DAMODARAM SANJIVAYYA NATIONAL LAW UNIVERSITY

VISAKHAPATNAM

PROJECT TITLE:

Competition Law & Film Industry

SUBJECT:

Competition Law

NAME OF THE FACULTY:

Ms. Varshita Mangamoori

NAME OF THE STUDENT:

C. Anand Hitesh Sharma

ROLL NO:
2016-027
SEMESTER – VIII
SECTION – A

1
ACKNOWLEDGMENT:

I am highly indebted to my Respected Investment Law Professor, Ms. Varshita Mangamoori,

for giving me a wonderful opportunity to work on the topic: “Competition law and Film
industry”, and it is because of her excellent knowledge, experience and guidance, this project
is made with great interest and effort. I would also like to thank my seniors who have guided
my novice knowledge of doing research on such significant topic. I would also take this as an
opportunity to thank my parents for their support at all times. I have no words to express my
gratitude to each and every person who have guided and suggested me while conducting my
research work.

2
Scope of the Study: The scope of the study is limited to the competition of film sector in
India.

Research Methodology:

Research Methodology used was doctrinal methodology. Descriptive and analytical type of
study is done in this project. Doctrinal Methodology includes research from primary sources
such as books, articles, journals, case study, news papers and also taking the help of web
articles.

Review of Literature:

The researcher had taken the information from the articles, websites and books which
provided a lot of help for completion of the project. The information in the articles and
websites are cited.

Research Question:
Whether are they any anti- competitive practices prevailing in Indian Film industry?

3
CONTENTS:

1. Introduction……………………………………………………………………..5

2. Sectors in Film distribution……………………………………………………..6

2.1 Horizontal concentration

2.2 Vertical integration

2.3 Barriers to entry

3. Market definition…………………………………………………………………9

4. About Competition law in India…………………………………………………10

5. About Indian Film industry……………………………………………………....10

6. Competition law and the entertainment industry in India………………………..11

7. Nexus between IPR and Competition Law……………………………………….15

8. Cartelization in Indian Film Industry……………………………………………..15

9. Conclusion………………………………………………………………………...17

4
 1. Introduction-

In the entertainment Industry, cinema remains amongst the most popular form of art and in
many countries appears to be one of the most widely practiced cultural activity. Every day
there are technological advancements and much is yet to come in this regard.

Over more than one hundred years after its conception, a critical period has been reached
where, different questions from those seen so far are likely to be raised as far as competition
is concerned, questions linked to the horizontal concentration and vertical integration of
companies operating in film distribution markets along with the promotion of development of
the industry.

The Indian Film industry in order to discipline itself had set up self-disciplinary association
or agencies. The associations are either societies or companies under Section 8 of the
Companies Act. These associations or companies formulate by-laws and work as a dispute
resolution agency for disputes between exhibitors, producers and the distributors/exhibitors.
In this manner, the pecuniary interests of the exhibitors were protected.  This is being done
firstly, by registering the name of the film with one of the associations. Such registration
protects two films from having the same release at the same time.

Secondly, whenever a producer enters into an agreement with a distributor for a certain zone,
the same needs to be registered by an association. This is being done with the idea that a
producer does not sell the same movie rights to another distributor in the same area to obtain
further finance. Moreover, when the film being produced involves a large amount of finance,
another distributor is usually appointed for a zone or two distributors would form a joint
venture to finance the film.

Now, with the advent of new technology, migration of the Indian community to different
countries and due to other such reasons, the demand for Indian films extended in various
countries. This created the opportunity for the producers to sell the rights in the entire world,
DTH and satellite rights, internet rights etc. of the film. The new technology also led to an
increase in breach of piracy and reduction in the earnings of the producers. These factors
have led to the closure of many single screen exhibitors all over India.

5
To assess the competitive conditions in which films are distributed, an analysis in several
stages is required. Firstly, the market concerned should be defined and the degree of
concentration of that distribution activity determined. Secondly, it must be found whether
there are regulations or practices which prevent market entry; where such barriers co-exist
with high concentration, there will be the risk of exercise of market power, which will make
further horizontal concentration and, in some cases, vertical integration, threatening to
competition.

