JOHN MUELLBAUER, ECONOMICS AND CONSUMER BEHAVIOR 148–59 (1980). See Angus Deaton & John Meullbauer, An Almost Ideal Demand System, 70 AM. ECON. REV. 312 (1980). NYDOCS:19868.1 290 ECONOMETRICS third term is based on the prices of the various products. It is helpful in understanding the AIDS specification to suppose that the own price coefficient is negative and that the cross price coefficients are positive (although neither is necessary to have a well-behaved demand system). In that case, the revenue share of a product increases when its own price decreases or when the price of another product increases. AIDS has a number of desirable properties: The AIDS demand specification is a first-order approximation to any demand system.50 This implies that even if the true underlying demand system is not AIDS, AIDS will nevertheless provide a reasonably accurate approximation in the neighborhood of given point of approximation. AIDS allows for easy imposition and testing of the properties of consumer demand.51 These restrictions can be imposed during estimation. Alternatively, the restrictions can be tested using standard statistical methods after estimation of the AIDS model. The AIDS model also can be obtained through aggregation over individual consumers and can be treated as the demand system for a representative consumer.52 The demands and welfare calculations for this representative consumer appropriately reflect the aggregated demands and welfare of the individual consumers. The downside to the flexibility of AIDS is the large number of parameters that need to be estimated. Even after imposing restrictions from the theory of consumer choice, AIDS estimation with N products will involve something less than N2 parameters.53 d. Comparison to Other Demand Systems The logit model: (1) is easy to estimate, (2) satisfies the restrictions of consumer demand, and (3) aggregates across individual consumers. However, logit is not very flexible. The IIA property constrains all of the cross elasticities of demand with respect to a particular product’s price to be equal.54 This property would not hold when an industry 50. 51. 52. 53. 54. Id. at 312. Deaton & Muellbauer, supra note 49, at 312. Id. POLLAK & WALES, supra note 44. Jerry A. Hausman, Project Independence Report: An Appraisal of U.S. Energy Needs Up to 1985, 6 BELL J. ECON. 517 (1975); McFadden, supra note 35, at 222; Hausman & Leonard, supra note 29, at 322. NYDOCS:19868.1 MERGER SIMULATION 291 consists of several “premium” brands that have large industry shares, and several “economy” brands with smaller shares. One expects the economy brands to compete more closely with each other than with the branded premium brands because one expects the cross elasticities between the economy brands to be larger than the cross elasticities between economy and premium brands. A demand specification that severely limits the values the cross elasticities can take, could result in severely biased cross elasticity estimates and therefore, incorrect conclusions concerning the extent of competition between products. With the use of nested logit models, products within a nest are permitted to compete more closely with each other than with products outside the nest, thus reducing the problem of equal cross elasticities. However, the problem is not entirely eliminated because the cross elasticities within a nest are still constrained to be equal. The “random effects” or “mixed” logit model assumes each consumer has logit demand, but differs in the value weights that they place on price and other product attributes. As a result, aggregate demand does not exhibit the equal cross elasticity property, although the property continues to hold for each individual. For example, people who bought Toyota station wagons and place a good deal of weight on having a station wagon would be more likely to switch to a Honda station wagon than to a sports car, if the price of the Toyota station wagon were to increase. In aggregating over individuals, the people who choose station wagons largely determine the cross elasticities among station wagons, while the people who choose sports cars largely determine the cross elasticity of sports cars with respect to station wagons. Therefore, in the aggregate, the cross elasticities among station wagons are “large” and the cross elasticities of sports cars with respect to station wagons are “small.” The random effects logit requires substantially fewer parameters be estimated than a typical flexible functional form such as AIDS. However, the random effects logit is substantially more difficult to estimate than AIDS in a typical application. In addition, although it is less restrictive than the basic logit model, the random effects model may not have the flexibility to perform as well as AIDS in many situations. In the one direct