Exercising choice: some reflections on competition enforcement in online markets
It is a pleasure to be participating in such a robust exchange of views, particularly with respect to how competition authorities should assess and address anti-competitive activity in online markets. First, a word about my role at the Competition and Markets Authority (CMA) (*). My remarks here today are personal, as I am not involved directly in investigating online enforcement matters. That crucial role falls on the executive, and the case teams. I chair case decision groups (CDGs) in antitrust cases, as well as phase 2 merger and market inquiries and regulatory appeals, and participate in case management panels in criminal cases. My remarks today therefore are more akin to observations, based on some years of comparative research into vertical restraints, our recent experience with these practices in the online world, and my own thinking on what might be important in assessing them.
Online markets are a major CMA priority. Their development is fundamental to cross-border and global trade. Online information and search tools help consumers identify and compare competitive offers. Online platforms, devices, and mobile payments facilitate e-commerce. All of this improves consumer choice and empowerment while helping new entrants, particularly disruptive innovators who challenge traditional business models and markets, thereby increasing competition and economic growth. This is not just so much rhetoric, though; it is almost everyone’s reality.
For example, competition law conferences these days often focus on online restraints. My remarks today do too, but sometimes the discussion seems a bit removed, and focuses a bit too much on the restraint itself, what it restricts (active or passive sales), whether it is offline or online, and necessarily its impact on the interaction between firms. I would like to suggest that we also think more from the consumers’ perspective, and consider the shopper ‘journey’ (if that isn’t too much of a woolly marketing metaphor). To consumers, online and offline aren’t really separate. Many shopping journeys do take place purely along one of those channels; but increasingly the line is blurring. As we all readily experience, some shoppers start searching in the real world, then go online to comparison shop, and then make the purchase; some go the other way; and some consumers start online, dip into a shop and pop back online again. Some even go online while in-store, comparison shop with other bricks or clicks outlets, then show these rival offers at check-out, which stores can then match or better, or lose that custom. To the consumer then, online and offline options are merging; and firms are experiencing this too, moving towards providing service in both channels to meet growing customer expectation.
When online activity enables businesses to be more responsive to consumer demand, we see markets improve directly, leading to better products and services, and more personalisation of the offer to consumers. Markets thus operate more efficiently for both consumers and businesses – through better targeting of spending and greater optimisation of resources. To my mind, these developments make it even more important to look at the facts of each market, rather than just the route to market. Similarly, in assessing business practices, we need to have a view on how a potentially anti-competitive restraint might affect this market environment, rather than on the particular form of ‘restraint’ that is used.
One of the CMA’s 5 strategic goals is to extend the frontiers of competition, looking at new markets and new business models and responding appropriately, and of course, online commerce is a big part of that. The UK already has the world’s most internet-dependent economy, with online-related activity worth £118 billion a year, or 8.3% of GDP: more than twice the average among G20 countries. However, while bringing significant benefits for consumers, businesses and markets, there are also risks that we need to understand better. That is why the CMA is working on a research project to identify sectors of the economy where online commerce is developing more slowly than might be expected, and why. If this is because of misleading conduct or anti-competitive business practices, then consumer protection and competition authorities need to act, and act quickly.
Alongside the huge benefits that the internet provides for consumers in terms of improved information and choice, new sources of consumer detriment are emerging. For example, fake reviews, undisclosed commercial blogging, complex tariff structures, misleading or skewed search results, drip pricing, concealed recurring payments, and complex bundling can all harm consumers’ interests and distort competition. Problems may be even worse in markets characterised by information asymmetries, consumer biases (including to inertia) or vulnerability.
We need to act quickly to protect consumers and we need to act comprehensively, recognising that the online world is international. We also need to act so consumers do not lose trust in online markets themselves, so that internet-based trade can continue to flourish and offer them the information and confidence they need to exercise effective choice.
Our work on online and app-based games is a good example of this, building on the success of one of our predecessor organisations, the Office of Fair Trading (OFT). As this online market developed, a range of harmful practices were raising concerns, playing in particular on children’s inherent inexperience, vulnerability or credulity – such as hiding the real-world cost of items needed to progress, or imposing unfair pressure to purchase in order to care for online pets. Consultation with industry and other authorities secured consensus on a set of principles that would work across borders – ie as e-commerce does – which was successful in addressing harmful conduct.
