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DOJ and HHS Coordinate Enforcement Efforts in Health Care

The Antitrust Division of the U.S. Department of Justice (DOJ) and the Office of Inspector General of the U.S. Department of Health and Human Services (HHS) entered into a Memorandum of Understanding (MOU), effective December...more

DOJ Continues to Emphasize Antitrust Merger Enforcement

The Deputy Assistant Attorney General of the Antitrust Division of the U.S. Department of Justice (DOJ), Andrew Forman, recently spoke to the American Bar Association’s Mergers and Acquisitions Committee at the Business Law...more

FTC Commissioner Favors Fairness over Efficiency

On September 22, 2022, Commissioner Alvaro Bedoya of the Federal Trade Commission (FTC) delivered a speech entitled “Returning to Fairness,” challenging basic tenets of antitrust law and current enforcement....more

FTC Testimony to Senate—with a Dissent

On September 20, 2022, the Chair of the Federal Trade Commission (FTC) testified before the U.S. Senate Judiciary Committee’s Subcommittee on Antitrust, Competition Policy, and Consumer Rights on “Oversight of the Enforcement...more

FTC Reaches Agreement with NLRB to Further Protect Labor Markets

The Federal Trade Commission (FTC) and the Department of Justice have prioritized the protection of labor markets. From scrutinizing “no-poach” agreements and restrictive covenants to analyzing the impact of mergers and...more

On First Anniversary of Executive Order on Competition, DOJ Celebrates Interagency Efforts to Promote Competitive Markets

The U.S. Department of Justice (DOJ) recently recognized the first anniversary of President Biden’s Executive Order on Promoting Competition in the American Economy (EO) and “celebrated the Antitrust Division’s most...more

Federal Trade Commission’s Focus on Pharmacy Benefit Managers

In early June, the Federal Trade Commission (FTC) exercised its authority under Section 6(b) of the Federal Trade Commission Act and launched an inquiry into prescription benefit managers (PBMs)....more

Final Listening Forum on Firsthand Effects of Mergers and Acquisitions to Be Held on May 12, 2022

The Federal Trade Commission (FTC) and the Antitrust Division of the U.S. Department of Justice (DOJ) are actively considering ways to “modernize” and strengthen their merger enforcement guidelines....more

Antitrust Enforcers Continue March to Protect Labor Markets in Health Care and Other Industries

On January 28, 2022, a federal grand jury in Maine returned an indictment charging four managers of home health care agencies with participating in a conspiracy to suppress the wages and restrict the job mobility of Personal...more

Hospital Transactions Subject to Hart-Scott-Rodino Reporting Obligations See Dramatic Rise in Second Requests for Information

Hospital transactions, including acquisitions and mergers, that meet Hart-Scott-Rodino (HSR) thresholds must, subject to any available exception, be reported to the Federal Trade Commission (FTC) and the Antitrust Division of...more

Commissioner Wilson Issues Strong Comments to Antitrust Bar

On November 9, 2021, Federal Trade Commission (FTC) Commissioner Christine Wilson addressed the American Bar Association Antitrust Law Section’s 2021 Fall Forum. Her prepared comments, entitled “The Neo-Brandeisian...more

Federal Trade Commission Continues Quest to Stem the Merger Tide

The Federal Trade Commission (FTC) has reimplemented a policy of requiring all merger enforcement orders to include the requirement that acquisitive firms obtain prior approval from the FTC before closing any future...more

FTC Chair Outlines Vision and Priorities

Chair Khan’s Priorities - In a memo dated September 22, 2021, the Chair of the Federal Trade Commission (“FTC”), Lina Khan, described for the FTC Staff and fellow Commissioners what she described as her “vision and...more

FTC Moves to Revamp and Increase Merger Retrospective Reviews

On September 17, 2020, the Federal Trade Commission (“FTC”) announced efforts to revamp and increase its retrospective research efforts. This retrospective analysis, which has been a continuing project for the FTC, “seeks to...more

Are Efforts to Speed Up Antitrust Merger Reviews Working?

Last September, Makan Delrahim, the Assistant Attorney General for the Antitrust Division of the Department of Justice (“DOJ”), announced efforts to streamline antitrust merger reviews with a stated goal of completing the...more

Seeking Opinions on Potential Conduct from the Antitrust Division of the Department of Justice

The Antitrust Division of the Department of Justice (“DOJ”) has a process that allows organizations to seek written opinions from the agency on whether proposed conduct will violate the antitrust laws. (The Federal Trade...more

The Benefits of an Effective Antitrust Compliance Program

The Antitrust Division of the U.S. Department of Justice (“DOJ”) recently released guidance outlining how DOJ evaluates antitrust corporate compliance programs as part of its Corporate Leniency program. This guidance...more

Early Termination of HSR Waiting Period Is Not Available During Government Shutdown

The Hart-Scott-Rodino Antitrust Improvements Act (“HSR”) (section 7A of the Clayton Act, 15 U.S.C. §18a) requires parties to a transaction meeting certain size thresholds to complete and file a Notification and Report Form...more

Will the FTC Match DOJ’s Efforts to Speed Up Merger Reviews?

On October 3, 2018, at a hearing before the U.S. Senate Subcommittee on Antitrust, Competition Policy, and Consumer Rights (“Hearing”), Makan Delrahim, the Assistant Attorney General for the Antitrust Division of the...more

Subtle Changes to Final Judgments by Antitrust Enforcers Prove Costly to Defendants

The Federal Trade Commission and the Antitrust Division of the U.S. Department of Justice (collectively, the “Federal Antitrust Enforcement Agencies”) have made a concerted effort of late to describe themselves as “antitrust...more

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