WHAT IS ANTITRUST?
According to the U.S. Federal Trade Commission (FTC) antitrust laws:
“… prohibit conduct by a single firm that unreasonably restrains competition by creating or maintaining monopoly power.”
It’s a common misconception that a strict monopoly is necessary before antitrust rules apply. A monopoly is a term the FTC uses to characterize the market power used by a company to raise prices and exclude competitors over the long term. This can happen with a monopoly, but also with a duopoly or an oligopoly[1][2].
The structure of the hop merchant class is an oligopoly. A few firms dominate the industry[3]. Antitrust laws allow competing firms to collaborate in special cases. The reasonableness of their collaboration determines whether it is legal. If, for example, they wield market power together or if they cannot act independently as a result, that is harmful to competition … and illegal[4]. Evidence of anticompetitive behavior can be direct or circumstantial[5]. Antitrust cases have been difficult due to 40 years of weak enforcement that has set precedent[6]. One challenge is that some behavior, which would be illegal when done as the result of a joint agreement, is legal if there is no evidence of such an agreement[7].
That’s a very macro view. Let’s go a little deeper. Most antitrust cases include collusion[8]. Collusion often takes one of the following three forms:
1) Price fixing. This can be the agreement among competitors to raise, fix or maintain the price at which their products are sold. The competitors involved can charge different prices. Their coordination of their movements is what is illegal, not the specific price charged. There are several types of price fixing that may not be obvious at first glance:
a. holding prices firm,
b. adopt a standard formula for computing prices, or
c. the lack of advertised prices.
2) Bid rigging. There are several types of bid rigging in addition to the obvious situation where competitors agree who will win and who will lose a bid. Subcontracting, for example, is when a competitor agrees not to bid but then later receives a supply contract in exchange from the successful bidder[9].
3) Market division. This is where competing firms allocate specific customers or types of customers, products or territories amongst themselves.
CONDITIONS FAVORABLE TO COLLUSION
The hop industry seems to meet all the necessary criteria for collusion to occur[10]. According to the DOJ, the probability of collusion increases under the following conditions:
1) There are few sellers. The fewer the number of sellers, the easier it is for them to get together and agree on prices, bids, customers, or territories.
2) If other products cannot easily be substituted for the product in question or if there are restrictive specifications for the product being procured.
3) When the product is highly standardized it is easier for competing firms to reach agreement on a common price structure.
4) When repetitive purchases are common, as vendors may become familiar with other bidders and future contracts provide the opportunity for competitors to share the work.
5) When competitors know each other well socially, through trade associations, legitimate business contacts, or when employees change employers within the industry.
In a September 2022 article, “Who Sets Hop Price … and How?”, I discussed the speed with which tacit collusion affects hop prices via a farmers and merchant network. Although the name “tacit collusion” sounds bad, tacit collusion involves no communication and as a result is legal[11].
TYING PRODUCTS
Not all anticompetitive behavior requires collusion. One type of antitrust violation that does not is called “tying”[12]. Tying or “bundling” products is when a seller makes the purchase of one product dependent upon the buyer’s agreement to take a second product. Without purchasing both products, the buyer will not get the product he wants. A merchant requiring a brewery to purchase a public variety to get access to a proprietary variety they want would likely be guilty of tying. When I was a practicing hop merchant, I had this happen to me more than once. I don’t know if this is a common practice today.
THE MICROSOFT ANTITRUST CASE
A good example of a situation that looks like tying was the U.S. Government’s case against Microsoft. The government claimed Microsoft gained an unfair advantage by requiring PC manufacturers preload their Internet browser, Internet Explorer, to get the Windows 95 operating system[13]. The customer did not need both products but had to take both to get the one they wanted[14]. Microsoft’s claimed everything they did was pro-competitive, innovative and innocent[15].
In 2000, Mircosoft was found guilty of violating antitrust law. Judge Jackson ordered the breakup of the company. Jackson determined Microsoft tied sales of the Windows operating system to the Internet browser and that the company’s threats of withholding discounts if computer makers did not carry its browser were anticompetitive[16]. A higher court later overturned the finding of tying and the ruling to break up the company saying judge Jackson had an anti-Microsoft bias[17]. In 2001, the U.S. Department of Justice (DOJ) and Microsoft reached a tentative settlement, a consent decree intended to last five years[18]. Microsoft changed the practices thought to be anticompetitive and the consent decree was approved and signed the consent decree in 2002[19].