Just as the internet facilitates increased competition, some firms in ‘bricks and mortar’ industries may seek to protect their positions, particularly by preventing or restricting online business models and competition. For example, the internet intensifies price competition, which some firms will want to limit. They may just be trying to protect their margins, or they may say they need to restrict price competition online so they can continue to compete on non-price elements such as service and presentation in-store. Incumbents might use other techniques to block entry or innovation by online rivals, limiting the use of platforms or online sales channels. They might defend their conduct using efficiency-based arguments based on limiting free-riding, improving service, or protecting brand signalling of quality. These can be legitimate concerns, and sometimes the firms are quite frank and say they are simply protecting what most consumers still choose to use: bricks-and-mortar sales outlets. Difficult questions of balancing efficiency, exclusivity and exclusion have arisen in such cases in traditional markets and they continue to do so when assessing restraints of online commerce.
While some forms of misleading consumer practices are new or repackaged – once identified it is relatively clear that they are harmful. As I mentioned, the question then is how to act quickly and comprehensively enough to protect consumers. With anti-competitive conduct, there are added challenges. A particular online restraint might look familiar to those we encounter in traditional distribution channels, but it is no less controversial for that. There are very different schools of thought regarding vertical restraints and price and non-price abuses of a dominant position – whether in the online world or not. Competition authorities from different market traditions and with different policies, priorities and responsibilities tend to differ in approach. The cross-border and even global reach of some practices, the speed with which they proliferate, and the inevitable balancing required in assessing some forms of anti-competitive conduct makes timely and comprehensive enforcement more difficult. This makes it even more important that we work together and learn from each other to get it right in our own particular cases.
This is why we have made sure that another 2 of the CMA’s strategic goals – refocusing our consumer protection work and delivering effective enforcement – are both being accomplished with a strong emphasis on online markets and noting enforcement approaches in other jurisdictions. This includes significant work to understand how new technologies are changing the ways in which markets work and when and how competition enforcement should be adapted and used to ensure that anti-competitive conduct is deterred.
To contribute to that process, I would like to discuss some practices, and enforcement approaches, pose some questions, and then conclude with a suggestion on how one might approach such practices.
Price floors and price channels
Resale price maintenance (RPM) and internet minimum advertised pricing (IMAP) act to set a price floor, one generally, the other online. The concerns with price restrictions are obvious to any competition authority. That is why there is such a suspicion of these practices, and why the burden tends to shift relatively swiftly to the firm imposing RPM or IMAP to try to justify the conduct, usually based on the efficiency arguments I mentioned earlier, relating to preventing free-riding and thereby ensuring quality and service.
Direct or indirect price-fixing is obviously one of the most serious competition law infringements, and we often receive complaints about RPM – including in an online context. The CMA treats allegations of RPM very seriously as an ‘object’ infringement, because it has such a high potential for restricting competition, and consumers may end up paying more than is necessary. Of course, the analysis of RPM and indeed the legislative framework expressly provides opportunities for firms to present evidence of offsetting benefits. One of the crucial questions, in my view though, involves the choices available to consumers and what they themselves value. Can consumers who don’t value service still shop around, or are they faced with one price practically everywhere?
Online markets span borders and many firms’ distribution practices are regional or even global. Nevertheless, even when items can be purchased online, most retail markets remain national and different enforcement approaches to RPM exist. In some jurisdictions, there are well-known changes from per se prohibition to an effects-based analysis. Other authorities look for evidence of an agreement, coercion and monitoring. There are also some authorities who don’t require proof of all of these elements. Should case law recognise that there may be more subtle techniques of pressuring retailers, than actual coercion? Should one look at the evidence in the particular case and identify whether the pressure exerted resulted in a retailer not making its own independent choice on price?
What if anything could we do about these different approaches and issues? As enforcers we are already ‘learning by doing’ and communicating with another as we do. Sharing experience and analysis on cases won’t necessarily lead to convergence though, and it is not obvious that convergence is required just because a practice is online. Online markets can still vary country by country due to levels of e-commerce, market structures, language issues and local preferences or biases. I’m not sure how a common approach to verticals in the online world would be any easier to forge than in the real world. In addition, we can’t leave every case with an online – and hence typically cross-border element – to the European Commission; resources are limited everywhere and even more complaints might not be taken forward. In many cases anyway a national competition authority may be particularly best placed. I think this holds in particular for the UK mobility scooters IMAP cases that I will discuss shortly. So do we try to learn which approach is most suited to addressing RPM with online aspects? I’m not sure this is possible to identify either. After all, different authorities have different priorities, investigative methods and different economic priors about such conduct. What I think is most important though is the evidence in each particular case.
