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FTC Seeks Public Comment on Potential Franchise Rule

The Federal Trade Commission (FTC) made another move to protect two of the Biden administration’s priority constituencies: small business and workers. This time, it targeted perceived unreasonable restraints in the franchise...more

FTC Extends Comment Period on Proposed Ban of Noncompete Agreements

The Federal Trade Commission (FTC) continues to pursue its campaign against noncompete clauses. On January 5, the FTC voted 3-1 to publish a notice of proposed rulemaking, which, if implemented, would bar employers from...more

Fore! Professional Golf Investigation is Driver of New Antitrust Theories

As a sport, golf has rarely, if ever, been described as "cutting edge." But in the courtroom, golf may be at the forefront of the latest antitrust developments. In the coming months, the legal war unfolding in professional...more

FTC Proposes Rule to Ban Noncompete Clauses With Very Limited Exceptions

On January 5, the Federal Trade Commission (FTC) voted 3-1 to publish its Notice of Proposed Rulemaking, proposing a new rule that, if implemented, would bar employers from entering into noncompete agreements with their...more

DOJ Evolves Its Strategy of Increased Criminalization of Employment Restrictions Under Antitrust Laws

The Biden administration’s Department of Justice (DOJ) Antitrust Division recently secured its first criminal conviction for a labor-side violation of Section 1 of the Sherman Act after VDA OC LLC (VDA) entered a guilty plea....more

DOJ Making Good on Section 2 Monopolization Enforcement Promises With Latest Criminal Indictment

On Tuesday, December 6, the U.S. Department of Justice (DOJ), Antitrust Division, announced the unsealing of criminal charges against 12 individuals in the Southern District of Texas as part of an 11-year price fixing and...more

FTC Policy Statement Seeks to Expand US Antitrust Enforcement

On November 10, the Federal Trade Commission (FTC) issued a “Policy Statement Regarding the Scope of Unfair Methods of Competition Under Section 5 of the Federal Trade Commission Act” (Policy Statement). The Policy Statement...more

Recent No-Poach Developments: Hold the Pickle, Hold the Dismissal — Eleventh Circuit Overturns Burger King's District Court...

In early September, the Eleventh Circuit reversed the district court’s judgment for defendants Burger King Corporation, Burger King Worldwide, Inc., and their ultimate parent Restaurant Brands International, Inc....more

Recent No-Poach Developments: Federal Enforcement Agencies Ally to Promote Labor and McDonald’s Latest Judicial Win

Antitrust in labor markets remains a “hot topic” for government, business, and labor. The antitrust enforcement agencies, consistent with the Biden administration’s “Executive Order on Promoting Competition in the American...more

FTC Requires Divestitures in Gasoline Terminal Deal

The FTC is increasingly focused on competition in gasoline and fuel markets and has “redoubl[ed] its commitment” to “aggressive antitrust enforcement” in these areas. The most recent example of this renewed commitment came...more

Federal Court Denies DOJ's Request to File Statement of Interest in Pending McDonald's No-Poach Class Action

The Biden administration's Department of Justice, Antitrust Division (DOJ) continues a practice largely begun under the Trump administration of intervening in private litigation and requesting permission to file statements of...more

No-Poach Case Against HP Dismissed for Failure to Allege a Plausible Conspiracy

Many recent no-poach agreement antitrust claims have risen within the franchise context, where the alleged agreement was plainly described in the operative franchise agreements. In those cases, the parties fought over what...more

American Airlines and the Government Accuse Each Other of Prohibiting Competition

The Antitrust Division of the U.S. Department of Justice (DOJ) and several state attorneys general are challenging the American Airlines Group, Inc. (American) collaboration with competitor JetBlue Airways Corp. (JetBlue)....more

Senate Proposal Opens the Door for Increase in State Attorneys General Antitrust Lawsuits

On September 23, the U.S. Senate advanced legislation that puts all businesses at risk of defending antitrust lawsuits across different jurisdictions at the same time. Senate Bill 1787 (S. 1787) — the Antitrust Enforcement...more

Sixth Circuit Reverses Antitrust Preliminary Injunction Ordering Health Insurer to Keep Hospital in Its Network

Introduction - On August 10, the Sixth Circuit issued its opinion in St. Luke's Hospital et al. v. ProMedica Health System, Inc., reversing an unusual preliminary injunction under Section 2 of the Sherman Act that ordered...more

Executive Order Throws Down the Gauntlet for a New Era of Antitrust Enforcement

On July 9, President Biden signed an executive order on promoting competition in the American economy, listing broad priorities for antitrust enforcement. In conjunction with this order, the Federal Trade Commission (FTC) and...more

U.S. District Court Dismisses Government Actions Against Facebook

On June 28, while both congressional bodies continue to introduce and consider numerous legislative proposals to “reform” and amend the existing legal analytical framework, the U.S. District Court for the District of Columbia...more

FTC Meeting Opens the Door to a Period of Greater Uncertainty

Last week the Federal Trade Commission (FTC or Commission) held its first open Commission meeting in over 20 years. Chair Lina Khan led the meeting and promised future open meetings of the Commission on a “regular” basis....more

Lina Khan Selected as FTC Chair

On June 15, the U.S. Senate approved Lina Khan’s nomination as a commissioner of the Federal Trade Commission (FTC) by a 69-28 vote. Her confirmation assured that the Democrats would hold a 3-2 majority of commissioners....more

Unanimous Court Cuts FTC's Power to Seek Monetary Redress

On April 22 the Supreme Court held in AMG Capital Management, LLC v. FTC that the Federal Trade Commission (FTC) does not have authority under the Federal Trade Commission Act Section 13(b) to seek, nor a court to award,...more

FTC to Develop New Group Aimed at Antitrust and Deceptive Practices Rulemaking

While the debate continues about whether the Federal Trade Commission (FTC) has the authority to make rules governing antitrust or competition law issues, on March 25, Acting FTC Chair Rebecca Kelly Slaughter announced the...more

It Could Be a Very Bitter Pill: US, Foreign, and State Antitrust Enforcement Agencies Launch Group to Change Traditional Analysis...

Over the past several years, the Democratic commissioners of the U.S. Federal Trade Commission (FTC) have made clear their dissatisfaction with the agency’s historic treatment of pharmaceutical mergers. Now, it appears that...more

HSR Thresholds Lower for 2021

Yesterday, the Federal Trade Commission (FTC) announced the annual changes to the thresholds for Sections 7A (Hart-Scott-Rodino Antitrust Improvements Act) and 8 (interlocking directors) of the Clayton Act. For only the...more

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

SEC and DOJ Antitrust Division to Increase Collaboration on Rulemaking and Investigations

On June 22, the Department of Justice Antitrust Division (the Division) and the Securities and Exchange Commission (SEC) announced a first-of-its-kind Memorandum of Understanding (MOU) between the two agencies. The MOU was...more

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