Effects Doctrine Application in Digital Markets

1. Introduction

The effects doctrine in competition law determines when a jurisdiction may apply its competition rules to conduct occurring wholly or partly outside its territory because that conduct produces, or is reasonably capable of producing, substantial competitive effects within the jurisdiction.

The doctrine is particularly important in digital markets because digital businesses routinely operate across borders. A platform may be incorporated in one country, maintain servers in another, develop algorithms in a third, and provide services to users, advertisers, app developers, merchants, or consumers across dozens of jurisdictions.

Consequently, a competition authority does not necessarily need to establish that the anti-competitive conduct physically occurred within its territory. The central question becomes:

Did the foreign conduct have sufficiently substantial, foreseeable, and economically meaningful effects on competition within the enforcing jurisdiction?

In digital markets, this can involve:

online platforms;

app stores;

search engines;

digital advertising;

cloud computing;

AI services;

data markets;

online marketplaces;

social-media platforms;

payment systems;

digital content;

ad-tech;

cybersecurity;

SaaS products;

digital intermediaries; and

cross-border mergers.

2. Meaning of the Effects Doctrine

The traditional territorial approach focuses on where conduct occurred.

The effects doctrine instead focuses on where competitive effects occurred.

For example, assume:

Platform A is incorporated in Country X;

its algorithmic ranking system is developed in Country X;

its contracts with advertisers are concluded in Country X;

but the platform has millions of users and advertisers in Country Y;

the platform uses exclusionary ranking practices that disadvantage competing services in Country Y.

Country Y may seek to apply its competition law even though the principal corporate decisions were made in Country X.

The justification is that competition within Country Y's market has been affected.

3. Why the Doctrine Is Especially Important in Digital Markets

Digital markets make territorial boundaries economically less significant.

A single digital product can simultaneously operate across:

code → infrastructure → platform → users → advertisers → data → algorithms → transactions

A decision made at one point in this chain may produce competitive consequences worldwide.

For example, changing an app-store rule in California can affect:

Indian developers;

European consumers;

Japanese game publishers;

Australian advertisers; and

Brazilian payment providers.

Therefore, digital markets create a fundamental competition-law question:

Which jurisdiction has authority to regulate the competitive effects of globally deployed digital conduct?

4. Elements of the Effects Doctrine

Although formulations differ between jurisdictions, several recurring elements can be identified.

A. Foreign conduct

The conduct may occur outside the enforcing jurisdiction.

Examples include:

an overseas platform agreement;

foreign merger negotiations;

algorithmic decisions made abroad;

foreign licensing arrangements;

international data-sharing agreements.

B. Domestic competitive effects

The conduct must affect competition within the jurisdiction.

Examples:

increased prices;

reduced innovation;

exclusion of domestic competitors;

reduced access to digital infrastructure;

discriminatory platform ranking;

reduced choice;

higher advertising costs.

C. Substantiality

A merely trivial or remote effect should generally not justify expansive jurisdiction.

The effect should ordinarily have meaningful economic significance.

D. Foreseeability

The domestic effect should be reasonably foreseeable rather than purely accidental.

E. Directness or sufficiently close connection

The closer the relationship between foreign conduct and domestic competitive harm, the stronger the jurisdictional claim.

5. Digital Markets Complicate the "Effect" Analysis

Traditional markets often allow competition authorities to identify:

sellers;

buyers;

physical locations;

transactions;

prices.

Digital markets are more complicated.

A platform may provide a service for a zero monetary price while monetizing:

attention;

advertising;

data;

subscriptions;

commissions;

ecosystem participation.

Therefore, the effects doctrine must recognize non-price competitive effects.

6. Effects on Consumers

Foreign digital conduct may directly affect domestic consumers.

Examples include:

restricting alternative apps;

increasing subscription fees;

degrading search results;

reducing privacy;

restricting payment options;

limiting interoperability;

reducing product variety.

A platform's foreign decision can therefore have a domestic competitive effect even where consumers never interact with the foreign corporate entity directly.

7. Effects on Competitors

A particularly important category involves foreclosure.

A foreign platform may:

deny APIs;

impose discriminatory access conditions;

exclude rival applications;

impose exclusivity;

manipulate rankings;

restrict interoperability;

impose unreasonable technical requirements.

If competitors serving domestic users are harmed, the effects doctrine may provide jurisdictional justification.

