By: Dominic Enright
Volume X – Issue II – Spring 2025
I. INTRODUCTION
Few issues in healthcare spark as much frustration and debate as the soaring cost of prescription drugs. At the heart of the crisis are Pharmacy Benefit Managers (PBMs), powerful intermediaries that shape drug pricing and access while operating with minimal transparency. Originally designed to control costs and streamline the pharmaceutical supply chain, PBMs have instead amassed significant market power, raising concerns about reduced competition and unfair market practices. This article examines how PBMs influence drug pricing, the antitrust challenges they present, and the evolving legal efforts to restore competition in the pharmaceutical industry.
II. DRUG PRICING IN THE UNITED STATES
The pricing of prescription drugs in the United States is a complex and opaque process shaped by the interplay of pharmaceutical manufacturers, intermediaries, insurers, and government programs. Unlike many other developed countries, the United States permits manufacturers to set drug prices without direct regulation. However, the final cost to consumers is shaped by a convoluted chain of negotiations, rebates, fees, and markups that occur throughout the supply chain. [1]
At the core of this process are pharmaceutical companies, which develop, produce, and market prescription medications. Manufacturers set the Wholesale Acquisition Cost (WAC), the list price at which they sell to wholesalers and direct purchasers, prior to the application of any discounts. In addition, manufacturers self-report an Average Wholesale Price (AWP), a benchmark price used in reimbursement contracts, though it does not reflect the actual price paid by pharmacies or patients. [2] Because AWP is self- reported by drug manufacturers and not subject to regulation, it is often subject to intense inflation. Manufacturers often justify high prices by citing extensive research and development (R&D) costs; however, pricing strategies are also significantly influenced by market exclusivity granted through patents, as well as the anticipation of negotiation rebates with intermediaries.
A critical layer in the pricing system involves Pharmacy Benefit Managers (PBMs), [3] which serve as powerful intermediaries between drug manufacturers, insurers, and pharmacies. One core function of PBMs is to determine which medications are covered by insurance plans. PBMs develop formularies, which are lists of covered drugs, and negotiate directly with drug manufacturers to secure rebates, or postsale price concessions, in exchange for favorable placement on those formularies. [4] Although PBMs claim that their negotiations reduce insurance premiums, critics contend that PBMs often prioritize drugs that generate larger rebates rather than selecting the most cost-effective therapies. The rebate negotiation process remains largely enigmatic, and PBMs typically pocket an undisclosed share of the rebates they obtain, passing through only a portion to insurers and plan sponsors.
Health insurers also play a significant role by designing pharmacy benefit structures and determining patients’ cost-sharing obligations. Insurers pay administrative fees to PBMs while pharmacies purchase medications from wholesalers, usually at a price above WAC, and seek reimbursement from PBMs after dispensing drugs to patients. Independent pharmacies, in particular, argue that reimbursement rates often fall below acquisition costs and are further eroded by Direct and Indirect Remuneration (DIR) fees, which PBMs impose retroactively. [5] As a result, many pharmacies increasingly rely on sales of non-prescription products such as personal care items, supplements, and cosmetics. Although the federal government does not regulate prices in the commercial market, it exercises influence through public programs such as Medicare and Medicaid, where statutory rebates and recent reforms, such as those introduced by the Inflation Reduction Act, seek to moderate prices.
For patients, the pricing structure translates into varying out-of-pocket costs. Insured individuals typically pay either a fixed copayment (e.g. $20 per prescription) or a coinsurance rate (a percentage of the drug’s price), depending on their plan design.6 In contrast, uninsured individuals are often charged with the full pharmacy retail price, which is an enormous price. Thus, while the physical movement of drugs from manufacturers to wholesalers to pharmacies to patients remains relatively straightforward, the financial flows that determine final costs are characterized by hidden negotiations and cost-sharing arrangements. The resulting system places significant financial burden on both consumers and independent providers.
III. CONTEMPORARY ANTITRUST ENFORCEMENT IN THE PHARMACEUTICAL INDUSTRY
i. Legal Foundations
U.S. antitrust law has evolved over more than a century to promote competition, prevent monopolistic abuses, and protect consumers. Its legal foundation rests on three major statues: the Sherman Antitrust Act of 1890, the Clayton Antitrust Act of 1914, and the Federal Trade Commission Act of 1914.