comparison, the results for AIDS and the random effects NYDOCS:19868.1 292 ECONOMETRICS logit were similar in some respects, but different in others.55 A topic for future research is determining the conditions under which the random effects logit or, alternatively, a flexible functional form would be preferred.56 e. Empirical Implementation of the AIDS Empirical implementation of the AIDS is often possible when retail scanner data are available on brands for a number of cities and time periods. For example, there may be data on 10 brands in 25 cities for 104 weeks. It is best to cast a wide net when choosing the products to include in the demand system because the purpose of estimating the demand system is to determine the extent of competition between products. It is better to be over-inclusive, letting the data decide the extent to which products compete. The basic AIDS revenue share equation needs to be modified to account for the fact that a product’s revenue share might differ across time and cities for reasons other than differences in prices and expenditure. For example, consumer preferences for the product might grow over time or be seasonal. In addition, consumers in one geographic area might have a greater preference for the product than the consumers in other geographic areas. To account for time-invariant differences in demographics or preferences across cities, separate constants are needed for each city and brand in the specification. To account for changes in demographics or preferences over time, time trend variables and seasonal variables in the specification are also included. 55. 56. Aviv Nevo, Mergers with Differentiated Products: The Case of the Ready-to-Eat Cereal Industry, 31 RAND J. ECON. 395 (2000). Among the alternative flexible functional demand forms is the popular log-log (or isoelastic) demand system, which derives its name from the fact that the logarithm of a product’s quantity is related to the logarithms of all the products’ prices and the logarithm of category expenditure. Taking logs can sometimes “linearize” the data, which enables it to be analyzed more easily. Other flexible demand systems exist, i.e., the various translog forms. See, e.g., POLLAK & WALES, supra note 44, at 53-59; Deaton, supra note 44, at 1788–93. These systems share many of the properties of the AIDS; however, they are more difficult to estimate. NYDOCS:19868.1 MERGER SIMULATION 293 The AIDS model describes consumer demand for a product conditional on category expenditure. However, category expenditure itself is determined as part of the consumer’s overall decision as to how to allocate the total expenditure across the full range of product categories. In other words, the consumer’s unconditional demand for a product can be broken into two parts, or stages, from a conceptual point of view.57 In the first stage, the consumer decides how to allocate total expenditure among the various product categories. In the second stage, the consumer decides how to allocate the expenditure for a given category across the products within the category.58 Under two-stage budgeting, to determine the unconditional demand for a given product, one must combine the demand for the product, conditional on category expenditure, with the demand for the category as a whole. Thus, one needs to estimate the demand for the category as a whole. This equation is referred to as the “top-level” demand equation. The two-stage budgeting approach can be extended to three or more stages, which is useful if the category contains a large number of products, rendering the estimation of a single AIDS specification, including all of the products, unwieldy. In that case, one can divide the category’s products into segments, perhaps according to product characteristics or company market research. For example, the products in the beer category might be segmented into light beers, premium beers, and low-priced beers. A separate AIDS model can be estimated for each segment, conditional on segment expenditure. Then a segment demand model can be estimated, conditional on beer expenditure, and finally, a top-level beer demand model can be estimated, conditional on total expenditure. The three models can be combined to derive the unconditional demand for any given product.59 57. 58. 