Notice2021-19097
United States v. Zen-Noh Grain Corporation, et al.; Response to Public Comments
Primary source
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Published
September 3, 2021
Issuing agencies
Justice DepartmentAntitrust Division
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<title>Federal Register, Volume 86 Issue 169 (Friday, September 3, 2021)</title>
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[Federal Register Volume 86, Number 169 (Friday, September 3, 2021)]
[Notices]
[Pages 49563-49567]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2021-19097]
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DEPARTMENT OF JUSTICE
Antitrust Division
United States v. Zen-Noh Grain Corporation, et al.; Response to
Public Comments
Pursuant to the Antitrust Procedures and Penalties Act, 15 U.S.C.
16(b)-(h), the United States hereby publishes below the Response to
Public Comments on the Proposed Final in United States v. Zen-Noh Grain
Corporation, et al., Civil Action No. 1:21-cv-01482-RJL, which was
filed in the United States District Court for the District of Columbia
on August 30, 2021, together with a copy of the two comments received
by the United States.
A copy of the comments and the United States' response to the
comments is available at <a href="https://www.justice.gov/atr/case/us-v-zen-noh-grain-corp-and-bunge-north-america-inc">https://www.justice.gov/atr/case/us-v-zen-noh-grain-corp-and-bunge-north-america-inc</a>. Copies of the comments and the
United States' response are available for inspection at the Office of
the Clerk of the United States District Court for the District of
Columbia. Copies of these materials may also be obtained from the
Antitrust Division upon request and payment of the copying fee set by
Department of Justice regulations.
Suzanne Morris,
Chief, Premerger and Division Statistics, Antitrust Division.
United States District Court for the District of Columbia
United States of America, Plaintiff, v. Zen-Noh Grain Corp., and
Bunge North America, Inc., Defendants.
Civil Action No.:1:21-cv-01482 (RJL)
Response of Plaintiff United States to Public Comments on the Proposed
Final Judgment
Pursuant to the requirements of the Antitrust Procedures and
Penalties Act (the ``APPA'' or ``Tunney Act''), 15 U.S.C. 16, the
United States hereby responds to the two public comments received
regarding the proposed Final Judgment in this case. After careful
consideration of the submitted comments, the United States continues to
believe that the divestiture required by the proposed Final Judgment
provides an effective and appropriate remedy for the antitrust
violation alleged in the Complaint and is therefore in the public
interest. The United States will move the Court for entry of the
proposed Final Judgment after the public comments and this response
have been published as required by 15 U.S.C. 16(d).
[[Page 49564]]
I. Procedural History
On April 21, 2020, Zen-Noh Grain Corp. (``ZGC'') agreed to acquire
35 operating and 13 idled U.S. grain elevators from Bunge North
America, Inc. (``Bunge'') (``collectively, ``Defendants'') for
approximately $300 million (``the Transaction''). The United States
filed a civil antitrust Complaint on June 1, 2021, seeking to enjoin
the proposed Transaction. The Complaint alleges that the likely effect
of the Transaction would be to substantially lessen competition for
purchases of corn and soybeans in nine geographic areas of the United
States in violation of Section 7 of the Clayton Act, 15 U.S.C. 18. See
Dkt. No.1.
At the same time the Complaint was filed, the United States filed a
proposed Final Judgment and an Asset Preservation and Hold Separate
Stipulation and Order (``Stipulation and Order'') in which the United
States and Defendants consent to entry of the proposed Final Judgment
after compliance with the requirements of the APPA. See Dkt. Nos. 2-2,
2-1. The proposed Final Judgment requires the Defendants to divest
certain grain elevators and related assets of Bunge or ZGC affiliate
CGB Enterprises, Inc. (``the Divestiture Assets'') to Viserion Grain
LLC and Viserion International Holdco LLC (``Viserion''), or to another
acquirer or acquirers acceptable to the United States, within 30
calendar days after entry of the Stipulation and Order.
