Comment from Sarah Davies (General Counsel, VP of Legal and Government Relations at International Franchise Association)

Summary: The International Franchise Association (IFA) is submitting comments to request that the new guidelines explicitly recognize the unique nature of the franchise model as a procompetitive business model. They argue for the use of the "rule of reason" analysis for franchise-specific arrangements like territorial grants, cooperative advertising, and joint purchasing, while also requesting the restoration of specific safe harbors for small-to-mid-sized systems.