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FTC Targets Contractual Restrictions on Voluntary Cooperation

The staff of the Federal Trade Commission (FTC) Bureau of Competition issued a statement on June 15, 2023, sternly criticizing the use of confidentiality and nondisclosure agreements that “impede” the FTC’s ability to conduct...more

DOJ Withdraws Healthcare Antitrust Policy Statements

The U.S. Department of Justice (DOJ), Antitrust Division, recently withdrew three sets of guidelines that had been relied upon heavily by the healthcare industry: the 1993 Antitrust Enforcement Policy Statements Issued for...more

Three Reasons Companies Need Customized Antitrust Compliance Programs Now

Antitrust compliance programs that are tailored to a company’s culture, line of business, and competitive conditions have long been worth their weight in gold. But as 2022 draws to a close, a looming economic slowdown and an...more

Abandoned Hospital Merger Reveals Lessons for Healthcare M&A

A proposed healthcare acquisition was abandoned following the Federal Trade Commission’s (FTC or the Commission) unanimous vote to oppose the transaction. In the face of 5-0 FTC opposition, New Jersey providers RWJBarnabas...more

DOJ Update Underscores Risks when Responding to Antitrust CIDs

The Antitrust Division (Division) of the U.S. Department of Justice (DOJ) announced an update to its Civil Investigative Demand (CID) forms and its investigative deposition process on September 10. When conducting civil...more

Antitrust Enforcers Unlikely to Lessen Scrutiny of Healthcare Mergers During Pandemic

COVID-19 has financially stressed the U.S. healthcare system in several ways. In many cities, hospitals have needed to add healthcare capacity (especially ICU beds) to serve rapidly increasing numbers of COVID-19 patients. At...more

Coronavirus Triggers Concerns Over Price Gouging

Last Friday, the White House declared a national state of emergency amid concerns of the global spread of the coronavirus. Nearly every state and numerous cities have followed suit by issuing declarations triggering emergency...more

“Reasonableness” Is in the Eye of the Beholder: Vague Contracts Clauses Invite Litigation

Schick, the shaving product company, recently announced it was abandoning its proposed $1.4 billion acquisition of rival startup Harry’s Razors. The announcement followed the U.S. Federal Trade Commission’s (FTC) threat to...more

Consummated Tech Mergers: Will the Government Seek to Unscramble the Eggs?

There are increasing calls for the antitrust enforcement agencies to review the effects of past acquisitions in the tech sector. Senator Elizabeth Warren has pledged to appoint enforcers committed to reversing such mergers....more

2019 ABA Antitrust Spring Meeting: Federal and State Antitrust Enforcement Takeaways

The American Bar Association’s 67th Antitrust Law spring meeting held earlier this month featured several sessions addressing the efforts of federal and state antitrust enforcement agencies, including a number of discussions...more

DOJ Announces Settlement of Anti-Steering Antitrust Case Against Atrium Health

The U.S. Department of Justice (DOJ) and the Attorney General of North Carolina announced a settlement last week in their civil antitrust case against Atrium Health, the largest hospital system in the state of North Carolina....more

New FTC Complaint Merits Attention of Group Purchasing Organization Suppliers and Participants

The Federal Trade Commission announced on February 12, 2018, that it has filed an administrative complaint seeking injunctive relief against three large dental supply companies, alleging that they violated the antitrust laws...more

President Orders FTC to Report on Competition in Healthcare Markets

On October 12, 2017, President Donald J. Trump signed an executive order designed to promote choice and competition in healthcare markets. The order was reported as a first step in the administration’s effort to undermine the...more

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