2. Sectors in Film Distribution:

Television plays an increasingly important role in film exhibition. The emergence of new
channels alongside the traditional broadcast channels are financed by advertising and licence
fees of encoded channels for which a charge is made and whose arrival has been made
possible by the development of cable and satellites.1 This new category of channels may itself
be divided in two, those charging by monthly subscription (premium channels) and pay per
view channels. Similarly, the video sector is an expanding method of film exhibition as most
households now have a video recorder. This sector principally covers the purchase and rental
of pre-recorded film cassettes.

Though this sector has seen significant changes however, the traditional vehicle for
distribution remains the cinema. There is a trend towards the grouping of cinemas within a
small number of national or regional circuits with independent cinemas not part of a circuit
now being the exception. This development is explained primarily by the very substantial
investment entailed by the modernisation of existing cinemas and the appearance of cinema
complexes. Cinemas in these networks, mainly located in urban areas, either in town centres
or in the suburbs, are designed to meet the new demands of the public in terms of comfort
and services. Thus, the new complexes have comfortable auditoria with large screens, offer
easy access and parking, and are well-served by shops, restaurants and other related services.

To assess the competitive conditions in which films are distributed in the three different
sectors, an analysis in several stages is required. Firstly, the market concerned should be
defined and the degree of concentration of that distribution activity determined. Secondly, it
must be found whether there are regulations or practices which prevent market entry; where
such barriers co-exist with high concentration, there will be the risk of exercise of market

1
Notably multichannel distribution technologies such as cable networks, Direct Broadcast Satellites (DBS),
Satellite Master Antenna Television (SMATV), and Multichannel Microwave Distribution Systems (MMDS).

6
power, which will make further horizontal concentration and, in some cases, vertical
integration, threatening to competition.

(2.1) Horizontal concentration

Once the film distribution market has been defined together with its particular components,
the degree of concentration of the industry is an important element to be taken into
consideration. Some firms in the film industry are quite large by absolute standards, and there
appears to be a trend toward the creation of even larger enterprises by merger. In competition
analysis, however, it is not the absolute size of a firm which by itself is important, but the
resulting market share.

In the cinema industry there has been a trend toward consolidation into a limited number of
circuits, each of which may control several cinemas in a given market. In many markets a
relatively few independent cinemas survive. Television broadcasting is highly concentrated in
most markets, with relatively few broadcast channels available. The advent of cable
television, which provides many more channels, and of direct satellite broadcasting, is rapidly
altering the television environment, however. Film production, on the other hand, appears to
be less highly concentrated in many countries.2 Alongside the large, well-established
production companies exist a number of independent producers, which produce successful
films from time to time. The trend toward vertical integration in the industry, discussed
further below, may adversely impact this situation, however.

(2.2)Vertical integration

Vertical integration may take the form of a system of common ownership or of contractual
provisions. In either case, co-ordination of production, distribution and exhibition decisions
upstream and downstream are the result, and these replace or supplement the incentives that
existed when competitors in these industries were acting independently. These vertical
relationships may be efficiency-enhancing; they have the advantage for the companies
concerned of ensuring the better co-ordination of production and distribution decisions.
However, where market conditions upstream or downstream -- concentration, barriers to
market entry etc. -- allow, these vertical relationships may lead to co-ordinated decision-

2
Competition Policy and a Changing Broadcast Industry, OECD (1993)

7
making, resulting in more complete exploitation of market power or to decisions which
disadvantage rival companies.3

In the film industry, vertical integration is not a new phenomenon, since producers and
cinema operators long ago realised that their operations could be enhanced by joint control of
distribution and exhibition. With the advent of new distribution media (television and video),
this vertical integration was extended and has now taken a more complex turn with the
sometimes inextricably linked ownership of the three film distribution sectors.

By controlling the distribution of their films, producers and distributors can improve
economic efficiency and ensure that their films are shown. But in addition, if concentration in
these industries is high and entry difficult, vertical integration may squeeze out competition
from independent producers and exhibitors. When examining the principal restrictive
practices implemented, it is therefore important to distinguish between those which improve
efficiency and those which have a negative effect on competition.

