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27. Antitrust / Competition Law

06/23/23

27.1. Introduction

The Brazilian Federal Constitution, in its art. 1, elevates the social values of work and free enterprise as foundations of the Brazilian Federative Republic. On its turn, art. 170 provides for the Free Competition, which is the subject matter of this Chapter.

Free Competition is a constitutional principle that fights “the abuse of economic power aimed at market domination, elimination of competition, and arbitrary increase in profits”. Therefore, it is the duty of the State to ensure the prevention/repression of abusive practices carried out by market players with a dominant position, when they bring harmful effects to free competition.

In this sense, the antitrust system is dedicated to combating practices that are harmful to competition, particularly according to four main aspects:

  1. antitrust conspiracies, which aim at restraining competition;
  2. abuse of dominant position, actions of a monopolizing company or with sufficient market power to affect competition;
  3. mergers, corporate transactions such as mergers and acquisitions that may affect competition and, therefore, consumers well-being; and
  4. government initiatives limiting competition and government actions restricting or distorting competition.

Law No. 4,137/1962 – the first Brazilian Antitrust Law – was strongly influenced by US rules and was in force for almost thirty (30) years. However, application thereof was somewhat scarce because the institutional structure that it created was practically inoperative.

Subsequently, Law No. 8,158/1991 was enacted and was in force for a short period, until the publication of Law No. 8,884/1994, which gave the Administrative Council for Economic Defense (“CADE” – the acronym in Portuguese), the Brazilian Antitrust Agency, a new structure, transforming it into a federal independent government agency linked to the Ministry of Justice, with legal personality and adjudicating function. It gave CADE greater autonomy and credibility if compared to the previous law. In addition, Law No. 8,884/1994 also consolidated antitrust protection as one of the pillars of the Brazilian economy.

However, given some inefficiencies associated with the existence of overlapping agencies, as well as discussions about the requirements for reporting transactions, among others, it urged the discussion of amendments to the law, resulting in its complete overhaul.

Finally, in May 2012, Law No. 12,529/2011, the current Brazilian Antitrust Law, was enacted, establishing a new structure for the Brazilian Antitrust System, enabling more effective action by CADE and introducing the prior control system for transactions. Upon enactment of the new Law, the antitrust policy in Brazil changed significantly.

In addition to structuring the Brazilian Antitrust System – SBDC, said law also provides for the “prevention and repression of antitrust violations, guided by the constitutional dictates of freedom of initiative, free competition, social function of property, consumer defense, and repression of the abuse of economic power”, as established in its art. 1.

As per the sole paragraph of the same article, the “collectivity is the holder of the legal assets protected by this Law”.

27.2 BRAZILIAN ANTITRUST SYSTEM

Law No. 12,529/2011 structures the so-called Brazilian Antitrust System (“SBDC” – the acronym in Portuguese), formed by (i) the Administrative Council for Economic Defense (“CADE”) and the current (ii) Office for the Promotion of Productivity and Antitrust Advocacy, linked to the Ministry of Finance, which succeeded the former Economic Monitoring Office (“SEAE”), each with different functions, as further detailed below.

27.2.1. Administrative Council for Economic Defense

CADE was created with Law No. 4,137/1962, according to its art. 8. Back then, it was a huge antitrust advance in Brazil, since it allowed access to a highly technical administrative body in the field of Antitrust Law, thanks to its specialization.

The Antitrust Law, moreover, rules both the prevention and the repression of antitrust violations, so that CADE acts on two main fronts: one of a preventive nature, focused on the control and approval of mergers and acquisitions; and another of a repressive nature, through the repression of violations to the economic order.

However, CADE also has a third function: the “educational function”, the purpose of which is to disseminate the antitrust culture, also called advocacy.

CADE is the main body responsible for the protection of free competition in Brazil, with authority for fact-finding in administrative cases related to antitrust violations, as well as for the analysis of mergers and acquisitions (such authority belonged to the former SDE – Economic Law Office and SEAE – Economic Monitoring Office, under the aegis of Law No. 8,884/1994).

Currently, CADE is formed by the following bodies, pursuant to art. 5 of said Law: (i) Administrative Tribunal for Economic Defense; (ii) General Superintendence; and (iii) Department of Economic Studies.

