Mergers are surging, enforcement is changing, but one element of competition practice remains remarkably stable. A divestiture can save a deal otherwise destined for challenge. The substance of divestiture review still follows the principles applied in the past, and practice at the agencies remains reassuringly familiar. In an era of tougher and longer reviews, however, deal structure and timing may merit a new approach. Merging parties that fix deals before the culmination of review, and perhap
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