Premerger Notification

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In response to COVID-19, the FTC’s Premerger Notification Office (PNO) just announced several changes for all Hart-Scott-Rodino (HSR) filings going forward.  While these changes have been described as temporary, no specific end date has been identified.

  1. Hard copy HSR filings will no longer be accepted, until further notice
  2. No HSR filings whatsoever may be submitted on Monday, March 16.
  3. Starting at 8:30 a.m. on Tuesday, March 17, HSR filings must be submitted through a new, temporary e-filing system.  That system is not yet operational.  It will require parties to upload documents to a secure FTP site.
  4. While this temporary e-filing system is in place, early termination will not be granted for any filing.

Continue Reading Coronavirus Sparks Changes to Premerger Notification Process at the FTC

On May 7, 2019, The Governor of the State of Washington signed into law Substitute House Bill 1607 (“HB 1607”) – a first-of-its-kind premerger notification requirement covering healthcare transactions closing on or after January 1, 2020. HB 1607 is a timely reminder that state attorneys general have not hesitated in recent years to enforce both federal and their own state antitrust laws when a transaction poses local anticompetitive concerns.
Continue Reading The State of Washington Has Another Arrow in its Healthcare Antitrust Quiver: State Healthcare Antitrust Enforcement in the Spotlight