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Analyzing The Digital Markets Act (DMA) In The Context Of Competition In The European Union

Modern techniques have replaced traditional ones as a result of the information and communication technology industry's explosive expansion. The modernization process is reflected in both the emergence of new facets of life and the decline of traditional customs. One such instance is the conventional market, which is currently fighting against competition from both inside its own traditional framework and from contemporary markets such as supermarkets and malls.[1]

The industrial revolution is said to have had a significant impact on society, culture, the economy, and human resource management. Positive developments have been brought about for enterprises in conventional marketplaces by the fourth industrial revolution. But, given that new markets are being created via the Internet of Things (IoT) and digital marketplaces, some business owners see it as a danger.

Technical data-based business transactions carried out electronically are referred to as e-commerce, or the digital marketplace.[2] It includes the introduction of products, services, or brands through digital media, usually through the use of internet networks. Business transactions completed electronically via public networks, devoid of physical presence between parties and without regard to jurisdictional boundaries, characterise digital marketplaces and are valued economically.[3]

Economic behaviour is changing from traditional to digital methods, which has a dynamic impact on the dynamics of the digital market and the competitiveness among businesses.[4] In this dynamic environment, competition law and its regulators have to take into account things like the future growth of digital platforms and the importance of intangible capital.[5]

When two or more parties in a business sector compete with one another to achieve comparable goals, business competition takes place. It may have an effect on trade, industry, business climate, certainty, effectiveness, public interest, and welfare of the populace policies. A robust economy depends on fair competition because it fosters the healthy development of businesses. But because monopolistic behaviour and other unfair strategies are so common, regulatory bodies are required to maintain fair competition. To regulate this part of the market, regulatory bodies are equipped with a multitude of instruments and capabilities.

Since unfair economic competition does not happen at random, there are particular causes for it to exist. Business actors alter or fabricate circumstances to suit their own interests by engaging in unfair activities, either individually or collectively. Though it may eventually hurt other firms, these acts are motivated by motives that attempt to benefit a business actor at the expense of others.

Large corporations' monopoly or dominance in the digital market has prompted the creation of laws like the Digital Markets Act (DMA) of the European Union. In the context of the dominant position of tech giants, this legislation seeks to level the playing field for technological enterprises. It lays out rules for internet businesses, especially those in charge of data access and platforms like Microsoft, Google Alphabet[6], Amazon,[7] Apple,[8] Meta, and Google, who together have acquired more than 400 businesses globally in the past ten years. Ensuring fair competition and contestability in the digital market sector are the two key goals of the DMA. In the end, the EU believes that this would provide customers more options by pushing smaller businesses to compete with Big Tech and innovate.

The Digital Markets Act (DMA) was introduced with the intention of fostering greater competition and addressing concerns about digital monopolies created by large technology companies. Additionally, as Amazon has said, these new restrictions would stop these internet giants from utilising data collected on their platforms by business clients to gain an unfair competitive edge over them. These big businesses' actions are seen to function as gatekeepers for the internet platform economy. On the basis of this context, this article will discuss the idea behind the European Union's Business Competition Digital Markets Act (DMA) and look at how the law affects the digital market.[9]

A Brief History Of DMA

Roadmap of DMA
It took less than three years to draft the Digital Markets Act (DMA), which is unusually swift for an EU lawmaker. Prior to 2018, the general consensus was that the competition laws in place were adequate for the digital era. Nonetheless, a change in policy was signalled in 2019 with the release of the Crémer Report,[10] which was ordered by EU Commissioner Margrethe Vestager. The research endorsed the notion of additional laws for specific scenarios in the digital economy, even though it was inconclusive. As a result, the Commission began to evaluate the possibilities for a "New Competition Tool" (NCT) and the implications of regulating big platforms ex ante.[11]

If there had been "structural competition problems" in a market, the NCT would have permitted quick fixes without requiring proof of a breach of EU competition laws. In the end, the Commission chose the DMA, which combined the market research tool and the ex-ante regulatory strategy into one instrument. Following discussions, the DMA proposal was released in December 2020, and the wording was accepted by the Parliament and Council in 2022. Following a transition phase, the DMA is scheduled to take effect in the first half of 2023.[12]

Competition Law as a blueprint.
Notably, the DMA's legal responsibilities are mostly derived on previous competition law rulings, if not entirely from them. For instance, Article 6(5) of the DMA, which forbids gatekeepers from providing preferential treatment to their own goods and services in rankings and indexing, takes into account the Commission's ruling in the Google Shopping case.[13] Similarly, Article 6(2) addresses concerns raised by the Commission during its inquiry into Amazon's use of merchant data from third parties.

