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FTC Proposes Significant Expansion and Changes to HSR Merger Notification Form

On June 27, 2023, the U.S. Federal Trade Commission (“FTC”), with the collaboration and concurrence of the Antitrust Division of the U.S. Department of Justice (“DOJ”), announced a Notice of Proposed Rulemaking (the “Notice”)...more

FTC Announces New Increased HSR Filing Thresholds for 2023

On January 23, 2023, the Federal Trade Commission (FTC) published new, higher notification thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the “HSR Act”). The HSR Act requires the FTC to adjust the...more

FTC Takes Unprecedented Enforcement Actions Against Non-Compete Restrictions

On January 4, 2023, the Federal Trade Commission (“FTC”) announced settlements with three companies for their use of employee non-compete restrictions in alleged violation of Section 5 of the FTC Act. Specifically, the FTC...more

Congress Increases Merger Filing Fees for Large Deals and Makes Other Significant Changes

Congress passed the Consolidated Appropriations Act of 2023 (the “Act”) on December 22, 2022, and President Biden signed it into law on December 29, 2022. The Act significantly amends the Hart-Scott-Rodino Act (the “HSR Act”)...more

FTC Proposes Sweeping Ban of Employee Non-Competes

On January 5, 2023, the Federal Trade Commission (FTC) issued a proposed rule broadly seeking to ban non-compete agreements with nearly all U.S. workers, with only limited exceptions. The proposed rule would: •make it...more

Quarterly Cartel Catch-Up: Year-End Edition 2022

In 2022, antitrust authorities around the world were pursuing more investigations, bringing new types of cases, and making policy changes to spark even more enforcement actions. In the United States, the Department of...more

U.S. Antitrust Authorities’ Recent Scrutiny of Interlocking Directorates Signals Escalation of Enforcement Under Section 8 of the...

Recent scrutiny of interlocking directorates – when a person serves as an officer or board director of two competing corporations – by the U.S. Department of Justice Antitrust Division (DOJ) and the Federal Trade Commission...more

DOJ and FTC Enter Separate MOUs With the NLRB to Enhance Worker Protections and Competition in U.S. Labor Markets

In the latest employment-related collaborations under President Biden, the U.S. Department of Justice Antitrust Division (“DOJ”) and Federal Trade Commission (“FTC”) both recently announced new partnerships with the National...more

Antitrust Scrutiny Intensifies Around Private Equity Healthcare Transactions

On June 3, 2022, Andrew Forman, Deputy Assistant Attorney General of the United States Department of Justice Antitrust Division (DOJ) publicly stated that the DOJ is considering “enhancing antitrust enforcement around a...more

Race to Self-Report: U.S. Department of Justice Antitrust Division Updates Leniency Program and Revises FAQs, Including...

On April 4, 2022, the U.S. Department of Justice Antitrust Division (the “Division”) announced noteworthy updates to its Corporate Leniency Program as well as its frequently asked questions (“FAQs”) that explain the Program,...more

Monopolists Going “Directly to Jail?” DOJ Announces Intent to Criminally Prosecute Section 2 Violations

In the latest sign of the Biden administration’s aggressive antitrust enforcement agenda, on March 2, 2022, while speaking on a panel at the ABA White Collar Crime Conference in San Francisco, Deputy Assistant Attorney...more

Quarterly Cartel Catch-Up: Recent Developments in Criminal Antitrust for Busy Corporate Counsel – Q4 2021

The end of 2021 continued to be a busy time for antitrust enforcers in the U.S. and around the world. Perhaps most notably, in November the Senate confirmed Jonathan Kanter to lead the U.S. Department of Justice’s Antitrust...more

FTC Announces New Increased HSR Filing Thresholds for 2022

On January 24, 2022, the Federal Trade Commission (FTC) published new, higher notification thresholds under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the “HSR Act”). The HSR Act requires the FTC to adjust the...more

U.S. Antitrust Agencies Announce Review of Merger Analysis Framework

On January 18, 2022, the U.S. Federal Trade Commission (“FTC”) and the Department of Justice Antitrust Division (“DOJ”) held a joint press conference to announce the launch of a broad‑ranging public inquiry aimed at...more

MoFo Competition: Antitrust Shifts You Need to Know

“If adopted and implemented by the agencies, the measures [in Biden’s executive order] would amount to the toughest antitrust enforcement that we’ve seen in the U.S. in decades.” The award-winning women partners of...more

New FTC Policy Restricts Future Acquisitions for Some Merging Parties

On October 25, 2021, the Federal Trade Commission (FTC or Commission) adopted a new policy requiring merging parties that enter into settlements to resolve competition concerns to give the FTC veto power over future deals in...more

Quarterly Cartel Catch-Up: Recent Developments In Criminal Antitrust For Busy Corporate Counsel ‒ Summer 2021

More than halfway through the year, 2021 has shaped up to be another busy time for antitrust enforcers. In July, the Biden administration confirmed that antitrust remains a top priority by issuing a sweeping Executive Order,...more

Charting A New Course For Antitrust: President Biden’s Executive Order Promoting Competition In The American Economy

On July 9, 2021, President Biden signed a sweeping executive order (EO) creating a “whole-of-government competition policy” that directs more than a dozen federal agencies to work in concert with the Department of Justice...more

Senate Passes Bill To Increase HSR Filing Fees For Large Transactions

On June 6, 2021, the U.S. Senate passed the Merger Filing Fee Modernization Act of 2021. Co-sponsored by Senators Amy Klobuchar (D-MN) and Chuck Grassley (R-IA), the bill would increase filing fees for certain large...more

AMG Capital v. FTC – SCOTUS Strips The FTC Of A Critical Enforcement Tool

In a unanimous decision reversing the Ninth Circuit, the Supreme Court in AMG Capital v. FTC ended a federal circuit split and squarely held that the FTC lacks authority to pursue equitable monetary relief in federal court...more

FTC Announces Temporary Suspension Of Early Termination

On February 4, 2021, the Federal Trade Commission (FTC) announced the temporary suspension of grants of early termination of the 30-day waiting period under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR Act)....more

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