What I Found in a Federal Antitrust Court Case That Every Author Should Know

I recently attended a talk by Leila Sales, an author and professional editor, on the process of finding a literary agent. My main takeaway was that finding an agent is hard, getting a book published is harder, and making significant money doing all this is nearly impossible.

Although I don’t have much interest in being “an author,” I am interested in how money flows through the economy. I started with the question: how much money do people spend on books, and what portion of that flows to authors?

What I found surprised me: there’s plenty of money here, and it’s not Amazon taking most of it. It’s the publishers.

Americans Are Spending a Large and Growing Amount on Books

Despite the rise of smartphones and social media, Americans are still spending a healthy and growing amount of money on books.

U.S. residents spent $42 billion on books in 2025, split between $33 billion on recreational books and $9 billion on educational books.[1] [2] Moreover, recreational book sales have been growing at 4.7% annually since 2012. Here is the trend:

Two things stand out to me from the data.

First, the collapse in recreational book sales going into 2012 (the rise of smartphones) and subsequent recovery tells me the “people don’t read” narrative is overblown. People loved smartphones when they first came out and now a lot of people are going back to traditional books.

Second, the real (inflation-adjusted) growth of U.S. recreational book sales has been 1.3% over 2007-2025.[3] This means inflation in recreational book prices has been negative over the last 18 years (they are getting cheaper relative to other goods and services). One way to interpret this trend is that consumers expect “more book” for “less money.”

Retailers Take a 30-40% Cut

Before any of the $33 billion that consumers spend gets to authors or publishers, retailers take their cut. I think retailers take about 30-40%, triangulating from different sources:

• Barnes & Noble’s final public financial statements from 2019 (before their acquisition by a private equity firm) show a gross margin of about 30%, including real estate costs.[4] Backing out ~10% for real estate, my standard assumption for large-store retail, we get to a retailer margin on books of about 40%.
• The Association of American Publishers reported consumer book revenue to publishers of $21.2 billion in 2024,[5] which we can compare to the BEA’s total 2024 personal consumption of recreational books of $31.1 billion. I’m assuming the $9.9 billion gap goes to retailers. These figures imply a retail margin of ~32%, although this calculation is inexact since these are not apples-to-apples comparisons.
• Finally, various Internet forum discussions about Amazon’s Kindle Direct Publishing (KDP) program suggest that Amazon takes about 40% of the sale price. Amazon’s category margins are not visible from its public financial statements.

Publishers Take Most of the Rest, and Leave Little to Authors

During my research on the publishing industry, I came across a fascinating court case.

In 2022, the publishing firms Penguin Random House (PRH) and Simon & Schuster (S&S) attempted to merge. The United States Department of Justice challenged the merger on antitrust grounds, arguing that the merger would create a near-monopoly player in the industry, further depressing already-poor economic opportunities for authors.

In the resulting court case, United States v. Bertelsmann SE & Co. KGaA, the District Court judge ruled in favor of the government and the merger was blocked. Moreover, the trial judge’s opinion—which contains extensive direct testimony from PRH and S&S executives, taken under oath, in the public record—is a gold mine of information regarding how the publishing industry truly operates and how it negotiates with authors.

Here are my takeaways from Bertelsmann:

A.    The Publishing Industry is an Oligopoly

The U.S. publishing industry is effectively an oligopoly.[6]

The oligopoly is dominated by the “Big Five” publishing houses—PRH, HarperCollins (HC), S&S, Macmillan, and Hachette. These publishers collectively have about 60% market share for the sale of “trade” (consumer) books,[7] and the top 8 publishers (out of 2,191 total book publishing firms as measured by the U.S. Census) account for 52.6% of the total industry revenue (this figure includes non-consumer books).[8]

Moreover, the Big Five control 91% of the market for so-called “lead titles,” [9] which are basically the books that publishers think will sell well. Any market where 91% of the relevant deal flow goes to 5 entities is clearly an oligopoly. Now imagine a seed-stage fundraising market where 5 venture capital firms controlled 91% of the deal flow. Do you think founders would get good or bad terms?

