Comment from Andrew M. Langer (President at the Main Street Foundation)

Summary: The Center for Regulatory Analysis and Engagement (CRAE), a project of the Main Street Foundation, supports updating the Collaboration Guidelines but argues for a disciplined, evidence-based approach that distinguishes between procompetitive collaborations and those that impair market contestability. They emphasize that many modern collaborations, particularly in high-tech sectors like AI, are necessary for innovation and market entry, and warn against speculative enforcement theories that could discourage investment.