(2.3)Barriers to entry

Various barriers to entry to film exhibition may be erected, whether of a regulatory nature,
thus constituting barriers to entry in the more traditional sense, or relating to the
implementation of practices. Examples include:

 Regulations, which exist in some countries, intended to protect distribution in the

cinema from the development of television and video; such regulations may provide
that new films released in the cinema may not be shown on television or marketed on
video for a fixed clearance period; they may also provide for the following hierarchy
in film distribution: cinema, video and finally television. Regulatory clearance periods
may also vary according to the nationality and box office success of a film, thus
creating further discrimination, as marketing on video may increase the film
producer’s return.4 Thus, many producers tend to demand longer clearance periods
between marketing on video and the broadcasting of their films on pay-per-view and

3
Competition Policy and a Changing Broadcast Industry, OECD (1993)
4
This discrimination will be continued if a shorter clearance period is granted more readily to successful
national films than to foreign films; the producer may then increase profits through good video sales.

8
 premium television channels in order to increase video retailers’ returns and
consequently their own;
 In the second category of barriers, the growing dominance of large cinema circuits in
many markets may operate to squeeze cinemas which do not belong to a circuit out of
the schedule of film releases. Not only may independent cinemas thus be deprived of
first-run films to show on their screens but they may also be forbidden to exhibit older
films which are no longer being shown as first runs by competitors who are members
of a circuit. The circuit members keep this option, plus the corresponding revenues for
themselves, thus controlling all of a film’s revenues until its box office value is
exhausted. Similarly, through their programming, these major circuits may squeeze
out small producers, showing films by powerful producers only;
 In other respects, however, entry barriers in cinema exhibition may be considered
relatively insignificant. It does not appear unduly difficult in most markets simply to
build and operate a cinema complex, any more than any other type of large retail
establishment. Those entry barriers that exist appear to be centred on the ability to
acquire the rights to exhibit popular first run films.

3. Market definition5

Market definition entails distinguishing between new films shown exclusively in cinemas,
known as "first run films", and others, and examining the different film distribution sectors-
television, video and cinema- endeavouring to identify any relevant sub-sectors. Given that
first run films are available only in cinemas, do consumers consider older films (or indeed
other forms of entertainment) available on other media, as close substitutes? That is an
empirical question, of course. Despite continuing advancements in home entertainment
technology, however, the cinema continues to be a popular form of entertainment. As long as
producers continue to choose to exhibit new, mass market films only in cinema houses, a
good argument can be made for first run exhibition as a distinct product market. Thus it must
be asked whether producers are likely to consider television or video as alternatives to cinema
houses for new films. In the near future such a change does not appear to be likely. As
discussed further below, new technology could alter such a calculation in the longer run,
however.

5
For a theoretical description of methods of analysis and market definition which may be applied to the film
industry, see Competition Policy and a Changing Broadcast Industry, OECD (1993)

9
 4. About Competition Law in India-

India’s pursuit of globalization has resulted in removal of controls and liberalization of the
economy. A key step in India’s March towards facing competition – both from within the
country and from international players – is the inception of a competition law regime. As a
general rule, competition laws are premised upon the economic principle that competition is
desirable in a free market. Competition laws seek to prevent businesses from engaging in
practices that are harmful to competition and consumer welfare. This ideology is, in some
ways, distinct from the ideology promulgated by the erstwhile legislation dealing with
restrictive trade practices in India – the Monopolies and Restrictive Trade Practices
(“MRTP”) Act. The MRTP Act primarily focused on curbing monopolies in the market.
However, with the advent of competition laws in India, the focus has now shifted from
curbing monopolies, to promoting competition.

The Competition Act is not intended to prohibit competition in the market. What the Act
primarily seeks to regulate, are the practices that have an adverse effect on competition in the
market in India. In addition, the Act intends to promote and sustain competition in markets,
protect consumer interests, and ensure freedom of trade in the market in India.

5. About Indian Film industry-

Bollywood, as the Hindi film industry is popularly known, is the largest contributor to the
industry’s revenue, followed by the South Indian movie industry and other language cinema
industries such as Begali, Bhojpuri, Marathi and Gujarati. Although the country’s filmed
entertainment industry is the largest in the world in terms of the number of films it produces
(around 900) and its theatrical admissions (around 3 billion), it continues to be small in size
in terms of revenue, mainly due to low ticket realization and occupancy levels. Moreover,
lack of quality content and rising competition from Hollywood films continue to affect it.