27.2.1.1. Administrative Tribunal for Economic Defense

CADE’s Tribunal is the collegial body and highest authority, being an adjudicating body, pursuant to the provisions of art. 6 of the Antitrust Law, composed of one (1) President and six (6) Commissioners, with a term of office of 4 years, appointed by the President of Brazil, after approval by the Federal Senate, reappointment being prohibited.

In summary, CADE’s Tribunal is responsible, among others, for deciding on the following:

  • decide on the existence of an antitrust violation and impose the penalties established by the law;
  • decide administrative proceedings related to conduct control, for the imposition of administrative sanctions;
  • consider appeals against preventive measures adopted by the Rapporteur or by the Superintendent General;
  • analyze cease-and-desist agreements and merger control agreements.

27.2.1.2. General Superintendence

The General Superintendence, in turn, is composed of a Superintendent General, with a two-year term of office, which may be renewed only once, and by two Assistant Superintendents. The Superintendent General is appointed by the President of Brazil, after approval by the Federal Senate, while the Assistant Superintendents are appointed by the Superintendent General.

The role of the General Superintendence is to investigate and produce evidence, having the following main duties: (i) institution, fact-finding, and issuance of opinions in proceedings to investigate antitrust violations; (ii) fact-finding and issuance of opinions in mergers and acquisitions; and (iii) proposing agreements and preventive measures.

27.2.1.3. Department of Economic Studies

The Department of Economic Studies (“Dee” – the acronym in Portuguese) is headed by a Chief Economist, who is jointly appointed by the Superintendent General and the President of CADE’s Tribunal, having as main duties (i) advising CADE mainly on economic matters, preparing studies and/or opinions on economic matters, on its own initiative or at the request of CADE’s Tribunal or the General Superintendence, dealing with mergers and antitrust violations; and (ii) preparing studies to ensure CADE’s technical and scientific updating.

27.2.2. Office for the Promotion of Productivity and Antitrust Advocacy

The Office for the Promotion of Productivity and Antitrust Advocacy (“SEPRAC” – the acronym in Portuguese), successor to the former Economic Monitoring Office – SEAE, is responsible for the so-called “antitrust advocacy” before government agencies and the society.

SEPRAC is responsible for promoting free competition by preparing studies that analyze, from a competition perspective, public policies, self-regulations, and normative acts of general interest to economic agents, consumers, or users of services.

In addition to intervening as amicus curiae in administrative and judicial proceedings, most of the time, SEPRAC issues opinion on legislative proposals that are processed in the National Congress; on propositions of regulatory agencies; and on assessments requested by CADE, by the Foreign Trade Chamber, or by forums in which the Ministry of Finance participates.

27.3. CADE’S FUNCTIONS

CADE basically performs three main functions, namely: preventive, repressive, and educational.

Preventive Control corresponds to the analysis and decisions in mergers and acquisitions between companies, which may potentially harm free competition (“Mergers and Acquisitions” – more detailed in Section 27.4, below).

Repressive Control corresponds to the analysis and trial of antitrust violations, which are set forth in art. 36 et seq. of Law No. 12,529/2011 and CADE’s Internal Regulation (“RICADE” – the acronym in Portuguese).

The Educational Role, in turn, focuses on the dissemination of the culture of free competition, notably in the development of antitrust policy, as a way of implementing public policies, through partnerships with institutions and government agencies, resulting in the consolidation of concepts, growing academic interest in the area, dissemination of competition policy within the society, and technical improvement of decisions.

27.4. MERGERS AND ACQUISITIONS

As mentioned, articles 88 to 91 of Law No. 12,529/2011 comprehend provisions on the so-called control of structures, through the analysis of mergers and acquisitions. It is a concept that is related to the increase of economic power in the market by one or more players, which the legal literature defines as “increase of wealth in a few hands”1.

Article 90 does not define mergers and acquisitions under a competition law perspective, although it presents situations in which they are carried out, as listed below, except in cases intended for competitive biddings held by the direct and indirect government and the contracts resulting thereof (art. 90, sole paragraph):

  1. two (2) or more previously independent companies merge;
  2. one (1) or more companies acquire, directly or indirectly, by purchase or exchange of stocks, shares, bonds or securities convertible into stocks or assets, whether tangible or intangible, by contract or by any other means or way, the control or parts of one or more companies;
  3. one (1) or more companies incorporate one or more companies; or
  4. two (2) or more companies enter into an associative contract, consortium, or joint venture.