8. Effects on Digital Advertising

Digital advertising illustrates the doctrine particularly clearly.

Suppose an ad-tech company based abroad:

controls an advertising exchange;

owns a publisher-side platform;

operates a demand-side platform;

gives preferential treatment to its own services; and

affects advertising transactions involving domestic publishers.

Even if the relevant contractual decisions are made abroad, the competitive effects may occur domestically.

This resembles the economic structure examined in the Google AdSense proceedings.

9. Effects in Multi-Sided Markets

Digital platforms frequently operate multi-sided markets.

A platform may simultaneously serve:

consumers;

advertisers;

sellers;

developers;

publishers;

payment providers.

Conduct affecting one side can produce effects on another.

For example:

discriminatory treatment of competing advertisers → reduced advertiser participation → reduced platform investment → weaker publisher monetization → reduced consumer choice.

The effects doctrine must therefore consider indirect competitive effects.

10. Network Effects

Network effects strengthen the territorial consequences of digital conduct.

If a platform has:

100 million global users;

10 million domestic users;

a change in its global architecture may immediately affect the domestic user base.

Network effects can transform what appears to be foreign conduct into significant domestic competitive conduct.

11. Data-Driven Effects

Data creates another important jurisdictional dimension.

A global platform may collect:

search data;

location data;

purchasing data;

behavioural information;

advertising data;

biometric information;

device information.

If foreign conduct enables the platform to accumulate data that strengthens its position in a domestic market, the competitive effects may arise domestically.

This is especially important where data creates:

entry barriers;

economies of scale;

switching costs;

targeting advantages;

algorithmic advantages.

12. Algorithmic Conduct and the Effects Doctrine

Algorithms make territorial analysis even more difficult.

An algorithm may be:

developed in one country;

trained using data from several countries;

deployed globally;

continuously optimized through user interactions.

Suppose an algorithm systematically demotes competing services in a particular country.

The relevant question is not simply:

Where was the algorithm written?

Instead:

Where does the algorithm produce competitive consequences?

This is a major application of the effects doctrine to AI and algorithmic markets.

13. Cloud Computing and Digital Infrastructure

Cloud services are inherently cross-border.

A cloud provider may operate:

data centres in several countries;

international backbone networks;

regional cloud zones;

APIs;

developer ecosystems.

If the provider uses exclusionary contractual terms internationally and those terms foreclose domestic cloud competitors, the effects doctrine may become relevant.

14. App Stores

App stores provide another major example.

A global platform may impose:

mandatory payment systems;

commissions;

anti-steering rules;

restrictions on alternative app stores;

restrictions on external payment links.

Even if these rules are formulated at headquarters outside the country, they may govern developers and consumers inside the country.

The competitive effect therefore arises partly within the domestic market.

15. Cross-Border Mergers

The effects doctrine is particularly significant for digital mergers.

Suppose:

Company A is based in the United States;

Company B is based in Europe;

neither company has major physical operations in India;

but both have significant Indian users.

If their merger threatens competition in Indian digital markets, the Indian competition authority may have a jurisdictional basis for examining the transaction where the statutory combination requirements are satisfied.

Digital acquisitions can therefore have global competitive effects without substantial physical assets.

16. Killer Acquisitions and the Effects Doctrine

Digital companies frequently acquire:

startups;

AI companies;

data companies;

developer tools;

emerging platforms.

The acquired company may have little current revenue but substantial future competitive potential.

A foreign acquisition may therefore affect domestic innovation even when the target has minimal traditional assets in the jurisdiction.

The effects doctrine can help explain why competition authorities examine the consequences of such transactions beyond conventional territorial boundaries.

17. Relevant Market Must Still Be Established

The effects doctrine does not eliminate the need for substantive competition analysis.

Authorities generally still need to examine:

relevant product market;

relevant geographic market;

dominance or market power;

competitive constraints;

exclusionary conduct;

actual or likely effects.

For digital markets, relevant markets may include:

online search;

app distribution;

mobile operating systems;

digital advertising;

online marketplaces;

cloud computing;

digital payment services.

18. Territoriality Versus Effects

The distinction can be illustrated simply:

Modern digital competition enforcement increasingly requires the second perspective.

19. Case Law 1 — United States v. Aluminum Co. of America (Alcoa)

United States v. Aluminum Co. of America, 148 F.2d 416 (2d Cir. 1945) is one of the foundational authorities associated with the effects doctrine.