Amid the excesses of the Gilded Age, as towering industrial empires tightened their grip on the American economy, a growing coalition of reformers rallied against the unchecked power of monopolists who stifled competition, crushed small businesses, and bent democracy to their will. The Sherman Antitrust Act was the first federal law in the United States aimed at curbing monopolies and promoting fair competition in the marketplace. Section 1 of the Sherman Act prohibits:
“Every contract, combination in the form of trust or otherwise, or conspiracy, in restraint of trade or commerce among the several States, or with foreign nations, is hereby declared to be illegal.” [7]
This section targets concerted practices like price fixing, bid rigging, and market allocation. Section 2 of the Act separately outlaws attempts to monopolize, though it does not ban monopolies that arise through legitimate means such as superior products or innovation. It states:
“Every person who shall monopolize, or attempt to monopolize, or combine or conspire with any other person or persons, to monopolize any part of the trade or commerce among the several States, or with foreign nations, shall be deemed guilty of a misdemeanor, and, on conviction thereof; shall be punished by fine not exceeding five thousand dollars, or by imprisonment not exceeding one year, or by both said punishments, in the discretion of the court.” [8]
Early interpretations of the Sherman Act, notably in Standard Oil Co. v. United States (1911), established the “rule of reason” [9] framework, requiring courts to evaluate whether a practice’s effect was unreasonably harmful to competition. This doctrinal shift placed the burden on plaintiffs to show that specific conduct produced harm, a standard that still governs much of antitrust litigation today.
Seeking to address perceived gaps in the Sherman Act’s effectiveness, Congress passed the Clayton Act in 1914. Among its provisions, Section 7 became particularly important for regulating mergers and acquisitions, prohibiting transactions where:
“the effect of such acquisition may be substantially to lessen competition, or to tend to create a monopoly.” [10]
In contrast to the Sherman Act’s reactive framework, the Clayton Act took a proactive approach by attempting to halt anticompetitive consolidation before harm occurred. However, it is important to note that the law does not generally prohibit conglomerate mergers unless they involve industries closely linked in commerce.
That same year, in effort to further strengthen the federal government’s ability to police anticompetitive conduct, Congress enacted the Federal Trade Commission Act of 1914, which established the Federal Trade Commission (FTC) as an independent administrative agency tasked with promoting consumer protection and maintaining competition. Section 5 of the FTC Act declared unlawful:
“Unfair methods of competition in or affecting commerce, and unfair or deceptive acts or practices in or affecting commerce, are hereby declared unlawful.” [11]
This language provides the FTC broader enforcement powers beyond the confines of the Sherman and Clayton Acts, allowing it to target conduct that may not meet traditional antitrust standards but still harms competitive conditions.
ii. Enforcement Landscape: Federal, State, and Private Litigants
Unlike the European Union and many Asian countries where antitrust enforcement is largely centralized, the United States employs a decentralized model featuring multiple enforcers: the Federal Trade Commission (FTC), the Department of Justice’s (DOJ) Antitrust Division, state attorneys general, and private litigants. The FTC and DOJ serve as the federal government’s primary enforcers of antitrust law. Both agencies review proposed mergers and investigate anticompetitive conduct, although criminal prosectuions—for hard-core offenses like price fixing and bid rigging—fall exclusively under the DOJ’s jurisdiction. Civil enforcement actions may be brought by either agency. [12] The state attorneys general independently possess authority under federal and state law to bring antitrust suits, often collaborating with federal agencies. [13] Additionally, private parties may file suit. The structure of American antitrust enforcement which is dispersed among federal, state, and private actors was arguably designed to facilitate competition between the various players in order to encourage a more vigorous enforcement of antitrust laws. The priorities and philosophy of federal antitrust enforcement often shift with presidential administrations. Under President Biden’s tenure, for instance, the FTC has pursued an aggressive approach to merger review as part of a broader revival of structural antitrust principles [14] while previous republican administrations have taken a less aggressive stance.
iii. Trends & Challenges in Pharmaceutical Antitrust
Over the past two decades, the pharmaceutical supply chain has become increasingly consolidated and vertically integrated particularly through the rise of PBMs. Originally founded as third party administrators, PBMs evolved into powerful intermediaries controlling formularies, negotiating rebates, and setting pharmacy reimbursement rates.
