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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

Here to Stay? FTC and DOJ Announce that 2023 Merger Guidelines Remain in Effect

Since their release, the federal antitrust agencies’ 2023 Merger Guidelines (2023 Guidelines) have faced significant criticism from many. There was speculation that the Federal Trade Commission (FTC) and Department of Justice...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

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

HSR Size-of-Transaction Threshold to Increase to $119.5 Million

On January 22, 2024, the Federal Trade Commission (FTC) announced revised thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Effective 30 days after the official publication date in the Federal...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

The Interplay: Key Decisions at the Intersection of Antitrust & Life Sciences - October 2023

This marks the second issue of WilmerHale’s The Interplay: Key Decisions at the Intersection of Antitrust & Life Sciences, a monthly bulletin that will highlight developments in the antitrust and life sciences space. We will...more

FTC and DOJ Release Draft Updated Merger Guidelines for Public Review and Comment

On July 19, 2023, the Federal Trade Commission and the Department of Justice released a draft update of the Merger Guidelines. The draft Guidelines describe how the agencies “review...mergers and acquisitions to determine...more

Proposed Changes to HSR Notification Form Would Intensify Scrutiny on Private Equity Funds: Some Thoughts on What to Expect and...

As described in our Client Alert of July 6, 2023, the Federal Trade Commission (FTC) and the Department of Justice (DOJ) proposed on June 27, 2023, a massive overhaul of the Hart-Scott-Rodino Act (HSR) pre-merger notification...more

FTC and DOJ Propose Sweeping Changes to HSR Notification Form: Convergence and Intensifying Idiosyncrasy

For the first time in 45 years, the Federal Trade Commission (FTC) and the Antitrust Division of the US Department of Justice (DOJ) proposed on June 27, 2023, a massive overhaul of the Hart-Scott-Rodino Act (HSR) pre-merger...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

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

DOJ Obtains First Criminal Monopolization Conviction in Over 40 Years: Revolution or Reprise?

On October 31, 2022, the US Department of Justice (DOJ) secured a criminal guilty plea from Nathan Zito, the president of a Montana paving and asphalt contractor, to attempted monopolization under Section 2 of the Sherman...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

Fourth Circuit Affirms First-Ever Decision Requiring Divestiture in Private Antitrust Case

On February 18, the Fourth Circuit affirmed a district court decision ordering a divestiture in a private merger challenge. Although the FTC and DOJ have successfully challenged a few closed transactions, the Jeld-Wen...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

DOJ Updates Guidance for Merger Remedies: What Businesses Need to Know

On September 3, 2020, the Department of Justice Antitrust Division (DOJ) updated its 2004 Merger Remedies Manual (see here). The updated Manual clarifies important aspects of the DOJ’s merger remedy practice about which there...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

More Bite, Less Bark: Merger Enforcement at the FTC in the Trump Administration

Since the beginning of the Trump Administration, the Antitrust Division of the Department of Justice (DOJ) has captured headlines for its aggressive public stance regarding merger enforcement. Actions attracting attention...more

Wait, I Thought We Were Done? DOJ Challenges $4B Merger Months After HSR Filing and Expiration of the HSR Waiting Period

Earlier this week, the Antitrust Division of the Department of Justice (DOJ) filed a lawsuit seeking to unwind Parker-Hannifin's $4.3 billion consummated acquisition of Clarcor. This is a notable challenge for two reasons. ...more

Facelift for Two Millennials: DOJ and FTC Update Guidelines for IP Licensing and International Enforcement

More than 21 years ago, the US antitrust agencies issued guidance to the business community on two critical topics of antitrust enforcement: (1) the licensing of intellectual property rights and (2) international enforcement...more

FTC/DOJ Guidance to Human Resource Professionals - Enforcement Scrutiny of Employment-Related Conduct

Last month, the Federal Trade Commission (FTC) and Department of Justice (DOJ) issued their Antitrust Guidance for Human Resource Professionals. The HR Guidance reflects the agencies' enhanced scrutiny in a realm that may not...more

Department of Justice Obtains Guilty Plea for Obstruction in Merger Investigation

On October 14, the US Department of Justice's Antitrust Division announced that Ralph Groen, a former information technology executive of the bus operator Coach USA Inc., had pleaded guilty to criminally obstructing justice...more

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