The Big Five’s power also appears to be entrenched. The publishing industry has seen a trend towards consolidation since the mid-1970s, which has led to the dominance of the Big Five.[10] Moreover, no new firm has been able to enter the market in the past thirty years and take significant market share from the Big Five, including deep-pocketed companies like Amazon and Disney.[11]

Individual editorial groups within publishers, called “imprints,”[12] do not introduce significant competitive pressure in the view of the Bertelsmann trial judge. Although imprints are somewhat independent in their decision-making process, and occasionally bid against each other for books, they usually present a unified bid for any high value title.[13]

B.    A Small Number of Winners Drive Most Publisher Profits

Book publishing is a tournament industry, where most players are losers and gains are concentrated among a few winners. From Bertelsmann:[14]

• Only 35% of books are profitable at all
• The top 4% of profitable titles generate 60% of publisher profitability

The lopsided nature of book profitability—where a few breakout winners carry a long tail of losers—drives publishers to think of their catalogue of books as a portfolio, much like an angel investor would.[15] The big winners in the portfolio provide the cash flow that allows the publisher to take risks on new and unproven authors.

Publishers’ annual revenue comes from two sources: a “front list” and a “back list.” The front list consists of new books published in the current year, most of which do not earn out their production cost. The back list—books that were originally published in prior years and continue to sell—is highly profitable.

The Big Five have large back lists, which provide stable, recurring annual cash flow. We will return to the implications for authors shortly.

C.   How Authors Are Paid

Publishers pay authors in two ways: royalties and advances (which are just part of the royalties paid up-front). Of the two, the advance is the bigger factor for most authors, since most books will not earn enough in royalties to pay back the advance.[16]

These days, the advance is typically structured as a series of four payments based on milestones reached during the writing period (signing, first draft, publication, 12 months after publication.) It can take 3-4 years for the entire advance amount to be paid out.[17] Any royalty payments earned by the author after the book launches first go to repay the advance. After the advance is “earned-out,” subsequent royalties go to the author.

Industry-standard royalties (which can be negotiated by famous authors, but not by normal authors) vary by the format of the book:[18]

Book Format	Industry Standard Royalty Rate
Paperback	7.5%
Hardcover (first 5,000 sold)	10%
Hardcover (5,000-10,000 sold)	12.5%
Hardcover (10,000+ sold)	15%
e-books, audiobooks, and other digital	25%

We will return to the implications of these royalty rates below.

In terms of the sales process, authors are represented by literary agents, who typically take 15% of all advances and royalties as their commission.[19] Agents have an affirmative fiduciary duty to get the best deal possible for their clients,[20] and leverage their knowledge of and relationships with publishing houses to try to get the book sold. Sometimes, agents negotiate directly with a single publisher to place the book, and at other times, agents will organize a competitive bidding process among several interested publishers. In general, agents attempt to maximize the amount of the advance, since that is the only payment most authors will ever see.

When deciding how much to bid for a book, publishers begin by building an internal model containing a sales forecast, expected costs (including printing, distribution, and marketing), and author advances and royalties. In projecting sales, they will rely on “comparables” (very similar to how we might value a stock) from authors in the same genre, with similar public stature, or prior books from the same author. Publishers’ estimates of sales tend to be reliable.[21]

Publishers and imprints do consider non-modeled factors as well, such as the editorial team’s excitement about the book, and are even influenced by FOMO. From the trial judge’s opinion in Bertelsmann:

It is not uncommon for editors and publishers to experience a “kind of auction fever,” in which they change their sales expectations for a book and increase what they are willing to pay for it during a competitive round-robin auction. Id. at 180:20–181:11 (Pietsch). “[T]he interest of other parties validates [a publisher's] own sense of what a book is worth.” Id. The record contains numerous examples of *17 books that sold for unexpectedly high advances and achieved other favorable terms for their authors due to the bidding frenzy incited by competitive auctions. For instance, in a hybrid auction of rounds followed by best bids, [Redacted], initially received bids of between $150,000 and $400,000 from four publishers. See PX 944-B (Porro bidding summary); Trial Tr. at 923:16–930:18 (Tart) (discussing book's acquisition); PX 320 (emails). After six rounds of bidding, PRH's Viking imprint more than doubled its initial bid and won the book for $775,000 “over stiff competition.” PX 39 (email from Tart); see also PX 944-B (Porro bidding summary); Trial Tr. at 923:16–930:18 (Tart). At the best-bids stage, Viking decided to “stretch” from its initial bid clearance of $700,000 because “there just is literally no telling what the opponents hold in their hands.” PX 326 at 1 (emails between Tart and Viking editor Wendy Wolf).[22]

A competitive bidding process tends to produce good outcomes for authors, and is one of the few avenues authors still have to increase their earnings when dealing with Big Five publishers. Most other avenues have been taken away due to lack of competition, as we will see below.

