The DOJ-FTC International Guidelines describe how the Agencies consider international comity and the factors considered. The International Guidelines state, “In determining whether to investigate or bring an action, or to seek particular remedies in a given case, the [DOJ and FTC] take into account whether significant interests of any foreign sovereign would be affected.” Factors considered include: the existence of a purpose to affect or an actual effect on U.S. commerce; the significance and foreseeability of the effects of the anticompetitive conduct on the United States; the degree of conflict with a foreign jurisdiction’s law or articulated policy; the extent to which the enforcement activities of another jurisdiction, including remedies resulting from those enforcement activities, may be affected; and the effectiveness of foreign enforcement as compared to U.S. enforcement.   See International Guidelines, https://www.justice.gov/atr/internationalguidelines/download, at p. 27-28.