A HOP MERCHANT CONSPIRACY?
In 1984, a Federal grand jury completed an investigation into John I. Haas and several other hop merchants for antitrust violations. The investigation resulted in no indictments[20]. That was not the end. In July 1984, the U.S. government filed a civil suit accusing John I. Haas and others of anticompetitive behavior including price-fixing charges[21]. The merchants were not found guilty, nor did they admit to any wrongdoing. The civil case was settled with the signing of a consent decree by John I. Haas. The company agreed not to violate antitrust laws in the future[22]. That still was not the end of the litigation.
A 1986 lawsuit filed by Anheuser-Busch Inc. against several hop merchant companies claimed they conspired to fix the price of hops between 1976 and 1984[23]. They suggested hop merchants engaged in covert communications, used coded messages and conspired to secretly fix prices[24]. In October 1987, a judge ruled the matter be settled via arbitration, something that was not standard in hop contracts prior to 1982[25]. The details of any subsequent arbitration were not public.
“Absence of Evidence is not the Evidence of Absence.”
- Carl Sagan “Dragons of Eden” 1977[26]
WHAT IS A CONSENT DECREE?
Since I’ve never been involved in an antitrust case, I had no idea how a consent decree works. The definition of a consent decree according to the Cornell Law School Legal Information Institute is as follows:
CONSENT DECREE
“… A consent decree is also often used in government regulation in areas such as antitrust, securities and environmental law. When the government sues a person or company and the defendant agrees to stop its illegal conduct, the government may agree not to pursue the case, and the court approves and issues a consent decree.”[27][28]
So, it seems a consent decree is a way to correct any undesirable behavior without an official admission of guilt and without any penalty. In the 1980s, when the U.S. government filed its civil suit against John I. Haas, 97% of antitrust cases ended in a consent decree. The practice remains the most common method to resolve such civil cases[29].
ANTITRUST LAWS
This part about antitrust laws may be boring so I’ll keep it brief. Feel free to skip to the next section if you’re familiar with the antitrust legislation.
When working with American farmers, it’s common to hear them mention THE CAPPER-VOLSTEAD ACT OF 1922. The goal of the act is to increase farmer bargaining power in the market for the sale of their goods. The act provided limited exemption from antitrust laws farmers to act together “in collectively processing, preparing for market, handling, and marketing in interstate and foreign commerce” their agricultural products[30]. The exemption is limited to these activities.
Farmers, however, must satisfy two conditions for the exemption to apply[31]:
The cooperative must be operated for the mutual benefit of its farmer members.
The cooperative must not deal in the products of nonmembers in an amount greater than the value of the products it handles for its members.
The Act envisions a world where the farmer is separate and subject to abuse from the entity marketing his goods. In 2023, the line between farmer and merchant in the U.S. are blurred. Farmers own the entities that market hops and entities that market hops produce hops. Within the industry whether a person is a farmer or a merchant is subject to interpretation and the subject of jokes. Which hat they wear when they discuss collective bargaining activity may be a legal gray area. One of the weaknesses of Capper-Volstead is the subjective interpretation necessary to enforce the act[32]. The Act is clear, however, that a cooperative cannot:
1) restrict its members’ agricultural output,
2) coerce competitors or customers or collude with third parties to fix prices,
3) combine with other firms to lessen competition, or
Since the creation and domination of proprietary varieties there have been no challenges to the way the business structures have evolved.
For more information on the Capper-Volstead Act, click here:
The Sherman Antitrust Act of 1890 outlaws the unreasonable restraint of trade[35]. The act prohibits “monopolization, attempted monopolization, or conspiracy or combination to monopolize.” A company, or a group of companies, are judged based on the reasonableness of their actions and the restraint of trade. Not all agreements between companies that restrain trade are unreasonable[36].
For more information on the Sherman Antitrust Act, click here.
The Clayton Act of 1914 sought to prevent the development of monopolies and cartels[37]. The law sought to prevent anticompetitive practices by regulating mergers and acquisitions and by targeting price discrimination (i.e., predatory pricing practices)[38][39]. Section 7 of the Act prohibits mergers and acquisitions where the effect “may be substantially to lessen competition, or to tend to create a monopoly.”[40] An illegal monopoly exists when a company controls the market for a product or service and obtained their power by suppressing competition through anticompetitive conduct[41].