59. It is not necessary that the consumer actually go through this thought process for the two-stage budgeting methodology to be an appropriate way of modeling the consumer’s decision problem. This two-stage budgeting approach was developed by W.M. Gorman, Two-Stage Budgeting, in COLLECTED WORKS OF W.M. GORMAN, VOLUME 1: SEPARABILITY AND AGGREGATION 22 (C. Blackorby & A.F. Shorrocks eds., 1995). Use of multi-stage budgeting does impose restrictions on the demand system. However, these restrictions can be tested. See, e.g., Hausman & Leonard, supra note 29. NYDOCS:19868.1 294 ECONOMETRICS h. Issues in Estimation When estimating a demand system, a potential “simultaneity” problem arises because factors unobserved to the econometrician may affect both consumer demand and the price setting of firms. In that case, the prices appearing on the right-hand sides of equations would be correlated with the error terms of these equations. Ordinary least squares and its variants would be biased and inconsistent. In general, the solution to the simultaneity problem is to employ an “instrumental variables” technique, which involves finding variables (the instruments) that are correlated with the endogenous variables (in this case, prices), but not correlated with the error terms. The endogenous variables are in essence replaced with the instruments, and the simultaneity problem disappears (since the instruments are not correlated with the error terms, as were the endogenous variables).60 In an AIDS system, the estimated cross elasticities are not guaranteed to be positive and some may be negative, especially when the number of products is large. Negative cross elasticities can be a cause for concern because they are counter-intuitive and because they can lead to odd results in consumer welfare calculations or merger simulations. The first question to ask is whether the two products in question might, in fact, be complements rather than substitutes, in which case the true cross elasticities would be negative. If the products should be substitutes, the next question to ask is whether the estimates are statistically significantly different from zero. If not, the negative estimated cross elasticities should be of no concern unless they unduly affect subsequent calculations of interest, i.e., merger simulations. In that case, the cross elasticity can be constrained to zero; however, one must proceed carefully once restrictions from economic theory have been imposed, because these properties link the elasticities together. If one or more cross elasticities are estimated to be negative and statistically significantly different from zero, then the appropriate response depends upon the number of negative estimated cross elasticities relative to the total number of estimated cross elasticities. If the number of products is large, so that many cross elasticities have been 60. For additional details, see Appendicies II and IV. NYDOCS:19868.1 MERGER SIMULATION 295 estimated, it would not be surprising to find some negative and statistically significant cross elasticities. However, a relatively large number of negative cross elasticity estimates would suggest a problem with the data or the model specification. The appropriate response would be to examine the data for errors and try different model specifications (i.e., add other variables to the specification or implement a different flexible functional form).61 A common finding in consumer demand studies is the rejection of restrictions based on economic theory. One would generally want to impose these properties, particularly if consumer welfare calculations are to be performed using the estimated demand system. The consumer welfare calculations are not valid if the properties do not hold. If, on the other hand, one is performing other types of calculations (i.e., price increases) the properties are less important, and if the properties are rejected, one might want to proceed without imposing them. Generally, one should examine the reason for the rejection of the properties. If the difference between the unrestricted model and the restricted model is small from an economic point of view, one may impose the restrictions even if they have been rejected by the statistical test. If the difference between the models is economically important, then one needs to reconsider the econometric specification. For a given category, i.e., facial tissue, the number of individual products can be quite large because each brand (i.e., Kleenex) might have many different package sizes or types (i.e., stand-up versus flat) and many varieties (i.e., different colors). Specifying a demand system to account for all of the individual products is not realistic. Instead, the products must in some way be aggregated and the demand system specified for the aggregates. The question is the proper degree of aggregation and the appropriate aggregation method to use. Sometimes the degree of aggregation (and the method) is predetermined. For example, the econometrician may not have access to disaggregated data without substantial additional cost. In this situation, the econometrician has little control over the degree of aggregation. When disaggregated data are available, the degree of aggregation that should be undertaken is determined by practical considerations and 61. Choosing an alternative demand system specification that forces all cross price