INTERNATIONAL AND NATIONAL LEGAL MODELS FOR COMBATING UNFAIR COMPETITION: A COMPARATIVE ANALYSIS

This article analyzes the problem of unfair competition within the framework of both international and national legal systems. Using the examples of the USA, Germany, France, Japan, Canada, and others, the author explores legal mechanisms, legislative approaches, and practical differences in combating unfair competition. The article compares broad and narrow interpretations of the concept and classifies countries into three legal groups based on their regulatory approach. It also addresses the legal uncertainty surrounding unfair competition, forms of liability, and the need for legal adaptation in the context of the digital economy. The findings emphasize the importance of integrating international best practices into national antitrust policy frameworks.