The case concerned conduct involving an international cartel and aluminum markets.

Judge Learned Hand's reasoning became highly influential in establishing that foreign conduct could attract U.S. antitrust scrutiny where it was intended to affect, and actually affected, the U.S. market.

Digital relevance

The principle is highly relevant to:

global platforms;

international digital cartels;

global advertising arrangements;

cross-border data markets;

multinational AI services.

The modern digital equivalent is:

foreign decision-making + foreseeable domestic competitive effects.

20. Case Law 2 — Hartford Fire Insurance Co. v. California

Hartford Fire Insurance Co. v. California, 509 U.S. 764 (1993) is another major U.S. authority.

The Supreme Court considered conduct occurring partly outside the United States and recognized the relevance of substantial effects within the United States.

Digital significance

The reasoning is particularly useful where:

foreign firms coordinate pricing;

global platforms establish common contractual policies;

international suppliers coordinate market conduct.

For digital markets, the case demonstrates that physical location of corporate conduct does not necessarily determine antitrust jurisdiction.

21. Case Law 3 — Empagran S.A. v. F. Hoffmann-La Roche Ltd.

F. Hoffmann-La Roche Ltd. v. Empagran S.A., 542 U.S. 155 (2004) provides an important limitation.

The Supreme Court examined the relationship between foreign and domestic antitrust injuries.

The case demonstrates that not every foreign injury connected with domestic conduct automatically creates jurisdiction.

Digital significance

This is crucial.

A competition authority should not simply argue:

"The company operates domestically, therefore every global harm is within our jurisdiction."

Instead, there must be a sufficiently meaningful connection between:

the relevant conduct;

domestic competitive effects; and

the jurisdiction's antitrust interests.

22. Case Law 4 — Intel Corp. v. Commission

Intel Corp. v. Commission, Case C-413/14 P is significant in European competition law concerning conduct affecting the European market.

The broader European approach permits competition rules to apply where conduct implemented outside the EU produces sufficiently connected effects within the EU market.

Digital relevance

Intel is useful for analysing:

global rebate strategies;

exclusionary contractual arrangements;

semiconductor ecosystems;

technology platforms;

hardware-software integration.

The semiconductor example is especially important for digital markets because supply chains frequently cross numerous jurisdictions.

23. Case Law 5 — Google Shopping

European Commission, Google Search (Shopping), Case AT.39740

The Google Shopping decision provides an important digital-market example.

The Commission examined Google's treatment of competing comparison-shopping services in search results.

The competitive issue concerned conduct affecting the European market even though Google operated as a global enterprise.

Digital significance

It demonstrates how a competition authority can examine:

algorithmic ranking;

self-preferencing;

search neutrality;

platform leverage;

traffic foreclosure.

The case illustrates that the competitive effects of globally deployed technology can be assessed at the level of the affected regional market.

24. Case Law 6 — Google Android

European Commission, Google Android, Case AT.40099

Google Android concerned practices involving:

licensing arrangements;

pre-installation;

tying;

default settings;

restrictions affecting competing services.

The conduct involved a globally deployed technological ecosystem.

Effects-doctrine significance

Android demonstrates how conduct embedded in a global technological system can affect competition within a particular jurisdiction.

The relevant competitive effects included:

reduced opportunities for competing search providers;

distribution advantages;

network effects;

default-related consumer behaviour.

25. Case Law 7 — Google AdSense

European Commission, Google AdSense, Case AT.40411

This case concerned Google's conduct in online search advertising.

It is particularly relevant because digital advertising is inherently cross-border.

Effects-doctrine significance

The case illustrates how contractual restrictions and platform practices can influence:

advertisers;

publishers;

competing advertising intermediaries;

online traffic.

The competitive consequences can therefore arise across multiple national markets despite centralized corporate decision-making.

26. Case Law 8 — Intel and the Extraterritorial Dimension

Intel is particularly instructive because the underlying market involved international technology supply chains.

A modern equivalent could involve:

semiconductor manufacturer → AI accelerator → edge-computing provider → cloud platform → application developer.

A restrictive arrangement at one level may produce downstream effects in several jurisdictions.

The effects doctrine permits competition authorities to focus on the competitive consequences rather than treating every international supply chain as jurisdictionally fragmented.

