That's very fair. I think in the end it should be the job of a regulator to look at the actual level of competition in a market, because it is hard to prescribe a bright-line test. Many have tried. The commission tried with its 25% rule, and government is now trying with its competitive presence test. Ultimately this should probably devolve back to a regulator, which is why we recommended the TCT.
But is the presence of three independent players in a market a bad starting point? We don't think so.