The situations described in items I and III above are the typical merger and acquisition transactions under corporate law, involving merger and incorporation.

The transaction outlined in item II, on the other hand, is somewhat broad, involving both the acquisition of equity interests and securities, as well as tangible or intangible assets.

Item IV, on its turn, describes the need for mandatory submission of associative contract, consortium, or joint venture agreements.

Still with regard to mergers and acquisitions, they may be classified as horizontal, vertical, and conglomerate. In summary, the following definitions apply:

  • Horizontal Mergers: between companies that sell similar products or services.
  • Vertical Mergers: between companies that develop different functions in the same supply chain.
  • Conglomerate Mergers: Between companies that offer diverse products or services.

Finally, the transactions listed above are subject to premerger notification to CADE. Article 88 of the Antitrust Law establishes that the parties involved in the transaction shall submit to CADE mergers and acquisitions in which, cumulatively, meet certain revenue criteria in relation to the groups involved in the transaction. The amounts are those set out in Joint Ministerial Ordinance No. 994/2012, namely:

  1. at least one of the groups involved in the transaction has recorded, in the last balance sheet, annual gross revenue or total business volume in Brazil, in the year prior to the transaction, equivalent to or greater than seven hundred fifty million Reais (R$750,000,000.00); and
  2. at least one other group involved in the transaction has registered, in the last balance sheet, annual gross revenue or total business volume in Brazil, in the year prior to the transaction, equivalent to or greater than seventy-five million Reais (R$75,000,000.00).

Accordingly, notifiable transactions cannot be completed until CADE issues a final decision. Completion of these acts, in whole or in part, without CADE’s approval results in the practice known as gun jumping, as further detailed in Section 27.6 below.

1 DA FONSECA, João Bosco Leopoldino. Direito Econômico. 9th ed., Rio de Janeiro: Forense, V.1., p. 71 

 

27.5. PREMERGER NOTIFICATION SYSTEM

Law No. 12,529/2011 introduced the premerger notification system, which replaced the former a posteriori submission system, basically consisting of the obligation that a notifiable transaction be submitted to CADE’s analysis and approval prior to its completion.

Under the former system, a merger could be notified to CADE a posteriori, within fifteen business days after it was completed.

The premerger notification system aims at preventing irreparable damage to the market and consumers, by ensuring that market conditions are preserved while the SBDC analysis is carried out.

27.6. GUN JUMPING

With the premerger notification system introduced by Law No. 12,529/11, the so-called gun jumping emerged, originating from the U.S. economic law, which consists of premature completion of the deal, in whole or in part, without CADE having authorized it, in violation of the premerger system.

Gun jumping is a complex topic that requires attention, as even the prior exchange of competitively sensitive information, or the advance payment of part of the contractual amounts, or down payment at levels above a certain percentage of the contract price, can be understood as gun jumping, giving rise to penalties.

In this sense, art. 88, paragraph 4 of the Antitrust Law establishes that “until the final decision on the transaction is rendered, the conditions of competition between the companies involved shall be preserved, under penalty of imposition of the sanctions provided for in paragraph 3 of this article”.

Therefore, the company that incurs in gun jumping may be subject to the payment of fines that can range from R$60 thousand to R$60 million, in addition to the possible invalidation of the already completed merger and the investigation of any antitrust practices.

As a consequence, companies subject to a notifiable transaction shall keep their physical structures and competitive conditions unchanged until final decision by CADE and cannot exchange sensitive information that is not strictly necessary for the execution of the formal instrument.

Resolution CADE No. 24 of July 8, 2019 describes the procedures that shall be followed by the antitrust authorities in the analysis of the practice of gun jumping, and even the sentencing guidelines criteria with respect to the applicable fine.

27.7. MERGER NOTIFICATION FEE

As for the costs, the company shall pay a procedural fee of eighty-five thousand Reais (R$85,000.00), currently in effect, when submitting a merger notification to the SBDC, pursuant to article 23 of Law No. 12,529/2011.

