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CRA advises Cegedim Santé in French Competition Authority decision on Doctolib

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On 6 November 2025, the French Competition Authority (ADLC) issued a landmark decision on digital platforms against Doctolib for abusing its dominant position on the markets for online medical appointment booking services and remote medical consultation solutions and for “a killer acquisition” (below the threshold) of its main competitor MonDocteur. According to the Decision, Doctolib required subscribers to use its own services using exclusivity clauses and tied sales and eliminated its main competitor MonDocteur by acquiring it in 2018. Notably, this Decision is the first application of Article 102 TFEU to sanction ex post a merger falling below national notification thresholds.

A CRA team including Laurent Flochel and Romain Bizet assisted the lead complainant Cegedim Santé during the proceedings. The team conducted some analysis on the definition of the relevant markets, the qualification of Doctolib’s dominant position and provided some economic analysis of the tying and exclusivity practices and their exclusionary effects.

The press release of the French Competition Authority is here ADLC’s website.