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Antitrust Breakup Fees: 2023 Data and Key Takeaways for Future Dealmaking

Looking back at 2023 mergers and acquisitions (M&A) activity, antitrust-related breakup fees continued to be an important tool in allocating antitrust risk between deal parties. These typically take the form of a “reverse”...more

New Year, New Merger Control Thresholds and Filing Fees

The Federal Trade Commission (FTC) announced 2024 adjustments to the Hart-Scott-Rodino (HSR) thresholds. These thresholds determine which mergers and acquisitions may be required to be reported to United States federal...more

4 Antitrust Enforcement Trends for 2024

In the coming year, Federal Trade Commission (“FTC”) Chair Lina Khan and Department of Justice (“DOJ”) Assistant Attorney General of the Antitrust Division Jonathan Kanter are expected to continue to advance a more aggressive...more

The No-Longer Nascent Use of Nascent Competition Theory

Recent trends in antitrust merger enforcement have brought into sharp focus the acquisition of nascent or potential competitors in the technology and life sciences sectors. These deals include so-called “killer acquisitions”...more

FTC and DOJ Publish Final Revised Merger Guidelines, Driving Increased Uncertainty for M&A Activity

On December 18, 2023, the Federal Trade Commission (FTC) and Department of Justice Antitrust Division (DOJ) (together, the “agencies”) jointly released their final revised 2023 Merger Guidelines, reflecting modest adjustments...more

Navigating Healthcare Antitrust in the Biden Era

It’s no secret that Democrats are traditionally trustbusters, but the Biden Administration is taking things to a whole new level, bringing novel—and arguably weak—cases that nonetheless slow or block tie-ups among healthcare...more

FTC Employs New Tactic in Effort Against Drug Makers Alleged to Have Improperly Listed Patents in the FDA’s Orange Book

On Nov. 7, 2023, the Federal Trade Commission (FTC) announced it is disputing the listing of more than 100 patents in the Food and Drug Administration’s (FDA) “Approved Drug Products with Therapeutic Equivalence Evaluations,”...more

US Merger Control Notification Threshold Increases to $111.4 Million

The Federal Trade Commission (FTC) announced 2023 adjustments to the Hart-Scott-Rodino (HSR) thresholds. These thresholds determine which mergers and acquisitions must be reported to United States federal antitrust agencies...more

Congress’s Year-end Spending Bill Significantly Increases US Merger Control Filing Fees for Large M&A Transactions

On December 23, 2022, Congress passed the Consolidated Appropriations Act of 2023 (the “Act”) with bipartisan support. In addition to numerous spending provisions totaling $1.7 trillion, the Act includes antitrust-related...more

With Microsoft Complaint, Lina Khan’s FTC Takes on Another Big Tech Gaming Deal

On December 8, 2022, the same day that the Federal Trade Commission (FTC) delivered its opening arguments to a federal judge in California in the FTC’s bid to halt Meta’s acquisition of virtual reality gaming company Within,...more

The FTC Continues to Broaden Its Enforcement Authority to Pursue Chair Khan’s Agenda

On July 9, 2021, just days into her tenure as Federal Trade Commission (FTC or Commission) Chair, Lina Khan led the Commission’s charge to rescind the agency’s 2015 policy statement (2015 Statement) on its approach to...more

Tech Companies Bear the Brunt of DOJ Push on Interlocking Directorates

The United States Department of Justice (DOJ) announced last week that directors at several technology companies have resigned as a consequence of the agency’s renewed focus on overlapping board membership between...more

European Commission Acts to Block Illumina-Grail Transaction Just Days After Judge Rejects FTC Action Against the Deal

This morning the European Commission (EC) moved to unwind and block Illumina’s $7.1 billion acquisition of Grail. Illumina announced that it intends to appeal the decision. This development comes on the heels of Illumina’s...more

FTC’s Ambitious Challenge to Meta VR Deal Possesses Sweeping Implications for Tech M&A

FTC Suit Aspires to Chill M&A-Based Growth by Larger Tech Firms - Federal Trade Commission Chair Lina Khan has consistently criticized past FTC leadership for being too lenient with Big Tech M&A activity, and for not...more

Bedoya Confirmation to FTC Empowers Chair Lina Khan to Pursue Progressive Agenda

After months of partisan deadlock, this week Georgetown law professor and privacy scholar Alvaro M. Bedoya was confirmed by the Senate to serve as a member of the Federal Trade Commission (FTC). Bedoya’s confirmation gives...more

Historic Shift by the FTC on Vertical Merger Review, with More to Come

In a departure from past enforcement priorities, the Federal Trade Commission has challenged three vertical mergers over the past year, leading the parties to abandon two of the three deals...more

US Merger Control Notification Threshold Increases to $101 Million

The Federal Trade Commission announced its 2022 adjustments to the Hart-Scott-Rodino (HSR) thresholds. These thresholds determine which mergers and acquisitions must be reported to United States federal antitrust agencies for...more

The Restoration & Return of Prior Approval Provisions in FTC Merger Orders

Earlier this week, the Federal Trade Commission officially reinstated the practice of including “prior approval” requirements in consent orders settling merger investigation cases by the Commission (the 2021 Statement), the...more

Antitrust Update: Recent FTC Announcements

On September 28, 2021, the U.S. Federal Trade Commission (FTC) published a blog post outlining the agency’s plans to expand and purportedly strengthen its process for in-depth investigations of transactions (known as “Second...more

Mixed Ruling on Epic’s Antitrust Challenge to Apple’s App Store

On September 10, 2021, a federal judge in the U.S. District Court for the Northern District of California ruled that Fortnite developer Epic Games (Epic) failed to adequately prove its antitrust allegations relating to...more

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