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NAL - I'm failing to see how telling your employees not to do things that violate or give the impression of anti-trust law is a smoking gun.

That seems like a no-brainer thing a company should be doing.

the problem is when it becomes more instruction on "if you do X, make sure you don't say suspicious words so nobody notices we are doing X"

"...so that when we get sued and in discovery they ask for all documents discussing markets, nothing will come up."