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uct services that are separately defined as mooring services rendered in

marinas and boat parks, boatyard field services markets, and field leas-

ing services markets.

The Geographical Market with regard to Mooring Services

Rendered in Marinas and Boat Parks:

Beta Marina, which is one of

the companies subject to transfer within the scope of the transaction, is

the operator of Istanbul City Port Marina in Istanbul; Göcek Village

Port Marina, and Göcek Exclusive Marina, all of which are located in

the Aegean region. The geographical market analysis with regard to

such marinas has been separately considered. For the Istanbul City

Port, the relevant geographical market has been defined as the “

dis-

tricts of Adalar, Ataşehir, Beşiktaş, Beyoğlu, Çekmeköy, Kadıköy,

Kağıthane, Kartal, Maltepe, Pendik, Sancaktepe, Sultanbeyli, Şişli,

Tuzla, Ümraniye and Üsküdar,

” and for Göcek Village Port Marina and

Göcek Exclusive Marina, it has been defined as the “

Aegean and

Mediterranean Sea coastal line.

” However, a specific determination of

the relevant geographical market was found to be unnecessary since a

narrow determination would not substantially change the evaluation of

concentration.

The Geographical Market with regard to Boatyard Field

Services:

For Istanbul City Port Marina, the relevant geographical mar-

ket has been determined as “

the cities bordering the Marmara Sea.

On the other hand, since the assessment would not be affected by dif-

ferent determinations of the relevant geographical market, a specific

determination of the relevant geographical market was deemed unnec-

essary for these marines in terms of the boatyard field services.

The Geographical Market with regard to Field Leasing Services:

Although the definition of the relevant geographical market has been

considered as “

Turkey,

” a specific determination of the relevant geo-

graphical market was deemed unnecessary since even a narrow city-

based or side-based determination for Istanbul would not affect the

concentration evaluation.

Evaluation of Concentration

The Board has severally addressed the evaluation of concentration,

separately, in terms of the relevant product market:

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NEWSLETTER 2015