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Proposed FTC Budget Signals Continued Enforcement Initiatives

The Federal Trade Commission’s (FTC’s) recently proposed fiscal year 2025 budget makes clear that enforcement is still a high priority....more

Are Conduct Remedies to Merger Challenges Back on the Table?

The leadership of the Federal Trade Commission (FTC) and the Antitrust Division of the Department of Justice uniformly describe the mandate of their respective agencies as one of antitrust “enforcement” and not “regulation.”...more

Supreme Court Determines That Constitutionality of FTC’s Administrative Review Process Can Be Challenged in Federal District Court

The Federal Trade Commission (FTC) has the distinct advantage of being able to bring enforcement actions before its own administrative tribunals....more

Independent Physician Association Enforcement Not Forgotten

On September 30, 2022, the Federal Trade Commission (FTC) obtained civil monetary penalties in the amount of $263,000 from San Juan IPA, Inc. (“San Juan”), an independent physician association operating in northwestern New...more

What Happens When Parties Abandon a Transaction Challenged by the FTC?

When the Federal Trade Commission (FTC) makes a determination to challenge a hospital transaction, the FTC first seeks injunctive relief from the relevant federal district court, requesting that the court prohibit the...more

Lina Khan Takes Charge of the Federal Trade Commission

On June 15, 2021, in a 69–28 vote, the Senate confirmed Lina Khan to fill the current vacancy at the Commissioner level of the Federal Trade Commission (“FTC”). Immediately upon her confirmation, President Biden tapped Ms....more

Distinguishable Products and Tying Claims in Health Care Markets

Unlawful tying occurs when an entity with market power in one product (the “tying” product) agrees to sell that product but only on the condition that the buyer also agrees to buy a second product (the “tied” product), or at...more

FTC Issues Its Financial Report for Fiscal Year 2020

On November 16, 2020, the Federal Trade Commission (“FTC”) issued its annual financial report. For the seventh consecutive year, the FTC has made the determination to issue an annual financial report and separately issue (in...more

Revisiting a Dominant Firm’s Obligation Under the Antitrust Laws to Deal with a Rival

One of the more difficult questions faced by a dominant firm is whether to do business with a rival. The general rule, premised on the principle that true competition affords everyone the ability to make decisions about whom...more

Oncology Provider Is Subject to $100 Million Criminal Antitrust Penalty

On April 30, 2020, the Antitrust Division of the U.S. Department of Justice (“DOJ”) issued a press release announcing a deferred prosecution agreement with a major oncology practice in Florida. As a condition of the deferred...more

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