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Data Barriers to Entry: What We’ve Learned About Spotting Them and What We Still Don’t Know About Solutions

BY | March 19, 2026

Data has become a core competitive asset in digital and non-digital markets, yet not all data accumulation by a dominant firm creates barriers to entry. This article takes stock of...

Data has become a core competitive asset in digital and non-digital markets, yet not all data accumulation by a dominant firm creates barriers to entry. This article takes stock of what enforcement practice and academic research have taught us about when data actually deters entry, and how policy can respond. Drawing on merger and conduct cases, as well as on academic research, Section I distills five factors that determine whether data raises barriers to entry: data’s centrality to quality an

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