elasticities to be positive, i.e., the logit demand system, may place restrictions that are inconsistent with the data. NYDOCS:19868.1 296 ECONOMETRICS the desire not to distort the econometric estimates. A good way to proceed is to test the effect of using different levels of aggregation within a range dictated by the practical considerations. In some cases the degree of aggregation does not significantly affect the results, while in others results have proven otherwise. Regarding the method of aggregation, economic theory dictates that an appropriate price index, with a corresponding quantity index, be used to aggregate products. In many circumstances this approach is feasible. However, in a situation where one or more new varieties (i.e., package sizes or flavors) have been introduced during the period covered by the data, formation of appropriate price and quantity indices is more problematic. Incorporating a new product into a price index is a complex undertaking and correctly addressing this issue may not be desirable when it is not the primary focus of the exercise. As an alternative solution, a new variety’s revenue and quantity can be aggregated with those of other products and then this aggregate can be further aggregated with other products using economically correct price and quantity indices. Retail scanner data may include information on the extent of in-store promotional and advertising activity, which would be expected to affect consumer demand. Therefore, it might be useful to incorporate this information into the AIDS demand system. Advertising and promotion should work in the same fashion as prices. An increase in the advertising and promotion for one product would both increase the demand for that product and decrease the demand for competing products. The natural way to incorporate this information is to make city-brand specific effects a function of the extent of advertising and promotion of each of the products. Similarly, in the top level, an “index” that combines the advertising and promotional activities of all the brands could be entered as an additional variable in the share equations. However, this approach would add a significant number of additional parameters to be estimated. Therefore, in some situations a modified approach might be useful. For example, an index that combines the advertising and promotion variables of the other products into a single variable might be used in place of the individual advertising and promotion variables for each product. When weekly data are used, a danger exists that the elasticity estimates obtained from a demand system represent short-run behavior rather than long-run behavior. Specifically, if consumers stock up on NYDOCS:19868.1 MERGER SIMULATION 297 products when they go on sale, their short-run responsiveness to price changes (i.e., sales) might exceed their long-run responsiveness to price changes (i.e., permanent price changes). Consumer inventorying behavior could lead to incorrect conclusions about the effects of a merger. One implication of consumer inventorying behavior is that a week with larger than normal demand (i.e., due to a sale) may be followed by weeks with smaller than normal demand (as consumers deplete their inventories rather than purchasing at the full price). However, the opposite has been observed: Larger than normal demand one week sometimes is followed by larger than normal demand the next week. This result is inconsistent with substantial consumer inventorying behavior; however, other recent studies have reported finding evidence of inventorying behavior.62 Of course, the situation differs across product categories and, thus, the extent of inventorying behavior should be investigated in a given situation. If it appears to be an issue, then there are two ways to account for it. First, the dynamic behavior might be explicitly modeled and the long-run elasticities calculated as a function of the short-run elasticities and the parameters describing the dynamic behavior. Second, the data could be aggregated over time (monthly) and the model re-estimated on the time-aggregated data.63 Surveys have also been used to estimate cross-elasticities of demand. A well-designed survey conducted on a representative sample of the population can provide unbiased results relatively quickly and efficiently. A survey to estimate cross elasticities of demand might ask the respondent to rank alternatives and to describe the various alternatives in terms of their characteristics (e.g., brand, price, taste, size). Market outcomes can be simulated for a base case scenario and then for an alternative scenario where an attribute is changed – for instance the price of one product may be increased by ten percent. While surveys may be able to generate estimates of cross elasticities that are not otherwise available, the cost of a survey may be significant. 