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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 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

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

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

European Commission Blocks Illumina/GRAIL a week after FTC’s Administrative Law Judge Rejects FTC’s Challenge

The last week has seen crucial developments at the European Commission (EC) and U.S. Federal Trade Commission (FTC) regarding the antitrust review of the $7.1 billion proposed acquisition by Illumina (the leading supplier of...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

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

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

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

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 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

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