You may have seen that the CMA recently decided to close its RPM investigation involving a sports bra manufacturer and 3 UK department stores. This was because, after a thorough review of the evidence, including written and oral representations from the parties, the CDG – which I chaired – concluded that there were no grounds for action in that case. I believe that this shows that the new collective decision-making model and governance processes introduced in 2012 are working well – CDGs provide a fresh pair of eyes in CA98 cases and help us deliver robust decisions at pace. It remains the case that the CMA treats allegations of RPM very seriously. Direct or indirect price-fixing is among one of the most serious infringements of competition law and RPM is a practice that features frequently in complaints to the CMA, including in the online context.
IMAP and online sales bans
The CMA has concerns about the use of internet minimum advertised prices and other vertical restraints that prohibit the advertising of any prices online, or ban online sales outright. In 2 cases prioritised for their impact both on vulnerable consumers and on online commerce as well as their precedential and deterrent value, the OFT found separate infringements by 2 manufacturers of mobility scooters and a number of their respective retailers. Specifically, one firm had banned online sales and the advertising of prices online, while another prohibited online advertising of prices below its own recommended retail prices.
As restrictions on consumer choice go, such practices could not be more obvious. They reduce price transparency and significantly increase search costs for consumers, of particular concern when the internet is important for search and consumers face high search costs due to their circumstances. Here, by definition these types of scooters tend to be sold to consumers who find it difficult to visit bricks and mortar stores, which were few and far between. Most obviously though, IMAP restrictions soften intra-brand competition, reduce discounting and can mean higher prices for consumers. It has to be said though that online cases can raise difficult issues: while the OFT found in these cases that the restrictions had as their obvious consequence the prevention, restriction or distortion of competition, through our casework and own research/analysis we are still working to understand the range of scenarios in which such practices will be harmful.
Dual pricing restrictions raise similar issues. Setting a higher price for online sales may be seen as a way of restricting passive sales. This may, then, limit the geographic trading area of the dealer, which can be regarded as a restriction of the territory into which, or the customers to whom a dealer may sell his goods. How these practices affect competition and consumer choice in individual cases needs to be considered. IMAP and dual pricing can come in different forms, including restricting online discounts. Therefore, depending on the practice, theories of harm that arise with RPM and its case law may also apply.
Price ceilings and platforms
Restraints that set price ceilings are more tricky for an authority to assess, because on their face they promise some form of ‘Best Price Guarantee’, a boon for consumers one would think, allowing them to focus on the non-price aspects of the product that they want, sure that they will get a great deal. This would initially seem all the more helpful when implemented through an online platform that quickly allows providers to make offers that buyers can compare and choose from easily. In some cases, however, this can lead to a softening of competition, with the ceiling becoming a floor. In some cases, perhaps something like RPM is what is actually operating, and firms are only able to offer the Best Price Guarantee because they ‘know’ no one will undercut them. Or perhaps the mechanism itself is acting to dissuade entry of lower-priced products, since that important distinguishing element has effectively been removed. This can operate to soften price/commission competition on the platforms, and any resulting increased costs of sales may be passed through by third party sellers to consumers.
Price parity and price relativity agreements have come up in a number of antitrust cases. In relation to Amazon’s price parity requirement for third party sellers listing products on Amazon Marketplace, for example, there were parallel Article 101 cases being run by the OFT and by Germany’s Bundeskartellamt. This demonstrates the ongoing concerns that competition authorities have about retail most-favoured nation clauses (MFNs), and their potential to soften price competition between platforms and exclude new entrants – reducing consumer choice. The OFT was ‘minded to close’ the case after Amazon indicated that it would – essentially - remove the parity clause from its contracts. It’s notable that Amazon didn’t just remove parity in the countries where the competition authorities were taking cases, but across the EU.