62. 63. See, e.g., Igal Hendel & Aviv Nevo, Sales and Consumer Inventory (NBER Working Paper No. w9048, July 2002). Time-aggregation provides another test of inventorying behavior. If the estimated elasticities are significantly lower in the time-aggregated model, inventorying behavior might be present. NYDOCS:19868.1 298 ECONOMETRICS In addition, it is difficult to avoid selecting a biased sample. If, for instance, a surveyor wanted to determine the popularity of a film, the easiest method would be to stand outside a theater showing that film and survey people as they leave. However, since most people go to theaters near their homes, there will likely be a demographic bias. The same film in a different part of town may be received very differently. Another example of a biased survey would be Internet surveys. Clearly, the respondents will only be Internet users, and they are not generally representative of the population as a whole. Telephone surveys are the most popular interview method – over 95% of homes have a phone – however calling during the day will bias the sample since only people who do not work or who work from home will be reached. It is not likely that they will be representative of the population as a whole. While these drawbacks exist for any survey, a well-designed survey can be extremely useful and in some instances may be the only way to get estimates of certain parameters. The estimated demand system is typically used to estimate the likely effects of a merger on prices, to calculate the welfare changes induced by changes in prices or qualities of products, or to determine the lost profit damages resulting from patent infringement. Since the demand system has been estimated, any calculations based on the demand system will reflect the statistical variation inherent in the estimated demand system parameters. Thus, it is typically desirable to calculate standard errors for any results derived from the estimated demand system. Econometrics offers several straightforward ways in which to do this. 3. PCAIDS a. Introduction PCAIDS, which is short for proportionally calibrated AIDS, is an approximation to the AIDS model that offers advantages in many situations.64 AIDS often yields estimated cross elasticities that have low precision and algebraic signs that are inconsistent with economic theory. Moreover, AIDS requires substantial data, which are typically available 64. For details, see Roy E. Epstein & Daniel L. Rubinfeld, Merger Simulation: A Simplified Approach with New Applications, 69 ANTITRUST L.J. 883 (2001). NYDOCS:19868.1 MERGER SIMULATION 299 only for retail sales tracked by check-out scanners. PCAIDS, in contrast, uses only market shares and reasonable values for two elasticities—the price elasticity of industry demand and the price elasticity of any one product. Estimates of these elasticities often can be obtained from marketing information or, when appropriate, through demand estimation. This simplicity is achieved by placing restrictions on the structure of the AIDS model. There are methods both to test the validity of the restrictions and to relax them to generalize the analysis. In summary, PCAIDS is a reasonably general method for calibrating AIDS demand with minimal data, and for which proportionality is a useful starting point. PCAIDS has similarities to, and differences from, the ALM. Both rely on the principle of proportionality, which allows them to be implemented using only market shares, the price elasticity of industry demand, and a single brand-level demand elasticity or other equivalent condition. There are three main differences: First, the predicted unilateral effects from PCAIDS tend to be larger than those from the ALM. The two models might be viewed as providing approximate upper and lower bounds on the likely price effects of the transaction. Second, it appears easier to relax the assumption of proportionality for PCAIDS. Since proportionality is a strong assumption it is important to be able to investigate the effect of not using it, and this analysis is easily manageable with PCAIDS. Third, PCAIDS can be used even when information on underlying product prices is not available. b. Estimation A simple example with three independent firms, each owning a single brand, helps explain the logic of PCAIDS. The AIDS model specifies that the revenue share of each brand depends on the logarithms of the prices of all brands. More formally, the share of each brand, as a percent of total market revenues is a function of the weighted average of the natural logarithms of the prices of all of the brands in the system. The weights or coefficients, which can be used to calculate own and cross elasticities, must be determined to simulate the effects of a merger.65 Three “own-coefficients” specify the effect of