A wave of vertical integrations beginning in the 1990s saw pharmaceutical companies acquiring PBMs directly—such as Merck & Co.’s acquisition of Medco Containment Services in 1993 [15] and Eli Lilly & Co.’s purchase of PCS Health Systems, Inc. in 1994. [16] Although these early integrations raised concerns, antitrust scrutiny during this era was relatively weak and historically, vertical integration was less scrutinized than other forms of anticompetitive behavior. Furthermore, the prevailing philosophy at the time presumed vertical mergers were generally efficiency-enhancing unless specific harms could be proven. These conditions, coupled with political factors and an increasing regulatory focus on the technology sector, paved the way for these massive consolidations.
In the 2000s, PBMs engaged in significant horizontal consolidation. Express Scripts’ acquisition of Medco in 2012 [17] and OptumRx’s acquisition of Catamaran in 2015 [18] exemplified the trend. Today, the “Big Three” PBMs—CVS Caremark, OptumRx, and Express Scripts—control nearly 80% of prescription drug claims, with the top six controlling roughly 94%. [19] Critics argue that PBMs now occupy positions of extraordinary market power, able to manipulate formularies, steer patients, inflate reimbursements, and distort drug pricing in ways that harm both competitors and consumers. All Big Three PBMs demonstrate evidence of vertical integration: CVS Health owns and operates CVS Caremark (PBM), CVS Pharmacy, and Aetna (Insurance); [20] Cigna Corporation owns Express Scripts (PBM) and Cigna Health Insurance; [21] and UnitedHealth Group maintains and operates OptumRx as well as UnitedHealthcare. [22] The FTC and DOJ have increasingly recognized these concerns, although enforcement faces doctrinal challenges under traditional antitrust standards that often presume vertical conduct is benign unless clear consumer harm can be demonstrated. Addressing the anti-competitive risks associated with PBM dominance will require overcoming longstanding skepticism toward vertical theories of harm and adapting legal standards to the realities of modern pharmaceutical markets.
IV. ANTITRUST PHILOSOPHY: CONSUMER WELFARE V. NEO-BRANDEISIANISM
i. Robert Bork’s Consumer Welfare Standard
Robert Bork, an influential legal scholar, judge, and antitrust theorist, fundamentally reshaped modern competition law through his 1978 book, The Antitrust Paradox. [23] At the core of Bork’s philosophy was the consumer welfare standard, which held that antitrust enforcement should focus exclusively on whether firms harmed consumers through higher prices, reduced output, or diminished quality. [24] In Bork’s view, antitrust laws were intended not to protect competitors for their own sake but to advance consumer interests. His “paradox” highlighted the concern that courts and regulators, by seeking to preserve small businesses and diffuse economic power, were harming consumers by punishing efficient companies and protecting smaller, less efficient competitors.
To his credit, Bork offered a clearer and more economically grounded framework at a time when antitrust enforcement was often inconsistent, animated by vague appeals to fairness or small business protectionism. His framework shifted the focus of antitrust law toward measurable outcomes like price and output. By the 1980s, particularly under the influence of the Chicago School of Economics, Bork’s consumer welfare standard became the dominant interpretive lens for antitrust law, shaping judicial decisions and academic thinking for decades. However, the broad adoption and misapplication of the consumer welfare standard had unintended consequences. While Bork’s original conception was broader than price alone, courts and regulators increasingly interpreted the standard narrower, focusing almost exclusively on short-term price effects. As a result, other forms of bad conduct that harmed innovation, labor markets, data privacy, or market structure were often overlooked if immediate consumer prices remained stable or decreased.
ii. Neo-Brandeisian Critiques
In response to the perceived limitations of Bork’s framework, a new school of thought— commonly referred to as the Neo-Brandeisian movement—has emerged to challenge the prevailing orthodoxy in antitrust law. Drawing inspiration from early 20th-century Supreme Court Justice Louis Brandeis, this school rejects the narrow, price-centric focus of the consumer welfare model. [25] NeoBrandeisians argue that economic concentration, even when associated with lower prices, can entrench market power, suppress innovation, and undermine small businesses. Rather than measuring harm solely through price effects, Neo-Brandeisians emphasize market structure and power asymmetries as central concerns. They argue that antitrust is not merely about protecting consumers at the checkout line, but about preserving open and fair markets where no entity can serve as a gatekeeper to commerce. This school of thought has increasingly influenced modern discourse, as concerns about Big Tech, labor monopsonies, and healthcare require enforcers to look beyond the limited lens of consumer prices. Major subscribers to this school of thought include the likes of former FTC Chair Lina Khan and legal scholar Tim Wu. [26] This resurgence has influenced recent enforcement approaches, particularly in sectors where price effects are difficult to measure such as digital platforms.