For more information on the Clayton Act, click here.
The Federal Trade Commission Act bans “unfair methods of competition” and “unfair or deceptive acts or practices.”[42][43] It promotes informed consumer choice and competition and allows the FTC to impose penalties if it determines consumers have been injured by anticompetitive business activity[44].
For more information on the Federal Trade Commission Act, click here.
Despite all these Acts that enable the government to maintain a competitive environment, enforcement of U.S. antitrust laws has been weak since the 1970s. This is due in part to the interests of big business and the technocracy[45][46]. There is some indication that stricter enforcement of antitrust laws will be more common in the future[47][48].
MARKET CONCENTRATION
The ability to maintain or increase prices during poor market conditions demonstrates the power of consolidation[49]. Merchants are resorting to selling on the Lupulin Exchange. Some proprietary varieties that are in surplus continue to sell at premium prices[50]. It seems the surplus has not affected merchant price expectations. The absence of a bear market during such a surplus reveals the degree of market consolidation and the effect of proprietary varieties on the market. This is different from earlier periods when the market was less concentrated and free market competition thrived as measured by the Herfindahl-Hirschman Index (HHI) (Figure 1).
Figure 1. Herfindahl-Hirschman Index of U.S. Proprietary Hop Variety Acreage 2000-2020
Source: UDSA NASS National Hop Report data 2000-2020
Note: Market concentration represents proprietary variety competition for acreage, which is, in the opinion of the author, the scarcest and most valuable resource in the industry.
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The HHI is used to measure changes in market concentration within an industry. The merger guidelines of the FTC do not measure the effect of increased market concentration on consumer prices[52]. Market concentration is negatively correlated to competition (meaning the higher the concentration the lower the competition)[53]. The DOJ uses the Herfindahl-Hirschman Index (HHI) to measure market concentration. Market share is often measured in terms of sales or shipments, but those units do not apply to an R&D venture. Measuring the market share for a joint R&D venture, however, is challenging. Another limitation of the HHI is that it cannot calculate net harmful effects done to consumers[54].
Something caused farmers to respond differently between 2012 and 2022 than they did in 1980, 1991 and 2008 to increasing prices. One key difference between those periods is that in 2020 proprietary varieties peaked at 73.44% of U.S. Pacific Northwest (PNW) production[51].
In 2021, President Biden signed executive order 14036 on promoting competition in the American economy[55]. The order was a way to address concerns that antitrust enforcement has been too lenient over the past 40 years[56]. It stated,
“… excessive market concentration threatens basic economic liberties, democratic accountability, and the welfare of workers, farmers, small businesses, startups, and consumers.”
To combat these injustices, the order provided additional resources to enforce existing laws[57].
The existence of increased market concentration and reduced competition is apparent. There has been very little change in the USDA season average prices (Figure 2).
Figure 2. U.S. Season Average Prices for Hops 2012-2022
Source: Hop Growers of America 2022 Statistical Report.
All this despite the size of the surplus, which I estimated to be 54-million-pounds (24,494 MT) in my February 2023 article called “The Truth Behind the Hop Surplus”.
JOINT RESEARCH VENTURES
The FTC allows certain forms of collaboration among competitors for research and development (R&D) among other things[58]. The National Cooperative Research Act of 1984 (NCRA) allows joint ventures among competitors to collaborate for research purposes[59]. The NCRA, however, does not allow collaborators to do the following:
1) exchange information among competitors related to costs, prices or marketing that is not reasonably required to conduct the R&D that is the purpose of the joint venture;
2) form agreements involving production and marketing of products not developed through the R&D joint venture;
3) execute agreements to restrict or require the sale, licensing or sharing of inventions not developed through the venture[60].
To avoid the coordination of R&D activities leading to anticompetitive conduct (i.e., the production and pricing of products) individuals involved in the marketing and sales for the products developed by the joint venture should be separate from the R&D efforts[61]. According to Barthhaas, the U.S. hop industry had 69 participants in 2021 (Figure 3). Is it feasible for such separation to exist in such a small industry?
Figure 3: BarthHaas Estimated Number of Hop Growers in the Pacific Northwest of the U.S.
Source: 2021/2022 BarthHaas Report[62]
I demonstrated in my April 2023 article, “The Secret Behind Who Controls the Hop Industry” there are a few family names that surface repeatedly. This happens in the companies conducting R&D of some proprietary varieties and the companies distributing the product of that R&D (Figure 4). Recurring names alone do not suggest impropriety. The current arrangement creates the circumstances where somebody could misbehave … if they were so inclined. There is no evidence to suggest that has happened.