This provision protects business customers from gatekeepers who exploit their data to compete with them. Article 6(7) is similar to the Commission's probe into Apple Pay and its NFC technology limitations in that it requires gatekeepers to permit third-party service providers to work with their hardware and software.

There are benefits and drawbacks to basing legislation on ongoing legal issues. There are questions regarding the procedural legality of the DMA since critics contend that the law does not benefit from the expertise acquired from competition cases. Proponents counter that there is nothing to be learned from prior decisions because the DMA works on the borderline of competition law, which might indicate that competition law disputes take too long. The DMA is commended overall for its efficient procedures and practical attitude.[14]

Not many of the instances that were included in the DMA have been challenged in EU courts; Microsoft, Google Shopping, and Google Android are a few examples. This raises no questions about the DMA's duties' legality. Under EU law, an administrative act's validity is independent of the cases that served as its judicial model continuing to exist. Testing legal theories in court is a somewhat cheap method. The EU courts will continue to confirm or deny the validity of Article 102 TFEU[15] in certain ongoing competition disputes that are being appealed or will be appealed. Differing rulings from judges may result in a legal system with contradictory laws.

Scope Of DMA

DMA Dual Concept
Two fundamental ideas that define the DMA's purview are "core platform service" (CPS) and "gatekeeper."[16] These ideas are exclusive to the DMA and aren't found in conventional competition legislation. A gatekeeper is a structural notion that concentrates on the largest enterprises inside CPSs; nevertheless, gatekeeper status is not the same as dominance in EU competition law. A CPS determines which goods or services are covered by the DMA.

Only digital services offered by gatekeepers and included in a predetermined list of CPSs are subject to the DMA's requirements. The hesitation of EU parliamentarians towards tackling market power in the digital economy is reflected in this dual filter strategy. Certain sections of the DMA defend the inclusion of digital services on the CPS list by implying that they are fundamentally uncontestably and unfair.[17] Gatekeeping, in this perspective, is a means of directing enforcement efforts towards priority providers. Some sections, however, indicate that the DMA is worried about the unreasonable limitations huge platforms place on contestability and fairness, irrespective of the services they offer. The DMA's emphasis on corporate size is evident in its use of numerical thresholds for gatekeeping criteria, such as revenue and user base.

In between these two points of view seems to be the DMA, which regulates certain digital services when they are offered by specific platforms. Since gatekeeper traits are included in the CPS characteristic list, this technique has created some misunderstanding.[18] This uncertainty begs the question of whether the DMA is more focused on providers of digital services or on efficiently targeting market dominance in the digital economy.

Core platform services.
For digital services to be included by the DMA, they must be categorised as core platform services (CPS). The DMA characterises CPS as services having substantial incumbency qualities, such as extreme scale economies, powerful network effects, and data-driven benefits, even though it does not define them specifically in its recitals. In addition, CPSs have characteristics that deviate from competitive environments, namely user lock-in and the lack of multi-homing.

Article 2(2) of the DMA[19] lists ten CPSs, which include web browsers, operating systems, cloud computing services, online advertising services, online search engines, online social networking services, video-sharing platform services, online intermediation services, and virtual assistants. During the legislative process, online browsers and virtual assistants were introduced.

The DMA expressly states that cooperative non-commercial initiatives cannot be classified as CPSs. The definitions specified in the legislation for each CPS determine the extent of the DMA. Referencing Regulation 2019/1150 (the "P2B Regulation"), for instance, defines online intermediation services as those that enable direct transactions between consumers and business users. According to the P2B Regulation, online search engines are also described as services that let users enter queries to look up any website.

Conversely, the DMA defines online social networking services as platforms that let users interact, exchange material, connect, and find other users and content across various devices. The Audiovisual Media Services Directive, which covers services offering user-generated videos to the public for information, entertainment, or education, is the basis for the definition of video-sharing platform services.[20]

The European Electronic Communications Code, established by Directive 2018/1972, serves as the definition for number-independent interpersonal communication services. Users can communicate with each other directly and interactively using these services without having to connect to numbering plans.[21] The Network and Information Services Directive is used to define cloud computing services, which are digital services that provide users access to shared computer resources.