Even when analyzed under both the Borkian and Neo-Brandeisian frameworks, PBMs exhibit characteristics of concentrated market power that justify greater scrutiny. Under Bork’s framework, PBMs might once have been presumed efficient intermediaries but mounting evidence shows that their conduct, which has led to inflated drug costs, ultimately raises consumer prices and reduces access, violating even the narrow interpretation of the consumer welfare standard. Beyond these measurable harms, PBMs also distort competitive structures by squeezing independent pharmacies and consolidating control over which drugs reach patients. These practices align directly with Neo-Brandeisian concerns about concentrated market power. Thus, while Bork’s philosophy identifies clear consumer-facing harms in PBM practices, it proves too narrow to fully capture the structural degradation of upstream harms. A contemporary antitrust approach must account for both immediate consumer harms and the erosion of competitive markets that stifle innovation and choice.
V. PREDATORY REBATES: RESURRECTING THE ROBINSON-PATMAN ACT FOR PBMS
The Robinson-Patman Act of 1936 (RPA) was enacted as an amendment to the Clayton Act to address anti-competitive price discrimination. Originally passed in response to the growing dominance of chain stores, the statute sought to protect small retailers and wholesalers from exclusionary pricing practices that favored large buyers. A key provision of the statute makes it unlawful:
“for any person engaged in commerce, in the course of such commerce, either directly or indirectly, to discriminate in price between different purchasers of commodities of like grade and quality…” [27]
Unlike the Sherman or Clayton Acts, which focus primarily on conduct that harms consumers or competition among sellers, the RPA centers on second-line injury—harm to competing buyers disadvantaged by discriminatory pricing. The statute also prohibits buyers from knowingly inducing unlawful pricing discrimination, recognizing the coercive leverage that dominant purchases can exert over suppliers. Although the RPA applies only to physical commodities and not services, prescription medications qualify, bringing drug pricing practices squarely within its scope.
In today’s drug market, PBMs wield extraordinary influence over which drugs are covered by insurance plans and how they are priced. Through complex arrangements, PBMs negotiate preferential discounts and rebates from drug manufacturers, ostensibly in exchange for favorable formulary placement. These rebates are typically not passed along to consumers or smaller competitors, such as independent pharmacies, and result in higher list prices for patients.
This dynamic raises serious concerns under the RPA. When drug manufacturers offer steep rebates to dominant PBMs that are not made available to smaller or independent buyers purchasing the same drug, there may be clear violations of the Act. Additionally, PBMs may be liable for knowingly inducing such discriminatory pricing, using their massive market power to negotiate more favorable terms at the expense of their rivals. This dynamic raises serious concerns under the RPA. When drug manufacturers offer steep discounts to dominant PBMs that are unavailable to smaller buyers purchasing the same drugs, prima facie [28] violations of the RPA may exist. Historically, courts have limited RPA’s application by imposing stringent burdens. However, given the modern day market structure where dominant intermediaries suppress competition not through greater efficiency but through exclusion, this behavior warrants reassessment.