each brand’s 65. This discussion suppresses the aggregate expenditure terms from the original AIDS specification. This “homotheticity” assumption is NYDOCS:19868.1 300 ECONOMETRICS own price on its share. These coefficients should have negative signs, since an increase in a brand’s price should (all other prices held constant) reduce its share; indeed, these coefficients are closely related to and have the same signs as the own elasticities. The six other coefficients specify the effects of the prices of other brands on each brand’s share. These “cross-coefficients” are expected to be positive (assuming the three brands are substitutes), since these terms are related to and have the same signs as the cross elasticities.66 There are a total of nine elasticities in this example. The number of demand elasticities grows as the square of the number of brands, so analysis of most markets must confront the econometric complications caused by a large number of unknown parameters. The restrictions imposed by PCAIDS are designed to reduce the number of parameters that have to be estimated on the basis of a simple assumption: The share lost as a result of a price increase is allocated to the other firms in the relevant market in proportion to their respective shares. This is the IIA assumption discussed above, and it reduces the number of unknown price coefficients from nine to three. We only need to know the three own-coefficients (and market shares) to calculate the remaining six cross-coefficients. In fact, the proportionality assumption reduces the information requirement of PCAIDS even further. It can be shown that the PCAIDS model, like the ALM, can be calibrated with only two independent pieces of information (in addition to the shares)— the elasticity of demand for a single brand and the elasticity for all brands in the aggregate. Thus, only the aggregate elasticity and the ownprice elasticity for Brand 1 are needed as inputs in the calculation of the own-coefficient for Brand 1, and proportionality implies that all remaining unknown own-coefficients can be determined as simple multiples of the Brand 1 own-coefficient. Thus, knowledge of the own elasticity of any one brand and the aggregate industry demand elasticity 66. reasonable to the extent that changes in industry expenditure have no significant effects on share. The market shares predicted by AIDS are required to sum to 100%—the adding-up property. PCAIDS also imposes homogeneity, the assumption that equal proportional changes in all prices have no effect on market share (e.g., if all prices went up by 10 percent, the market shares for the various brands should not change). Adding-up and homogeneity reduce by one the number of brands to be analyzed in the AIDS model. NYDOCS:19868.1 MERGER SIMULATION 301 is sufficient to obtain estimates of all relevant demand parameters of the PCAIDS model from the market share data. All the information required to calibrate PCAIDS should be available. Market shares typically are known with reasonable accuracy. It should be feasible to infer the own elasticity of demand for at least one brand sold by the merging parties from marketing studies in the party’s documents (including surveys and focus groups), from econometric analyses, or from accounting data. The industry demand elasticity of demand typically is considerably smaller than the demand elasticity of any one brand, since brand substitution is easier than industry substitution.67 Absent independent information about the magnitude of that elasticity, an aggregate elasticity of –1 may be a good starting point for a preliminary merger simulation. To illustrate, again consider a three-brand demand system, with shares for the brands (each sold by a different firm) of 20 percent, 30 percent, and 50 percent. Now assume: there is a proposed merger between sellers of Brands 1 and 2; the industry elasticity is –1; and the own elasticity for the first brand is –3. The PCAIDS are elasticities as shown in Table 1. The calculated own elasticities—the other negative values on the diagonal—can be larger or smaller than the elasticity for the brand used to calibrate the system. Reading down each column of elasticities, the cross elasticities corresponding to the change in a given price, are equal as expected, given proportionality. PCAIDS simulation with these parameters predicts a unilateral post-merger price increase (absent efficiencies) of 13.8 percent for Brand 1 and 10.8 percent for Brand 2. The same elasticities, however, yield significantly lower price increases using the ALM. 67. Suppose the prices of all cereals rose by 10 percent. Since many consumers, particularly children, are likely to continue eating the similar quantities of cereal for breakfast (some, of course, will not and consumption of cereal for other purposes, such as snacks, may