On January 31, 2007, the Japan Fair Trade Commission (“JFTC”) published for public comment a draft of the revised “Guidelines on the Application of the Anti-Monopoly Act to Reviewing Business Combination” (Kigyo Ketsugo Shinsa ni Kansuru Dokusenkinshiho no Unyou Shishin) (the “Revised Guidelines”).[1] The draft of the Revised Guidelines contains several key provisions that propose

significant changes to the current Merger Guidelines. If adopted, these changes are likely to have important implications for transactions that are subject to review by the JFTC.