Traditional antitrust enforcement, long dominated by the consumer welfare standard, largely ignored these buyer-side harms and exclusionary price discrimination. Yet as PBMs consolidate power over drug pricing, access, and reimbursement, the need for a broader enforcement lens becomes clear. Broadening the lens to include harm to buyers and competitors as outlined in the Robinson-Patman Act, offers a promising path for rebalancing competition policy in the pharmaceutical sector. Invoking the RPA could provide a stronger statutory foundation tailored to combat the discriminatory rebate structures that define PBM market dominance. By favoring drugs with higher list prices and larger rebates, PBMs incentivize manufacturers to raise prices and exclude lower-cost generics, ultimately harming competition, raising consumer costs, and stifling innovation. As economic and political conditions evolve, so too must antitrust enforcement strategies. Although long considered dormant, the RPA may offer a powerful but underutilized legal tool to combat harmful pricing disparities embedded in PBM rebate practices. Leading voices like Lina Khan, expressed renewed interests in the RPA as a potential legal tool and its viability is being reexamined. As economic and political conditions evolve, so too must antitrust enforcement strategies. The Robinson-Patman Act may be the missing piece—a statutory remedy designed precisely for the exclusionary, buyer-driven price discrimination now hindering access to lifesaving medicines. [29]
VI. CONCLUSION
The mounting crisis of drug pricing in the United States reflects a deeper structural problem: the growing concentration of market power among intermediaries like PBMs. Despite the severity of these harms, modern antitrust enforcement has struggled to keep pace with the complex realities of vertical integration, exclusionary rebate structures, and information asymmetries that increasingly define the healthcare market. At the heart of this enforcement gap lies a deeper philosophical debate: whether antitrust should continue to focus narrowly on consumer prices, as the consumer welfare standard prescribes, or whether it should return to a broader vision of market fairness as advocated by NeoBrandeisian thinkers. Nowhere is the need for this rethinking more urgent than in the pharmaceutical sector, where anticompetitive conduct harms not only prices but also access and innovation. Addressing these challenges requires revisiting the tools of antitrust law, including statutes that have fallen into disuse. The Robinson-Patman Act (RPA), designed precisely to combat these harms, could rebalance competition in the pharmaceutical supply chain, protect independent pharmacies, and lower costs for consumers.
Importantly, Congress has begun to show a renewed and bipartisan interest in strengthening antitrust enforcement. Lawmakers across the political spectrum have recognized that unchecked corporate concentration threatens not only economic fairness but the functioning of freemarkets themselves. This sentiment has forged a rather unlikely coalition of lawmakers uniting progressives like Senators Elizabeth Warren and Bernie Sanders with conservatives such as Senator Josh Hawley and Representative Ken Buck. [30] Within this context, revitalizing the Robinson-Patman Act is not about turning back the clock, but about adapting historic principles of fairness and competition to the realities of modern healthcare. If this bipartisan momentum can be matched with strategic implementation, it could mark a critical turning point—lowering drug costs and ensuring that healthcare markets serve the public rather than entrenched intermediaries.
Endnotes
[1] How Are Prescription Drug Prices Determined?" American Medical Association. Accessed April 27, 2025. https://www.ama-assn.org/delivering-care/public-health/how-are-prescription-drug-prices-determined.
[2] AWP vs. WAC: What's the Difference?, SmithRx (Oct. 25, 2022), https://www.smithrx.com/blog/awp-vs-wacwhats-the-difference.
[3] Lovisa Gustafsson & Shawn Bishop, What Pharmacy Benefit Managers Do — and How They Contribute to Drug Spending, Commonwealth Fund (Mar. 20, 2025), https://www.commonwealthfund.org/publications/explainer/2025/mar/what-pharmacy-benefit-managers-do-howthey-contribute-drug-spending.
[4] Lovisa Gustafsson, What Pharmacy Benefit Managers Do — and How They Contribute to Drug Spending, COMMONWEALTH FUND (Mar. 27, 2025), https://www.commonwealthfund.org/publications/explainer/2025/mar/what-pharmacy-benefit-managers-do-howthey-contribute-drug-spending.
[5] DIR Fees, Simply Explained, Pharmacy Times (Nov. 29, 2022), https://www.pharmacytimes.com/view/whitepaper-dir-fees-simply-explained.
[6] What Is a Copay?, Blue Cross and Blue Shield of Minnesota, https://www.bluecrossmn.com/understanding-healthinsurance/understanding-healthcare-costs/what-copay.
[7] Sherman Anti-Trust Act (1890), National Archives, https://www.archives.gov/milestone-documents/sherman-antitrust-act.
[8] Sherman Anti-Trust Act (1890), National Archives, https://www.archives.gov/milestone-documents/sherman-antitrust-act.
[9] Bona Law, Antitrust Standards of Review: The Per Se, Rule of Reason, and Quick Look Tests, Bona Law Insights (Mar. 27, 2018)
[10] 15 U.S.C. § 18 (2024), https://www.law.cornell.edu/uscode/text/15/18
[11] 15 U.S.C. § 45(a)(1) (2024).