Operating systems are characterised as system software that manages hardware operations and permits the execution of software programmes on them. Software that allows users to view and interact with web material is known as a web browser. Virtual assistants are described as programmes that, in response to user input, conduct tasks, inquiries, and grant access to services or physical device controls.

Although the DMA doesn't define online advertising services specifically, it does state that they include exchanges, advertising networks, and other forms of intermediation services-as long as they're offered in tandem with another CPS. The DMA does not extend coverage to stand-alone internet advertising providers.[22]

Although the technical clarity of these definitions is intended to promote legal certainty, it also limits the flexibility of the law. Overall, the definitions provide clarity on which services are under the purview of the DMA by outlining broad rather than specific types of CPSs.

Legal science is only as strong and authoritative as its ontological, epistemological, and axiological integrity. Consequently, it is essential to investigate the legislation using suitable methodologies, particularly in scientific study. Normative research, which looks at laws that are viewed as social norms or regulations that apply in society and act as guidelines for behaviour, was the research methodology employed in this study. Unlike empirical research, which is distinguished by field research methodologies, normative legal study is similar to library research.

Normative legal research, sometimes referred to as doctrinal legal research, is limited to the study of written laws or regulations. Because the goal of the research is to comprehend legal theories, it is known as doctrinal legal research.[23] Because it mostly uses secondary material from libraries, this kind of research is frequently referred to as document studies or library research.

Rather than generalising data, the qualitative research technique places an emphasis on gaining a thorough knowledge of a topic. It entails using in-depth analytical approaches and looking at problems case-by-case because qualitative procedures imply that every situation is different. This method is required to collect data on the study's themes. Three methodologies were utilised in normative research: the case approach method, the conceptual approach method, and the statutory approach.[24]

European Union Digital Markets Act Competition Concept

Global rivalry is getting fiercer in today's economic environment due to technological improvements, especially in the fields of information, manufacturing, transportation, and communication. In business, competition occurs when several parties or businesses compete for orders by providing the best terms or rates. Businesses want to be successful, so they try to offer goods and services that are appealing in terms of cost, quality, and customer service. Succeeding in this cutthroat market requires winning over customers' allegiance by inventiveness, smart technology use, and efficient resource management.

Because of the business world's rapid growth and the significant market demand for products and services, business actors are always innovating to suit the wants of customers. Maintaining consumer loyalty and averting market stagnation need this innovation. But there are also a lot of cases of unfair commercial competition brought on by this atmosphere. Dishonest or illegal tactics used by business players to obtain an edge in the manufacturing or marketing of products and services, or to obstruct fair competition in the market, are referred to as unfair business competition.

Situations when a business actor gains an advantage and makes money at the cost of others, even while this hurts competitors, can give rise to unfair commercial competition. A company with greater inventiveness, expertise, and competitiveness has a better chance of taking the lead in the industry and establishing a stronghold. [25]Because of its dominance, a company may misuse its market position to operate without much competition and even to pursue anti-competitive acts. The idea of a dominating position is changing in tandem with the advancement of the underlying legal and economic theories.

The market dominance of online platforms that facilitate business-consumer connections has been highlighted in a number of papers in recent years. Additionally, the difficulty traditional competition rules have in pursuing anti-competitive conduct in this sector has been highlighted. [26]For example, in order to accommodate the particularities of the digital economy, Germany revised its competition legislation in 2017 and now treats free goods and services provided by platforms as a single market.

The European Commission has proposed the Digital Markets Act (DMA) to introduce platform liability in order to supplement current competition regulations in response to these concerns.[27] The DMA is an ex-ante regulatory framework that was motivated by competition law and is intended to promote an open, transparent, safe, and equitable digital market throughout Europe.

Twenty days after it is published in the European Union's Official Journal, on November 1, 2022, the DMA is expected to go into force. On May 2, 2023, six months later, it will become operative. The primary objective of the Digital Markets Act is to provide an equitable and competitive landscape for all digital enterprises, regardless of their scale.[28] To prevent huge platforms from imposing unfair conditions on consumers and companies, the legislation will provide explicit criteria for these platforms, detailing what they can and cannot do.

Through the implementation of necessary measures to promote free markets, the DMA aims to stop significant firms in the IT industry from abusing their dominating positions. Network effects and economies of scale in data gathering and processing are two examples of factors that might generate entry barriers and strengthen the dominating positions of some businesses. The DMA places a series of requirements on big companies referred to as "gatekeepers" that they must follow. The purpose of these legislation is to curb the practices of large internet platforms that abuse their market power.

