COMPARATIVE ANALYSIS OF THE U.S. ANTITRUST SYSTEM AND THE UZBEK ANTIMONOPOLY REGIME: INSTITUTIONS, STANDARDS, PROCEDURES, REMEDIES, AND CORPORATE GOVERNANCE

Abstract

This study offers an exhaustive comparative legal analysis of the U.S. antitrust system and the newly reformed Uzbek antimonopoly framework. It examines institutional allocation, substantive prohibitions, merger control mechanisms, enforcement tools and remedies, corporate governance interactions, and procedural safeguards. The United States prioritizes case law, economic reasoning, and private litigation, supplemented with criminal enforcement against hard-core cartels and treble damages for private plaintiffs. Uzbekistan, under the 2023 Law “On Competition,” adopts a preventive administrative model with clearly defined thresholds for dominance, share acquisition, and turnover. This research incorporates enforcement statistics, detailed case law analysis, and OECD recommendations to highlight key divergences. Particular emphasis is given to: the U.S. geographic market definition versus Uzbek statutory dominance approach; low- and high-price anticompetitive conduct (Brooke Group, Matsushita v. Zenith); treble and double damages regimes; and tacit versus explicit collusion distinctions. Policy recommendations focus on harmonizing Uzbekistan’s preventive system with robust economic analysis while retaining its structural and procedural strengths.