Traditionally, the Indian film industry has been social relationship centric, under which the
arrangements/agreements were either oral or scantily documented and the disputes were
usually resolved without going into arbitration or litigation. This, however, meant absence of
proper chain of title documentation leading to uncertainty in the flow of rights. Only in the
past few years, the Indian film industry has woken up to the need for written contracts and

10
protection of intellectual property (“IP”) rights. The need arose because the Indian film
industry witnessed a paradigm shift in its structure in the last decade. Previously, the films
where funded by private money lenders, often mafia money, primarily interested in the
collections from distribution rights or the box-office and ignored the residual income from
the repurposing of the IP. But after it was accorded the “industry status” in 2000 by the
Government of India, the following years saw the films receiving funding from the banks,
and Indian corporate such as Sahara, Reliance group, Mahindra and foreign studios such as
Warner Bros., 20th Century Fox and the like. The banks, Indian corporations and foreign
investors insisted on written contracts with the producers and required the producers to have
watertight contracts with the cast and the crew including appropriate chain of title
documentation. With the increase in commercialization opportunities, the talents that
hesitated to sign even a one page contract until early 2000 started presenting detailed written
contracts to preserve their commercialization rights, e.g., merchandising rights.

Earlier, there were quite a few unauthorized remakes of foreign films in various Indian
languages. However, no actions were taken against such films, probably because foreign
studios did not consider India as their target market. With the globalization of the Indian film
industry and entry of foreign players in India, there is an increase in litigation on this account
as well. Bollywood production house BR Films had been sued by 20th Century Fox for
allegedly copying the storyline and script of its comedy My Cousin Vinny in the movie
Banda Yeh Bindaas Hai.

6. Competition law and the entertainment industry in India-

In January 2012, Rajkamal Films, an Indian production and distribution company, released
Vishwaroopam, a spy thriller set in Afghanistan and the United States. Raaj Kamal Film
International vs M/S Tamil Nadu Theatre Owners,6
The film’s content has been controversial, it was initially banned in one state, but there was
also a dispute as to the manner of its distribution that may have wider implications for the
Indian entertainment industry. The company wanted to simultaneously release its film
through Direct-to-Home (DTH) television networks as well as through cinemas, and the
Tamil Nadu Theatre Owners’ Association threatened to boycott the film. In response,
Rajkamal Films approached the Competition Commission of India for a ruling on the

6
Raaj Kamal Film International vs M/S Tamil Nadu Theatre Owners, 2013

11
Association for restraint of trade. To what extent can a competition regulator intervene in
disputes within an artistic industry?
In the early 1990s the Narasimha Rao government began to restrict the state’s involvement in
the economy and to rework economic regulations. But it took until 2002 for the Monopolies
and Restrictive Trade Practices Act 1969, one of the key acts in need of revision, to be
replaced by the Competition Act. While the competition legislation and related regulations
are still a work in progress, as evident from several amendments since 2007 — the opening
up of the economy is increasing demand for regulatory intervention. The entertainment
industry in particular is testing the limits of the Competition Act.
The demand for intervention of the Competition Commission in disputes in the entertainment
industry is likely to grow because production houses increasingly rely on formal sector
finance and insurance and collaborate with overseas companies, all of which have better
exposure to competition laws. But if the Commission is to benefit India’s film industry it will
need to evolve clear rules regarding its jurisdiction in cases involving issues, like language
and culture, which are prima facie beyond its mandate.
In this information before the CCI, it was alleged that there was an abuse of dominance and
cartelization against the film distributors and exhibitors, resulting in the disruption of the
DTH release. In response the distributors have stated that Hassan has violated an informal
understanding in the industry to release films exclusively on theatres. Although Section 3(5)
of the Competition Act excludes agreements made in furtherance of exploitation of an IP
right. As long as the terms of license are ‘reasonable’, IP owners are free to impose any
measure. In other words, an informal pact for exclusivity in distribution of films does not
stand valid before a court of law.
‘The facts discussed above prima facie show that the resolution of OP was in the nature of an
agreement among the members of the association and was intended to limit and control the
market of exhibition of movies as well as innovative use of technical development in
exhibition of feature films and thus, prima facie appeared to be in contravention of the
provisions of Section 3 of the Act.’