Figure 4. HBC Ownership & Pathway to Market
COMPETITION
According to the National Bureau of Economic Research, the negative correlation between market concentration and competition is most common when barriers to entry or the threat of predatory behavior by incumbents exist[63]. New entrants to the hop industry from California to New York and anywhere in between can attest to the barriers to entry in the hop industry. Equipment costs, processing and storage infrastructure are dwarfed by less-tangible barriers like expertise and hop production experience, which are scarce. As for the predatory practices used by incumbents in the U.S. hop industry to eliminate competitors, I can attest to their existence.
The power dynamic in the industry has shifted with the growth of proprietary varieties. In the new paradigm of proprietary varieties, farmers no longer in control of their fate. Real power in 2023 is determined by the ability to influence how land is used, not ownership of the land itself[64]. The relationship of proprietary variety ownership to the merchant companies that control the industry’s processing, storage and distribution capacity necessitates self-censorship among farmers lest they offend the owners of intellectual property (IP) upon whom their livelihood depends.
OBSERVATIONS AND QUESTIONS
American hop farmers demonstrated in 1980, 1991 and 2008, they overproduce for the market in response to increased prices. That did not happen between 2012 and 2022.
According to the USDA, HBC variety acreage increased 1,078% during that time, from 2,720 acres to 29,323 acres (1,101 hectares to 11,871 hectares)[65]. In 2022, American farmers produced proprietary varieties owned by the Hop Breeding Company, LLC (HBC) on over 49.05% of U.S. PNW acreage[66]. Other companies owned varieties produced on an additional 19% of U.S. PNW acreage in 2022[67]. Patent law allows the patent owner to manage production of its IP to preserve its value. I am curious how that was accomplished with such competence between 2010 and 2022.
Question: Is the management of the production of a proprietary variety more complicated when more than one rival merchant company is involved in its production?
Another interesting coincidence is the acreage reduction of 2023. We will see the extent to which the acreage of certain varieties was reduced in the 2023 June Hops Strung for Harvest report later this month. Anecdotal evidence suggests that multiple merchants decided to reduce production of their proprietary varieties at the same time. I am curious how they came to the realization that acreage reduction was necessary in 2023.
Question: Wouldn’t each merchant be concerned that by reducing acreage with their producers they would concede valuable market share to a competitor?
Perhaps losing market share was an acceptable risk given the growing cost of holding inventory. The March 2023 Hop Stocks Report indicated there were 186 million pounds (84,369 MT) of hops in inventory as of March 1, 2023. That inventory has a farm gate value of $1.09 BILLION using an average of the 2019-2022 U.S. season average prices from Figure 2, which is $5.86 per pound. That’s a lot of inventory to finance.
Question: How much of that inventory is unwanted in 2023?
Assuming a margin of 40% on that inventory, which was my average margin on deals when I was a merchant), that inventory has a street value of $1.53 BILLION.
Question: Is that inventory still really worth $1.09 billion?
As a recovering hop merchant, I understand it is clear when you have surplus hops that brewers don’t want. Your warehouse gets full of older hops you know you can’t sell except at a deep discount. Your revenue slows down. You realize your contracts were worthless. The customers you once enjoyed talking to treat you like an enemy. It’s stressful.
There are examples of simultaneous discovery in history. The telephone, the theory of evolution and even calculus were all discoveries made independently by more than one researcher at the same time[68]. Perhaps, the 2023 acreage reduction was the result of a simultaneous awareness that the surplus that began in 2016 would not correct itself and it was time to act. We should give everybody involved the benefit of the doubt that that’s exactly what happened … but can we be sure?
“What’s Past is Prologue”
- William Shakespeare, The Tempest Act 2, Scene 1[69]
If you believe you or your company has been the victim of antitrust activity, anticompetitive business practices, fraud or price gouging, you should report that to the Bureau of Competition at the FTC[70].