27. Case Law 9 — Microsoft

United States v. Microsoft Corp., 253 F.3d 34 (D.C. Cir. 2001) concerned Microsoft's use of its operating-system position to protect and extend its position against competing technologies.

Although not a pure effects-doctrine case, it is highly relevant to the digital application of jurisdictional principles.

Microsoft illustrates how:

operating-system dominance;

application interfaces;

distribution;

technical restrictions;

ecosystem control

can produce competitive effects beyond the immediate location of corporate decision-making.

28. Case Law 10 — Qualcomm

The various Qualcomm competition proceedings, including European Commission, Qualcomm (Exclusivity Payments), Case AT.39711, demonstrate the importance of analysing globally structured technology markets.

Qualcomm's position in semiconductor and wireless technology illustrates how conduct concerning global supply chains can affect downstream competition.

Digital relevance

This is particularly useful for:

5G;

AI chips;

edge computing;

semiconductor ecosystems;

licensing;

device platforms.

29. Indian Position: Competition Act, 2002

The effects doctrine has particular importance under Indian competition law because the Competition Act expressly contemplates conduct outside India that produces competitive effects within India.

The central provision is Section 32 of the Competition Act, 2002.

It enables the Competition Commission of India to inquire into an agreement, abuse of dominant position, or combination occurring outside India where the conduct has, or is likely to have, an appreciable adverse effect on competition in India, subject to the statutory requirements.

This is extremely important for digital markets.

30. Section 32 and Digital Platforms

Suppose a foreign platform:

develops its algorithm overseas;

enters international agreements overseas;

controls a global app store;

operates its payment infrastructure overseas;

but its practices:

restrict Indian developers;

increase costs for Indian consumers;

foreclose Indian competitors;

limit interoperability in India.

Section 32 allows the CCI to examine the competitive effects within India.

31. Relationship Between Sections 3, 4, 5/6 and 32

The provisions can be conceptually separated:

Section 3

Deals primarily with anti-competitive agreements.

Section 4

Deals with abuse of dominant position.

Sections 5 and 6

Deal with combinations and their regulation.

Section 32

Provides an important jurisdictional bridge for conduct outside India producing effects within India.

Therefore:

Section 32 does not itself establish an antitrust violation; it facilitates jurisdiction over qualifying foreign conduct.

The substantive violation must still be established under the applicable provisions.

32. Digital Self-Preferencing

Consider a global marketplace that:

operates outside India;

controls its ranking algorithm globally;

gives preferential ranking to its own products;

sells those products to Indian consumers.

The relevant question is not merely where the ranking algorithm was developed.

The CCI can consider whether the conduct has competitive consequences in India.

Potential theories include:

leveraging;

discriminatory access;

self-preferencing;

foreclosure;

denial of market access;

ecosystem expansion.

33. Algorithmic Price Discrimination

A global platform could deploy an algorithm that:

identifies Indian consumers;

dynamically changes prices;

discriminates between sellers;

allocates traffic;

favours affiliated businesses.

If the algorithm is operated abroad but affects Indian competition, the effects doctrine becomes highly relevant.

34. Cross-Border Digital Cartels

The doctrine also applies to cartel scenarios.

Imagine competing global platforms coordinate:

commission rates;

advertising prices;

transaction fees;

seller restrictions;

data access conditions.

If Indian users or businesses are substantially affected, foreign location alone should not insulate the arrangement from Indian competition scrutiny.

35. Global AI Markets

The effects doctrine becomes even more important with AI.

An AI company may:

train models abroad;

operate computing infrastructure abroad;

license models internationally;

distribute APIs globally.

Yet its conduct may affect:

Indian AI developers;

Indian cloud providers;

Indian enterprises;

Indian consumers.

Potential competition concerns include:

exclusive AI licensing;

discriminatory API access;

tying AI models to cloud services;

preferential treatment;

interoperability restrictions;

acquisition of emerging AI competitors.

36. Cross-Border Data Advantages

Suppose a global platform acquires enormous datasets abroad and then uses them to improve services offered in India.

The competition concern may involve:

global data accumulation → algorithmic advantage → Indian market foreclosure.

This demonstrates that competitive advantage can be generated internationally but exercised domestically.

37. The "Substantial Effects" Requirement

The effects doctrine should not become unlimited.

Authorities should consider:

Magnitude

How large is the domestic effect?

