Delineating market boundaries in the Russian mass notification market: An application of critical loss analysis

Telecom companies are a frequent target of antitrust investigations in Russia. In an industry where services tend to become more and more complex and companies actively invest in diversifying their businesses, the antitrust authority in most of its telecom cases has chosen to define markets narrowly, which increases antitrust risks for the companies. This paper uses poll data on mass SMS notifications - a market in recently investigated by the FAS Russia - to demonstrate, using critical loss analysis, that the market should be defined in broader terms. In particular, the main empirical finding is that the relevant product market boundaries should cover not only SMS, but also email, messengers and push and voice notifications.