D.   Publishers Collude to Suppress Author Earnings

In Bertelsmann, the trial judge found many examples of industry collusion,[23] which would be disturbing to me if I were an author:

• Standardized terms (publishers do not negotiate) on audio rights and e-book royalties
• Publishers uniformly moving e-book royalties from 50% to 25%
• Publishers uniformly moving advances to 4-part delayed payments

All of these are present value reductions in what an author gets paid for their book.

The following passages from the trial judge’s opinion are damning:

When selling the publishing rights to [Redacted] highly sought-after book, her agent attempted to hold an auction that excluded audio rights. S & S wanted the book but refused to bid because “[t]he only way to prevent agents from breaking off audio rights like this is to hold firm to our policy of no deals without audio rights.” PX 652 at 2. An S & S editor ruminated, “It will be very interesting to see whether PRH, Hachette, Harper or Macmillan participate. M[y] understanding is that they too have the ‘no audio, no deal’ rule.” Id. The agent was forced to restart the auction with audio rights included, see PX 568 at 3, presumably because the book received insufficient offers or only received offers that included audio. See PX 320 at 1 (in the first round, PRH bid for bundled audio rights in violation of the auction's initial rules). In the renewed auction that included audio rights, the bidding was fervid and reflected vigorous competition.

Audio rights are now always included in book contracts and may not be sold separately. See id. at 257:14–258:6 (Pande), 622:17–25 (Karp); PX 328 (internal PRH email) at 1–2 (“We have to get those [audio] rights.”). [emphasis mine]

This is collusive behavior that is documented, on the record, in the trial opinion of a United States Federal District Court judge. It may not rise to the level of being illegal under antitrust law. But it is collusion. When you as an author are facing “non-negotiable” terms from a Big Five publisher, this is where they are coming from.

E.    Publishers Have a Two-Tier Class System for Authors

Publishers do not see all authors/books as equal. The industry effectively has a two-track system, with some books viewed as “lead titles” or “priority titles,” and everything else. While there is likely no agreed-on industry cutoff for what counts as a lead title, the government’s antitrust lawyers in Bertelsmann define lead title as a book that earns an advance of $250,000 or more.

Lead titles (by the $250,000 cutoff) comprise 2% of all book acquisitions and represent 70% of all advance payments ($1 billion in total).[24] This implies the remaining 98% of books share the remaining 30% of advance payments (about ~$400 million) amongst themselves.

The Big Five acquire 91% of lead titles, described in the chart as “anticipated top sellers”:[25]

Authors of lead titles get significantly better treatment from publishers. See: [26]

from the perspective of editors and publishers, not all books are created equal. Beyond advances, contracts for books that are expected to sell well are more likely to include favorable terms like higher royalty rates, higher levels of marketing support, “glam” packages (e.g., for hair, makeup, and wardrobe services), and airfare for authors.19 See Trial Tr. at 988:2–8 (Dohle)

Books with high advances get significantly more marketing support from publishers. Lead titles get $40,000-90,000 worth of dedicated marketing budgets, while non-lead titles get less than $10,000. In one imprint at PRH, books with an advance of $150,000 or greater get a dedicated publicist, 5-15 book tour stops, and a national media campaign. Books with lower advances get only a contact in the publicity department and little if any of the other support.[27]

The following chart[28] shows average publisher marketing spend (y-axis) by amount of advance (x-axis):

The natural question for a new author is, “which tier am I in?” Unfortunately, unless you are a celebrity or have an established social media presence, the answer is probably that you are in the bottom tier. This means that much of the publisher’s value proposition, in terms of marketing, publicity, and media relationships, does not apply to you. You get a below-minimum-wage advance and the email address of somebody in the publicity department.

