The Digital Markets Act (“DMA’) will impose far-reaching obligations on some large technology firms operating in the European Union. The DMA’s definitions and obligations are designed to bite without effects-based analysis. Thus, the hope is to bypass the length and risk of traditional antitrust proceedings. We argue that this procedural goal will likely be missed. By being intentionally vague the DMA will invite challenges, both on gatekeeper designation and obligations, that can only be
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