A firm that offers essential platform services that operate as a vital gateway for corporate users to access end users and has a substantial influence on the internal market is known as a gatekeeper. This business either continues to have a solid and long-lasting position in its operations or is expected to do so soon.

Companies need to have a market value of at least €75 billion ($82 billion) or yearly EU revenues of at least €7.5 billion ($8.2 billion) during the previous three years in order to be eligible to serve as gatekeepers. Additionally, "Gateway" has to have 10 registered corporate users in the EU and at least 45 million monthly users.[29]

Businesses known as "gatekeepers" act as crucial go-betweens for various user groups, including buyers and sellers. As gatekeepers draw a lot of users (buyers) to one side of the network, they may end up becoming required middlemen to get access to particular marketplaces or clients. Sellers on the opposite side of the platform might not have many options but to use the infrastructure of the gatekeeper.[30]

A platform that operates in at least three EU member states in one (or more) of the eight primary digital world services-such as search, social networks, advertising, and marketplaces-is referred to as a gatekeeper in DMA.

Regulations pertaining to "gatekeepers" in the digital industry are established by the DMA. These big companies serve as middlemen in the digital sphere between companies and customers, and their scale has a big impact on internal markets. For corporate users, their influence over digital gateways is essential, and they frequently have a strong and permanent position. Operating systems, social networking sites, messaging apps, search engines, and online intermediary services are a few examples of gatekeepers.[31]

Effects Of The European Union Digital Markets Act Regulation On Digital Market Act
Trade patterns have changed dramatically as a result of the digital era, with conventional in-person transactions taking place in marketplaces or shops giving way to digital or online transactions. The digital revolution presents obstacles for enterprises and law enforcement alike. Businesses need to consider the potential and threats given by the digital market as they adjust to the changing market dynamics. Due to this change, entrepreneurs must now conduct their company online and persuade customers to do the same. Business rivalry will undoubtedly be impacted by this change.

It is necessary to reevaluate legal frameworks in order to ensure fair competition and safeguard business operators in light of the dynamics of digital trade. Current rules have to take into account every facet and strategic element that facilitates the smooth operation of the digital market.[32] By drawing limits between what is and is not acceptable, the law helps to prevent unforeseen cases of unfair competition.

Legal authorities also have a major impact on preserving legal clarity, which is necessary for resolving disputes.[33] It is critical to understand how the digital market operates differently from traditional markets in terms of both structure and dynamics. Thus, it is imperative that all business actors-individuals as well as corporations-create a climate of healthy competition in the marketplace.

Digital marketplaces have advantages for businesses and consumers alike, but these advantages might be compromised in the absence of clear rules governing conduct. To guarantee the protection of firms' and customers' rights and duties, clearly defined rules and regulations are required, which will stop unfair competition in the digital market. Ensuring that commercial rivalry in the digital sphere is regulated requires comprehensive regulatory regulations. Social, political, cultural, and economic activities are only a few of the facets of social life that the law regulates.

It is especially crucial for handling society's ever-increasing expectations and requirements and for managing the finite amount of financial resources. Fairness and a framework for economic activity are two ways in which the law greatly promotes economic progress and the general well-being of society.

The "winner takes all" phenomenon is common in digital markets, when a profitable enterprise gradually solidifies its market position, making it harder for Competitors to compete and eventually consolidating the dominance of one dominant company.[34]

Because competition in digital markets differs from traditional offline markets, governments and competition authorities are paying close attention to the growth of the digital economy. Critical elements of digital marketplaces are multi-sided markets, where operators engage with two or more user groups, resulting in cross- and network-network effects, and platform-based business models. The issue of corporate competitiveness in these marketplaces is made more difficult by these features. [35]

Additionally, there are a number of possible business competition breaches in the digital age, including as:
  • Possibility of abusing a leading market position.
  • Possibility of cartel activity. Because of digital platforms, prices among competitors in the market are transparent, allowing firms to forecast market trends, examine customer behaviour, and modify pricing plans as necessary.
  • Tracking of acquisitions, consolidations, and mergers. The worth of data possessed by the merging parties is usually not one of the particular requirements that need to be met for a merger to be disclosed to competition authorities.
Because they do not fulfil the requirements, many merger transactions-despite the fact that the data possessed by the merging parties is extremely valuable-do not need to be disclosed. A further tendency is "killer acquisition" or "killer takeover," in which big digital firms invest in or buy out smaller or newly established businesses that they see as possible Competitors in the future[36]. In response, regulators have revoked a number of mergers involving significant internet platforms because they may have included unfair commercial practices.

