'Profits above all else' came primarily from three sources: 1) The 'Chicago School' emerging from the University of Chicago economics department, most active from the 1950's to the 1970's, and of which Milton Friedman was the exemplar; 2) The 'Powell Memo' that corporate lobbyist and later Supreme Court Justice Lewis F. Powell wrote to the US Chamber of Commerce in 1971; and 3) The efforts of Robert Bork, who was a militant critic of antitrust regulation and believed that mergers and acquisitions were good because they always lowered prices for consumers, and led to the creation of greater shareholder wealth.