News & Analysis as of

Restrictive Covenants No-Poaching Federal Trade Commission (FTC)

Harris Beach Murtha PLLC

Federal Trade Commission Forms Task Force to Address Labor Market Conduct

On February 26, 2025, Andrew N. Ferguson, the newly appointed Chair of the Federal Trade Commission (FTC), issued a memorandum outlining the agency’s populist agenda and directing the formation of a “Joint Labor Task Force”...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

FTC Launches Task Force to Protect Competition in Labor Markets, Scrutinize Noncompete Agreements

On February 26, 2025, Federal Trade Commission (FTC) Chairman Andrew N. Ferguson directed the agency to form a new “Joint Labor Task Force” that will focus on enforcing federal antitrust laws to protect competition in labor...more

Sheppard Mullin Richter & Hampton LLP

DOJ and FTC Issue Antitrust Guidelines for Business Activities Affecting Workers

Four days before President Trump took office, the Department of Justice (“DOJ”) and Federal Trade Commission (“FTC”) (together, “the Agencies”) under the Biden administration released their “Antitrust Guidelines for Business...more

Pillsbury Winthrop Shaw Pittman LLP

New DOJ–FTC Antitrust Guidelines for Business Activities Affecting Workers: Key Changes and Practical Takeaways

While the original guidelines focused primarily on per se illegal wage-fixing and no-poach agreements, the 2025 Guidelines illustrate a significant expansion in enforcement, broadening scrutiny to compensation benchmarking,...more

McCarter & English, LLP

Antitrust Guidelines for Worker-Related Business Practices: How to Stay on the Right Side of Antitrust Hiring Laws During the...

The Department of Justice Antitrust Division (DOJ) and the Federal Trade Commission (FTC) (together, the Agencies) issued Antitrust Guidelines for Business Activities Affecting Workers (2025 Guidelines) in January. The 2025...more

Troutman Pepper Locke

FTC and DOJ Issue Antitrust Guidelines for Business Activities Affecting Workers

Troutman Pepper Locke on

On January 16, the Federal Trade Commission (FTC) and the Department of Justice (DOJ) issued “Antitrust Guidelines for Business Activities Affecting Workers” (2025 Guidelines). The 2025 Guidelines aim to “promote clarity and...more

Morrison & Foerster LLP

A Parting Gift to Labor Markets: Outgoing Antitrust Enforcers Issue Revised Guidelines on Practices Affecting Workers, But Will...

In the final days of the Biden administration, the FTC and DOJ jointly issued antitrust guidelines on business practices that impact workers that replace the 2016 Antitrust Guidance for Human Resource Professionals, which...more

Mogin Law LLP

Biden Antitrust Teams' Reminders for Employers. Will Trump 2.0 Care?

Mogin Law LLP on

In the closing days of the Biden administration, antitrust law enforcers issued cautions to employers about conduct that could draw criminal charges against them. One is the use of restrictive non-disclosure agreements that...more

Holland & Knight LLP

DOJ, FTC Issue New Antitrust Guidelines on Business Practices Impacting Workers

Holland & Knight LLP on

Less than a week before the administration change from former President Joe Biden to President Donald Trump, the U.S. Department of Justice (DOJ) and Federal Trade Commission (FTC) released new guidance highlighting business...more

McGuireWoods LLP

DOJ, FTC Issue Updated Antitrust Guidance for Employers on Business Activities Affecting Workers

McGuireWoods LLP on

On Jan. 16, 2025, the U.S. Department of Justice and the Federal Trade Commission jointly issued new Antitrust Guidelines for Business Activities Affecting Workers, replacing the 2016 Antitrust Guidance for Human Resource...more

Skadden, Arps, Slate, Meagher & Flom LLP

Antitrust Enforcers Are Increasingly Focused on Labor Markets, and Not Just in the Merger Context

Labor markets have been a focus of antitrust regulators at the Department of Justice (DOJ) and Federal Trade Commission (FTC) since the Obama administration. Indications are that enforcers will be even more aggressive across...more

Clark Hill PLC

The Attack on Employment Noncompetes: The Status of Federal Initiatives

Clark Hill PLC on

Historically, enforcement of noncompete agreements has been a subject of state law, not federal law. States have taken many different approaches to the agreements. A few states have enacted laws that ban the enforcement of...more