E-Mail[71]:
antitrust@ftc.gov
Regular Mail:
Office of Policy and Coordination
Room CC-5422
Bureau of Competition
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Telephone: (202) 326-3300
Collusion is difficult to detect. The Antitrust Division of the U.S. Department of Justice needs your help. If you think you have a possible violation, contact the Citizen Complaint Center of the Antitrust Division:
Email: antitrust.complaints@usdoj.gov
Phone: 1-888-647-3258 (toll-free in the U.S. and Canada); or 1-202-307-2040
Regular Mail:
Citizen Complaint Center Antitrust Division
U.S. Department of Justice
950 Pennsylvania Avenue. NW, Suite 3322
Washington, DC 20530
[1] https://scholarship.law.cornell.edu/cgi/viewcontent.cgi?article=4275&context=clr&httpsredir=1&referer=
[2] https://9to5mac.com/2021/12/14/apple-and-google-accused-of-duopoly-could-face-antitrust-action-in-the-uk/
[3] https://open.lib.umn.edu/principleseconomics/chapter/11-2-oligopoly-competition-among-the-few/
[4] https://www.ftc.gov/enforcement/anticompetitive-practices
[5] https://www.computerworld.com/article/2534379/timeline--the-gates-era-at-microsoft.html?page=2
[6] https://www.cnbc.com/2023/01/27/dojs-antitrust-case-against-google-is-ambitious-but-risky.html
[7]https://appliedantitrust.com/08_other_horizontal/cases/ferrellgas_mdl/2_8cir/propone_8cir_supp_appellees2_21_2017.pdf
[8] https://www.justice.gov/atr/file/810261/download
[9] https://www.justice.gov/atr/file/810261/download
[10] https://www.justice.gov/atr/file/810261/download
[11] https://www.econstor.eu/bitstream/10419/62592/1/724283404.pdf
[12] https://www.justice.gov/atr/chapter-5-antitrust-issues-tying-and-bundling-intellectual-property-rights
[13] https://www.justice.gov/archive/atr/public/press_releases/1998/1764.htm
[14] https://www.ftc.gov/advice-guidance/competition-guidance/guide-antitrust-laws/single-firm-conduct/tying-sale-two-products
[15] https://www.nytimes.com/2018/05/18/opinion/microsoft-antitrust-case.html
[16] https://www.washingtonpost.com/archive/politics/2000/04/04/judge-says-microsoft-broke-antitrust-law/165a2acf-05a1-45fd-9dc0-2a3992752804/
[17] https://www.computerworld.com/article/2582620/appeals-court-reverses-microsoft-breakup-order.html
[18] https://www.justice.gov/atr/usdoj-antitrust-division-us-v-microsoft-corporation-information-settlement
[19] https://www.google.com/url?sa=i&rct=j&q=&esrc=s&source=web&cd=&ved=0CAIQw7AJahcKEwiwj-uBt6P_AhUAAAAAHQAAAAAQAg&url=https%3A%2F%2Fnews.microsoft.com%2Fdownload%2Flegal%2FConsentDecree%2F01-16-08MSFTConsentDecreeTimeline.docx&psig=AOvVaw1RnjicsnwPzXupoXe3ZA6Z&ust=1685754795086373
[20] https://www.washingtonpost.com/archive/business/1986/08/11/anheuser-busch-sues-hops-dealers/6a00264d-433f-4c0e-838c-e6ab45163f3c/
[21] https://www.justice.gov/archive/atr/public/press_releases/1984/325646.pdf
[22] https://www.washingtonpost.com/archive/business/1986/08/11/anheuser-busch-sues-hops-dealers/6a00264d-433f-4c0e-838c-e6ab45163f3c/
[23] https://openjurist.org/832/f2d/470/hops-antitrust-litigation-anheuser-busch-inc-v-i-haas-and-l-and-anheuser-busch-inc
[24] https://www.upi.com/Archives/1986/08/06/Brewery-claims-its-victim-of-hops-conspiracy/9909523684800/
[25] https://casetext.com/case/in-re-hops-antitrust-litigation-2
[26] https://www.amazon.com/Dragons-Eden-Speculations-Evolution-Intelligence/dp/0345346297
[27] https://www.law.cornell.edu/wex/consent_decree
[28] https://chicagounbound.uchicago.edu/cgi/viewcontent.cgi?article=1024&context=uclf
[29] https://www.ftc.gov/sites/default/files/documents/public_statements/antitrust-settlements-culture-consent/130228antitruststlmt.pdf
[30] https://www.rd.usda.gov/files/cir35.pdf