F.     The Publisher Value Proposition

Publishers handle a range of tasks relating to the production and distribution of books. These tasks include:

• Editing
• Book cover design (bigger publishers may design a dozen different covers and help the author select the one that will catch the most audience attention)
• Printing (usually subcontracted to a third party printer)
• Marketing
• Distribution

The opinion in Bertelsmann focuses on the Big Five publishers’ marketing ability, noting that “when a publisher really gets behind a book, particularly a big publisher, the chances are that that book is going to probably succeed on some level.”[29]

Although all publishers focus on getting physical books into stores, the larger publishing houses have a wider network of relationships. Big Five publishers “have teams dedicated solely to selling, marketing, and publicizing books, which have built critical relationships with booksellers and the media,” “can secure author interviews on prominent programs like the Today Show, Good Morning America, or NPR,” and even “[hire] data scientists to study Amazon's search algorithms and [spend] money to get books better positioned in Amazon's search results.”[30]

When I look at this set of publisher activities, the one that seems the most difficult to replicate as a small publisher or a self-published author is the network of relationships with hundreds of independent bookstores. Bookstores value their relationships with publishers, as they serve a risk mitigation function. Publishers generally offer a full-price return option (minus shipping costs) to booksellers for books they can’t sell.[31] In finance terms, this is effectively a free put option being given to the bookseller.

Is this a good deal for authors? I think it can be, but the price is steep. In exchange for permanent ownership of your intellectual property and 75% of all digital and audio sales in perpetuity, a Big Five publisher will get your physical book into stores and give it exactly one marketing push. I don’t know how you feel about that. But it makes me angry.

The Finance Case Against a Standard Publishing Deal

As a former bond trader and fixed income portfolio manager, I use finance analogies to understand much of the world. When I put my investor hat on, there is a great deal of this book writing game that does not make sense to me.

A.    You Are a Compounding Asset

Media intellectual property does not exist in a vacuum. Today, it is usually attached to the personal brand of a person.

A song may or not be good on its own merits, but it is going to be more valuable to the marketplace if Taylor Swift wrote it. A new book might or might not be good, but a lot of people will buy it if they find out Stephen King wrote it.

Artistic creators of any kind—authors, musicians, actors, whatever—increase the power of their personal brand over time. Each additional piece of content produced by a person boosts their personal brand, and as the creator’s personal brand improves, it increases the value of all previous works by the same person, regardless of the initial quality of those prior works.

From a finance perspective, this works much like compound interest. Anyone familiar with finance will know that compound interest is among the most powerful forces in the universe. The value of your first book compounds with the value of every subsequent book you write.

When a publisher buys a book from an author, arguably they are paying the current fair market price[32] for that book. But the fair market price the publisher offers doesn’t account for how the value of the current book will increase in the future based on the author producing additional good books.

Not only that, but every additional piece of non-book content or media appearance the author produces—a newsletter article, being a guest on a podcast, a YouTube video, a tweet, a LinkedIn post—also raises the author’s brand and therefore the value of the book that has already been sold to the publisher. Yes, the publisher may spend $50,000 marketing the book, but they’re only doing that once. You are doing it every day. And the publisher gets ~90% of the proceeds of every book YOU sell when the podcast host who is interviewing you puts your book purchase link in the show notes.

You should not lock in a low value for your intellectual property by selling a book to a publisher at a bargain basement price, when you are going to be the one marketing it over the rest of your life.

B.    Audio and Digital Rights Are Worth More Than Publishers Let On

Digital and audio rights produce significant revenue for publishers. HarperCollins, a Big Five publisher owned by the publicly traded company News Corp., reported in its audited financial statements that about 24% of its global revenue came from e-books and audiobooks.[33]

Perhaps a 90%/10% revenue split in favor of the publisher makes sense for a physical book, when they are doing the kludgy work of getting the books printed, delivering them to a bookseller, dealing with returns, etc. However, the logic of a publisher-favored revenue split (75%/25%) makes no sense when applied to audio and digital rights.

Digital media has a zero marginal cost of replication. After the work is created, every additional copy that is sold is pure profit.

