On clauses 8 and 9, I would think that what is now in Bill C-59 with the HHI is good. That's more in line with worldwide standards than market share thresholds, for sure.
As far as clause 3 is concerned, to me, the underlying problem is this need to always choose between sections 45 and 90.1 as a vehicle. That will not be changed. Then it would be a good idea to put some serious sanctions in clause 3 as well, but it will run into problems before the courts, because these are criminal provisions.
If you want to have a level of sanction that matches what is done elsewhere, it should be around 10% as a theoretical maximum. Typically, the authority will go around 4% or 5% of turnover at the level where the profits should be. That's the practice. That would mean, in Canada, if you go by a factor of one to 10 with the EU or the U.S., we would be playing in the $100 million range.