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ABUSE OF DOMINANCE – MONSANTO



Department of Agriculture, Cooperation & Farmers Welfare Ministry of Agriculture & Farmers Welfare Government of India (‘MOA&FW’) - Informant
And M/s Mahyco Monsanto Biotech (India) Limited (‘MMBL’) - Opposite Party No.1[1]
WITH
Nuziveedu Seeds Ltd. (‘NSL’) – Informant 1, Prabhat Agri Biotech Ltd. (‘PABL’) – Informant2 and Pravardhan Seeds Pvt. Ltd. (‘PSPL’) – Informant 3
AND
Mahyco Monsanto Biotech (India) Limited (MMBL) - Opposite Party No.1, Monsanto Inc, USA (MIU)- Opposite Party No. 2, Maharashtra Hybrid Seeds Company (MAHYCO)- Opposite Party No. 3, Monsanto Holdings Private Limited (MHPL)- Opposite Party No. 4[2]




Monsanto, engaged in the activities of developing and licensing of Genetically Modified (GM) trait of Bt cotton hybrid seeds and sublicensing of Bt cotton technology in India, had made headlines, for abusing its dominant position in the market. The Competition Commission of India (“CCI”), on receiving information took up the matter. The order of CCI dealt with two cases[3], due to commonality of issues involved.
The issue arose when many Indian seed companies including the Informants entered into sub-license agreement with MMBL for procuring its Bt cotton technology namely, Bollgard-I i.e. (“BG-I”) and second generation cotton technology namely, Bollgard –II (“BG-II”), in consideration of an upfront one-time non–refundable fee of INR 50 lacs (INR 5 Million) and recurring fee called as, i.e. ‘Trait Value’. The ‘Trait Value’ is the estimated value for the trait of insect resistance conferred by the Bt gene technology. The trait value is determined by MMBL on the basis of Maximum Retail Price (MRP) per packet, in advance for each crop season.

However, the fixation of trait value has been a matter of dispute since 2005 when the trait value for BG-I was Rs.1250/- per packet/-. The matter was first taken to the erstwhile Monopolies and Restrictive Trade Practices Commission (“MRTPC”), pending proceeding of which, MMBL reduced the trait value to Rs.900/- per packet. Post the ‘Settlement and Release of Claims Agreement’ and consequent ‘Supplementary and Amendment Agreement’ entered into by MMBL with the Indian seed companies, the MRP was set as Rs. 750/- per packet (Including trait price of Rs. 148.50/-). After dissolution of the MRTPC, the matter was transferred to the Competition Appellate Tribunal (“COMPAT”) and thereafter, various State Governments came up with their own legislations, and fixed the MSP of cotton seeds, specifying the MSP’s, ranging from (BG-I) at Rs.650/- and (BG-II) at Rs.750/-, with trait values as Rs.50/- and Rs.90/ per packet-, (BG-I) at Rs.830/- and (BG-II) at Rs.930/-, with trait values as Rs.50/- and Rs.90/- per packet, against which MMBL filed writs, some of which are pending adjudication till date.

The sub-licenses granted for BG-I and BG-II expired during the pendency of the litigations and MMBL renewed the sub–license agreements in March 2015 for BG-II only (as BG-II replaced BG-I) fixing the trait values at Rs.163.28/- to Rs.174.90/- (plus taxes) on the MRP of Rs.930/- to Rs.1100/- per packet in various states.

The informants alleged that the sub-license agreements between MMBL and the seed companies are one-sided, arbitrary and onerous as the amount recovered by MMBL from seed companies over the years on account of royalty charges and trait value is much more than the expenses incurred in developing the said technology, and the trait value charged is much higher than those of the state governments and thus, there is no justification to charge such high trait values at increased rates. Further the group companies of MMBL are not being subjected to the unfair conditions as imposed upon the Informants and they are not required to pay such trait

MMBL however, has always defended its actions contending that the issues raised were merely contractual disputes between the parties and has no competition issue involved therein. Further, the allegations with regard to unfairness of the sub-license agreement were misplaced as the agreements entered into between the parties after negotiations and the trait value charged from Indian seed companies is lowest in the world and the increase was justified as reward for innovation.

CCI observed that since the ultimate aim of choosing Bt cotton technology is to protect the cotton crop from the pests (Bollworm) all the Bt technologies technologies, irrespective of the gene constituents, are considered as substitutable. Thus, the relevant upstream product market in the present case appears to be market for ‘provision of Bt cotton technology.

As the Bt cotton technology cannot be sold directly to the farmers, the technology needs to be added to the hybrid by seed manufacturers to produce Bt cotton seeds which have an inbuilt resistance mechanism to deal with harmful pests like bollworm. Therefore, the technology provider needs to partner with seed companies through technology licensing agreements so as to integrate the technology into cotton hybrids. CCI noted that there also exists a downstream relevant market i.e. market for ‘manufacture and sale of Bt cotton seeds in India’ connected with the upstream relevant market.

CCI was of the view that MMBL holds a dominant position in the relevant upstream market as the Bt cotton technology sub-licensed by MMBL is used in more than 99% of the area under Bt cotton cultivation in India, and the competitors of MMBL do not seem to pose effective competitive constraints and there is huge consumer dependence. Further entry of a new technology is subject to regulatory approvals and huge investments which create significant entry barriers.
CCI observed the allegations of imposition of unfair conditions in the sub-license agreements, charging of unfair price, discriminatory treatment, limiting and restriction of technical and scientific development relating to Bt cotton technology and cotton seeds market, denial of market access and leveraging of dominant position in the Bt cotton technology market to protect cotton seeds market, and was of the view that the termination conditions are excessively harsh and do not appear to be reasonable as may be necessary for protecting any of the IPR rights. Such agreements discourage and serve as a major deterrent for the sub licensee from exploring dealing with competitors. The agreements would have the effect of denial of market access to the seed manufacturers, given their dependence on MMBL for Bt cotton technology and thus, have the effect of foreclosing competition in the upstream Bt Technology market which is characterized by high entry barriers. In view of these aspects, the agreements entered by MMBL with sub-licensees appear to be causing appreciable adverse effect on competition and as such are anti-competitive agreements and as a result is abuse of dominant position by MMBL in the Bt cotton technology market in India, in terms of Section 3(4) r/w Section 19(3) and section 4 of the Act.
Accordingly, under the provisions of Section 26(1) of the Act, CCI directed the Director General of the Commission (“DG”) to investigate the MMBL and the role of the officials/ persons who at the time of such contravention were in-charge of and responsible for the conduct of their business.




[1] Reference Case No. 2 of 2015
[2] Case No. 107 of 2015
[3] namely, Reference Case No. 02 of 2015 and Case No. 107 of 2015

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