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Market definition is an important component in the premerger investigation,but the models used in the market definition have not developed much in thepast three decades since the Critical Loss Analysis (CLA) was proposed in 1989.The CLA helps the Hypothetical Monopolist Test to determine whether thehypothetical monopolist is going to profit from the small but significant andnon-transitory increase in price (SSNIP). However, the CLA has long beencriticized by academic scholars for its tendency to conclude a narrow market.Although the CLA was adopted by the 2010 Horizontal Merger Guidelines (the 2010Guidelines), the criticisms are likely still valid. In this dissertation, wediscussed the mathematical deduction of CLA, the data used, and the SSNIPdefined by the Agencies. Based on our research, we concluded that the narrowmarket conclusion was due to the incorrect implementation of the CLA; not themodel itself. On the other hand, there are other unresolvable problems in theCLA and the Hypothetical Monopolist Test. The SSNIP test and the CLA are brightresolutions for market definition problem during their time, but we have moreadvanced tools to solve the task nowadays. In this dissertation, we propose amodel which is based directly on the multi-dimensional substitutability betweenthe products and is capable of maximizing the substitutability of productfeatures within each group. Since the 2010 Guidelines does not exclude the useof models other than the ones mentioned by the Guidelines, our method canhopefully supplement the current models to show a better picture of thesubstitutive relations and provide a more stable definition of the market.

A New Solution to Market Definition: An Approach Based on Multi-dimensional Substitutability Statistics