"In other words, while Germany’s codetermination regime may render hostile takeovers more challenging, it is not clear that the number of hostile takeovers would be much
higher in its absence. Herein lies a major difference between Germany and the United States. For example, between 1981 and 2010, the United States saw 60,244 mergers in which the acquirer and the target were publicly traded corporations. The United States thus has a particularly vigorous market for corporate control and thus stands to lose much more from imposing codetermination."