Qualcomm’s initiative consists of an article by Jodie williams titled « Risks and Reward: Building an Antitrust Compliance Program ». This paper gives a cursory overview of the three elements for a successful antitrust compliance program. First, the compliance program’s objectives must be set. The objectives frame the issues with which the company is trying to comply. Second, identify the tools and resources at the compliance program’s disposal. The tools and resources, in turn, determine how robust of a program can be developed. Finally, strive for strong implementation. Implementing a compliance program that meets business needs and allows for continuity and reinforcement will have a lasting, positive impact on the company. It also offers somme practical tips to incorporate these elements into practice.