On November 2, the trade association ComicsPRO wrote to the U.S. Department of Justice to join in the American Booksellers Association's request that the department investigate practices by Amazon.com, Wal-Mart, and Target that "may constitute illegal predatory pricing."
ComicsPRO represents the interests of direct-market comic book retailers, and its letter was signed by its nine-member Board of Directors.
The letter notes that the organization supports ABA's position that "the practices of Amazon.com, Walmart.com, and Target.com to offer bestselling hardcover books for sale at prices well below the wholesale cost renders independent booksellers unable to compete and devalues the books in the eyes of consumers." It further notes that the association believes that the practice affects the comic book industry "as substantially as it affects the traditional book trade, and extends to the sale of graphic novels."
Focusing on graphic novels, the ComicsPRO letter states that "we believe that Amazon.com, Wal-Mart, and Target are using these pricing strategies to gain control not only of the market for hardcover bestsellers, but to also gain control of the market for newly released hardcover graphic novels." Noting that the association believes the mass retailers are using these discounted titles simply as loss leaders, the ComicsPRO Board writes, "Pricing these products below cost does not encourage new readership, it simply devalues the concept of purchasing books to read and is not sustainable as an independent revenue model. If the practice of predatory pricing continues indefinitely, thousands of independent comic retailers are at risk of losing their livelihoods since they are unable to compete."
The letter closes with a call for the DOJ to "undertake to investigate these pricing practices immediately" and states that ComicsPRO will "provide any information necessary with respect to this issue as it affects the comic book industry."
ComicsPRO's website notes that the association is dedicated to promoting graphic literature to readers around the world by fostering a healthy distribution channel, engaging the publishing industry, and encouraging creative talent. --Dan Cullen