Duration

Is the effect temporary or persistent?

Foreseeability

Could the firm reasonably foresee the domestic consequences?

Causation

Can the competitive harm be connected to the foreign conduct?

Market significance

Does the conduct affect an important part of the relevant market?

Competitive mechanism

How exactly does the conduct reduce competition?

38. Direct and Indirect Effects

Digital markets frequently produce indirect effects.

For example:

foreign app-store rule
↓
higher developer commissions
↓
reduced developer entry
↓
fewer applications
↓
reduced consumer choice in India.

The final competitive effect may therefore be several steps removed from the foreign decision.

Authorities must distinguish legitimate indirect effects from speculative chains of causation.

39. Effects Doctrine and Comity

The doctrine creates potential conflicts between jurisdictions.

A company may face:

EU competition law;

Indian competition law;

U.S. antitrust law;

UK competition law;

Australian competition law;

for substantially similar global conduct.

Competition authorities therefore need to consider:

international cooperation;

information sharing;

conflicting remedies;

regulatory comity;

consistency of obligations.

40. Risk of Multiple and Conflicting Remedies

Suppose one authority orders:

interoperability.

Another orders:

structural separation.

A third requires:

data portability.

A fourth prohibits:

certain contractual terms.

The firm may face technically inconsistent obligations.

Digital competition enforcement therefore increasingly requires international coordination.

41. Effects Doctrine and Merger Control

The doctrine is especially important for global digital acquisitions.

A transaction can create domestic competitive harm even where:

neither company is incorporated domestically;

the acquisition agreement is signed abroad;

the target's principal assets are foreign.

What matters is whether the transaction has a legally cognizable competitive impact within the jurisdiction.

42. Killer Acquisitions

A foreign Big Tech company might acquire:

an AI startup;

a cybersecurity startup;

a data analytics company;

a search technology;

a cloud-management company.

The startup may have limited domestic turnover but significant future competitive significance.

Effects-based merger analysis therefore helps authorities capture potential innovation harm that conventional geographic analysis might overlook.

43. Effects Doctrine and Market Definition

The doctrine does not eliminate geographic market analysis.

Instead, authorities must determine whether the relevant market is:

national;

regional;

global; or

multi-jurisdictional.

For example:

Cloud computing may be globally supplied but locally constrained by data residency, latency, regulation, or enterprise procurement.

Digital advertising may have global infrastructure but country-specific advertisers and publishers.

Thus, geographic market definition remains economically important.

44. Effects on Innovation

Traditional antitrust analysis often focuses on:

price;

output;

consumer choice.

Digital markets require greater attention to innovation.

Foreign conduct may suppress:

startup formation;

technological experimentation;

alternative AI models;

open-source development;

interoperability;

privacy-enhancing technologies.

These innovation effects can occur domestically even when the underlying corporate conduct is foreign.

45. Effects on Market Access

One of the strongest theories involves denial of market access.

A global platform may prevent:

Indian applications from accessing APIs;

Indian sellers from obtaining equal ranking;

domestic payment providers from integrating;

local advertisers from accessing inventory;

competing cloud providers from interoperating.

Where domestic market access is materially restricted, the jurisdictional connection becomes considerably stronger.

46. Effects Doctrine and Platform Gatekeepers

Gatekeeper platforms create especially strong effects.

A platform may simultaneously control:

discovery;

ranking;

payment;

identity;

advertising;

data;

interoperability.

Consequently, a single global platform rule can affect an entire domestic digital ecosystem.

The effects doctrine is therefore particularly suited to ecosystem-level competition analysis.

47. Enforcement Challenges

Authorities face several difficulties.

1. Identifying causation

The relationship between foreign conduct and domestic harm may be complex.

2. Algorithmic opacity

The competitive consequences of an algorithm may be difficult to observe.

3. Data access

Authorities may need information stored overseas.

4. Multiple jurisdictions

Several regulators may investigate simultaneously.

5. Remedy conflicts

Different jurisdictions may demand incompatible remedies.

6. Rapid technological change

Market conditions may change before litigation concludes.

48. Safeguards Against Overreach

The effects doctrine should be applied carefully.

Authorities should normally establish:

identifiable foreign conduct;

a relevant domestic market;

meaningful competitive effects;

causal connection;

sufficient foreseeability;

legally recognized jurisdiction;

proportionality of intervention.

