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Federal Court Applies Antitrust Standard of Per Se Illegality to “Algorithmic Pricing” Case

A federal district court in Seattle recently issued an important antitrust decision on “algorithmic pricing.” Algorithmic pricing refers to the practice in which companies use software to help set prices for their products or...more

Hart-Scott-Rodino Reporting Threshold Increases by $6.9 Million

The past two weeks have been quite busy in the world of the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (15 U.S.C. § 18a) (HSR). First, on January 7, 2025, the Federal Trade Commission (FTC) announced a record $5.6...more

FTC Announces Final Junk Fees Rule Applying to Live-Event Tickets and Short-Term Lodging

On December 17, 2024, the U.S. Federal Trade Commission (FTC) announced its final “Junk Fees Rule” (the “Final Rule” or “Rule”) to prevent certain practices related to pricing in the live-event ticketing and short-term...more

FTC and DOJ Withdraw Guidelines for Collaborations Among Competitors

On December 11, 2024, the U.S. Department of Justice (DOJ) and the Federal Trade Commission (FTC) (together, “the Agencies”) jointly withdrew the 2000 Antitrust Guidelines for Collaborations Among Competitors (“Guidelines”)....more

FTC Finalizes Long-Awaited Rules that Will Substantially Increase the Scope and Detail of Premerger Antitrust Filings under...

The FTC has finalized significant changes to the information and level of detail that will be required in premerger antitrust filings under the HSR Act. The new rules will take effect in early 2025. Among other changes,...more

DOJ and FTC Raise Concerns about Overlapping Ownership in Public Utility Companies

On April 25, 2024, the U.S. Department of Justice Antitrust Division (DOJ) and the Federal Trade Commission (FTC) filed a joint comment with the Federal Energy Regulatory Commission (FERC or Commission) raising concerns about...more

FTC Issues Warning on the Use of Algorithms to Recommend or Set Prices

The U.S. Federal Trade Commission (FTC) recently published a blog post warning that the use of algorithms to assist in determining prices may violate federal antitrust laws, regardless of the business or industry. The FTC...more

FTC Blocks Interlocking Directorate and Makes Good on Its Commitment to Pursue Purported “Unfair Methods of Competition” as...

For the first time in 40 years, the Federal Trade Commission (FTC) has taken action to enforce Section 8 of the Clayton Act, which prohibits so-called interlocking directorates. In the same action, the FTC mounted its first...more

Colorado Antitrust Reform Carries Broad State Impact

During its 2023 legislative session, the Colorado General Assembly repealed the state's prior antitrust law — the Colorado Antitrust Act of 1992 — and passed the Colorado State Antitrust Act of 2023. On June 7, Colorado...more

FTC Proposes Sweeping Changes to Hart-Scott-Rodino Filing Requirements

On June 27, 2023, the Federal Trade Commission (FTC), with the concurrence of the Department of Justice Antitrust Division, announced a wide range of significant proposed changes to the Hart-Scott-Rodino (HSR) pre-merger...more

Antitrust: DOJ Scuttles ACO Guidance, Unsettles Ground under Provider Joint Contracting Models

On Friday, February 6, 2023, the Department of Justice (DOJ) announced the withdrawal of the 2011 Statement of Antitrust Enforcement Policy Regarding Accountable Care Organizations Participating in the Medicare Shared Savings...more

DOJ Withdraws Policy Statements That Defined Limited Safe Harbor for Information Sharing Among Competitors

On February 3, 2023, the U.S. Department of Justice’s Antitrust Division (DOJ) announced that it is withdrawing three policy statements the DOJ and Federal Trade Commission (FTC) issued between 1993 and 2011, related to...more

Hart-Scott-Rodino Reporting Thresholds and Filing Fee Structure to Change Significantly

On January 26, 2023, the FTC published a Notice in the Federal Register announcing the latest annual adjustments to the statutory thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (15 U.S.C. § 18a)...more

New State Antitrust Enforcement Venue Act Gives State Attorneys General Venue Preference in Antitrust Litigation

On December 29, 2022, President Biden signed the Consolidated Appropriations Act of 2023, an omnibus spending bill that also contained several pieces of key antitrust legislation. In particular, the law included a bill...more

DOJ Antitrust Division and HHS OIG Enter into Partnership to Increase Coordination and Enforcement in Health Care

On December 9, 2022, the U.S. Department of Justice Antitrust Division (DOJ) and Office of Inspector General of the U.S. Department of Health and Human Services (OIG) announced they had entered a Memorandum of Understanding...more

FTC Releases New Policy Statement on “Unfair Methods of Competition” Enforcement under Section 5 of the FTC Act

As part of the Biden Administration’s ongoing efforts to reinvigorate antitrust enforcement and the promotion of competition, on November 10, 2022, the Federal Trade Commission (FTC) released a new “Policy Statement Regarding...more

Colorado Attorney General Releases Proposed Privacy Rules and Begins Holding Stakeholder Meetings

On July 7, 2021, Colorado enacted the Colorado Privacy Act (CPA), becoming the third U.S. state to adopt a comprehensive privacy law. As previously described, the CPA doesn’t apply to everyone. Instead, it only applies to...more

How To Assess Interlocking Directorates In Antitrust Ramp-Up

Recent activity and statements from the U.S. Department of Justice and Federal Trade Commission signal that the federal agencies are likely to be more aggressive in pursuing enforcement against what they identify as...more

FTC Imposes Civil Penalty for Faulty “Messenger Model” Contracting

On September 30, the Federal Trade Commission (FTC) filed a complaint and proposed judgment in U.S. District Court for the District of Columbia against San Juan IPA, Inc. (San Juan) for allegedly operating an unlawful...more

FTC Releases Paper Opposing Certificates of Public Advantage for Health Care Transactions

On August 15, 2022, the Federal Trade Commission (FTC)—in a bipartisan, 5-0 vote—issued a policy paper detailing its concerns with Certificates of Public Advantage (COPAs). The FTC identified six states with active COPA...more

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