Many businesses are eager to use any methods required in order to achieve substantial profits. On the other hand, participating in dishonest activities is bad for businesses as well as society. Competitors. In response, regulators have revoked a number of mergers involving significant internet platforms because they may have included unfair commercial practices.

The European Union enacted the Digital Markets Act (DMA), which includes measures for fining Big Tech corporations that break it. If DMA requirements are not met, the following outcomes may occur:
  • Penalties of up to 10% of the global yearly revenue of the corporation, or up to 20% in the event of recurrent infractions.
  • Periodic penalty payments of up to 5% of the average daily turnover.
  • Further remedial measures in the event of persistent infractions and post-market analysis.[37]

The new rule mandates that businesses provide interoperability of their messaging services with other platforms and grant business users access to their data. Additionally, DMA forbids computer companies from controlling their services in an oppressive manner and from stopping consumers from uninstalling pre-installed programmes automatically.

It is yet unclear how the Digital Markets Act (DMA) will directly affect big platforms' business models, particularly in the near future. We may make assumptions about its long-term implications, though.
  • To begin with, the DMA may encourage the enactment of such "platform laws" in other states.
  • Secondly, even in countries where there are no "platform laws," the DMA may trigger antitrust lawsuits against platforms that have a dominating position but are not gatekeepers. There is historical precedence supporting the broad application of laws against the abuse of dominance.
  • Thirdly, the DMA forbids some tactics designed to lessen "contestability," which would lead platforms to look for different ways to stay competitive.
Proposals to limit Big Tech corporations' dominance on the internet have generated both support and opposition. Not everyone is confident that these steps will lessen the dominance of these giants and increase competition, despite the belief of many experts to the contrary. Opponents contend that laws of this kind might hinder innovation and lower the standard of products and services.[38]

The financial side raises further concerns. It is anticipated that the DMA's implementation will be costly for governments as well as the so-called gatekeepers themselves. Since these businesses are some of the most publicly traded equities in the world, any action that would topple them would have a big financial impact on regular people, who the law is meant to safeguard.

The proposed laws have faced fierce opposition from big IT corporations who claim they unjustly target US companies. Nonetheless, the Digital Markets[39] Act (DMA) is advantageous to both companies and individual consumers, according to the European Commission. Today's startups and small enterprises may work in a more equal atmosphere, relying less on gatekeepers for their services and having more chances to develop without being subjected to unjust terms and circumstances. Users now have more options and control over the services they use thanks to this improvement. Additionally, consumers will find it simpler to choose services that are more reasonably priced and to chose alternatives outside of the confines of online platforms, which will stimulate the market.

Some of the biggest platforms are starting to modify their ways of doing things in response to the new requirements of the Digital Markets Act (DMA). As an example, Google has said that it will let select European developers to use other payment methods; they characterise this as a first step towards compliance with the DMA.

How Can Digital Market Act Be Applied In Indian Competition
The European Union created the Digital Markets Act (DMA) as a comprehensive legislative framework to govern digital platforms that possess substantial market power. Despite being unique to the EU, the DMA's goals and guiding principles might offer important perspectives to Indian competition authorities facing comparable issues in the digital realm. We shall examine how the DMA's main clauses and methodology may be used in the Indian setting in this article.[40]

Applicability of Digital Market Act in Indian Competition:

  • Definition of Core Platform Services (CPS): Search engines, social networking sites, online intermediation services, and other services with substantial market power are all considered CPS according to the DMA. To discover CPS in the Indian market, Indian competition authorities may use a similar strategy that leverages social media, search engines, and e-commerce platforms.[41]
  • Identification of Gatekeepers: Gatekeepers are classified by the DMA according to their influence on the market and level of market domination. Similar standards, such market share, user base, and economic clout, might be employed by Indian competition regulators to pinpoint gatekeepers in the domestic market.
  • Regulatory Obligations: To maintain fair competition, gatekeepers are subject to particular requirements set down by the DMA, including non-discrimination, data exchange, and interoperability. To encourage competition and innovation, Indian competition authorities may want to consider placing such requirements on gatekeepers in India.
  • Ex-ante Regulation: The ex-ante regulatory approach of the DMA, which permits competition authorities to step in before harm happens, is one of its main characteristics. Similar measures might be taken by Indian authorities to proactively address concerns related to competition in the digital economy.
  • Enforcement Mechanisms: To guarantee adherence to its regulations, the DMA offers robust enforcement tools, such as penalties and structural remedies. The enforcement tools of Indian competition authorities may be strengthened in order to discourage anti-competitive activities in the digital market.[42]

