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Meet the New Boss, Not So Different From the Old Boss? Antitrust in the Trump Era

After President Trump’s election for a second term, those predicting where federal antitrust enforcement was headed had to contend with internal tensions in the Trump coalition that extend to economic policy more broadly:...more

Washington Enacts Broad Premerger Notification Law: The Cutting Edge of State Merger Review

On April 4, 2025, Washington became the first state to enact the Uniform Antitrust Premerger Notification Act (Model Act), requiring parties to certain notifiable transactions under the Hart-Scott-Rodino Antitrust...more

2025 M&A Report

This year’s M&A Report offers a detailed review of the M&A market and outlook, including a breakdown by various geographies and industry sectors. We examine what might be in store with antitrust and CFIUS under the Trump...more

HSR Size-of-Transaction Threshold to Increase to $126.4 Million

On January 10, 2025, the Federal Trade Commission (FTC) announced adjusted thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Effective 30 days after the official publication date of the adjusted...more

FTC Reminds Merging Parties: Don’t Jump the Gun During the HSR Waiting Period!

Three crude oil producers have agreed to pay civil penalties totaling $5.7 million to settle allegations that they engaged in “gun jumping,” namely, allowing the acquirer to exercise control over the target’s business conduct...more

FTC and DOJ Target Healthcare and Life Sciences Industries - Urgent Care: Current Antitrust Enforcement Trends in the Healthcare...

The healthcare industry remains a focal point of President Biden’s antitrust agenda. The president’s July 2021 Executive Order on Promoting Competition in the American Economy called on federal agencies to focus antitrust...more

2024 M&A Report

While the 2022 M&A market was buoyed by deal carryover from 2021 and more conducive market conditions in the first half of the year, the 2023 M&A market felt the impact of the Federal Reserve’s most aggressive interest rate...more

Antitrust Review of Defense Mergers: DOD Gets its Own Production of Parties’ Materials in HSR Merger Reviews

Parties contemplating transactions in the defense sector need to know about a new obligation to provide materials to the Department of Defense (DOD) that will substantially affect their obligations for transactions that are...more

FTC and DOJ Release New Merger Guidelines

On December 18, 2023, the Federal Trade Commission and the Department of Justice jointly released their final Merger Guidelines. The Guidelines “identify the procedures and enforcement practices [the agencies] most often use...more

Fix-It-First: A Seismic Shift in US Antitrust Agency Approaches to Merger Remedies

Under their current leadership, the U.S. federal antitrust agencies have shown antipathy to resolving merger investigations through remedy undertaking that are embodied in consent decrees, preferring instead to seek to...more

Blast From the Past: FTC Revives Conglomerate Concerns as Basis for Merger Challenges

On May 16, 2023, the Federal Trade Commission filed a complaint in the Northern District of Illinois seeking to enjoin closing of Amgen Inc.’s proposed $28 billion acquisition of Horizon Therapeutics. This is the first time...more

Fix-It-First: Navigating a Seismic Shift in US Antitrust Agency Approaches to Merger Remedies

Senior officials at the US Department of Justice Antitrust Division (DOJ) and the US Federal Trade Commission (FTC) have made clear that they will not entertain or will sharply limit resolutions of merger investigations...more

HSR Size of Transaction Threshold to Increase to $111.4 Million

On January 23, 2023, the Federal Trade Commission (FTC) announced revised thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Effective on February 27, 2023, the lowest size-of-transaction filing...more

Antitrust Update: New Law Increases HSR Filing Fees for Large Deals, Imposes Foreign Subsidy Disclosure Requirement and Broadens...

On December 29, 2022, President Biden signed into law the Consolidated Appropriations Act of 2023 (the Act), which changes the fee structure for transactions that are notified under the Hart-Scott-Rodino Antitrust...more

Interlocking Directorates Under Section 8 of the Clayton Act: Can an Old Statute Learn New Tricks?

On June 3, 2022, Department of Justice Antitrust Division Deputy Assistant General Richard A. Powers reiterated the Division’s intent to bring more cases to trial and touted the Division’s record number of open...more

Is Vertical the New Horizontal for FTC Merger Enforcement? Recent Agency Challenges and the Way Forward

Since March 2021, the Federal Trade Commission (FTC or Commission) has challenged three proposed acquisitions based on vertical competitive concerns. The parties in two of those transactions - Nvidia/Arm and Lockheed...more

The FTC’s New “Warning Letter” in Merger Reviews: More Waiting After the HSR Waiting Period?

In an August 3 blog post, the Federal Trade Commission (FTC) announced a change to the FTC’s merger review process with potentially far-reaching effects. Emphasizing the agency’s constrained capacity resulting from a “tidal...more

Focus on Healthcare in New Biden Administration Executive Order on Competition

On July 9, 2021, the Biden Administration issued an Executive Order on “Promoting Competition in the American Economy.” The Order is notable in its breadth and commitment to a coordinated federal government approach to...more

FTC’s First Open Meeting Highlights Aggressive Enforcement Priorities and Partisan Divide

On Thursday, July 1, the Federal Trade Commission held its first meeting under Chair Lina M. Khan and first open business meeting in over twenty years. The Commission considered four items during the nearly two hour long...more

Politischer Wechsel und US-Kartellrecht: Nun aber richtig?

“Quo vadis, amerikanisches Kartellrecht?” Nach dem Überraschungssieg von Präsident Trump im November 2016 stellte sich diese Frage nicht nur in amerikanischen Kartellrechtskreisen. Zehn Monate später steht eine eindeutige...more

Essential Guidance for Non-(Standard) Essential Patent Pools: DOJ’s UTLP Business Review Letter

It has long been recognized that patent pools can create licensing efficiencies by establishing “onestop shops” for patents owned by multiple rights owners. There is also broad consensus that patentee collaboration in patent...more

Democratic FTC Commissioner Merger Dissents: A Roadmap for the Future?

In recent years, both Republican and Democratic-led antitrust agencies have pursued aggressive merger enforcement programs, litigating many cases and settling many more. However, “populist” and other progressive critics have...more

Antitrust in 2020 - The Year To Date

The first half of 2020 was a busy time for antitrust in the United States. The Department of Justice (DOJ) and the Federal Trade Commission (FTC) implemented expedited procedures for reviewing collaborations during the...more

COVID-19: An Antitrust Checklist

Businesses around the world are actively working to address the global COVID-19 pandemic, including through novel types of collaborations. In the United States, federal and state agencies, including the Department of Justice...more

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