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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

“Roll Up” or Roll On Out: Court Dismisses FTC Lawsuit Against Private Equity Firm Welsh Carson Under Section 13(b)

In a decision with significant implications for private equity firms and minority investors, on May 13, 2024, the US District Court for the Southern District of Texas dismissed the Federal Trade Commission’s (FTC) suit...more

Antitrust Division’s Updated Leniency Policy Impacts Leniency for Acquirors

The Antitrust Division of the Department of Justice has quietly made a change to its Leniency Policy and Procedures (the “Leniency Policy”) that could impact companies involved in transactions that discover potential...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

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

Blast From the Past: FTC Revives Conglomerate Concerns as Basis for Merger Challenges

On May 16, 2023, the Federal Trade Commission filed a complaint in the Northern District of Illinois seeking to enjoin closing of Amgen Inc.’s proposed $28 billion acquisition of Horizon Therapeutics. This is the first time...more

Highway to the Danger Zone: DOJ Withdraws Safety Zone Guidance for Healthcare Industry

The Department of Justice Antitrust Division (DOJ) recently withdrew three sets of policy statements regarding the US antitrust agencies’ enforcement approach to conduct in the healthcare industry. These policy statements...more

To Share or Not to Share: DOJ Withdraws Information Sharing Guidance

The Department of Justice (DOJ) Antitrust Division recently withdrew three sets of policy statements regarding the US antitrust agencies’ enforcement approach to conduct in the healthcare industry that may have broader...more

Is Vertical the New Horizontal for FTC Merger Enforcement? Recent Agency Challenges and the Way Forward

Since March 2021, the Federal Trade Commission (FTC or Commission) has challenged three proposed acquisitions based on vertical competitive concerns. The parties in two of those transactions - Nvidia/Arm and Lockheed...more

The FTC’s New “Warning Letter” in Merger Reviews: More Waiting After the HSR Waiting Period?

In an August 3 blog post, the Federal Trade Commission (FTC) announced a change to the FTC’s merger review process with potentially far-reaching effects. Emphasizing the agency’s constrained capacity resulting from a “tidal...more

FTC’s First Open Meeting Highlights Aggressive Enforcement Priorities and Partisan Divide

On Thursday, July 1, the Federal Trade Commission held its first meeting under Chair Lina M. Khan and first open business meeting in over twenty years. The Commission considered four items during the nearly two hour long...more

Developments in Antitrust Law: Keep an Eye on New York

Although much attention recently has been focused upon debates in Congress, potential legislative changes to U.S. antitrust law are not limited to proposals at the federal level. Many states are considering changes to their...more

117th Congress Takes Early Steps Towards Antitrust Reform

Critics of modern antitrust enforcement have been building momentum towards antitrust reform over the last several years. In the first week of February 2021, several members of Congress signaled that bipartisan legislative...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

Antitrust Populism and the Consumer Welfare Standard: What Are We Actually Debating?

For the last several years, debate over the proper role of antitrust has not been limited to academics, economists, lawyers, and judges, but routinely includes politicians, journalists, and increasingly the general public....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

COVID-19: An Antitrust Checklist

Businesses around the world are actively working to address the global COVID-19 pandemic, including through novel types of collaborations. In the United States, federal and state agencies, including the Department of Justice...more

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