It is also worthwhile pointing out that retail MFNs were also examined by the CMA in the somewhat different context of a market inquiry – in the recently concluded private motor insurance market investigation. Whilst different from enforcement action brought via a CA98 antitrust case, nevertheless, it is interesting to note that the inquiry group differentiated between narrow MFNs (between price comparison websites and insurance providers’ own websites) and wide MFNs (between different price comparison websites or between other sales channels, such as telesales). The CMA viewed the latter as problematic and sought an end to clauses that restrict a motor insurer’s ability to price its products differently on different channels, and expects this to lead to greater competition among price comparison websites in the private motor insurance market.
Preventing selective distributors from selling through platforms
Manufacturers of branded goods naturally want to protect their image, which they may argue may be undermined by sales through a third party platform. However, in considering restrictions on platform sales, there are different approaches in different jurisdictions, with some authorities doubting both the need for such brand protection and any efficiencies arising from such platform bans. Some find it difficult to see platform bans as indispensable, and press firms for other means of achieving the same aim. As a member of the European Competition Network we work closely with other authorities to understand the approaches they are taking in this area. Learning from each other is one thing, but suggesting that authorities adopt a similar approach to practices about which there is widely different opinion is not likely to be successful. Each case will depend on facts and on the evidence put to the relevant national competition authority in the context of its market. The CMA applies its prioritisation principles in a manner which considers the work of other European authorities, and we have seen directly how some national investigations may lead to pan-European changes to the manner in which companies’ distribution systems are set up – particularly in relation to online sales. We are also carrying out research to understand more about both the effect of certain restraints in an online world and the enforcement approaches of our colleagues in other jurisdictions.
There are many other practices I could mention – access to platforms, online-targeted advertising, personalised pricing and the controversial differences of opinion about search rankings. However, I’d like to use my remaining time to make one final observation, and one small suggestion.
New wine, old bottles, and telling the difference
One question that naturally arises is how online practices should be reviewed. Are they themselves so novel that traditional analytical approaches seem outdated and inappropriate? I don’t think so. First of all, and to a very large extent, anti-competitive practices online are just new wine in old bottles, and should not be allowed to fool anyone, least of all, enforcers. There is nothing particularly novel about pricing restraints, for example. If an authority or court analyses such restraints as object infringements when they occur in traditional markets, then this will be appropriate when firms practise them online. The same rationale applies for practices that have tended to be subject to effects-based analysis. Naturally, while each case needs to be assessed on its facts and its relevant context, there is no reason to change approach just because the practice goes online.
What about truly novel online practices though, ones that have not been seen before in traditional markets and which are not currently addressed by case law? First, it is difficult to say that anything we have seen so far is truly novel – price parity arrangements, minimum advertised pricing, discriminatory pricing, even denial of access to platforms all have predecessors offline. But what if something comes along that is truly novel? Does this mean that an object approach is inappropriate? Should an authority be required to prove that the practice is net harmful using a full effects-based analysis? No, on both counts. I think this sort of stricture on authorities would be too much, and would be particularly inappropriate in fast-moving online markets. Depending on the restraint, an object approach can still be the most appropriate enforcement approach. There are some limits though, and again not surprisingly these are the same that apply to enforcement approaches in the real world.
To my mind, if any practice is to be investigated as an object infringement then this should only occur when the practice is anti-competitive by its very nature. Such practices are those that have such a high potential for harm to competition that actual effects do not need to be proven. They include certain types of behaviour (such as price fixing and market sharing) that experience has shown are likely to produce negative effects on the market.
A novel practice, by definition, is one about which we have no experience. But authorities facing a novel practice can still approach it as an object infringement if they can show how it is inherently anti-competitive. In such situations, because the practice is new, case decisions should explain in what respect the restraint in question reveals the requisite harm in order to be characterised as a restriction by object. This may even be relatively brief, depending on the restraint and the facts, but it should exist. This allows the law to evolve and keep up with changing business practices, and provides companies with an explanation of why these practices are being characterised in this manner, thus ensuring that authorities are less likely to be accused of ‘stretching the object box’.
Despite my remarks focusing almost exclusively on forms of online pricing restraints, some of you may have noticed that in describing these practices I also noted how they limit consumer choice. What I’d like to explore now, is whether this adds anything? My final point today then, is to suggest that it does, very much.
