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FTC disputes new slate of Orange Book patents for weight loss, diabetes, asthma, and COPD drugs

On April 30, 2024, the Federal Trade Commission (FTC) announced that it sent a new set of warning letters to ten pharmaceutical companies. The letters inform the companies that the FTC has notified the Food and Drug...more

FTC finalizes rule banning non-compete agreements

On April 23, 2024, the Federal Trade Commission (FTC) voted to publish a final rule that, effective 120 days after publication, will ban the use of non-compete clauses nationwide, classifying such clauses as an unfair method...more

FTC continues to highlight FDA Orange Book patent listings

With the recent filing of an amicus brief in a private pharmaceutical patent infringement case, the Federal Trade Commission (FTC) has continued its focus on allegedly “improperly listed” patents in the Food and Drug...more

Third Circuit: crime-fraud exception can apply to attorney-client privilege in sham-litigation case

In a ruling with significant implications for companies facing sham-litigation claims, such as those that can arise in the Hatch-Waxman context for pharmaceutical manufacturers, the Third Circuit recently refused to vacate a...more

Private equity investment in health care remains in U.S. antitrust enforcers’ crosshairs

Private equity investment in the health care sector continues to be a significant area of focus for the U.S. antitrust agencies. On March 5, 2024, the Federal Trade Commission (FTC) hosted a public workshop to “examine the...more

DOJ and FTC update Second Request guidance to address the use of ephemeral messaging applications

On January 26, 2024 the Federal Trade Commission (“FTC”) and Department of Justice (“DOJ”) announced1 that the standard preservation letters and specifications for all voluntary access letters, second requests, and compulsory...more

FTC focused on competition and dominance in generative AI space

On January 25, 2024 the Federal Trade Commission (FTC) hosted a Technology Summit focused on generative artificial intelligence (AI) and other innovative technologies to address how control over key inputs—like data, chips,...more

The European Commission report on competition enforcement in the pharmaceutical sector

On 26 January 2024, the European Commission published a report on competition enforcement in the pharmaceutical sector, highlighting the role of EU competition law in safeguarding market participants and consumers,...more

FTC and DOJ finalize new merger guidelines articulating expansive theories of enforcement

On December 18, 2023 the Federal Trade Commission (FTC) and Department of Justice (DOJ) (“the Agencies”) released the 2023 Merger Guidelines (the Merger Guidelines). The substance of the new guidelines does not stray...more

Antitrust Enforcement in the Health Care Sector to remain a key focus in the Biden Administration

On December 7, 2023, the White House announced a series of initiatives to “lower health care and prescription drug costs by promoting competition.” Citing increasing concentration in the health care industry among payers,...more

DOJ lays out per se theory of liability for price fixing using algorithms

In recent court filings and public comments, the Department of Justice Antitrust Division (“DOJ” or “the Division”) has stated that price fixing using algorithmic software is per se illegal under the antitrust laws. These...more

Competition considerations featured in President Biden’s Executive Order on Artificial Intelligence

On October 30, 2023, President Biden issued an Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence. The Order, which recognizes AI’s extraordinary potential but also the...more

FTC and DOJ officials offer additional commentary on draft merger guidelines

On September 5, 2023 the Federal Trade Commission (FTC) and Department of Justice (DOJ) (the Agencies) hosted the first of three planned workshops intended to “facilitate public dialogue” on the 2023 FTC and DOJ Draft Merger...more

Two years later: A survey of President Biden’s Executive Order on promoting competition in the American economy

It has been two years since President Biden signed a far-reaching, industry-spanning Executive Order on Promoting Competition in the American Economy. The Executive Order outlined a “whole-of-government” approach to...more

Broiler Chicken Price-Fixing and Information Exchange Claims Against Agri Stats Defeated

On June 30, 2023 the U.S. District Court for the Northern District of Illinois granted a summary judgment motion filed by Hogan Lovells’ antitrust litigation team on behalf of its client Agri Stats, a company that provides...more

Another shot across the bow: FTC cautions against reliance on past PBM advocacy letters and reports

On July 20, 2023 the Federal Trade Commission (FTC) voted to issue a statement cautioning against reliance on previous agency advocacy letters, reports, and studies issued between 2004-2014 that took the position that certain...more

FTC and DOJ publish long-awaited draft of proposed merger guidelines

On July 19, 2023 the Federal Trade Commission (FTC) and Department of Justice (DOJ) (“the agencies”) released their 2023 Draft Merger Guidelines (the “2023 draft guidelines” or the “revised guidelines”). The publication of...more

FTC joins DOJ in rescinding health care antitrust policies

On July 14, 2023 the Federal Trade Commission (FTC) announced that it is withdrawing two antitrust policy statements related to antitrust enforcement in health care markets (the policy statements). Specifically, the FTC is...more

FTC Bureau of Competition warns against enforcing contract terms that hinder agency investigations

On June 16, 2023 the Federal Trade Commission’s (FTC) Bureau of Competition (the Bureau) issued a statement outlining its view that the enforcement of certain contract terms “can impede the Bureau’s law enforcement...more

FTC and DOJ outline potential changes to agencies’ review of pharmaceutical mergers

On June 1, 2023, the Federal Trade Commission (FTC) and the Antitrust Division of the US Department of Justice (DOJ) released a summary of a workshop jointly held by the agencies in June 2022 titled “Future of...more

U.S. Supreme Court clears the way for constitutional challenges to FTC, SEC

On April 14, 2023 the United States Supreme Court ruled in a unanimous opinion in Axon v. Federal Trade Commission that certain constitutional challenges to Federal Trade Commission (FTC) and Securities and Exchange...more

FTC seeks to reinvigorate enforcement of Robinson-Patman Act

The US Federal Trade Commission’s (“FTC”) reported investigations of Coca-Cola Co. and PepsiCo. Inc. for price discrimination are a significant step toward the agency’s revival of enforcement under the Robinson-Patman Act...more

FTC expands its interpretation of its Competition Enforcement Mandate

On 10 November 2022, the Federal Trade Commission (FTC or Commission) issued a Policy Statement (the Policy Statement) outlining a significant expansion of its mandate to target “unfair methods of competition” under Section 5...more

DOJ secures first criminal attempted monopolization conviction in decades

On 31 October 2022 the Department of Justice Antitrust Division (DOJ or the Division) announced that the president of a Montana paving and asphalt contractor pled guilty to one count of violating Section 2 of the Sherman Act...more

DOJ Antitrust Division cracks down on interlocking directorates

On 19 October 2022, the Antitrust Division of the US Department of Justice (the Division) announced that seven directors have agreed to resign from the boards of directors of five companies in response to the Division’s...more

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