Pursuant to the APPA's requirements, on June 1, 2021, the United
States also filed a Competitive Impact Statement describing the
transaction and the proposed Final Judgment. See Dkt. No. 3. On June 8,
2021, the United States published the Complaint, proposed Final
Judgment, and Competitive Impact Statement in the Federal Register, see
86 FR 30479 (June 8, 2021), and caused notice regarding the same,
together with directions for the submission of written comments
relating to the proposed Final Judgment, to be published in The
Washington Post and St. Louis Post-Dispatch, from June 4, 2021, through
June 10, 2021. On July 1, 2021, the Court entered the Stipulation and
Order. See Dkt. No. 14. On July 7, 2021, Defendant ZGC effectuated the
divestiture contemplated by the proposed Final Judgment by selling the
prescribed assets to Viserion. The 60-day period for public comment
ended on August, 9, 2021. The United States received two comments,
attached as Exhibits A and B.
II. The Complaint and the Amended Proposed Final Judgment
The Complaint alleges that ZGC's proposed acquisition of certain
grain elevator assets from Bunge would likely eliminate competition
between the Defendants to purchase grain from farmers in numerous
markets along the Mississippi River and its tributaries. In particular,
the Complaint alleges that in nine geographic areas, a Bunge river
elevator and a nearby ZGC (or ZGC affiliate CGB) elevator represent two
of only a handful of grain purchasing alternatives for area farmers. In
those nine geographic areas, ZGC and Bunge currently compete
aggressively to win farmers' business by offering better prices and
more attractive amenities such as faster grain drop-off services and
better grain grading. Unless remedied, the Transaction will eliminate
competition between ZGC and Bunge in those locations in violation of
Section 7 of the Clayton Act, 15 U.S.C. 18.
The proposed Final Judgment is designed to remedy the likely harm
to competition alleged in the Complaint by requiring a divestiture that
will establish an independent, economically viable competitor for the
purchase of corn and soybeans in the nine affected geographic markets.
The proposed Final Judgment requires the Defendants to divest nine
elevators within 30 days after the entry of the Stipulation by the
Court to Viserion or another acquirer or acquirers approved by the
United States. In each of those nine geographic markets, a Bunge
elevator competes head to head with one or more ZGC or CGB elevators.
The Divestiture Assets include the real property, buildings,
facilities, and other structures associated with the nine grain
elevators. The Divestiture Assets also encompass all existing grain
inventories at the elevators, and all contracts and other agreements
that relate exclusively to the elevators that will be divested.
The Divestiture Assets must be divested in such a way as to satisfy
the United States in its sole discretion that the assets can and will
be operated by the purchaser as a viable, ongoing business that can
compete effectively in the market for the purchase of corn and the
market for the purchase of soybeans. The Defendants proposed Viserion
as the acquirer, and, after rigorous evaluation, the United States
approved Viserion as the divestiture buyer.
The proposed Final Judgment allows the acquirer, at its option, to
enter into a transition services agreement with Defendants for a period
of up to six months. As explained in the Competitive Impact Statement,
the transition services covered by the proposed Final Judgment are
those that might reasonably be necessary to ensure that an acquirer or
acquirers can readily and promptly use the assets to compete in the
relevant markets. See Dkt. No. 3 at 10 at 12.
III. Standard of Judicial Review
The Clayton Act, as amended by the APPA, requires that proposed
consent judgments in antitrust cases brought by the United States be
subject to a 60-day comment period, after which the Court shall
determine whether entry of the proposed Final Judgment ``is in the
public interest.'' 15 U.S.C. 16(e)(1). In making that determination,
the Court, in accordance with the statute as amended in 2004, is
required to consider:
(A) The competitive impact of such judgment, including
termination of alleged violations, provisions for enforcement and
modification, duration of relief sought, anticipated effects of
alternative remedies actually considered, whether its terms are
ambiguous, and any other competitive considerations bearing upon the
adequacy of such judgment that the court deems necessary to a
determination of whether the consent judgment is in the public
interest; and
(B) the impact of entry of such judgment upon competition in the
relevant market or markets, upon the public generally and
individuals alleging specific injury from the violations set forth
in the complaint including consideration of the public benefit, if
any, to be derived from a determination of the issues at trial.
15 U.S.C. 16(e)(1)(A) & (B). In considering these statutory factors,
the Court's inquiry is necessarily a limited one as the government is
entitled to ``broad discretion to settle with the defendant within the
reaches of the public interest.'' United States v. Microsoft Corp., 56
F.3d 1448, 1461 (D.C. Cir. 1995); United States v. U.S. Airways Grp.,
Inc., 38 F. Supp. 3d 69, 75 (D.D.C. 2014) (explaining that the
``court's inquiry is limited'' in APPA settlements); United States v.
