This document is a formal submission to the UK Competition and Markets Authority addressing the proposed merger between Getty Images and Shutterstock. It raises structural competition concerns centred on the treatment of editorial labour in the supply of news imagery, particularly in relation to so-called “orphan” images where copyright ownership is unclear or diffuse. The submission argues that independent editorial agencies do not primarily monetise copyright, but rather the verification, contextualisation and legal assessment required to make images publishable, lawful and trustworthy. It contends that further consolidation risks strengthening copyright-aggregation models at the expense of verification-based editorial work, thereby entrenching monopsony power over smaller suppliers and suppressing remuneration for journalistic labour. Drawing on direct experience from a prolonged legal dispute involving global syndication chains, the submission highlights how enforcement barriers and subscription-based licensing models discourage independent agencies from pursuing legitimate claims. Framed within the growing risks posed by AI-generated and manipulated content, the document argues that weakening independent editorial suppliers would erode one of the last meaningful gatekeeping functions in visual journalism. It calls on the Authority to assess not only price effects, but also the merger’s impact on verification incentives, editorial sustainability and the integrity of the UK media ecosystem.