[12] Antitrust Enforcement and the Agencies, Federal Trade Commission, https://www.ftc.gov/adviceguidance/competition-guidance/guide-antitrust-laws/enforcers.
[13] State Attorneys General Step Up Antitrust Enforcement, Morgan Lewis (Apr. 8, 2025), https://www.morganlewis.com/pubs/2025/04/state-attorneys-general-step-up-antitrust-enforcement.
[14] Lina Khan, Encyclopedia Britannica, https://www.britannica.com/biography/Lina-Khan
[15] Eve Tahmincioglu, Merck and Medco Agree to Merge in Deal Worth $6 Billion, UPI (July 28, 1993), https://www.upi.com/Archives/1993/07/28/Merck-and-Medco-agree-to-merge-in-deal-worth-6- billion/2181743832000/.
[16] David R. Olmos, Lilly Will Pay $4 Billion Cash for Drug Plan Manager PCS, L.A. Times (July 12, 1994), https://www.latimes.com/archives/la-xpm-1994-07-12-fi-14701-story.html.
[17] Peter Frost, Express Scripts Closes $29.1-Billion Purchase of Medco, L.A. Times (Apr. 3, 2012), https://www.latimes.com/business/la-xpm-2012-apr-03-la-fi-medco-20120403-story.html.
[18] Sneha Banerjee, UnitedHealth to Buy Pharmacy Benefit Firm Catamaran for $12.8 Billion, Reuters (Mar. 30, 2015), https://www.reuters.com/article/business/healthcare-pharmaceuticals/unitedhealth-to-buy-pharmacy-benefitfirm-catamaran-for-128-billion-idUSKBN0MQ0WR/.
[19] The Top Pharmacy Benefit Managers of 2023: Market Share and Trends for the Biggest Companies—And What’s Ahead, Drug Channels Institute (Apr. 2024), https://www.drugchannels.net/2024/04/the-top-pharmacy-benefitmanagers-of.html.
[20] CVS Health Completes Acquisition of Aetna, Marking Start of Transformative Health Care Experience, CVS Health (Dec. 2018), https://www.cvshealth.com/news/company-news/cvs-health-completes-acquisition-of-aetnamarking-start-of.html.
[21] Cigna Completes Combination with Express Scripts, Establishing a Blueprint to Transform the Health Care System, Cigna Newsroom (Dec. 20, 2018), https://newsroom.thecignagroup.com/Cigna-Completes-Combinationwith-Express-Scripts-Establishing-a-Blueprint-to-Transform-the-Health-Care-System.
[22] Our Businesses, UnitedHealth Group, https://www.unitedhealthgroup.com/uhg/businesses.html.
[23] Robert H. Bork, The Antitrust Paradox: A Policy at War with Itself (Basic Books 1978).
[24] Christine S. Wilson, Welfare Standards Underlying Antitrust Enforcement: What You Measure Is What You Get, Luncheon Keynote Address at the George Mason Law Review 22nd Annual Antitrust Symposium: Antitrust at the Crossroads? (Feb. 15, 2019), https://www.ftc.gov/system/files/documents/public_statements/1455663/welfare_standard_speech_-_cmr-wilson.pdf
[25] Sean M. Tepe, A Brief Overview of the New Brandeis School of Antitrust Law, Patterson Belknap Webb & Tyler LLP (Oct. 22, 2020), https://www.pbwt.com/antitrust-update-blog/a-brief-overview-of-the-new-brandeis-school-ofantitrust-law.
[26] Timothy Wu, Faculty Biography, Columbia Law School, https://www.law.columbia.edu/faculty/timothy-wu (last visited Apr. 27, 2025).
[27] Robinson-Patman Act § 2(a), 15 U.S.C. § 13(a) (2024)
[28] Prima Facie, Legal Information Institute, Cornell Law School, https://www.law.cornell.edu/wex/prima_facie
[29] Katy Milani and Stacy Mitchell, "The Case for Reviving the Robinson-Patman Act," Institute for Local SelfReliance, August 12, 2024, https://ilsr.org/articles/the-case-for-reviving-the-robinson-patman-act/.
[30] Cat Zakrzewski, MAGA Antitrust: These Republicans Want to Break Up Big Tech, Washington Post (Apr. 3, 2025), https://www.washingtonpost.com/politics/2025/04/03/maga-antitrust-republicans-big-tech-ferguson-lee/.