Remember, the publisher is doing a one-time marketing push for your book. After that, you are doing all the work to drive further sales. And for every digital or audio sale post-release, that you did the work to drive, the publisher is keeping 75% of the revenue. For doing zero work.

Let’s do the math. Let’s say a customer buys a $10 e-book after listening to a podcast episode where you were a guest (which you booked yourself, three years after your book came out). Amazon takes a 40% cut off the top, so $4. $6 left. Then the publisher takes 75%, so $4.50. That leaves you with $1.50. Exactly what work did the publisher do to justify their $4.50 of this process?

Now it should be clear why a private equity firm bought Simon & Schuster. It should also be clear why, in the Bertelsmann trial testimony, a publishing industry executive said “We have to get those [audio] rights.”

C.   A $250,000 Advance Is Not Really $250,000

An advance of $250,000 paid over three years is not the same as an advance of $250,000 paid immediately. A four-payment cash flow stream (with the first payment at period zero) needs to be discounted to its present value.

I would use a discount rate based on the weighted-average cost of capital of the publishing or media industry (currently 5.95%[34]), since the author faces the publisher as a counterparty (and therefore the payment should be discounted by the publisher’s cost of capital). By this logic, a “$250,000” advance is worth only $229,717.91 in present value terms.

D.   Put Bidders in Competition

I used to run a €30 billion fixed income portfolio with hundreds of securities. We never bought or sold bonds without evaluating bids and offers from more than one dealer. Not soliciting multiple bids/offers would have been grounds for firing me.

It is baffling to me that agents shop many books in 1-1 negotiations with publishing houses, as opposed to sourcing multiple bids. The only reason publishers would offer big advances in direct negotiations is if they think it would be cheaper than letting the book go to auction. This is leaving money on the table. Don’t do this, since you get so little of it to begin with.

When Does a Traditional Publishing Deal Make Sense?

Despite reading through Bertelsmann and understanding the oligopolistic rent extraction present in the publishing industry, I am not categorically against it in all situations. Just like any investment can make sense at the right price and for the right portfolio, traditional publishing makes sense for some people, and not for others.

A.    You Should Consider Self-Publishing or Indie Publishers If…

Industry executives consider self-publishing a nonfactor.[35] I disagree. Brandon Sanderson famously raised $15 million via Kickstarter to self-publish a book, while Alex Hormozi self-published a book that did $100 million of sales in three days.

What these two cases have in common are authors who 1) have established audiences and 2) are able to source and manage a team.

Even if these things are only partially true for you, you should think carefully about whether paying the publisher’s very high price (75% of digital royalties and 90% of print royalties) is worth the marketing platform you are getting from a Big Five publisher. You may be able to find good editors at small publishers or via referrals, and if you are regularly producing content online, you will be able to build an audience over time.

What you can’t do independently is replicate publisher relationships with independent booksellers. But if a significant portion of physical books are being sold through Amazon, you can manage that part yourself.

I guess one other thing I can’t do is get myself booked on legacy media like the Today Show or Good Morning America. But does anyone even watch these shows anymore?

B.    You Should Consider Going with a Big Five Publisher If…

The counterpoints to Sanderson and Hormozi are Tim Ferriss and James Clear, who were nobodies until their breakout book hits propelled them to superstardom.

If you have no following or audience of your own, then it might make sense to rely on a publishing house to help you create one. Or, if you are unable or unwilling to do the process management necessary to get a book designed, edited, printed and distributed, then it might be worthwhile sacrificing a huge amount of margin to a publisher to get them to do that for you.

But I doubt Ferriss or Clear would take a traditional deal from a publisher today. Ferriss buys the audio rights to other people’s books when he can. And Clear supposedly sells a copy of Atomic Habits every 15 seconds, through his newsletter, the podcasts he goes on, etc. PRH is taking 75-90% of the revenue from those sales. James Clear is not an idiot—he can see this. That’s why he started his own publishing company.

You Do Not Need Any of This to Write

This whole rigmarole of getting an agent and publisher and all that just sounds like gatekeeping to me.

I hate gatekeeping. Thankfully, we are living in a golden age of human communication where everyone has access to a medium—the Internet—that allows them to talk to any person they want and produce just about any kind of content they want.

