I INTRODUCTION
At the administrative level,2 antitrust law and
practice in Brazil is governed by Law No. 12,529/11 (the
Competition Law), which entered into force on 29 May 2012 and
replaced Law No. 8,884/94.3 The new Competition Law has
consolidated the investigative, prosecutorial and adjudicative
functions into one independent agency: the Administrative Council
for Economic Defence (CADE). CADE's structure includes an
Administrative Tribunal for Economic Defence (the Tribunal)
composed of six Commissioners and a President, a
Directorate-General for Competition (DG) and a Department of
Economic Studies. The DG is the chief investigative body in matters
related to anticompetitive practices. The Tribunal is responsible
for adjudicating the cases investigated by the DG – all
decisions are subject to judicial review.4 There are
also two independent offices within CADE: CADE's Attorney
General's Office, which represents CADE in court and may render
opinions in all