27.8. ANALYSIS OF MERGERS AND ACQUISITIONS

27.8.1. Procedure

Initially, with regard to the analysis of mergers and acquisitions, the law provides for processing under (i) the fast track procedure, which is faster, since it grants a period of thirty (30) days for CADE’s General Superintendence to issue its opinion on the transaction under consideration2, as of the filing of the notification or amendment; or (ii) under the ordinary procedure, which demands more information and is more complex. For the latter, art. 88, paragraph 2 of the Antitrust Law establishes a period of consideration by CADE of up to two hundred and forty (240) days, which may reach up to three hundred and thirty (330) days, depending on appeals and extensions.

The merger notifications under the ordinary procedure shall be submitted along with the documents and pieces of information listed in Exhibit I to Resolution CADE No. 33 of April 14, 2022.

Resolution CADE No. 33/2022 also provides for a form to be completed by the parties for notifiable transactions in accordance with the fast track procedure (Exhibit II). CADE shall use the fast track procedure in cases of less competitive complexity, the decisions of which are usually issued in less than thirty (30) days as from the filing date.

The application shall be submitted, whenever possible, together by the parties to the transaction, which shall immediately report any subsequent changes to the data contained in the initial request.

Once the supplementary fact-finding is completed, CADE’s General Superintendence shall comment on satisfactory fulfillment thereof, receiving it as suitable for analysis on the merits or determining that it be redone, if incomplete. In the analysis of the merits, the opinion to be issued by CADE’s General Superintendence may follow three different directions of recommendation:

  1. approval of the transaction, without any restrictions;
  2. approval of the transaction, conditional upon structural or behavioral restrictions, such as, but not limited to: divestment of assets, assumption of access obligations and non-discrimination of competitors, among other antitrust remedies;
  3. total “rejection” of the transaction (veto).

Furthermore, if the merger is approved without restrictions, as recommended by CADE’s General Superintendence, CADE’s Tribunal may, at the request of one of its Commissioners and by means of a reasoned decision, refer the case to CADE’s Tribunal itself, so that a detailed analysis can be made by the Tribunal, and the Commissioner who summons it shall be deemed the Rapporteur.

In this case, the Rapporteur shall render a decision determining the inclusion of the case on the trial docket, if deemed sufficiently supported by evidence, or shall determine that supplementary fact-finding be carried out, if necessary, and may, at their discretion, within thirty (30) days, request that the CADE’s General Superintendence carries out the supplementary fact-finding, indicating the disputed points and specifying the actions to be taken.

If not called within fifteen (15) calendar days, the merger approved without restrictions by CADE’s General Superintendence may be completed by the parties.

In other events of restricted approval or vetoed transaction, CADE’s Tribunal shall analyze the case and may (i) uphold the veto or restricted approval, upon execution of a merger control agreement, by means of which antitrust structural and/or conduct remedies shall be ruled, which shall be complied with as a condition for the validity and effectiveness of the transaction; or (ii) approve the transaction without restrictions.

Also, within a term of fifteen (15) days as from publication of the decision issued by CADE’s General Superintendence that approves the merger, an appeal may be filed with CADE’s Tribunal by interested third parties or, for a regulated market, by the respective regulatory agency.

Once the case has been tried on the merits, the transaction cannot be notified again, nor can it be revised within the scope of the Executive Branch.

2 Cade Resolution No. 33/2022. Art. 7 – The decision to classify the application for a merger and acquisition in the fast track procedure is discretionary, and shall be adopted by Cade in accordance with the criteria of convenience and opportunity, based on the experience acquired by the bodies comprising the Brazilian Antitrust System in the analysis of mergers and in the identification of those that have less potential to violate competition. Paragraph 1 – The acts under analysis based on the fast-track procedure shall be subject to a simplified decision […]. Paragraph 2 The General Superintendence shall observe a term of thirty (30) days as from filing of the application or of the amendment thereto, to decide on mergers classified in the fast-track procedure and which are not reclassified for analysis in the ordinary procedure (emphasis added).

 

27.9. QUERIES

Article 9, paragraphs 4 and 5 of Law No. 12,529/2011, as governed by Resolution CADE No. 12/2015, allows any interested party to submit a Query to CADE’s Tribunal, requesting its understanding on the application of the antitrust legislation to a specific event of fact.

Queries may cover: (i) the interpretation of legislation or CADE’s regulation concerning merger control, in relation to certain transactions or properly defined de facto situations; (ii) the lawfulness of acts, contracts, business strategies, or conduct of any kind, already initiated by the party; or (iii) the lawfulness of acts, contracts, business strategies, or conduct of any kind, already conceived and planned, but not yet initiated by the party.