I was interested in the intersection of emotions and finance, so I wrote ~80 blog posts and about 100,000 words about it. That’s basically a book. But I didn’t need anyone’s permission. I just created a website and started posting.

So ask yourself, why are you writing?

Do you need the money? Understand that a first-time author with no audience is getting an advance of about $35,000 for three years of work. Is there really nothing you can do that provides a higher return on investment?

Do you care about the prestige of being a published author? I get it. I used to care about the prestige of working at McKinsey or going to Harvard. But then I realized, as I tell my students all the time, that you can’t eat prestige.

Do you feel the need to get your thoughts and ideas in front of people? That’s me. But I don’t need an intermediary for that. I get to communicate with my audience directly, with immediate feedback and no gatekeeping. I love this. I can write a blog post, see a consistent ~62% open rate over time, and know that people like my stuff. And people can respond to me directly and tell me what they liked and didn’t like. I don’t have to wait 3 years to put out a “book” just to watch it flop in the market.

If you are an author and you feel apprehension at going up against, or being dependent on, the publishing industry I get it. When I feel this emotion, I go back to Steve Martin’s old advice on success in any creative field: “Be so good they can’t ignore you.” Even though you might not be there yet on creative confidence, at least now you have the truth about the economic incentives in this business and you are no longer flying blind.

Then you can decide what you want to do. For me, if I enter the game, I want to sell. If I just want to write what I want to write, I’ll do that and put it on my blog for free.

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[1] U.S. Bureau of Economic Analysis, "Table 2.4.5U. Personal Consumption Expenditures by Type of Product" (accessed Thursday, April 30, 2026)

[2] Educational books refers to textbooks and course materials purchased directly by students and households. Textbooks purchased directly by school districts should show up in government spending, not in the personal consumption expenditures data.

[3] U.S. Bureau of Economic Analysis, "Table 2.4.6U. Real Personal Consumption Expenditures by Type of Product, Chained Dollars" (accessed Thursday, April 30, 2026), author’s analysis

[4] Barnes & Noble Form 10-K Exhibit 13.1, fiscal year ending April 27, 2019, accessed via EDGAR 

[5] Association of American Publishers, “AAP StatShot Annual Report:  Publishing Revenues Totaled $32.5 Billion for Calendar Year 2024” (accessed Friday, May 1, 2026)

[6] An oligopoly allows a small group of powerful firms to coordinate terms that would otherwise be competed away, leaving suppliers—in this case authors—with less compensation and fewer options than a competitive market would produce.

[7] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 3.

[8] U.S. Census Bureau, “2022 Economic Census,” NAICS code 51313.

[9] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), Exhibit 963.

[10] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 4.

[11] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 72-74.

[12] For reference, Penguin RandomHouse, the largest book publisher in the U.S., operates about 100 individual imprints, including familiar names like Bantam, Ballantine Books, and Random House. Simon & Schuster operates about 50.

[13] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 5, p. 14-15.

[14] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 5-6.

[15] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 5-6.

[16] It appears that 5-50% of books will earn out their advance, depending on the publisher. United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 14.

[17] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 13-14, 45-46.

[18] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 15.

[19] According to industry contacts, agents take possession of advance and royalty payments and then pass the author’s share on to the author. This strikes me as very strange. As a buyside investor, I cannot imagine allowing a broker to take possession of cash, collateral or securities at any point during a trade. From a counterparty risk perspective, I would much rather have my payments sent to me directly from a publishing house rather than a lone agent acting as an escrow account.

[20] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 14.

[21] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 16.

[22] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 16-17.

[23] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 46-47.

[24] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 25-26.

[25] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), Exhibit 963.

[26] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 30-31.

[27] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 30-31.

[28] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), Exhibit 972.

[29] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 20.

[30] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 19-21.

[31] National Public Radio, “BOOKstore Economics,” Planet Money podcast

[32] It actually isn’t the fair market price, since buyer oligopolies suppress market prices for sellers.

[33] News Corp. Form 10-K, fiscal year ending June 30, 2025, accessed via EDGAR 

[34] Aswanth Damodaran, “Cost of Equity and Capital (US)” (accessed Thursday, May 7, 2026)

[35] United States v. Bertelsmann, 646 F.Supp.3d 1 (D.D.C. 2022), p. 14-16.