In Hassan’s information to CCI the distributors’ and exhibitors’ associations did eventually
succeed in deferring the DTH release with their threats to boycott screening. This decision to
boycott is likely to violate the following provisions of the Competition Act:

12
• Refusal to deal: The threat of the distributors has an effect of restricting the ‘classes of
persons to whom goods are sold or from whom goods are brought’ which is prohibited under
sub-clause (d) of Section 3(4).
• Denial of market access: Section 4(2) (c) prohibits dominant entities from indulging in
‘practices resulting in denial of market access in any manner’. It is likely that the DG might
find a valid claim against the associations which control theatre distribution in Tamil Nadu
for denying home-video market to the actor.
In a nutshell, the cultural and linguistic issues limit the applicability of the competition laws
to the entertainment industry. Also the products of the entertainment industry specially films
and cinemas are singular goods and the CCI does not have the technical know-how to assess
the non-market consequence of the market competition. Another problem is that the cultural
segment focuses on a long term individual consumer whereas the market argument focuses on
short term individual consumer welfare effects.
Consider, for instance, the Karnataka Film Chamber of Commerce’s, which banned the
dubbing of films and tele-serials made in other languages into Kannada, and restricted the
number of screens available in Karnataka for films of languages other than Kannada. This
case has also gone to the Commission, who will have to decide whether Kannada-speakers
have the right to watch a film of their choice or whether non-governmental organisations
should have the right to show consumer choice on the grounds of a threat to language and
culture. But this is not a novel case. The Commission has over the last two years decided a
number of similar complaints filed by major film distributors against regional film industry
organisations.
Moreover, recently in 2017, the CCI has passed decision in order to provide further clarity
and to emphasise the position in certain national and regional trade associations of film artists
and producers for engaging in practices of controlling/limiting the supply of services and
market sharing. That Mr. Vipul Shah, the producer of films, filed an information against
Artists’ Associations, comprising the All India Film Employees Confederation, Federation of
Western India Cine Employees (FWICE) and its affiliated associations as well as Producers’
Associations, comprising the Indian Motion Picture Producers Association, the Film and
Television Producers Guild of India, and the Indian Film and Television Producers Council
stating that there was Memorandum of Understanding (MoU) regarding wages and rates of
member artists and there were restrictions on engaging non-members also there was a
committee which was entrusted with the vigilance of the said MoU.

13
The main contention in this case was that such acts have been held to be in contravention of
Sections 3(3) (b) and 3(3) (c) read with Section 3(1) of the Competition Act, 2002. The CCI
in this case reiterated the decision of Supreme Court and observed that the even trade unions
fall within the preview of the scrutiny of antitrust laws in India, although they are not directly
the part of trade unions but are part of the production chain. Further there was a clarity
provided that under the provided circumstance, where these bodies acted as operating
member in the trade union does not fall within the horizontal agreement.
Shri Kshitiz Arya Vs Viacom18 Media Pvt. Ltd (Competition Commission of India) Case
No. 03 of 20187

It is observed that the releasing of a movie is a strategic and tactical business decision taken
by the producers. The makers of a film have to consider a lot of factors before releasing the
movies for distribution such as market targeting, branding of the movie, distribution
expenditure, revenue sharing with the distributors and competition with other movies, among
others. A major concern for the producer of a movie is to get the maximum number of
screens for release of a movie as the same is directly proportional to the potential revenue
generated by the movie. Further, owing to piracy issues in the film industry, movie
production houses releasing mega budget movies adopt a business strategy of simultaneously
releasing their new movies in a large number of screens in order to realise maximum revenue
during the first week of their release. Thus, the strategy of production houses releasing mega
budgeted movie in not competing with another big budget movie does not seem to be unfair
as both the movies cannot be released simultaneously in maximum number of screens. It is
further observed that the rationale behind mega budget movies not competing with other
movies is that the producers would have lesser risk and would be able to earn better profit/
return on investment. Therefore, such decision, which is a result of market outcome, appears
to be a legitimate business decision rather than an anti-competitive practice.

The Commission notes that the anti-competitive conduct alleged against the makers
of Padman  and Padmavat does not get established. The evidence supplied in the information
does not seem to indicate any concerted action while deciding the dates for the release of the
movies and accordingly, the Commission observes that the facts of the case do not raise any
competition concerns. In view of the foregoing, the Commission is of the prima facie opinion

7
Case No. 03 of 2018

14
that no case of contravention of the provisions of the Act is made out against the OPs and the
matter is ordered to be closed forthwith in terms of the provisions of Section 26(2) of the Act.

7. Nexus between IPR and Competition Law

The objective of the competition law involves two faces firstly protect consumer welfare
secondly the economic freedom of market players. When a patent holder adopts any kind of
anti-competitive practices, governments can adopt measures like the compulsory licensing of
such technologies which has been stated in the 31(b) of the WTO Trade Related Aspects of
Intellectual Property Law (TRIPs) Agreement. 

