The assumption that seekers of a monopoly privilege from government will dissipate the expected value of future related rents by costly pursuit of the privilege is frequently used though subject to a growing debate.' Tullock has described a set of plausible circumstances where strategic bidding for a single prize leads to net gains for the rent seeking participants.2 That is, even with competition for rents, less than full dissipation of future gains may obtain. (Tullock also identifies other circumstances where the process is a zeroor negative-sum game.) If the theory of rentless rent-seeking holds under any set of circumstances, empirical work designed to identify wealth effects associated with a regulatory event is destined to fail. Indeed, such empirical analysis may find no effect when in fact a regulatory restriction has occurred. Yet reports of empirical research on regulatory effects have supported the hypothesis that rents have been generated.3 Do such empirical results implicitly support Tullock's theory of efficient rent-seeking? Are such results purely random observations of one of many discrete regulatory processes involving the same firms where the overall expected value is zero?4 Or is there an explanation of such results that is consistent with full dissipation of rents and systematic observation of abnormal positive returns for shareholders of directly affected firms? This article offers another explanation for observing profitable rent-seeking that is compatible with Tullock's observations and rent dissipation theory. The next section gives the explanation. That section is followed by a brief summary.