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Federal Court Applies Antitrust Standard of Per Se Illegality to “Algorithmic Pricing” Case

A federal district court in Seattle recently issued an important antitrust decision on “algorithmic pricing.” Algorithmic pricing refers to the practice in which companies use software to help set prices for their products or...more

Hart-Scott-Rodino Reporting Threshold Increases by $6.9 Million

The past two weeks have been quite busy in the world of the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (15 U.S.C. § 18a) (HSR). First, on January 7, 2025, the Federal Trade Commission (FTC) announced a record $5.6...more

FTC and DOJ Withdraw Guidelines for Collaborations Among Competitors

On December 11, 2024, the U.S. Department of Justice (DOJ) and the Federal Trade Commission (FTC) (together, “the Agencies”) jointly withdrew the 2000 Antitrust Guidelines for Collaborations Among Competitors (“Guidelines”)....more

FTC Finalizes Long-Awaited Rules that Will Substantially Increase the Scope and Detail of Premerger Antitrust Filings under...

The FTC has finalized significant changes to the information and level of detail that will be required in premerger antitrust filings under the HSR Act. The new rules will take effect in early 2025. Among other changes,...more

DOJ and FTC Raise Concerns about Overlapping Ownership in Public Utility Companies

On April 25, 2024, the U.S. Department of Justice Antitrust Division (DOJ) and the Federal Trade Commission (FTC) filed a joint comment with the Federal Energy Regulatory Commission (FERC or Commission) raising concerns about...more

FTC Issues Warning on the Use of Algorithms to Recommend or Set Prices

The U.S. Federal Trade Commission (FTC) recently published a blog post warning that the use of algorithms to assist in determining prices may violate federal antitrust laws, regardless of the business or industry. The FTC...more

FTC Blocks Interlocking Directorate and Makes Good on Its Commitment to Pursue Purported “Unfair Methods of Competition” as...

For the first time in 40 years, the Federal Trade Commission (FTC) has taken action to enforce Section 8 of the Clayton Act, which prohibits so-called interlocking directorates. In the same action, the FTC mounted its first...more

FTC Proposes Sweeping Changes to Hart-Scott-Rodino Filing Requirements

On June 27, 2023, the Federal Trade Commission (FTC), with the concurrence of the Department of Justice Antitrust Division, announced a wide range of significant proposed changes to the Hart-Scott-Rodino (HSR) pre-merger...more

Antitrust: DOJ Scuttles ACO Guidance, Unsettles Ground under Provider Joint Contracting Models

On Friday, February 6, 2023, the Department of Justice (DOJ) announced the withdrawal of the 2011 Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings...more

DOJ Withdraws Policy Statements That Defined Limited Safe Harbor for Information Sharing Among Competitors

On February 3, 2023, the U.S. Department of Justice’s Antitrust Division (DOJ) announced that it is withdrawing three policy statements the DOJ and Federal Trade Commission (FTC) issued between 1993 and 2011, related to...more

DOJ Antitrust Division and HHS OIG Enter into Partnership to Increase Coordination and Enforcement in Health Care

On December 9, 2022, the U.S. Department of Justice Antitrust Division (DOJ) and Office of Inspector General of the U.S. Department of Health and Human Services (OIG) announced they had entered a Memorandum of Understanding...more

How To Assess Interlocking Directorates In Antitrust Ramp-Up

Recent activity and statements from the U.S. Department of Justice and Federal Trade Commission signal that the federal agencies are likely to be more aggressive in pursuing enforcement against what they identify as...more

FTC Imposes Civil Penalty for Faulty “Messenger Model” Contracting

On September 30, the Federal Trade Commission (FTC) filed a complaint and proposed judgment in U.S. District Court for the District of Columbia against San Juan IPA, Inc. (San Juan) for allegedly operating an unlawful...more

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