InBev N.V./S.A., No. 08-1965 (JR), 2009 U.S. Dist. LEXIS 84787, at *3
(D.D.C. Aug. 11, 2009) (noting that a court's review of a consent
judgment is limited and only inquires ``into whether the government's
determination that the proposed remedies will cure the antitrust
violations alleged in the complaint was reasonable, and whether the
mechanisms to enforce the final judgment are clear and manageable'').
Under the APPA, a court considers, among other things, the
relationship between the remedy secured and the specific allegations in
the government's
[[Page 49565]]
complaint, whether the proposed Final Judgment is sufficiently clear,
whether its enforcement mechanisms are sufficient, and whether it may
positively harm third parties. See Microsoft, 56 F.3d at 1458-62. With
respect to the adequacy of the relief secured by the proposed Final
Judgment, a court may not ``make de novo determination of facts and
issues.'' United States v. W. Elec. Co., 993 F.2d 1572, 1577 (D.C. Cir.
1993) (quotation marks omitted); see also Microsoft, 56 F.3d at 1460-
62; United States v. Alcoa, Inc., 152 F. Supp. 2d 37, 40 (D.D.C. 2001);
United States v. Enova Corp., 107 F. Supp. 2d 10, 16 (D.D.C. 2000);
InBev, 2009 U.S. Dist. LEXIS 84787, at *3. Instead, ``[t]he balancing
of competing social and political interests affected by a proposed
antitrust consent decree must be left, in the first instance, to the
discretion of the Attorney General.'' W. Elec. Co., 993 F.2d at 1577
(quotation marks omitted).
``The court should bear in mind the flexibility of the public
interest inquiry: the court's function is not to determine whether the
resulting array of rights and liabilities is one that will best serve
society, but only to confirm that the resulting settlement is within
the reaches of the public interest.'' Microsoft, 56 F.3d at 1460
(quotation marks omitted); see also United States v. Deutsche Telekom
AG, No. 19-2232 (TJK), 2020 WL 1873555, at *7 (D.D.C. Apr. 14, 2020).
More demanding requirements would ``have enormous practical
consequences for the government's ability to negotiate future
settlements,'' contrary to congressional intent. Microsoft, 56 F.3d at
1456. ``The Tunney Act was not intended to create a disincentive to the
use of the consent decree.'' Id.
The United States' predictions about the efficacy of the remedy are
to be afforded deference by the Court. See, e.g., Microsoft, 56 F.3d at
1461 (recognizing courts should give ``due respect to the Justice
Department's . . . view of the nature of its case''); United States v.
Iron Mountain, Inc., 217 F. Supp. 3d 146, 152-53 (D.D.C. 2016) (``In
evaluating objections to settlement agreements under the Tunney Act, a
court must be mindful that [t]he government need not prove that the
settlements will perfectly remedy the alleged antitrust harms[;] it
need only provide a factual basis for concluding that the settlements
are reasonably adequate remedies for the alleged harms.'') (internal
citations omitted); United States v. Republic Servs., Inc., 723 F.
Supp. 2d 157, 160 (D.D.C. 2010) (noting ``the deferential review to
which the government's proposed remedy is accorded''); United States v.
Archer-Daniels-Midland Co., 272 F. Supp. 2d 1, 6 (D.D.C. 2003) (``A
district court must accord due respect to the government's prediction
as to the effect of proposed remedies, its perception of the market
structure, and its view of the nature of the case.''). The ultimate
question is whether ``the remedies [obtained by the Final Judgment are]
so inconsonant with the allegations charged as to fall outside of the
`reaches of the public interest.''' Microsoft, 56 F.3d at 1461 (quoting
W. Elec. Co., 900 F.2d at 309).
Moreover, the Court's role under the APPA is limited to reviewing
the remedy in relationship to the violations that the United States has
alleged in its complaint, and does not authorize the Court to
``construct [its] own hypothetical case and then evaluate the decree
against that case.'' Microsoft, 56 F.3d at 1459; see also U.S. Airways,
38 F. Supp. 3d at 75 (noting that the court must simply determine
whether there is a factual foundation for the government's decisions
such that its conclusions regarding the proposed settlements are
reasonable); InBev, 2009 U.S. Dist. LEXIS 84787, at *20 (``[T]he
`public interest' is not to be measured by comparing the violations
alleged in the complaint against those the court believes could have,
or even should have, been alleged.''). Because the ``court's authority
to review the decree depends entirely on the government's exercising
its prosecutorial discretion by bringing a case in the first place,''
it follows that ``the court is only authorized to review the decree
itself,'' and not to ``effectively redraft the complaint'' to inquire
into other matters that the United States did not pursue. Microsoft, 56
F.3d at 1459-60.