fall), ready-to-eat demand is not likely to be highly price sensitive. On the other hand, a 10 percent increase for a single brand, such as corn flakes, with no change in competitors’ prices, will be more price sensitive, since it will likely result in substantial switching to other products within the cereal category. NYDOCS:19868.1 302 ECONOMETRICS Table 1 PCAIDS Elasticities Brand 1 2 3 Elasticity with Respect to: p1 p2 p3 –3.00 0.75 1.25 0.50 –2.75 1.25 0.50 0.75 –2.25 c. Deviations from Proportionality—PCAIDS with Nests Proportionality will not always characterize the diversion of lost sales accurately when products are highly differentiated. Fortunately, it is straightforward to modify PCAIDS to allow a more general analysis. In a manner analogous to the generalization of the logit model, products that are closer substitutes for each other than consistent with proportionality may be placed together in “nests.” To illustrate, return to the three-brand example discussed in the previous section. In that example, Brand 2’s market share of 30 percent and Brand 3’s share of 50 percent implied that, when Brand 1’s price is increased, diversion to Brand 2 would be 60 percent of diversion to Brand 3. This can be characterized using a “nesting parameter,” which in this case is 0.6 (i.e., 60 percent). Now suppose that Brand 2 is relatively “farther” from Brand 1 in the sense that that fewer consumers would choose Brand 2 in response to an increase in the price of the first brand than would be predicted by proportionality. For example, Brand 2 may only be “half as desirable” a substitute as Brand 3 and the appropriate nesting factor really only 0.3. PCAIDS with nests allows a more flexible pattern of cross elasticities, as the model is no longer fully constrained by the proportionality assumption. Continuing with the example, we can capture the effect of Brand 2 being a less close substitute for Brand 1 than indicated by market shares by placing Brand 2 in a nest with a nesting parameter of 0.5. Table 2 compares the calculated elasticities for NYDOCS:19868.1 MERGER SIMULATION 303 the nested model with those of the original model.68 The nesting parameter rescales the cross elasticities in the right-hand panel; the cross elasticities measuring the responses of Brands 2 and 3 to the price of Brand 1, and those measuring the responses of Brands 1 and 2 to the price of Brand 3 are no longer equal. With nesting, Brand 2 is a poorer substitute for Brands 1 and 3 (as indicated by the smaller cross elasticities of Brand 2 demand with respect to the prices of Brands 1 and 3 and of Brands 1 and 3 demand with respect to the price of Brand 2), while Brands 1 and 3 is better substitutes for each other (as indicated by the larger cross elasticities of Brand 1 demand with respect to the price of Brand 3 and Brand 1 demand with respect to the price of Brand 3). Table 2 PCAIDS Elasticities with Nests Brand 1 2 3 Non-Nested Demand Elasticity with Respect to: p1 P2 p3 –3.00 0.75 1.25 0.50 –2.75 1.25 0.50 0.75 –2.25 Brand 1 2 3 Separate Brand 2 Nest, (Nesting Parameter = 0.5) Elasticity with Respect to: p1 p2 p3 –3.00 0.46 1.54 0.31 –2.08 0.77 0.62 0.46 –2.08 Simulation of a merger of Brand 1 and Brand 2 using this nested PCAIDS model predicts a unilateral price increase (without efficiencies) of 10.1 percent for both Brand 1 and Brand 2, compared to the original increases of 13.8 percent and 10.8 percent without nests. The unilateral effects are smaller with the nested model because the merging brands are less close substitutes for each other. What remains is the difficult question of when the proportionality assumption is inappropriate, making nests necessary for accurate merger simulations. To this point, there has been very little empirical testing of this question.69 Note, however, that if PCAIDS introduces the possibility 68. 69. The calculations continue to assume an own-price elasticity of –3 for Brand 1 and an industry elasticity of –1. A statistical test procedure is described in Jerry A. Hausman & Daniel McFadden, Specification Tests for the Multinomial Logit Model, 52 ECONOMETRICA 1219 (1984). One recent AIDS analysis of a grocery NYDOCS:19868.1 304 ECONOMETRICS of bias, it may still provide an economically useful approximation.70 Fortunately, PCAIDS makes it easy to detect whether nesting is likely to have economically meaningful effects through a sensitivity analysis of the nesting parameters. A coarse grid (e.g., 0.75, 0.50, and 0.25) covering a range of nesting factors may be adequate to assess sensitivity. There is a potentially more useful, data-based approach to the estimation of nesting parameters, which relies on brand-level margin data.71 Assume, for example, that the merging firms each produce a unique brand pre merger. It is not hard to show, in this case, that one can use brand margin