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Federal Trade Commission Releases Commentary on Vertical Merger Enforcement

Split along partisan lines, the Federal Trade Commission (Commission) voted last week to issue Commentary on Vertical Merger Enforcement (Commentary). The Commentary intends to “provide[] greater transparency to the public...more

FTC Announces HSR And Interlocking Thresholds For 2020

The U.S. Federal Trade Commission announced the annual changes to the thresholds contained in section 7A (Hart-Scott-Rodino) and section 8 of the Clayton Act (15 U.S.C. §§ 18a, 19) (Interlocking Directors). The new HSR...more

Qualcomm Loss Raises Risks for Substantial Market Participants' IP Licensing Decisions and Ability to Provide Loyalty Discounts

The U.S. Federal Trade Commission (FTC) convinced a California federal district court not only that Qualcomm’s longstanding intellectual property licensing practices and volume-based discounts violated the antitrust laws, but...more

Recent FTC Settlement Confirms Enforcement Priority to Protect Employees From Employer Collusion

On July 31, the FTC published its settlement with Therapy Source, LLC; its owner, Sheria Yarbray; and Neeraj Jindal, the former owner of a competing staffing company — Integrity Home Therapy (collectively, the respondents)....more

Annual HSR Merger Notification Threshold Adjustments Announced

On January 19, the Federal Trade Commission (FTC) announced the annual changes to the thresholds of the Hart-Scott-Rodino Antitrust Improvements Act (the HSR Act). These thresholds are adjusted annually based on changes in...more

Antitrust Division Threatens Criminal Prosecution for Employment Practices: Antitrust Agencies Issue Joint Guidance on Employment...

Even in the absence of an agreement to fix compensation, simply exchanging competitively sensitive information could serve as evidence of an implicit illegal agreement. On October 20, the Department of Justice (DOJ) and...more

FTC's Winning Streak Restored: Seventh Circuit Reverses Denial of Preliminary Injunction in Chicago Hospital Merger, Competition...

Recent appellate decisions confirm the uphill battle hospitals face when merging with other hospitals. On October 31, the U.S. Court of Appeals for the Seventh Circuit overturned the district court’s ruling in Federal Trade...more

The End of the Road for Hershey Medical Center's Merger: Parties Abandon Transaction After Third Circuit Rules That Hospital...

The decision serves as a reminder of the uphill battle that merging health care providers have faced since the FTC’s adoption of its current rigid market definition standard in 2007. The U.S. Court of Appeals for the...more

A Sweet Win for Hershey Medical Center's Proposed Merger: District Court Denies FTC's Attempt to Block Pennsylvania Hospital...

The district court’s decision may mark a turning point away from purely formulaic reliance on the FTC’s preferred approach and the testimony of self-interested payers....more

Some Useful Insights from Steris-Synergy Merger Case

The Federal Trade Commission suffered a rare loss when, on Sept. 24, the U.S. District Court for the Northern District of Ohio denied its request for a preliminary injunction, despite having accepted the FTC’s “actual...more

Federal Judge in Ohio Accepts Future Competition Theory: Parties Should Proceed with Caution in Deals to Acquire Potential...

The court’s decision in FTC v. Steris demonstrates the importance of conducting a thorough antitrust analysis of all aspects of a merger or acquisition from every possible angle, including likely future competition. On...more

Applicability of 'Investment Purpose' Exemption to HSR Reportability Focuses on Intent of Equity Purchasers

If a purchaser’s goals shift to include influence on the business management or board composition of the target issuer, an HSR filing must be considered. The Federal Trade Commission (FTC or Commission) has once again...more

FTC Issues First Formal Policy on Section 5's Unfair Competition Authority

Although the brief FTC statement is beneficial, the sweeping language contained in the policy statement gives little practical guidance to the business community. On August 13, the Federal Trade Commission (FTC) issued...more

DOJ, Antitrust Division Speaks Out On Non-Reportable Transactions

On April 25, Deputy Assistant Attorney General of Civil Enforcement Leslie Overton gave a speech focused entirely on the Antitrust Division’s enforcement activities related to transactions that do not trigger a filing under...more

FTC Finalizes Amendments To HSR Rules Regarding Transfer Of Exclusive Patent Rights In The Pharmaceutical Industry

The Federal Trade Commission (FTC) has finalized certain amendments to the Hart-Scott-Rodino (HSR) premerger notification regulations clarifying the scope of reportable transactions involving transfers of patent rights in the...more

Just How Much Integration Is Enough: FTC Advisory Opinion Finally Provides Guidance For Competitors Seeking To Collaborate Or...

The Federal Trade Commission (FTC) recently issued its first advisory opinion addressing clinical integration programs since the enactment of the Affordable Care Act (ACA). Without a doubt the advisory opinion is useful for...more

Will FTC Chairman Leibowitz’s Departure Change The Enforcement Landscape?

After three years at the helm of the Federal Trade Commission (FTC), Chairman Jon Leibowitz stepped down. Without a doubt Chairman Leibowitz has been a visible and relentless advocate for restricting pay-for-day or reverse...more

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