To submit the Query, the party shall comply with the applicable legal requirements, as well as pay the procedural fee, currently in the amount of fifteen thousand Reais (R$15,000.00), pursuant to article 23 of Law No. 12,529/2011, as amended by Law No. 13,196/2015.

27.10. VIOLATIONS TO THE ECONOMIC ORDER

27.10.1. Article 36 of Law No. 12,529/2011.

Article 36 of Law No. 12,529/2011 establishes that a conduct is deemed a violation to the economic order whenever it has as objective or may have the following effects, regardless of fault, even if they are not achieved: (i) limit, restrain, or in any way harm free competition; (ii) arbitrarily increase profits; (iii) control relevant markets for goods and services; and (iv) exercise a dominant position abusively.

It is worth emphasizing that an antitrust violation is characterized irrespective of the player’s fault and even if the harmful effects are only potential.

Article 36, paragraph 3, presents an exemplificative – and not exhaustive – list of practices that are deemed as violation to the economic order, among which it is possible to mention the following:

  • creation of mechanisms to exclude competitors:
  • resale price fixing;
  • territorial and customer base restrictions;
  • predatory pricing;
  • tie-in arrangements;
  • price discrimination;
  • market closing;
  • cartel.

27.10.2. Penalties

At the administrative level, conducts characterized as antitrust violation result in the following penalties:

  • Company: fine from one tenth percent (0.1%) to twenty percent (20%) of the gross revenue of the company, group or conglomerate obtained in the last fiscal year prior to the initiation of the administrative proceeding, in the field of business activity in which the violation occurred, which shall never be less than the benefit obtained, whenever it can be estimated.
    CADE may also consider the total revenue of the company or group of companies, when it does not have the revenue amount in the field of business activity in which the violation occurred or whenever it is presented incompletely and/or not demonstrated in an unequivocal and reputable manner.
  • Other individuals or legal entities governed by public or private law, associations of entities or persons organized de facto or de jure, even if temporarily, with or without legal personality, which do not carry out business activities, and it is not possible to use the gross revenue value criteria: the fine shall be between fifty thousand Reais (R$50,000.00) and two billion Reais (R$2,000,000,000.00);
  • Managers, directly or indirectly responsible for the offense committed, upon proof of their negligence or willful misconduct, a fine from one percent (1%) to twenty percent (20%) of that imposed on the company or legal persons or entities, in the cases described above.

In the case of recurrent violation, the imposed fines shall be doubled.

Without prejudice to the pecuniary penalties, the following sanctions may be imposed individually or cumulatively depending on the seriousness of the facts or the general public interest:

  • Publication in a newspaper indicated in the decision, of a summary of the adverse judgment, for two (2) consecutive days, from one (1) to three (3) consecutive weeks;
  • Prohibition of entering into agreements with official financial institutions and participating in competitive biddings for acquisitions, disposals, execution of works and services, concession of public services, in the federal, state, municipal, and Federal District government, as well as in indirect government entities, for a term not less than five (5) years;
  • Registration of the offender in the National Consumer Protection Register;
  • Recommendation to the proper government agencies that: (a) a compulsory license of the intellectual property right owned by the offender be granted, when the violation is related to the use of that right; and (b) the offender is not granted the right to pay federal taxes owed by the offender in installments under a payment plan, or that tax incentives or public subsidies be cancelled in whole or in part;
  • Company spin-off, transfer of corporate control, sale of assets, or partial cessation of activities;
  • Prohibition of trading in one’s own name or as a representative of a legal entity, for a term of up to five (5) years.

Law No. 12,529/2011, as amended by Law No. 14,470/2022, also establishes the right to double compensation for those that prove that they have been harmed by a conduct characterized as an antitrust violation, in return for damage suffered as a result of the violations listed in items I and II of paragraph 3 of art. 36 of said Law, without prejudice to the sanctions imposed in the administrative and criminal grounds.

The following factors are to be taken into account when imposing penalties: (i) the player’s willful misconduct and the seriousness of the violation; (ii) the offender’s good faith and the advantage gained/intended by the offender; (iii) consummation of the violation; (iv) the degree of harm or danger of harm to free competition, the national economy, consumers, or third parties; (v) the negative economic effects produced in the market; (vi) the size of the companies or the economic situation of the offender; and (vii) recidivism.