In its 2004 amendments to the APPA, Congress made clear its intent
to preserve the practical benefits of using consent judgments proposed
by the United States in antitrust enforcement, Public Law 108-237, 221,
and added the unambiguous instruction that ``[n]othing in this section
shall be construed to require the court to conduct an evidentiary
hearing or to require the court to permit anyone to intervene.'' 15
U.S.C. 16(e)(2); see also U.S. Airways, 38 F. Supp. 3d at 76
(indicating that a court is not required to hold an evidentiary hearing
or to permit intervenors as part of its review under the APPA). This
language explicitly wrote into the statute what Congress intended when
it first enacted the APPA in 1974. As Senator Tunney explained: ``[t]he
court is nowhere compelled to go to trial or to engage in extended
proceedings which might have the effect of vitiating the benefits of
prompt and less costly settlement through the consent decree process.''
119 Cong. Rec. 24,598 (1973) (statement of Sen. Tunney). ``A court can
make its public interest determination based on the competitive impact
statement and response to public comments alone.'' U.S. Airways, 38 F.
Supp. 3d at 76 (citing Enova Corp., 107 F. Supp. 2d at 17).
IV. Summary of the Comments and the United States' Response
The United States received two public comments in response to the
proposed Final Judgment: One from Missouri Attorney General Eric
Schmitt and another from Mr. Mark Calmer, an Iowa farmer and small
agricultural business owner. Consistent with the allegations in the
United States' Complaint, both comments express concern that ZGC's
proposed acquisition of certain Bunge elevators will reduce competition
for the purchase of soybeans and corn along the Mississippi River.
Missouri Attorney General Schmitt's comment expresses support for the
divestiture outlined in the proposed Final Judgment. Mr. Calmer's
comment does not express concerns about the adequacy of the divestiture
outlined in the proposed Final Judgment nor concerns with Viserion as
the proposed acquirer.
In his comment, Missouri Attorney General Schmitt emphasizes that,
as highlighted in the Complaint, the Transaction would ``eliminat[e]
crucial competition'' for the purchase of grain from farmers in
Southeast Missouri. Attorney General Schmitt further states his support
for the proposed Final Judgement, noting that ``[i]f entered, the
proposed judgment would replace the competition between Zen-Noh and
Bunge by establishing an independent player in the market that will
compete for the purchase of grain. This competition will help ensure
that Missouri's farmers receive a fair price for the crops that they
sell.'' See Exhibit A.
Mr. Calmer, a farmer located in Manson, Iowa, expresses concern
about increasing concentration in a number of agricultural markets,
including the grain export, beef packing, fertilizer and chemical, and
seed industries. With respect to grain elevator operations along the
Mississippi River, Mr. Calmer states that if the Transaction goes
through, it will greatly reduce competition for grain purchases. Mr.
Calmer does not discuss the terms of the proposed Final Judgment. See
Exhibit B. The proposed Final Judgment will preserve competition for
the purchase of grain: Where ZGC and Bunge elevators have overlapping
draw areas with few competitors, one of their facilities will
[[Page 49566]]
be divested. In Iowa, for example, the parties are selling Bunge's
elevator in McGregor to an independent competitor to maintain
competition for farmers in that area.
Nothing in either comment warrants a change to the proposed Final
Judgment or supports a conclusion that the proposed Final Judgment is
not in the public interest. As required by the APPA, the comments, with
the authors' contact information removed, and this response will be
published in the Federal Register.
V. Conclusion
After careful consideration of the public comments, the United
States continues to believe that the proposed Final Judgment provides
an effective and appropriate remedy for the antitrust violation alleged
in the Complaint and is therefore in the public interest. The United
States will move this Court to enter the Final Judgment after the
comments and this response are published as required by 15 U.S.C.
16(d).
Dated: August 30, 2021.
