A New Perspective On Data Deletion During On-Site Inspections

The Turkish Competition Board did not consider the act of leaving Knox Teams groups during the on-site inspection at Samsung, nor the resulting automatic deletion of messages, as conduct hindering or complicating the on-site inspection. Once the messages were accessed, their contents were found to be unrelated to the subject matter of the investigation. Consequently, no administrative fine was imposed on Samsung. Although this decision differs from the Competition Board's usual "deletion equals fine" approach, it is premature to interpret it as a shift in the Competition Board's overall practice

The Turkish Competition Board ("Board") evaluated the acts of data deletion and exiting group chats that occurred during an on-site inspection at Samsung Electronics İstanbul Pazarlama ve Ticaret Ltd. Şti. ("Samsung") from a perspective that departs in part from established precedent. Given this divergence from settled case law on obstruction or hindrance of inspections,