The distinguishing feature of this particular law is that abusive use of the IPRs is given no
room for abusing the competition level in the market. Intellectual property protection per se is
not abusive but ironically, if it dominates over the market it is only doing a legitimate job of
its purpose, namely to create to incentive for further innovation. However, when companies
refrain from licensing their intellectual property to competitors, they undermine the basic
tenets of competition law as well as the spirit of intellectual property protection.

Intellectual property is not differentiated from other tangible properties for the
purpose of competition law. So CCI can adjudicate matters relating to IPRs. The
competition commission can decide constitutional, legal and jurisdictional issues
except the validity of statute under which tribunal is established. In the case of  Amir
Khan Productions Private Limited v. Union of India 18 August, 2010, the court ruled that
competition commission has the power to deal with intellectual property cases. The
court laid down, “competition commission has the power to deal with intellectual
property cases. What can be contested before copyright board can also be contested
before Competition Commission Competition Act, 2002 has overriding effect over other
legislations for the time being in force.”

8. Cartelization in Indian film industry-

Cartel has been defined under the Competition Act to “include an association of producers,
sellers, distributors, traders or service providers who, by agreement amongst themselves,
limit, control or attempt to control the production, distribution, sale or price of, or, trade in
goods or provision of services.” Under general legal parlance, cartels are arrangements which
may be formed in secrecy, which may or may not be in writing, between firms in direct

15
competition with one another in the relevant market, which result in profits due to
unreasonable increase of prices by the cartel at the cost of exploitation of the customers of the
wholesalers as well as retailers.

The informants have alleged that the theatre owners, association of film theatres, various
trade associations whose members are inter-alia engaged in the business of films and TV
serials exhibition, production and distribution have formed a cartel.

Trade association was used as a platform to fulfil illegitimate objectives like taking collective
decisions which are anti- competitive, issuing anti-competitive circulars/diktats, issuing
sanctions against those who disregard such anti-competitive diktats/directions, facilitate
collusive / collective decision making with the intention of limiting or controlling the
production, distribution, sale / price of films.

Some of the instances of cartelization (section 3(3)) are:

Kerala Film Exhibitors Federation (KFEF) is guilty of directing the distributors not to supply
movie prints of Malayalam and Tamil language movies to M/s. Crown Theatre. And if a
distributor does not agree to the instructions of KFEF, that distributor is boycotted and the
distributor’s movies would not be screened in the State of Kerala in its member’s theatres.

Similarly, M/s PVR Ltd., Complained that the conduct of M/s Film Distributors Association
(Kerala) FDA (K) of imposing the revenue sharing pattern instead of allowing PVR to
negotiate independently with the individual distributors of the association. Also, they
imposed fines/penalties for non-obedience, disallowed films to be exhibited in other theatres
in Kerala.

Reasoning given by CCI: Denying market access to other language films or programs by
Karnataka Film Chamber of Commerce (KFCC) is not justified as it is the choice of a film
producer or artiste as to whether his film should be dubbed in other language or not. Similarly
the viewer should have the choice as to which movie/programme to watch. Thus,
Commission held that limiting the distribution of movies to pre-determined release centres by
the Kerala Film Exhibitors Federation and Others violates the provisions of section 3(3)(b)
read with section 3(1) of the Act.

16
 9. CONCLUSION

To conclude, in a multilingual country like India, the Competition Commission will often be
confronted by cultural and linguistic disputes presented in the garb of competition disputes. It
needs to formulate clear guidelines that set out when competition laws should apply to the
entertainment industry. Otherwise it may find itself in the unenviable position of adjudicating
politicised linguistic disputes that lie beyond its mandate. The market concerned should be
defined and the degree of concentration of those distribution activities needs to be
determined. Secondly, it must be found whether there are regulations or practices which
prevent market entry. Further such barriers co-exist with high concentration, there will be
high risk of exercise of market power, which will make further horizontal concentration and,
in some cases, vertical integration, threatening to competition. Also in a diversified country
like India, where there are more than 19,500 languages and 22 official languages the
Competition Commission will often be confronted by cultural and linguistic disputes
presented before CCI. Further CCI has to formulate clear-cut rules that can be applied to the
entertainment industry. 

17