Comment from Brian Scarpelli (Senior Global Policy Counsel at the Association for Competitive Technology)

Summary: The Association for Competitive Technology (ACT), a trade association representing small and medium-sized technology companies, supports the development of updated antitrust guidance on competitor collaborations. They argue that the new guidance should provide certainty for procompetitive collaborations—especially those involving AI, infrastructure, and algorithmic tools—while maintaining a clear distinction between lawful efficiency-enhancing conduct and unlawful coordination.