Top 10 Anti-trust/Competition Headlines from All Regions During the earlier part of the financial crisis the European Commission approved State aid for troubled banks (eg Northern Rock) under “Article 87(3)(c) EC Treaty and the Rescue and Restructuring Guidelines”. On 23 October 2009 the Beijing Dongcheng District People's Court announced the settlement of an Anti-Monopoly Law (AML) case brought by an activist lawyer in Beijing against China's largest mobile network operator, China Mobile. China’s Ministry of Commerce (MOFCOM) has continued its recent trend of taking an activist approach to merger control in imposing conditions under the Anti-Monopoly Law (AML) on the clearance of two proposed mergers, Pfizer/Wyeth and General Motors/Delphi. New measures for foreign currency loans and foreign currency indexed loans. China's Ministry of Commerce (MOFCOM) has announced two new conditional clearance decisions under the country's Anti-Monopoly Law (AML) merger control system, meaning five deals have now been subject to conditional approval or outright prohibition since the law commenced. On October 23, 2009, two private lawsuits filed under China's Anti-Monopoly Law ("AML") were resolved, allowing more insight into the workings of the new statute. The Proceeds of Crime Act 2002 (POCA) increased the already wide ranging powers available to the courts in relation to the confiscation and asset forfeiture regimes provided under the Criminal Justice Act 1988 and the Drug Trafficking Act of 1994. On September 29, 2009, the U.S. Court of Appeals for the Tenth Circuit upheld the Colorado District Court’s holding that a hospital has no antitrust duty to share its facilities, and thereby affirmed the grant of summary judgment for the hospital against a complaining physician. In August 2008, the People’s Republic of China ("PRC") implemented the Anti-Monopoly Law (the “AML”). On 8 July 2009, the European Commission announced that it had fined each of E.On (including its subsidiary E.On Ruhrgas) and GDF Suez EUR 553 million for operating a market-sharing agreement. | 