data to solve for unique nesting parameters. If one or more merging firms had several brands, however, it is possible for the nesting parameters to be over-identified (i.e., a range of nesting parameters would be consistent with the margin data) or under-identified (the data would not be sufficient to estimate all the nesting parameters). Nevertheless, one can still develop a range of values for the nesting parameters that is consistent with the available information, and that will generate informative predictions. d. Using PCAIDS This section offers an example of the application of PCAIDS to 1992 the acquisition of Scott by Kimberly-Clark. A PCAIDS analysis of this merger may be compared to a published simulation analysis by Hausman and Leonard that used supermarket scanner data to estimate an AIDS model.72 There were eight toilet tissue brands. Scott produced ScotTissue and Cottonelle, which had pre-merger shares of 30.9 percent 70. 71. 72. item using scanner data indicates that proportionality is reasonable but it does not formally test the hypothesis. See David A. Weiskopf, Assessment of the Relationship between Various Types of Estimation Bias and the Simulated Economic Impact of Certain Anti-Competitive Scenarios 55, Table B2 (unpublished Ph.D. dissertation, Vanderbilt University, Department of Economics, 1999). Coefficients estimated with the PCAIDS restrictions could have a variance that sufficiently lower variance to offset any bias introduced. Details are available in Roy J. Epstein & Daniel L. Rubinfeld, Merger Simulation with Nests: Using PCAIDS with Brand-Level Margin Data, (unpublished paper 2003). Hausman & Leonard, supra note 29. NYDOCS:19868.1 MERGER SIMULATION 305 and 7.5 percent. Kimberly-Clark produced only Kleenex, with a share of 6.7 percent. The PCAIDS model is calibrated using Hausman and Leonard’s estimated demand elasticity for Scott (–2.94) and a value for the aggregate elasticity (–1.17) that can be inferred from their analysis. Table 3 PCAIDS and Hausman-Leonard Elasticities Own Elasticity ScotTissue Cottonelle Kleenex Charmin Northern Angel Private Label Other Average PCAIDS –2.9 –3.2 –3.1 –2.6 –3.0 –3.1 –3.1 –3.1 –3.0 HausmanLeonard –2.9 –4.5 –3.4 –2.7 –4.2 –4.1 –2.0 –2.0 –3.2 Cross Elasticity PCAIDS 0.36 0.14 0.16 0.66 0.26 0.19 0.16 0.20 0.27 HausmanLeonard 0.24 0.22 0.13 0.35 0.41 0.26 0.09 0.27 0.24 Table 3 compares PCAIDS price elasticities to the elasticities estimated econometrically by Hausman and Leonard. The two methods yield similar results brand by brand, and on average there appears to be relatively little difference.73 This suggests that the proportionality assumption of PCAIDS is reasonably consistent with the toilet tissue data. Moreover, differences between the elasticities yielded by the two methods may not be statistically significant. Hausman and Leonard report low precision for many of the estimated cross elasticities. For 73. Each Hausman-Leonard cross elasticity in the table is calculated as the average of the cross elasticities with respect to the price of the brand given in the left-most column. The Hausman and Leonard study reported several negative cross elasticities (for non-merging goods) that we found difficult to interpret. The average values reported in the table exclude any negative cross elasticities. NYDOCS:19868.1 306 ECONOMETRICS example, they report a Kleenex-Scott cross elasticity of 0.061 with a standard error of 0.066; this means that their estimated cross elasticity is within two standard errors of our calibrated PCAIDS value of 0.16. Uncertainty about the true value of this cross elasticity is particularly crucial to the merger simulation analysis since the magnitude of this cross elasticity has a large effect on the price increases predicted from the merger. Taking into account the efficiencies assumed by Hausman-Leonard, the two simulation methods yield predicted price changes for the merging firms as shown in Table 4. The predicted price changes are similar for ScotTissue and Cottonelle. There is a greater difference between the predicted price changes for Kleenex, although even this difference may not be statistically significant. As a sensitivity test, a nest structure was used that lowered the PCAIDS Kleenex-Scott cross elasticity to 0.061 and left the other cross elasticities in the model essentially unchanged. The price increase for Kleenex predicted by this nested PCAIDS model fell to 1.7 percent. This experiment suggests that increasing the same cross elasticity by two standard errors in the Hausman-Leonard simulation would produce a Kleenex price change much closer to the PCAIDS result. Table 4 Simulated Unilateral Effects for Toilet Tissue ScotTissue Cottonelle Kleenex NYDOCS:19868.1 Price Change (%) HausmanPCAIDS Leonard –0.3 –1.1 0.7 0.5 4.3 0.2
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