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The Trump era DOJ and FTC: a return to merger remedies

This new stance, however, does not signal unchecked dealmaking for transacting parties. The Federal Trade Commission (FTC) and Department of Justice (DOJ) are simultaneously emphasizing that robust, evidence-based enforcement...more

FTC secures record USD5.68 million gun-jumping penalty

On January 7, 2025, the U.S. Federal Trade Commission announced a record USD5.68m civil penalty to settle alleged pre-merger coordination in violation of the HSR Act. This settlement is the largest dollar penalty that has...more

U.S. DOJ seeks rare $3.5 million “gun jumping” penalty against Legends Hospitality for pre-closing conduct in connection with its...

On August 5, 2024, the United States Department of Justice (“DOJ”) filed a rare[1] gun jumping[2] civil lawsuit and proposed settlement in the United States District Court for the Southern District of New York against Legends...more

Field of Dreams: FTC and DOJ Seek to Build a New Playing Field for Challenging Mergers

Proposed FTC and DOJ Merger Guidelines Formalize Biden Administration’s Aggressive Vision for Merger Enforcement – Top Ten Takeaways - When losing, some players seek to change the rules. Others seek to change the playing...more

Proposed Overhaul of HSR Form Will Dramatically Increase Burden on Filers

Earlier this week, the Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice (the “Antitrust Agencies”) announced proposed changes to the premerger notification process that mark the most...more

UPDATE: FTC’s Updated Filing Fees, Increased HSR Thresholds and Increased Interlocking Directorate Thresholds for 2023

The new Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”) thresholds will go into effect on February 27, 2023 and will apply to all transactions closing on or after that date. As previewed in...more

Significant US HSR Filing Fee Changes Under The Merger Filing Fee Modernization Act

On December 29, 2022, President Biden signed into law The Consolidated Appropriations Act of 2023 also known as The Omnibus Funding Bill (the “Bill”). The Bill includes the Merger Filing Fee Modernization Act which provides...more

The FTC Abandons (The Rule of) Reason

On November 10, 2022, the Federal Trade Commission (FTC) issued a policy statement (the “Policy Statement”) radically expanding the FTC’s interpretation of prohibited “unfair methods of competition” under Section 5 of the FTC...more

CMA Merger Control Jurisdiction to be Expanded Further

The U.K. Competition and Markets Authority (CMA) is expected to be granted wider jurisdictional powers for merger control enforcement in legislative proposals mentioned in today’s Queen’s Speech. The powers derive from the...more

Back to the Future—FTC Reinstates and Broadens Prior Approval Policy for Anticompetitive Mergers

On Monday, October 25, 2021, the Federal Trade Commission (FTC) voted along party lines to approve (3-2 with Commissioner Phillips and Commissioner Wilson dissenting) a new Prior Approval Policy Statement (Prior Approval...more

Proposed HSR Rules Affect Investment Firms/Master Limited Partnerships and Minority Acquisitions

The U.S. Federal Trade Commission (FTC) and U.S. Department of Justice Antitrust Division (“DOJ” and collectively, the “Agencies”) recently proposed changes to two aspects of the Hart-Scott-Rodino Act (“HSR Act”). The...more

Update — Antitrust and COVID-19

- US Agencies Encourage COVID-19-Related Collaboration - Practical Tips for Information Sharing & Document Creation - Possible Delays to US Merger Approvals The ongoing COVID-19 outbreak has, at least temporarily,...more

FTC Increases HSR Thresholds Effective February 27, 2020

On January 28, 2020, the U.S. Federal Trade Commission (FTC) announced the annual changes to the thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”). The new size of transaction...more

Five Key Aspects of the Long-Awaited Revised Draft US Vertical Merger Guidelines

On Friday, the Federal Trade Commission (“FTC”) and the Antitrust Division of the U.S. Department of Justice (“DOJ”) released joint draft Vertical Merger Guidelines (“Guidelines”) for public comment. This much anticipated...more

Key Antitrust Enforcement Trends — 2019 Antitrust Annual Report

Welcome to the 2019 Shearman & Sterling Antitrust Annual Report. Our seventh edition focuses on the contrasting use by regulators of antitrust laws with respect to the FANGs, and how antitrust is being enforced in the U.S....more

FTC Increases HSR Thresholds Effective April 3, 2019

The U.S. Federal Trade Commission (FTC) has revised, and once again raised, the thresholds for the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (the “HSR Act”). The new HSR Act thresholds were published in...more

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