Respectfully submitted,
For Plaintiff United States of America
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Jill Ptacek,
Attorney for the United States, U.S. Department of Justice,
Antitrust Division, 450 Fifth Street NW, Suite 8000, Washington, DC
20530, Tel: (202) 307-6607, Email: <a href="/cdn-cgi/l/email-protection#33595a5f5f1d434752505658734640575c591d545c45"><span class="__cf_email__" data-cfemail="b1dbd8dddd9fc1c5d0d2d4daf1c4c2d5dedb9fd6dec7">[email protected]</span></a>.
ATTORNEY GENERAL OF MISSOURI
ERIC SCHMITT
July 15, 2021
VIA ELECTRONIC MAIL
Robert Lepore, Esq.,
Chief, Transportation, Energy, and Agriculture Section, Antitrust
Division, Department of Justice, 450 Fifth Street NW, Suite 8000,
Washington, DC 20530, <a href="/cdn-cgi/l/email-protection#96c4f9f4f3e4e2b8daf3e6f9e4f3d6e3e5f2f9fcb8f1f9e0"><span class="__cf_email__" data-cfemail="b7e5d8d5d2c5c399fbd2c7d8c5d2f7c2c4d3d8dd99d0d8c1">[email protected]</span></a>.
Re: United States v. Zen-Noh Grain Corporation and Bunge North
America, Inc., No. 1:21-cv-01482, Comments of Missouri Attorney
General Eric Schmitt
Dear Mr. Lepore:
The farmers of Missouri rely on robust competition among
purchasers of grain to obtain fair compensation for their crops.
Without robust competition, the farmers' livelihood and their
ability to continue supplying vital crops to our country are
threatened.
The proposed acquisition by Zen-Noh Grain Corporation (``Zen-
Noh'') of grain elevators from Bunge North America, Inc. (``Bunge'')
poses an existential threat to the farmers of Missouri by
eliminating crucial competition between Zen-Noh and Bunge for the
purchase of corn and soybeans. Missouri farmers have expressed
concern that, post-acquisition, Zen-Noh would control seven
consecutive grain terminals along the lower Mississippi River.
Indeed, as the Antitrust Division notes in its Complaint, the
acquisition would concentrate 95% (in 2019) of Pemiscot County's
corn and soybean output within one buyer. In short, by eliminating
one of the few buyers of grain in the Missouri Bootheel, the
acquisition will lead to lower prices paid to Missouri farmers.
In light of the unacceptable threat to competition posed by the
acquisition, I write on behalf of my constituents in Southeast
Missouri to express my support for the proposed divestiture of grain
elevators to a suitable buyer. If entered, the proposed judgment
would replace the competition between Zen-Noh and Bunge by
establishing an independent player in the market that will compete
for the purchase of grain. This competition will help ensure that
Missouri's farmers receive a fair price for the crops that they
sell.
I respectfully request that the Court enter the proposed
judgment to restore competition for the purchase of grain in
Southeast Missouri.
Respectfully submitted,
Eric Schmitt,
Attorney General, State of Missouri, Supreme Court Building, 207 W.
High Street, P.O. Box 899, Jefferson City, MO 65102, Phone: (573)
751-3321, Fax: (573) 751-0774, <a href="http://www.ago.mo.gov">www.ago.mo.gov</a>.
Robert Lepore, Chief, Transportation, Energy and Agriculture
Section, Anti-Trust Division, United States Department of Justice,
Suite 8000, Liberty Square Building, 450 Fifth Street NW,
Washington, DC 20530
Dear Sir,
Thank you for inviting me as a farmer and Ag business owner to
submit my concerts and comments to your department as invited in an
article in the High Plains Journal dated June 7, 2021 regarding the
Department of Justice and Zen-Noh. I appreciate your time and
attention to this critical matter.
I started farming in 1972. We are an Iowa farming operation. Our
background includes approximately 5000 acres of farmland, an Ag
retail operation, an Ag drainage business and our son has a 500 head
cattle feedlot operation.
We are part of the small businesses that made this country. We
employ 12 full-time employees divided between the different
entities. We also employ part-time help seasonally. For years, we
have felt that Anti-Trust laws were not protecting our family
operated Ag businesses.
Export Houses
When foreign companies align themselves with grain export
houses, they don't have to offer competitive prices for our
products. We need competition to keep prices competitive and allow
for the average farm operation to have a profit. More grain dealers,
more export houses, more packers, more fertilizer and chemical
import companies are needed to keep the American farm engine
running. We need free trade to keep our costs sustainable.