Latham & Watkins LLP

Restrictive Covenant Crackdown Poses New Challenges for M&A Deal Teams

Latham & Watkins LLP on

Corporates and deal teams should pay careful attention to drafting non-competes and other restrictive arrangements as UK, EU, and US regulators step up enforcement. Regulators on both sides of the Atlantic are placing...more

Benesch

Trade Secrets/Non-Compete Quarterly Update - Q2 2023

Benesch on

Welcome to our Q2 Trade Secret and Restrictive Covenant Update. As you can tell from the update, Q2 was a busy quarter in this space from both a regulatory, legislative, civil litigation and criminal litigation perspective....more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Can Non-Compete Agreements Lead to Jail Time?

Can non-compete agreements lead to criminal fines—or even jail time? Yes, they can. That is because violating the Sherman Antitrust Act can result in criminal charges, not just civil liability....more

Littler

Will Europe Follow the Proposed U.S. Ban on Non-competes?

Littler on

The U.S. Federal Trade Commission (FTC) announced on January 5, 2023 a proposed ban on non-competes across the United States. With large global employers considering the implications of the proposed rulemaking, we reached out...more

Bradley Arant Boult Cummings LLP

FTC Proposes Rule to Strike Noncompete Agreements Nationwide

On January 5, 2023, the Federal Trade Commission (FTC) announced a proposed new rule that would effectively prohibit employers from requiring employees to agree to noncompete clauses. The public is invited to submit comments...more

Benesch

Trade Secrets/Non-Compete Quarterly Update - Q3 2022

Benesch on

Compared to Q1 and Q2 of 2022, Q3 was relatively slow with respect to trade secret legislation and significant restrictive covenant awards and/or case law. Still, and as described below, two new statutes require a company’s...more

Benesch

Trade Secrets/Non-Compete Quarterly Update - Q2 2022

Benesch on

As with the first quarter of 2022, Trade Secret and Restrictive Covenant activity continues to be robust at both the state and federal level. State legislators continue to introduce, analyze and negotiate restrictive covenant...more

BakerHostetler

Decision Benefits Franchise Businesses and Finds Alston Bars Challenge to No-Poach Agreements

BakerHostetler on

In June 2021, the Supreme Court reaffirmed in NCAA v. Alston that antitrust claims under Section 1 of the Sherman Act “presumptively” call for rule-of-reason analysis and that only the rare case merits “quick look” or per se...more

Holland & Knight LLP

Employee Talent Wars Gain Unprecedented Ammunition from Changing Antitrust Landscape

Holland & Knight LLP on

The current labor market is fraught with challenges for employers. In the wake of the COVID-19 market disruptions, the demand for employees, especially for experienced or highly trained employees, far exceeds the supply....more

Benesch

Just like 2021, the DOJ and FTC will remain active in the Restrictive Covenant Space

Benesch on

2021 saw significant activity by both the Department of Justice (“DOJ”) and Federal Trade Commission (“FTC”) in 2021. The DOJ, for example, finally followed through on its 2016 warning/threat to investigate and potentially...more

Troutman Pepper Locke

Ninth Circuit Upholds Unlimited Nonsolicitation Provision

Troutman Pepper Locke on

Over the past five years, the Department of Justice (DOJ) and civil litigants have rigorously challenged the lawfulness of buy-side restraints of trade, including noncompetes, no-poach, and nonsolicitation agreements, under...more

White & Case LLP

Analysis: FTC Encouraged to Ban or Limit Non-Compete Agreements in July 9, 2021 Executive Order; Breaks With Tradition, And...

White & Case LLP on

On Friday, July 9, 2021, President Biden signed Executive Order 14036, Promoting Competition in the American Economy, which includes—among 72 initiatives aimed at enhancing competition in the US—a directive encouraging the...more

Faegre Drinker Biddle & Reath LLP

The Pennsylvania Supreme Court Strikes Down a No-Hire Agreement as an Unreasonable Restraint on Trade

Recently, in Pittsburgh Logistics Systems, Inc. v. Beemac Trucking, LLC, No. 31 WAP 2019, — A.3d –, 2021 WL 1676399 (Apr. 29, 2021), the Pennsylvania Supreme Court found that a no-hire provision that was ancillary to a...more

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