Over the past few weeks, several Trump Administration antitrust enforcers at both the Federal Trade Commission (“FTC”) and U.S. Department of Justice Antitrust Division (“DOJ Antitrust”) have written or spoken about the...more
5/7/2025
/ Acquisitions ,
America First Trade Policy ,
Antitrust Litigation ,
Department of Justice (DOJ) ,
Diversity and Inclusion Standards (D&I) ,
Enforcement ,
Federal Trade Commission (FTC) ,
Mergers ,
Popular ,
Private Equity ,
Trump Administration
On January 14, 2025, the Federal Trade Commission (FTC) Office of Policy Planning released a second Interim Staff Report titled Specialty Generic Drugs: A Growing Profit Center for Vertically Integrated Pharmacy Benefit...more
1/24/2025
/ Competition ,
Cost-Sharing ,
Drug Pricing ,
Federal Trade Commission (FTC) ,
Generic Drugs ,
Health Insurance ,
Life Sciences ,
Mergers ,
Pharmaceutical Industry ,
Pharmacy Benefit Manager (PBM) ,
Prescription Drugs ,
Reimbursements
When considering the health care enforcement landscape in 2024 and where it might be headed in 2025, we would be remiss if we did not address the enforcement activities of state and federal agencies beyond those typically...more
The Federal Trade Commission (FTC) announced Friday increased jurisdictional thresholds for (1) notifications under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act), (2) the HSR Act filing fee schedule,...more
1/15/2025
/ Antitrust Division ,
Antitrust Provisions ,
Competition ,
Department of Justice (DOJ) ,
Federal Trade Commission (FTC) ,
Filing Fees ,
Hart-Scott-Rodino Act ,
Mergers ,
Pre-Merger Filing Requirements ,
The Clayton Act ,
Threshold Requirements
On December 18, 2023, the Federal Trade Commission (“FTC”) and the Department of Justice (“DOJ”) (collectively, the “Agencies”) published the long-awaited final 2023 Merger Guidelines. The 2023 Merger Guidelines are informed...more
12/29/2023
/ Antitrust Division ,
Biden Administration ,
Competition ,
Department of Justice (DOJ) ,
Enforcement ,
Executive Orders ,
Federal Trade Commission (FTC) ,
Horizontal Mergers ,
Mergers ,
Private Equity ,
Request For Information ,
The Clayton Act ,
Transparency ,
Vertical Mergers
Since the beginning of Chair Khan’s tenure at the Federal Trade Commission (and in line with President Biden’s aim to curb rising health care costs), the current FTC has committed to bring enforcement actions against health...more
For years, the antitrust enforcement agencies have indicated their antipathy toward resolving competition issues in proposed mergers by entering into consent decrees that prohibit certain conduct, rather than stopping the...more
On July 19, the Federal Trade Commission (“FTC”) and the Department of Justice (“DOJ”) (collectively, the “Agencies”) published Draft Merger Guidelines. The Draft Merger Guidelines, if adopted, would replace both the...more
The Federal Trade Commission, in coordination with the U.S. Department of Justice Antitrust Division, recently released a summary of the Agencies’ June 2022 joint workshop titled “The Future of Pharmaceuticals: Examining the...more