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U.S. Antitrust Agency Merger Roundup & Commentary: FTC Reverses Routine Use of Prior Approval Requirements in Merger Settlements,...

The June 2025 Quorum summarized recent actions by the Federal Trade Commission (“Commission” or “FTC”) and Department of Justice’s Antitrust Division (“DOJ”) indicating the Trump Administration’s rejection of the anti-merger...more

Trump Administration Reverses the Biden Administration’s Anti-Merger Policy and Returns to Merger Settlements; Proposed Budget and...

The current leadership of the Federal Trade Commission (FTC) and the Antitrust Division of the Department of Justice (Antitrust Division or DOJ) (collectively, “antitrust agencies”) have signaled an intention to reject the...more

Washington State Adopts First Broad State Antitrust Premerger Notification Act and Filing Requirement

Effective July 27, 2025, any person that files a Hart-Scott-Rodino (HSR) Act Notification and Report Form (HSR Form) with the Federal Trade Commission (FTC) and the Department of Justice (DOJ) must also submit an electronic...more

Federal Trade Commission Launches Public Inquiry as It Prepares to Lead President Trump’s Effort to Modify and Rescind...

Recognizing that “regulations that reduce competition, entrepreneurship, and innovation” are harmful to the U.S. economy, the Federal Trade Commission is seeking comment from the public on federal regulations that “exclude...more

FDIC Seeks Comment on Proposal to Rescind Its 2024 Statement of Policy on Bank Merger Transactions

The Federal Deposit Insurance Corporation (“FDIC”) is requesting public comment on its proposal to rescind its 2024 Statement of Policy on Bank Merger Transactions (“2024 Policy Statement”) and reinstate its prior Statement...more

DOJ Allegations that KKR Systematically Failed to Comply With the HSR Act – Highlights Importance of DOJ Corporate Compliance...

The Department of Justice (“DOJ”) has alleged in a complaint filed in the Southern District of New York on January 14, 2025 that KKR & Co. Inc. and certain of its investment advisors and funds (collectively, “KKR”)...more

FTC & DOJ Substantially Revise Guidance on Application of Antitrust Laws to Activities Affecting Workers: Trump Administration...

Two working days before the inauguration of President Trump, the federal antitrust agencies have withdrawn the Antitrust Guidance for Human Resource Professionals (2016) (“Guidance Document”), and issued Antitrust Guidelines...more

FTC Announces 2025 Thresholds for Merger Control Filings under HSR Act and Interlocking Directorates under the Clayton Act

The Federal Trade Commission (“FTC”) has increased the dollar jurisdictional thresholds necessary to trigger the reporting requirements of the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (“HSR Act”), and...more

Corporate Compliance Programs: Updated DOJ Guidance in Antitrust Investigations

The Department of Justice (Department or DOJ) considers the “adequacy and effectiveness of [a] corporation’s compliance program” as a factor in “conducting an investigation of a corporation, determining whether to bring...more

FTC Appeals Recent Losses in Non-Compete Rule Litigation, and Another Litigant Drops Its Challenge

We reported last month that the district court in the northern district of Texas had “set aside” the Federal Trade Commission’s recently finalized rule prohibiting employers from entering into, and enforcing, non-compete...more

FTC Substantially Expands HSR Merger Notification Form’s Information and Documentary Requirements; Promises the Return of Early...

The information and documentary materials (filing requirements) necessary to complete the Hart-Scott-Rodino merger notification filing form have been significantly expanded.  The new filing requirements will fall most heavily...more

FTC’s Rule Banning Non-Compete Agreements Is “Set Aside” Nationwide in District Court Ruling, But Two District Courts Find FTC...

The Federal Trade Commission’s (the FTC) rule prohibiting the entering into or enforcement of non-compete clauses between employers and employees (the Non-Compete Rule) made final in April 2024 and originally scheduled to go...more

District Court Issues Limited Preliminary Injunction in First Challenge to FTC Rule Prohibiting Use and Enforcement of Non-Compete...

The United States District Court for the Northern District of Texas (Dallas Division) has issued a preliminary injunction in favor of a plaintiff challenging the Federal Trade Commission’s (the “FTC” or the “Commission”)...more

The Biden Administration’s “Extensive Review of Interlocking Directorates Across the Entire Economy” May Put Your Board...

The identification, investigation and removal of persons who serve as directors or officers of two competing companies (i.e., “horizontal interlocks”) is a significant component of the Biden Administration’s antitrust...more

FTC Adopts Broad Ban on the Use of Non-Compete Clauses in Employment Agreements

The Federal Trade Commission has adopted a final rule (“Rule”) declaring it to be an unfair method of competition: With respect to a worker other than a senior executive: To enter into or attempt to enter into a...more

European Commission’s Revised Guidance on Market Definition Will Make It Easier to Allege Mergers Will “Significantly Impede...

The European Commission’s (“Commission”) substantially revised Market Definition Notice (“Revised Notice”) will make it significantly easier for it to allege that mergers and other transactions (“mergers”) are likely to...more

FTC Announces 2018 Thresholds for Merger Control Filings Under HSR Act and Interlocking Directorates Under the Clayton Act

The Federal Trade Commission (“FTC”) has announced its annual revisions to the dollar-jurisdictional thresholds in the Hart-Scott-Rodino Antitrust Improvements Act of 1976, as amended (“HSR Act”); the revised thresholds will...more

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