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FTC Makes Case for Increased Enforcement

The Federal Trade Commission (FTC) recently provided testimony to the House Committee on Appropriations, Subcommittee on Financial Services and General Government concerning its fiscal year (FY) 2024 budget request....more

Supreme Court Determines That Constitutionality of FTC’s Administrative Review Process Can Be Challenged in Federal District Court

The Federal Trade Commission (FTC) has the distinct advantage of being able to bring enforcement actions before its own administrative tribunals....more

New HSR Filing Fee Tier System in Effect

On February 27, 2023, the new Hart-Scott-Rodino (HSR) filing thresholds took effect. The size-of-transaction threshold changed from $101 million to $111.4 million, as the values are adjusted annually based on the change in...more

DOJ’s Antitrust Division Continues Its Pursuit of Overlapping Directorates

On March 9, 2023, the Antitrust Division of the U.S. Department of Justice (DOJ) announced that five directors resigned from four separate corporate boards and that another corporation declined to exercise its board...more

Accompanying Statements to Hart-Scott-Rodino Annual Report Exemplify Ongoing Tension at FTC

Federal Trade Commission (FTC) Commissioner Christine Wilson’s February 7, 2023, statement accompanying the Fiscal Year 2021 Hart-Scott-Rodino (HSR) Annual Report chastised the other three Commissioners for requesting more...more

DOJ Withdraws Long-Standing Health Care Antitrust Enforcement Policy Statements

In a quiet yet shocking announcement on February 3, 2023, the Antitrust Division of the U.S. Department of Justice (DOJ) withdrew three major antitrust policy statements that have served for years as mainstays of health care...more

FTC Tries Again to Provide Guidance on Enforcement Under Section 5 of FTC Act

The Federal Trade Commission (FTC) is authorized, pursuant to section 5 of the Federal Trade Commission Act (the “Act”), to address “unfair methods of competition.”...more

Independent Physician Association Enforcement Not Forgotten

On September 30, 2022, the Federal Trade Commission (FTC) obtained civil monetary penalties in the amount of $263,000 from San Juan IPA, Inc. (“San Juan”), an independent physician association operating in northwestern New...more

FTC Commissioner Favors Fairness over Efficiency

On September 22, 2022, Commissioner Alvaro Bedoya of the Federal Trade Commission (FTC) delivered a speech entitled “Returning to Fairness,” challenging basic tenets of antitrust law and current enforcement....more

FTC Testimony to Senate—with a Dissent

On September 20, 2022, the Chair of the Federal Trade Commission (FTC) testified before the U.S. Senate Judiciary Committee’s Subcommittee on Antitrust, Competition Policy, and Consumer Rights on “Oversight of the Enforcement...more

FTC Publishes Its Strategic Plan for Next Five Years

On August 26, 2022, the Federal Trade Commission (FTC) published its “Strategic Plan for Fiscal Years 2022–2026,” as required under the GPRA Modernization Act of 2010....more

FTC Maintains Strong Opposition to COPAs

On August 15, 2022, the Federal Trade Commission (FTC) released the FTC Policy Perspectives and Certificates of Public Advantage staff policy paper, along with a fact sheet....more

FTC Reaches Agreement with NLRB to Further Protect Labor Markets

The Federal Trade Commission (FTC) and the Department of Justice have prioritized the protection of labor markets. From scrutinizing “no-poach” agreements and restrictive covenants to analyzing the impact of mergers and...more

Federal Trade Commission’s Focus on Pharmacy Benefit Managers

In early June, the Federal Trade Commission (FTC) exercised its authority under Section 6(b) of the Federal Trade Commission Act and launched an inquiry into prescription benefit managers (PBMs)....more

A Recently-Released “Discussion Draft” of the “American Data Privacy and Protection Act” Provides Insight Into Recent Bipartisan...

As reported in a June 3, 2022 press release from the House Committee on Energy and Commerce, U.S. Representatives Frank Pallone, Cathy McMorris Rodgers, and Senator Roger Wicker released a “discussion draft” of a federal data...more

Constitutionality of FTC’s Structure and Procedures Under SCOTUS Review

Both the Federal Trade Commission (FTC) and the Antitrust Division of the Department of Justice (DOJ) have authority to enforce Section 7 of the Clayton Act by investigating and challenging mergers where the effect of such...more

FTC Has Full Slate of Commissioners

Last week, the U.S. Senate confirmed the nomination of Alvaro Bedoya to fill the open fifth Commissioner seat on the Federal Trade Commission (FTC). The confirmation fills the vacancy left when Rohit Chopra resigned in...more

Final Listening Forum on Firsthand Effects of Mergers and Acquisitions to Be Held on May 12, 2022

The Federal Trade Commission (FTC) and the Antitrust Division of the U.S. Department of Justice (DOJ) are actively considering ways to “modernize” and strengthen their merger enforcement guidelines....more

What Happens When Parties Abandon a Transaction Challenged by the FTC?

When the Federal Trade Commission (FTC) makes a determination to challenge a hospital transaction, the FTC first seeks injunctive relief from the relevant federal district court, requesting that the court prohibit the...more

FTC and DOJ to Hold Listening Forums on Merger Experience

As part of their initiative to reevaluate both the 2010 Horizontal Merger Guidelines and the 2020 Vertical Merger Guidelines (collectively, “Merger Guidelines”), the Federal Trade Commission (FTC) and U.S. Department of...more

Return of Early Termination of the HSR Waiting Period Not on the FTC’s Agenda, According to Commissioner Phillips

Parties to a transaction subject to the reporting requirements of the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR) must adhere to a statutory waiting period (30 days for most transactions) after filing their...more

Revised HSR Thresholds in Effect on February 23

Adjustments to the reporting thresholds under the Hart-Scott-Rodino Antitrust Improvements (HSR) Act of 1976 are in effect as of February 23, 2022....more

Antitrust Enforcers Continue March to Protect Labor Markets in Health Care and Other Industries

On January 28, 2022, a federal grand jury in Maine returned an indictment charging four managers of home health care agencies with participating in a conspiracy to suppress the wages and restrict the job mobility of Personal...more

FTC and DOJ Seek Public Comments on Merger Guidelines

The Federal Trade Commission and the U.S. Department of Justice’s Antitrust Division announced last week that they are soliciting public comments on ways to “modernize federal merger guidelines” to assist the agencies in...more

Hospital Transactions Subject to Hart-Scott-Rodino Reporting Obligations See Dramatic Rise in Second Requests for Information

Hospital transactions, including acquisitions and mergers, that meet Hart-Scott-Rodino (HSR) thresholds must, subject to any available exception, be reported to the Federal Trade Commission (FTC) and the Antitrust Division of...more

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