Some might say that focusing on choice can’t make much difference. After all, doesn’t every restraint of competition, every merger even, also restrict choice? I think there is something deeper going on than that, and competition authorities should take more note of impacts on consumer choice. Price is one factor, and a big one, but we all know that competition takes place over a range of factors, including quality, that appeal to consumers. Individuals value different things, and providers tailor their products accordingly. They do so due to the exercise of consumer choice. Consumer choice is the mechanism that actually drives competition, and yields efficient markets. It is not actually price, quality, or any other factor of the product itself that is determinative. It is the process – call it discovery, call it exchange, call it competition – but fundamental to that is consumers exercising their choice. That is what is at the heart of even the most rigid Chicago School efficient markets hypothesis. I think that we should all pay more attention to ensuring that consumers can exercise their choices effectively, particularly in online markets. Doing so would not make us think all that differently, but we would be – like consumers using the internet – markedly better informed.
Choice is a mechanism and it operates by consumers identifying competing offers, comparing them, and selecting their product based on the elements that they value, be it price, convenience, quality or whatever. Competition is not like some battle between rivals who then ‘win’ a territory or town; nor is it entirely like a race where one competitor beats another to ‘win’ a medal and the cheers of the crowd. Consumers have some say, and a crucial role in the process, and the winner is the firm that produces the kinds of products that best fit what the consumer values, and so chooses. Competition involves an interaction not only between rivals, but also among the rivals and the consumer. In a well-functioning market, active consumers exert pressure on firms to improve their product. Reasonably well-informed, confident, largely rational consumers exercising choice activates competition among firms. Exercising such effective choice ensures that consumers are more likely to receive the products they need, and are less likely to receive shoddy goods or services.
Is this a trivial observation? Is it empty rhetoric? Or is it a different form of substantive analysis from that currently undertaken at competition authorities? Your choice, but my answer is: none of the above.
It is not a trivial observation, because focusing a bit more on how choice is exercised means we better appreciate the actual mechanism at play in competition. It is not empty rhetoric, because focusing on how choice is exercised (and restricted) better informs our analysis. We find more relevant ways of looking at markets by ensuring we view them as the consumer does. I mentioned at the start of my remarks how shopper journeys increasingly flow back and forth between online and traditional markets, often in an iterative process through search and comparison shopping. As authorities responsible for protecting and promoting competition, our analysis should take into account the information and options that firms and technology make available to consumers, their routes to market, and how they make their choices. This is merely better observation and analysis and has to help better inform us about what consumers would do with or absent a particular restraint. Where would they go, what would they buy? Or how would rivals respond? Some of this thinking is of course already embedded in substitutability analysis and market definition, but it can have more of a role, particularly in analysing online activity.
For example, the UK communications regulator Ofcom has commissioned a number of studies of online markets, often with a heavy behavioural element, developing the understanding and evidence to underpin future enforcement. For example, it wants to understand why consumers are likely to trust some websites for online purchases and not others; when they are willing to make payments online; how the presence of online retailers’ high street, physical outlets makes a difference to consumers’ willingness to purchase; and how they respond to other users’ ratings and reviews. They also look into how behaviour changes with ‘digital literacy’, age and other relevant indicators. Improving our understanding of how consumers make choices is an essential element of this, and our understanding of this needs to get ahead of that of those online players whose actions, intentional or not, are manipulating consumers in harmful ways.
Similarly, some competition authorities – including the CMA – are considering how behavioural economics can help better understand how consumers make decisions (ie choose). Looking more at how choice operates is something that can actually be surveyed and examined. (And to those who want something more definable or operational than ‘choice’, I’d note that existing concepts of ‘competition’ or ‘competition on the merits’ are also actually surprisingly vague, and there is markedly little agreement on what they even mean. Perhaps focusing on how choice operates can help.)
So we ask of consumers: do they have a choice – how informed is it – can they exercise their choice? What is helping or hindering that exercise? Is the restraint necessary? Why? What is its purpose? How does that impact on consumer choice? And of course, is the restraint of choice net harmful? This is not a choice standard replacing an efficiency standard, but being built more into – and informing – one. So enforcers and courts can better appreciate the dynamic between providers and customers and better choose whether and how to intervene.