[31] https://www.theantitrustattorney.com/the-capper-volstead-act-gives-farm-cooperatives-a-limited-exemption-from-antitrust-liability/
[32] https://aglawjournal.wp.drake.edu/wp-content/uploads/sites/66/2023/03/Buck-Macro-Final.pdf
[33] https://www.theantitrustattorney.com/the-capper-volstead-act-gives-farm-cooperatives-a-limited-exemption-from-antitrust-liability/
[34] https://aglawjournal.wp.drake.edu/wp-content/uploads/sites/66/2023/03/Buck-Macro-Final.pdf
[35] https://www.archives.gov/milestone-documents/sherman-anti-trust-act
[36] https://www.ftc.gov/advice-guidance/competition-guidance/guide-antitrust-laws/antitrust-laws
[37] https://guides.loc.gov/this-month-in-business-history/october/clayton-anitrust-enacted
[38] https://history.house.gov/HistoricalHighlight/Detail/15032424979
[39] https://www.investopedia.com/terms/c/clayton-antitrust-act.asp
[40] https://www.ftc.gov/advice-guidance/competition-guidance/guide-antitrust-laws/antitrust-laws
[41] https://www.justice.gov/atr/antitrust-laws-and-you
[42] https://www.ftc.gov/legal-library/browse/statutes/federal-trade-commission-act
[43] https://www.ftc.gov/advice-guidance/competition-guidance/guide-antitrust-laws/antitrust-laws
[44] https://www.federalregister.gov/agencies/federal-trade-commission
[45] https://bfi.uchicago.edu/wp-content/uploads/2022/08/BFI_WP_2022-104.pdf
[46] https://www.technocracy.news/cradle-to-grave-the-massive-consolidation-of-the-health-care-industry/
[47] https://www.nytimes.com/2022/12/07/technology/meta-vr-antitrust-ftc.html
[48] https://www.reuters.com/legal/us-keeps-losing-antitrust-court-battles-few-expect-pullback-2022-10-04/
[49] https://www.nytimes.com/2009/08/27/business/27views.html
[50] https://lupulinexchange.com/listings?q=citra&page=3
[51]https://www.nass.usda.gov/Statistics_by_State/Regional_Office/Northwest/includes/Publications/Hops/2021/hops1221.pdf
[52] https://www.justice.gov/atr/horizontal-merger-guidelines-08192010
[53] https://one.oecd.org/document/DAF/COMP/WD(2018)69/en/pdf
[54] https://digitalcommons.pace.edu/cgi/viewcontent.cgi?article=1863&context=plr
[55] https://www.federalregister.gov/documents/2021/07/14/2021-15069/promoting-competition-in-the-american-economy
[56] https://www.pennlawreview.com/wp-content/uploads/2021/01/Rose-Sallet_FINAL.pdf
[57]https://www.whitehouse.gov/cea/written-materials/2021/07/09/the-importance-of-competition-for-the-american-economy/
[58] https://www.ftc.gov/sites/default/files/documents/public_events/joint-venture-hearings-antitrust-guidelines-collaboration-among-competitors/ftcdojguidelines-2.pdf
[59] https://www.ftc.gov/sites/default/files/documents/public_events/joint-venture-hearings-antitrust-guidelines-collaboration-among-competitors/ftcdojguidelines-2.pdf
[60] https://lawcat.berkeley.edu/record/1112592?ln=en
[61] https://lawcat.berkeley.edu/record/1112592?ln=en
[62]https://www.barthhaas.com/fileadmin/user_upload/kampagnen/barthhaas_bericht/2022/BarthHaas_Report_2021_2022_EN.pdf
[63] https://www.nber.org/reporter/2019number4/economics-and-politics-market-concentration
[64] https://www.forbes.com/sites/rickmiller/2018/10/25/what-is-power-really/?sh=5cdaf29f42a7
[65] Acreage data comes from the USDA National Hop Reports from 2010 to 2022
[66] This number includes an estimate for CTZ acreage calculated by the author based on the most recent available USDA figures.
[67]https://www.nass.usda.gov/Statistics_by_State/Regional_Office/Northwest/includes/Publications/Hops/2022/hopsan22.pdf
[68] https://indianapublicmedia.org/amomentofscience/what-is-multiple-discovery.php
[69] https://www.online-literature.com/shakespeare/tempest/3/
[70] https://www.ftc.gov/enforcement/report-antitrust-violation
[71] The FTC website on which this email is listed reminds you that email is not a secure means of transmission.