27.10.3. Cease-and-Desist Agreement

In certain situations, CADE may obtain from the defendant a cease-and-desist commitment related to the practice under investigation or its harmful effects upon the execution of a Cease-and-Desist Agreement.

It is an instrument to be entered into between the parties involved in the violation and CADE, as a means of guaranteeing important benefits for those that adhere thereto, and the contribution before CADE, to allow the investigation and punishment of other offenders not initially identified.

The Cease-and-Desist Agreement is ruled by article 85 of the Antitrust Law, as follows:

Art. 85. In the administrative proceedings referred to in items I, II, and III of Art. 48 of this Law, Cade may obtain from the defendant a cease-and-desist commitment related to the practice under investigation or its harmful effects, if duly grounded, for convenience and at the proper time, and if it understands that it complies with the interests protected by law.

Said article 85 shall also be complemented with the provisions of CADE’s Internal Regulation (“RICADE”), in particular the ones of Title IV, Chapter II, Section III, which define the procedures and requirements for submission of the application by the defendants, the process of negotiation and judgment of the final proposal.

27.11. JUDICIAL REVIEW OF CADE’S DECISIONS

CADE is the last instance, at the administrative level, responsible for the final decision on antitrust matters. However, CADE’s decisions may be challenged in court, pursuant to art. 5, XXXV combined with art. 109, I of the Brazilian Federal Constitution.

In actions in which CADE appears as plaintiff or defendant or as assistant or opponent, the court with competent jurisdiction is the Judiciary Section of the Federal District. On the other hand, in cases involving the judicial enforcement of CADE’s decisions, imposing a fine or imposing an obligation to do or not to do, CADE may choose to bring the action at the place of domicile of the defendant.

CADE’s decisions that impose a fine are extrajudicial enforcement instruments, in accordance with art. 93 of Law No. 12,529/2011, and the fines shall be entered as overdue tax liability with the Federal Debt Roster.

Despite the time spent analyzing a given merger and acquisition or a violating conduct in the administrative grounds, the proceedings can also last for years in the judicial grounds, due to the Brazilian Justice system moving slowly.

27.12. RELATIONSHIP BETWEEN THE SBDC AND OTHER INSTITUTIONS

The SBDC works together with federal bodies and regulatory agencies, which are responsible for certain sectors of the economy, mainly infrastructure and public services.

An example of that is found in the Technical Cooperation Agreement signed on November 10, 2023, between CADE and the Office of the Federal Controller General (CGU), aimed at technical and operational cooperation in relation to the repression of corruption acts and cartels.

There are several other agreements signed between CADE and government agencies, which include those with the Federal Government, the National Bank for Economic and Social Development – BNDES, the National Complementary Health Agency (ANS), the National Petroleum, Natural Gas, and Biofuels Agency (ANP), the Association of Federal Judges (AJUFE), the National Health Surveillance Agency (ANVISA), the Public Prosecutors’ Office of several Brazilian states, the INPI – National Institute of Industrial Property, ICC Brasil – Brazilian Committee of the International Chamber of Commerce, and SNC – National Consumer Office.

CADE also has international agreements with several nations, in addition to Cooperation Treaties and Protocols with MERCOSUR countries. The SBDC also takes part in many international meetings to exchange antitrust policy experiences, such as the OECD (Organization for Economic Cooperation and Development) and ICN (International Competition Network).

27.13. INCENTIVE TO COMPLIANCE PROGRAMS

In view of the risks associated with antitrust violations, the adoption of compliance programs has been encouraged, including by CADE, which published the “Guide – Compliance Programs – Guidelines on Structuring and Benefits of Adopting Antitrust Compliance Programs”, establishing guidelines for companies regarding these programs, specifically in the antitrust area.

There is not just one model for compliance programs, which can be more or less complex, depending on the size, market position, activities of each company, among other factors.

As for the benefits of these programs, the following can be mentioned: prevention of risks of violations of the law, early identification of problems, recognition of illegalities in other organizations (competitors, suppliers, distributors, or customers), reputational benefit, awareness of staff, and reduction of costs and contingencies.

Author: Fabiana Nitta

[email protected]
Tel.: (11) 94492 4494

Sonia Marques Döbler Advogados
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