This prevents the doctrine from becoming a general assertion of universal antitrust jurisdiction.

49. Practical Digital-Market Test

A useful analytical framework is:

Step 1 — Identify the conduct

What exactly occurred outside the jurisdiction?

Step 2 — Identify the digital market

Search? App store? Cloud? AI? Ad-tech? Marketplace?

Step 3 — Identify domestic exposure

Which domestic users, competitors, developers or businesses are affected?

Step 4 — Identify the competitive mechanism

Foreclosure? Tying? Self-preferencing? Exclusivity? Predation? Data advantage?

Step 5 — Establish substantial effects

Are the consequences economically meaningful?

Step 6 — Establish causation

Can the effects reasonably be traced to the foreign conduct?

Step 7 — Examine statutory jurisdiction

For India, Section 32 becomes particularly important.

Step 8 — Consider international coordination

Could another competition authority be investigating the same conduct?

Step 9 — Design proportionate remedies

Avoid unnecessary conflict with foreign regulatory systems.

50. Key Case-Law Principles

The major cases collectively illustrate several principles:

51. Importance for India

For India, the effects doctrine is particularly significant because the country's digital economy is deeply connected to global platforms.

Potential areas include:

mobile operating systems;

app stores;

digital payments;

online marketplaces;

search;

digital advertising;

cloud computing;

AI;

social media;

online travel;

food delivery;

ride-hailing;

fintech;

digital health.

A foreign company's headquarters or servers being outside India does not, by itself, eliminate the possibility of Indian competition-law jurisdiction.

52. Relationship With India's Digital Competition Policy

The effects doctrine is likely to remain important as digital competition regulation develops.

Modern competition analysis increasingly focuses on:

ecosystem power;

gatekeeper control;

data advantages;

interoperability;

switching costs;

self-preferencing;

default arrangements;

algorithmic discrimination;

AI infrastructure.

These phenomena frequently operate across borders.

53. Future Application to AI and Autonomous Agents

The doctrine may become even more significant with autonomous AI agents.

Imagine an AI agent developed abroad that autonomously:

negotiates prices;

chooses suppliers;

purchases advertising;

selects cloud infrastructure;

allocates computing resources.

If its automated decisions substantially affect competition in India, the traditional question—

"Where did the human decision-maker act?"

—becomes inadequate.

The more appropriate question may become:

Where did the autonomous system produce economically significant competitive effects?

54. Emerging Concept: Algorithmic Effects

A future competition-law framework may distinguish between:

Physical territoriality

and

algorithmic territoriality.

Algorithmic territoriality focuses on:

where users are located;

where transactions occur;

where competitors are affected;

where data is collected;

where algorithmic discrimination occurs;

where market access is restricted.

This may become a central concept in cross-border AI and platform enforcement.

55. Overall Legal Assessment

The effects doctrine is not a mechanism for imposing unlimited national competition law on every global business.

Its proper function is narrower:

to prevent the territorial organization of a digital business from shielding conduct that has substantial and legally relevant competitive consequences within another jurisdiction.

Digital markets make this principle particularly important because:

production is geographically dispersed;

users are globally connected;

algorithms operate across borders;

data flows internationally;

platforms have global network effects;

digital services have minimal physical presence;

corporate decisions can be centrally implemented worldwide.

56. Conclusion

The effects doctrine is one of the most important jurisdictional principles for modern digital competition law.

Its significance arises from the mismatch between territorial legal systems and borderless digital markets.

Cases such as Alcoa, Hartford Fire, Empagran, Intel, Google Shopping, Google Android, Google AdSense, Microsoft and Qualcomm demonstrate the evolution from a purely territorial approach toward one that considers economically significant effects.

In India, Section 32 of the Competition Act, 2002 provides a particularly important statutory basis for addressing foreign conduct that affects competition in India.

For digital markets, the central analytical proposition can therefore be summarized as:

The location of the code, contract, server, headquarters or corporate decision is not necessarily the location of the competitive harm.

The decisive issue is whether foreign conduct has a sufficiently substantial and legally cognizable effect on competition within the jurisdiction. As platforms, AI systems, cloud infrastructure, ad-tech networks and autonomous digital agents become increasingly interconnected, effects-based jurisdiction will become an increasingly important tool for preventing global digital market power from escaping effective competition-law scrutiny.