Challenges and Considerations

  • Jurisdictional Issues: Since the DMA is unique to the EU, using its principles in India would create jurisdictional problems. The principles will have to be modified by Indian authorities to fit the country's legal and regulatory environment.
  • Market Specificity: The digital market in India is distinct, with its own dynamics and difficulties. Indian authorities would have to carry out a comprehensive market study in order to pinpoint certain problems and provide focused remedies.[43]
  • Coordination with Other Regulators: In order to establish a cogent regulatory strategy, Indian competition authorities will need to work with other regulators, such as the Ministry of Electronics and Information Technology (MeitY) and the Telecom Regulatory Authority of India (TRAI), given the cross-cutting nature of digital marketplaces.

Companies compete fiercely for clients in today's global business market by providing competitive rates and terms. Businesses must innovate, employ the best technologies, and efficiently allocate their resources if they want to win this competition. To control big businesses, sometimes referred to as gatekeepers in the digital industry, the European Commission has proposed the Digital Markets Act (DMA).

Companies that are gatekeepers are those who have a big effect on the market, offer crucial platform services, and hold a solid, long-term position. In order to maintain fair competition and safeguard customers in the digital era, where trading activities have undergone major changes, the DMA seeks to regulate these businesses.

Despite being a European rule, Indian competition authorities may find the DMA's guiding concepts and methodology helpful while regulating digital marketplaces. Indian authorities may contribute to the development of a just and competitive digital economy that benefits companies and customers by embracing comparable ideas and customising them for the Indian environment.

  1. Visited on 10-04-2023
  2. Margrethe Vestager, "Fair Markets in a Digital World" (Speech at the Danish Competition and Consumer Authority, Copenhagen, 9 March 2018).
  3. P. Akman, (2019), "An Agenda for Competition Law and Policy in the Digital Economy," Journal of European Competition Law & Practice, Volume 10.
  4. European Parliament, "Digital Markets Act (DMA): Agreement Between the Council and the European Parliament" -
  5. A. K. Ramaiah, (2018), "Competition in Digital Economy: the State of merger Control on Customer Transportation in Asean," Inter-national Journal of Modern Trends in Business Research (IJMTBR), Volume 2.
  6. Google Search (Shopping) (AT.39740) Commission Decision of 27 June 2017.
  7. Amazon Marketplace (AT.40462) Opening of Proceedings of 17 July 2019.
  8. Apple - Mobile payments (AT.40452) Opening of Proceedings of 16 June 2020.
  9. Supra 8
  10. Jacques Crémer, Yves-Alexandre de Montjoye and Heike Schweitzer, Competition Policy for the Digital Era (European Commission 2019).
  11. Ibid
  12. European Parliament, "Digital Markets Act: Ending Unfair Practices of Big Online Platforms" -
  13. Ibid
  14. Ibid
  15. Consolidated version of the Treaty on the Functioning of the European Union - PART THREE: UNION POLICIES AND INTERNAL ACTIONS - TITLE VII: COMMON RULES ON COMPETITION, TAXATION AND APPROXIMATION OF LAWS - Chapter 1: Rules on competition - Section 1: Rules applying to undertakings - Article 102
  16. Whitecase "The Digital Markets Act (DMA) goes live",
  17. Ibid
  18. "EU's Digital Markets Act comes into force: What is it, and what does it mean for Big Tech?" dapat diakses online pada
  20. Supra 8
  21. Ibid
  22. Osborne Clarke, "EU rules for 'gatekeepers' coming in 2023 as Digital Markets Act is published" dapat diakses online pada
  23. Supra 8
  24. Supra 22
  25. Supra 18
  26. Ibid
  27. Ibid
  28. Supra 19
  29. Supra 16
  30. Ibid
  31. Dentons, "EU Digital Markets Act: next steps and long-term outlook" dapat diakses online pada
  32. Ibid
  33. Ibid
  34. Supra 16
  35. Ibid
  36. Supra 6
  37. Ibid
  38. Supra 5
  39. Ibid
  40. PRS Legislative Research -
  41. Ibid
  42. Ibid
  43. Ibid
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