De Gaulle Fleurance advises Cegedim Santé in proceedings before the French Competition Authority against Doctolib

De Gaulle Fleurance represented Cegedim Santé in proceedings before the Autorité de la concurrence brought against Doctolib. De Gaulle Fleurance acted for Cegedim Santé in the referral to the Autorité de la concurrence and in the subsequent procedure conducted against Doctolib. After a five-year investigation, the Autorité announced on 6 November 2025 a sanction of €4,665,000 against Doctolib for abusing a dominant position on two distinct markets: (1) online medical appointment booking (the Doctolib Patient service on the Doctolib platform) and (2) technological solutions dedicated to medical teleconsultations (the Doctolib Téléconsultation service). The Authority upheld two main allegations against Doctolib. First, it found that Doctolib imposed exclusivity on its professional health subscribers through contractual clauses and conditioned access to Doctolib Téléconsultation on prior subscription to the Doctolib Patient appointment-booking service (a tying practice). Second, it found that Doctolib’s acquisition of MonDocteur, then its principal competitor, served to lock the national market for online appointment-booking services and to consolidate its dominant position in an emerging market. While the Authority’s fine may not, in the firm’s view, fully reflect the extent of harm caused to the economy by the elimination of competition across two rapidly developing digital markets, the decision is nonetheless significant. It demonstrates the Autorité’s consideration of the characteristics of digital and platform markets. It also represents the first application in France of the Court of Justice of the European Union’s Towercast judgment (2023), confirming the earlier Continental Can decision (CJCE, 1973), by which a national competition authority may sanction an anticompetitive acquisition that falls below merger-control thresholds when that acquisition constitutes an abuse of a dominant position. Doctolib has announced its intention to appeal the decision. The Autorité will publish the full decision in the coming weeks; the Authority’s communiqué is already notably detailed. De Gaulle Fleurance represented Cegedim Santé with a team composed by: Thierry Titone (partner), Caroline Ruiz-Palmer (senior manager, lawyer) and Louisa Imatte (lawyer).

De Gaulle Fleurance advises Cegedim Santé in proceedings before the French Competition Authority against Doctolib

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