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DOJ Obtains First Criminal Monopolization Conviction in Over 40 Years: Revolution or Reprise?

On October 31, 2022, the US Department of Justice (DOJ) secured a criminal guilty plea from Nathan Zito, the president of a Montana paving and asphalt contractor, to attempted monopolization under Section 2 of the Sherman...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

HSR Size of Transaction Threshold to Increase to $101 Million

On January 21, 2022, the Federal Trade Commission (FTC) announced revised thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Effective February 23, 2022, the lowest size-of-transaction filing threshold...more

We Didn’t Like Your Merger, So Please Come Back: FTC Issues New Prior Approval Policy for Challenged and Aborted M&A Transactions

The US Federal Trade Commission (FTC or Commission) has announced a new policy to dramatically expand its use of prior approval orders in merger transactions. On October 25, the FTC issued a policy statement (Statement) under...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

Focus on Healthcare in New Biden Administration Executive Order on Competition

On July 9, 2021, the Biden Administration issued an Executive Order on “Promoting Competition in the American Economy.” The Order is notable in its breadth and commitment to a coordinated federal government approach to...more

US Supreme Court Bars the FTC from Seeking Restitution under Section 13(b) of the FTC Act: What Businesses Can Expect

On April 22, 2021, the US Supreme Court ruled that Section 13(b) of the Federal Trade Commission Act, which authorizes the Federal Trade Commission (FTC) to pursue certain injunctive relief in court, does not authorize the...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

HSR Size of Transaction Threshold to Decrease to $92 Million

On February 2, 2021, the Federal Trade Commission (FTC) announced revised thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Effective March 4, 2021, the lowest size-of-transaction filing threshold...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

DOJ Updates Guidance for Merger Remedies: What Businesses Need to Know

On September 3, 2020, the Department of Justice Antitrust Division (DOJ) updated its 2004 Merger Remedies Manual (see here). The updated Manual clarifies important aspects of the DOJ’s merger remedy practice about which there...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

HSR Size of Transaction Threshold to Increase to $94 Million

On January 28, 2020, the Federal Trade Commission (FTC) announced revised thresholds for merger notifications under the Hart-Scott-Rodino (HSR) Act. Parties to transactions that close on or after February 27, 2020 are subject...more

More Bite, Less Bark: Merger Enforcement at the FTC in the Trump Administration

Since the beginning of the Trump Administration, the Antitrust Division of the Department of Justice (DOJ) has captured headlines for its aggressive public stance regarding merger enforcement. Actions attracting attention...more

Pre-Merger Information Sharing: The FTC Weighs In

A month ago, we covered recent European competition law developments on pre-merger information sharing and “gun jumping” among merging parties. In a timely reminder that the same questions also are relevant in the United...more

Federal Trade Commission Update: Senate Hearings Reveal No Obvious Hurdles for Commissioner Nominees

The Senate Commerce Committee held a hearing on Wednesday on the nominees to serve on the Federal Trade Commission (FTC). The nominees are Joseph Simons (Chairman Designate), Christine Wilson, Noah Phillips and Rohit Chopra....more

HSR Size of Transaction Threshold to Increase to $84.4 Million

The Federal Trade Commission ("FTC") announced revised thresholds for merger notifications under the Hart-Scott-Rodino ("HSR") Act. Once effective, the lowest size-of-transaction filing threshold (also known as the "$50...more

Wait, I Thought We Were Done? DOJ Challenges $4B Merger Months After HSR Filing and Expiration of the HSR Waiting Period

Earlier this week, the Antitrust Division of the Department of Justice (DOJ) filed a lawsuit seeking to unwind Parker-Hannifin's $4.3 billion consummated acquisition of Clarcor. This is a notable challenge for two reasons. ...more

Facelift for Two Millennials: DOJ and FTC Update Guidelines for IP Licensing and International Enforcement

More than 21 years ago, the US antitrust agencies issued guidance to the business community on two critical topics of antitrust enforcement: (1) the licensing of intellectual property rights and (2) international enforcement...more

Developments in Merger Control: It Ain't Over 'til It's Over

Two recent enforcement actions are reminders that there are antitrust risks to be addressed after the deal is signed and even after it has closed. In the United States, the Federal Trade Commission (FTC) challenged Valeant...more

FTC/DOJ Guidance to Human Resource Professionals - Enforcement Scrutiny of Employment-Related Conduct

Last month, the Federal Trade Commission (FTC) and Department of Justice (DOJ) issued their Antitrust Guidance for Human Resource Professionals. The HR Guidance reflects the agencies' enhanced scrutiny in a realm that may not...more

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