In suggesting that we look more at the exercises of consumer choice, am I recommending a substantive change in approach? I am not. A few years ago a nice debate occurred between Robert Lande and Neil Averitt on the one hand, and Joshua Wright and Judge Douglas Ginsberg on the other. The former were recommending a consumer choice standard as a new substantive approach in antitrust law, particularly for the assessment of non-price restraints. The latter opposed it, saying that it would undermine welfare analysis, and put efficient business conduct under suspicion in the pursuit of an amorphous populist non-economic goal. I’m not suggesting the same change as Lande and Averitt’s, but simply a renewed recognition of and concern for the mechanism of choice at the heart of market transactions. It is not even such a great ‘renewal’ at that. In the UK, we have looked at practices that deny choice in many cases from local bus routes to global pharmaceutical companies. In markets work in particular, we have identified consumer difficulties in exercising choice as warranting serious examination, whether in personal current accounts, cash ISAs, dentistry, private health care, payment protection insurance and statutory audit. In advocacy to government about public service markets we have argued for empowering consumers through added choice tools. A concern for the exercise of choice is not new in other jurisdictions either. Spencer Waller has identified a greater focus on choice in US case law, particularly in high-tech industries. In Europe, Paul Nihoul has identified a steady flow of concern with choice in most of the competition cases under Article 102. Former FTC Commissioner Tom Rosch asked whether focusing more on choice would help bring US and EU approaches closer together?
So, the debate isn’t new, but is what I’m suggesting troublesome? Does more concern for how choice is exercised lead us inevitably to start thinking about numbers of rivals? No. It is not about numbers of rivals, it is about how consumers exercise a choice among rival offerings. More rivals or more choice doesn’t necessarily lead to a better exercise of that mechanism. Indeed, too much choice can lead to no choice at all, as people get swamped with too much information, and just shut down. Indeed there are examples (most recently with respect to some financial services markets) where increased competition leads to bad results: a lack of effective competitive constraint at best and at worst a race to the bottom, with firms providing ever more risky products.
My suggestion is not about choice itself; it is about its exercise. I do not view every reduction of choice as a problem, nor every increase in choice as a solution. I am just suggesting that in assessing alleged restraints we make sure we are aware of what really affects consumers’ interaction in the market. My focus is tightly on consumers and their ability to exercise their choice or not, depending on what restraint is being imposed in the market.
So to be clear: I am not arguing for choice, per se. I am not arguing for variety in itself. I am not arguing that smaller less efficient firms be protected from larger rivals simply for the sake of differing offerings. I can think of plenty of examples where a merger or arrangement leads to efficient outcomes at the expense of variety. Competition may increase even when choice is reduced. Competition law and policy isn’t about plurality: we are not the Choice in Markets Authority, after all. We protect and promote competition and markets, and in doing so all I’m saying is that we should be alert to how consumers make choices, not about choice itself. (Obviously, a necessary requirement for exercising choice is having some choice in the first place, but that is provided by entrepreneurs, not us.) We should just be more alert to how choices are made, or restricted, among competing offerings. And vertical restraints and abusive conduct are a key part of that, particularly in the online world.
I hope that a more informed process of analysis will lead to even better outcomes. I would like more direct recognition of how practices are affecting how consumers exercise choice, particularly online. If e-commerce is opening markets, improving and facilitating choice, and thereby empowering consumers, then we need to make sure that this continues, and is not restricted. If there are significant and artificial restrictions on consumers’ ability to choose effectively, then we need to analyse them closely. Incumbents who fear competition and seek to protect their existing business models at the expense of consumer choice should tread carefully.
To achieve good consumer outcomes and drive effective competition in markets, consumers need to be willing to access information about the various offers available, assess this information to identify the goods and services that provide the best value and quality, and act upon this assessment by choosing or switching to their preferred supplier.
Authorities should be prepared to intervene quickly and comprehensively when breaches of consumer law are distorting the information consumers need to be able to choose. Competition authorities should be equally prepared to intervene when breaches of competition law are significantly and artificially preventing consumers from exercising effective choice.
I hope some of my questions and this small suggestion stimulates discussion and further research in this area, and I look forward to working with you to continue to achieve the right results for consumers, for businesses and for markets in these difficult but important online cases.
(*) My thanks to colleagues at the CMA for stimulating discussions, particularly Louis Christofides, Antonia Horrocks, Mark Dungworth, Gaucho Rasmussen, Amanda Partridge, Hugh Mullan, Simon Constantine, Borbala Szathmary, Natalie Timan, Joseph Downie, Andrew Pickering and Helen Fleming.