The Progressive Policy Institute (PPI) is pleased to provide comments to the Federal Trade Commission (FTC) and the Antitrust Division of the Department of Justice (DOJ) on the draft Merger Guidelines (“draft Guidelines”), issued on July 19, 2023, in Docket FTC-2023-0043. PPI is a catalyst for policy innovation and political reform based in Washington, D.C., with offices in Brussels, Berlin, and the United Kingdom. Its mission is to create radically pragmatic ideas for moving America beyond ideological and partisan deadlock. PPI is home to a new center on competition advocacy that features expert analysis and commentary that is rooted in promoting competitive markets and the democratic values that support them.