News & Analysis as of

Gun-Jumping Department of Justice (DOJ) Hart-Scott-Rodino Act

Jenner & Block

Premerger Enforcement Actions Highlight Importance of HSR Compliance

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Cases involving premerger enforcements under the Hart-Scott-Rodino (HSR) Act are relatively rare. So far in 2025, however, we have seen two such cases involving potentially record-breaking penalties. The timing is notable, as...more

Polsinelli

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

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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

Husch Blackwell LLP

M&A Antitrust Update: 2025 Brings New HSR Thresholds, a Challenge to the HSR Rules, and a Gun-Jumping Violation

Husch Blackwell LLP on

The initial days of 2025 ushered in a trifecta of significant antitrust updates for dealmakers. First, the Federal Trade Commission (FTC) recently announced its annual adjustment to the monetary thresholds that apply to...more

Venable LLP

DOJ Settles Claims of Illegal Pre-Merger Coordination Against Crude Oil Companies with Record $5.6 Million Gun Jumping Penalty

Venable LLP on

On January 7, 2025, the U.S. Department of Justice (DOJ) filed suit against three Texas-based crude oil companies—XCL Resources Holdings, LLC (XCL), Verdun Oil Company II, LLC (Verdun), and EP Energy LLC (EP)—alleging...more

Mayer Brown

M&A Antitrust Alert: FTC Imposes Significant Gun-Jumping Penalty for Unlawful Pre-Merger Coordination Among Crude Oil Producers

Mayer Brown on

M&A practitioners have long regarded the integration planning and execution process as one of the keys to a successful M&A transaction. However, in deals subject to pre-merger antitrust clearance, it is critical to navigate...more

McCarter & English, LLP

FTC Imposes Record $5.6M ‘Gun Jumping’ Fine

Crude oil producers XCL Resources Holdings, LLC (XCL), Verdun Oil Company II LLC (Verdun), and EP Energy LLC (EP) have agreed to pay a $5.6 million civil penalty to settle violations under Section 7A of the Clayton Act, as...more

Wilson Sonsini Goodrich & Rosati

Gun-Jumping Violation Results in Record-Breaking Penalties

The Federal Trade Commission (FTC) has imposed a record-breaking $5.6 million fine on XCL Resource Holdings, LLC (XCL), Verdun Oil Company II LLC (Verdun), and EP Energy LLC (EP) to settle allegations that they engaged in...more

King & Spalding

Record “Gun Jumping” Penalty Imposed by FTC

King & Spalding on

Oil companies ordered to pay $5.6 million for exerting beneficial control before the expiration of the mandatory HSR waiting period. On January 7, 2025, the Federal Trade Commission (“FTC”) filed and resolved a merger...more

Troutman Pepper Locke

FTC Secures Record Gun-Jumping Settlement in Energy Transaction

Troutman Pepper Locke on

The Federal Trade Commission (FTC) and the Department of Justice, Antitrust Division (DOJ) announced a record-setting $5.6 million gun-jumping fine related to Verdun Oil Company II LLC’s acquisition of EP Energy LLC. Although...more

Cooley LLP

DOJ Hits Venue Services Group With $3.5 Million HSR Gun-Jumping Penalty

Cooley LLP on

The US Department of Justice (DOJ) filed a complaint and proposed consent decree alleging that Legends Hospitality Parent Holdings prematurely acquired beneficial ownership – often referred to as “gun jumping” – in connection...more

A&O Shearman

U.S. DOJ Seeks Rare USD3.5 million “Gun Jumping” Penalty For Alleged Pre-Closing Conduct In Violation Of Hart-Scott-Rodino Act

A&O Shearman on

On August 5, 2024, the United States Department of Justice filed a rare gun jumping civil lawsuit and proposed settlement in the United States District Court for the Southern District of New York against a global sports and...more

Bradley Arant Boult Cummings LLP

Justice Department Imposes $3.5 Million Civil Penalty, Strict Conditions Over Gun-Jumping Allegations

Earlier this month, the Department of Justice (DOJ) Antitrust Division filed a consent decree fining venue management firm Legends Hospitality $3.5 million over allegations that Legends improperly coordinated with an...more

Baker Botts L.L.P.

