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A Wait Until the Deal Closes: The Antitrust Agencies Send a Strong Message About the Dangers of Gun-Jumping

One of the most common questions clients have after a merger or acquisition has been signed is, “When can we start on combining the operations and doing business?” And one of the most challenging pieces of counseling is to...more

Annual Adjustment of HSR Thresholds Comes at a Time of Uncertainty

There is a lot of uncertainty in the Hart-Scott-Rodino Act (HSR) world. The new rules on what must be included in an HSR filing have been issued and are due to take effect on February 10, 2025, but that could be derailed or...more

The Long Awaited HSR Form and Rules Are Here, and They're Not as Burdensome as Feared

In June 2023, the FTC and DOJ (the “Agencies”) proposed a new rule that would significantly change the form and instructions for premerger notifications under the Hart-Scott-Rodino Act (“New HSR Form”). That proposal hinted...more

It’s That Time of Year: Announcement of the New Hart-Scott-Rodino Antitrust Filing Thresholds

The Hart-Scott-Rodino Act (“HSR”) requires that transactions over a certain value be reported at least 30 days prior to closing to the Federal Trade Commission (“FTC”) and U.S. Department of Justice Antitrust Division (“DOJ,”...more

Proposed Changes to HSR Process Could Quadruple the Burden of Making Premerger Notification to Antitrust Enforcement Agencies

The Federal Trade Commission and the Department of Justice Antitrust Division have proposed a massive redesign of the premerger notification process—one that may increase the time to complete an HSR filing from 37 to 144...more

The New Hart-Scott-Rodino Magic Number is $111.4 million, and Big Changes in HSR Filing Fees

The Hart-Scott-Rodino Act (“HSR”) requires that transactions over a certain value be reported to the Federal Trade Commission (FTC) and U.S. Department of Justice Antitrust Division at least 30 days prior to closing. That...more

Lowering the Bar: The FTC Lowers HSR Premerger Reporting Thresholds for the First Time in a Decade

On February 2, 2021, the FTC published its annual changes to the thresholds for determining whether certain transactions must be reported to FTC and DOJ under the Hart-Scott-Rodino Act before closing can occur....more

Antitrust Enforcers Target Securities Transactions for Violating the HSR ACT

U.S. antitrust enforcers continue to seek stiff penalties from companies that commit “gun jumping” by closing certain securities transactions without reporting them to the Federal Trade Commission (FTC) and United States...more

Avoiding the “Gun Jumping” Trap in Mergers and Acquisitions

From the moment a merger agreement is signed, the parties are often eager to begin the process of integrating and consolidating their operations. But doing too much coordination before closing could constitute “gun...more

The New Hart-Scott-Rodino Magic Number is $76.3 Million

The Hart-Scott-Rodino Act ("HSR") requires that transactions over a certain value be reported to the Federal Trade Commission (FTC) and U.S. Department of Justice Antitrust Division at least 30 days prior to closing. That...more

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