The American model is based.... The wording of the statute in the United States is incredibly broad. I think that would probably be more of a model than the European model. I haven't gone into depth with the legislative scheme in Europe.
I think the framework that already exists in the Competition Act—the section 103.1, which already provides for private access to the tribunal for some of these other reviewable matters—could just be plugged into that. It would have to be subject to the earlier qualification about dropping the need to prove someone has been substantially affected in order to bring a proceeding, just based on how that term has been interpreted by the tribunal.