DOJ Obtains $3.5 Million Civil Penalty and Appoints Antitrust Compliance Officer to Resolve Gun-Jumping Concerns

Baker Botts L.L.P. on

On August 5, the Department of Justice (DOJ) secured a landmark decision from the U.S. District Court for the District of Columbia in a high-profile monopolization litigation....more

Morrison & Foerster LLP

Don’t Jump the Gun: The US Department of Justice Issues Rare $3.5 Million Civil Penalty for Gun Jumping

On August 5, 2024, the U.S. Department of Justice (DOJ) filed a proposed settlement with Legends Hospitality Parent Holdings (“Legends”), a global venue services company, in connection with its proposed acquisition of ASM...more

A&O Shearman

U.S. DOJ seeks rare $3.5 million “gun jumping” penalty against Legends Hospitality for pre-closing conduct in connection with its...

A&O Shearman on

On August 5, 2024, the United States Department of Justice (“DOJ”) filed a rare[1] gun jumping[2] civil lawsuit and proposed settlement in the United States District Court for the Southern District of New York against Legends...more

Vinson & Elkins LLP

Gun-Jumping Isn’t the Stuff of Legends: DOJ Fines Hospitality Management Company $3.5 Million for Alleged Unlawful Pre-merger...

Vinson & Elkins LLP on

On August 5, 2024, the Department of Justice (“DOJ”) announced that it filed a civil complaint and proposed settlement with Legends Hospitality Parent Holdings LLC (“Legends”) for unlawful pre-merger coordination, commonly...more

Mintz - Antitrust Viewpoints

Sporting Events Business Faces $3.5 Million in Antitrust Gun Jumping Penalties

This week, the Antitrust Division of the U.S. Department of Justice (DOJ) reached one of its largest “gun jumping” settlements following allegations that sporting and entertainment events company, Legends Hospitality,...more

Vinson & Elkins LLP

Antitrust Issues in Renewable Energy - November 2023

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Participants in the renewable energy industry should be aware of antitrust and competition rules because renewable energy is no longer a nascent field. Europe generated almost 40% of its electricity from renewable sources in...more

McDermott Will & Emery

Heard at the 2023 Spring Meeting: Part 1

The American Bar Association’s Antitrust Law Section recently held its annual Spring Meeting in Washington, DC, featuring updates from federal, state, and international antitrust enforcers and in-depth commentary on leading...more

Polsinelli

Antitrust Enforcers Target Securities Transactions for Violating the HSR ACT

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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

Jones Day

Transaction "Designed" to Evade Merger Control Leads to U.S. and EU Penalties

Jones Day on

The Development: Antitrust authorities in the United States and European Union have assessed penalties and fines against Canon, and in the United States, Toshiba, for structuring a transaction to avoid premerger notification...more

Jones Day

FTC Warns Parties on Information Exchanges During M&A Due Diligence

Jones Day on

The Situation: The Federal Trade Commission ("FTC") recently published a blog post reminding merging parties to avoid creating antitrust liability through the exchange of competitively sensitive information during merger...more

A&O Shearman

Gun-jumping and Procedural Compliance

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The EU and U.S. competition authorities have been and remain active in enforcing gun-jumping cases, while in recent years other competition authorities across the world, including in China, have also become increasingly...more

Polsinelli

Avoiding the “Gun Jumping” Trap in Mergers and Acquisitions

Polsinelli on

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

King & Spalding

DOJ Challenges Illegal Antitrust “Gun Jumping” In Energy Transaction

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The Department of Justice Antitrust Division recently brought a civil antitrust lawsuit against Duke Energy Corporation, alleging that the electric power generator engaged in illegal “gun jumping” by obtaining beneficial...more

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