The Article 82 has been applied in a form-based approach. The form-based approach prohibits firm's behaviors based on the form of behaviors concerned without paying much attention to the effects of the behaviors. The form-based approach has an advantage in improving the predictability of law enforcement. However, it could hinder consumer welfare enhancing behaviors by not analyzing the overall economic effects, thus resulting in harming consumer welfare instead of enhancing it. Realizing this limitation, European Commission is currently reviewing the Article 82 of EC Treaty which prohibits the abuse of dominant firms. After finishing the review process, it is expected that the form-based approach would be replaced with the effect-based approach and more emphasis would be put on the economic analysis of each case. The experience of EU on the process of modernization of Article 82 would give us useful lessons in improving the regulation on the abuse of dominant firms in our competition policy.