If export houses are monopolized along the Mississippi and other
waterways, I can no longer bid multiple locations and discern
competitive pricing. If the 48 Bunge elevator sales go through it
greatly reduces our competition for bids. By Zen-Noh purchasing
those elevators, they no longer have to bid competitively from other
export houses controlling a large market share. From where we sit on
the farm, it appears they are exploiting grain merchandisers by
limiting competition.
This isn't the only industry that we see Anti-Trust laws not
being honored.
Cattle Industry
As we look at the cattle industry. There are basically 3 packers
left. JBS, the Brazilian-owned and controlled packer is profiting
$1000 per head right now while the producer is losing $200-$400/head
because our government has let the packers monopolize this industry.
They don't have to bid up on cattle because they know they are the
only game in town.
Fertilizer and Chemical Industries
Another instance is the fertilizer and chemical industry. The
same thing has been allowed to happen, being controlled by 3 major
companies. Last season we did have some relief because of foreign
imports of fertilizer. However the MOSAIC company complained, filed
a law-suit to lessen import by implementing strong tariffs. Our
government officials went along with it without regard to the family
farmer's struggle with prices. In less than a year, phosphorus
fertilizer prices went from $285/ton FOB Dubuque, Iowa on the
Mississippi to $645/ton. That is a 227% increase in less than 12
months.
Seed and Grain Industries
Another Ag sector being controlled is the seed industry. Foreign
countries are buying up small and large seed companies. Look at
Bayer (German owned), Syngenta (China owned), all monopolizing this
critical industry while our government allows foreign ownership and
control.
Non-Profit Organizations
Another thing happening in our area and across the United States
is the activity of allowing Non-profit organizations to buy
farmland. Non-profit organizations do not pay the state or federal
taxes the average farm operation has to pay. Locally we are seeing
the Latter Day Saints Church (Mormon) buying tillable and production
farmland under the operating name of Deseret Trust Company. Other
Non-profit entity names the Mormon church controls include Farm
Reserve Incorporated. We have several young farmers in central Iowa
trying to either get into farming or buy enough land to grow their
operation large enough to sustain the business. They can not bid and
win against these large Non-profits and their seemingly unlimited
funds.
As you are probably aware, Bill Gates controls another Non-
profit owning and controlling exorbitant amounts of farmland. These
groups buy the land, raising the cash rent so high the young and
local farmer can not get a foothold. It is a rare bank that is going
to go along with the risk associated with a young farmer paying
higher cash rent than is profitable. We, as local farmers, have to
compete with these Non-profits and it is not a level playing field.
[[Page 49567]]
Non-profits are milking our state and federal governments out of
approximately $100-$150/acre per year of state and local taxes. By
our accounts, because these Non-profits do not pay the local and
state taxes, their burden is passed along to the local farmer,
smaller communities and rural areas.
It is time for an investigation into these Non-profit
organizations
Steel Industry
Previous administrations have stopped foreign imports which
caused Us steel prices to skyrocket as major suppliers were only in
our country. This lack of competition has doubled the steel price--
leading to increased burden on farming operations. We need both. We
support competition.
Finally, please stop allowing our country to be sold piece by
piece to foreign entities. It seems of national interest that
foreign ownership of our resources is unwise for economic and
security reasons. Family-owned, hard-working Ag business are giving
up the fight and giving in to the pressure of foreign ownership and
the dollars it represents. We support legislation that would limit
foreign investors ownership and control of American farmland and the
inputs to support the industry around it.
From where we sit, it would be easy to believe that large
corporations are allowed to merge with other conglomerates to the
benefit of the individuals, governments and share-holders while
Americans are unprotected even though Anti-Trust laws have been
established but seemingly unenforced and ignored.
Please understand the need to open up imports and free trade! We
as farmers have to compete with our products being exported to
foreign markets, while our side has controlled input prices by
tariffs being leveled by our government siding with big business. We
see the economic impact of our government allowing monopolies
without regard to Anti-Trust laws.
I invite more discussion on these matters. Feel free to call my
cell [redacted]. I also want to personally invite you to be on the
grounds of our small business and operations. I would welcome the
conversation.
Thank you,
Mark Calmer
[Redacted]
[FR Doc. 2021-19097 Filed 9-2-21; 8:45 am]
BILLING CODE 4410-11-P
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