Noah Feldman Greene
Subscribe to Noah Feldman Greene's PostsNoah Feldman Greene focuses his practice on antitrust matters. He assists clients on mergers and acquisitions, including defending transactions before the Federal Trade Commission, Department of Justice, state antitrust authorities and foreign competition authorities. He also assists clients with premerger analysis and notifications under the Hart-Scott-Rodino Act. Additionally, Noah advises on antitrust compliance matters, antitrust litigation and government investigations. Read Noah Feldman Greene's full bio.
Fifth Circuit grants temporary stay preserving 2024 HSR rules
By Royce Brosseau, Jon B. Dubrow, Noah Feldman Greene, Gregory E. Heltzer, Elai Katz and Ryan Tisch on Feb 20, 2026
Posted In DOJ Developments, FTC Developments, Mergers & Acquisitions
On February 19, 2026, the US Court of Appeals for the Fifth Circuit granted the Federal Trade Commission’s (FTC) motion to temporarily stay the US District Court for the Eastern District of Texas’s order vacating the 2024 Hart-Scott-Rodino (HSR) Premerger Notification Rules “until further order” while the parties brief the FTC’s motion to stay the...
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Federal court vacates FTC’s new HSR rules
By Royce Brosseau, Jon B. Dubrow, Noah Feldman Greene, Gregory E. Heltzer, Elai Katz and Ryan Tisch on Feb 13, 2026
Posted In DOJ Developments, FTC Developments, Mergers & Acquisitions
On February 12, 2026, the US District Court for the Eastern District of Texas set aside and vacated the Federal Trade Commission’s (FTC) new premerger notification form and instructions. The 2024 Final Rule that amended the Premerger Notification Rules under the Hart-Scott-Rodino (HSR) Act, which became effective February 10, 2025, requires merging parties to submit...
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Indiana poised to become third state with “mini-HSR” regime
By Royce Brosseau, Jon B. Dubrow, Noah Feldman Greene and Gregory E. Heltzer on Jan 28, 2026
Posted In DOJ Developments, FTC Developments, Mergers & Acquisitions
On January 21, 2026, the Indiana Senate Committee on Judiciary voted unanimously to advance Indiana’s version of the Uniform Antitrust Pre-merger Notification Act (the Act). Indiana is poised to become the third state with a “mini-HSR” regime, following Washington and Colorado in 2025. Pending passage by the full legislature and signature by the governor, the...
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New HSR Rules Go Live: Your Playbook for Effective M&A
By Gregory E. Heltzer, Noah Feldman Greene and Jon B. Dubrow on Feb 10, 2025
Posted In DOJ Developments, FTC Developments, Healthcare Antitrust, Joint Ventures/Competitor Collaboration, Mergers & Acquisitions
Starting today, February 10, 2025, all merger filings will be subject to new Hart-Scott-Rodino (HSR) rules. The new HSR rules will fundamentally alter the premerger notification process, and substantially increase the burden on filing parties, who will need to provide significantly more information and documents with their initial filings. Companies can take steps today to...
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New Premerger Notification Regime to Fundamentally Change M&A Strategy
By Jon B. Dubrow, Raymond A. Jacobsen, Jr., Lisa P. Rumin, Ryan Tisch, Noah Feldman Greene, Graham Hyman and Reese Poncia on Oct 16, 2024
Posted In FTC Developments, Mergers & Acquisitions
On October 10, 2024, the Federal Trade Commission issued new final rules governing the US premerger notification filing process. These rules – the first major overhaul to the Hart-Scott-Rodino (HSR) filing form in the nearly 50-year history of the HSR Act – will fundamentally alter the premerger notification process. While the rules omit some of...
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New DOJ Task Force to Target ‘Multisided Giants’ in Healthcare
By Stephen Wu, Ashley Fischer, Daniel Powers and Noah Feldman Greene on May 10, 2024
Posted In DOJ Developments, FTC Developments, Healthcare Antitrust, Mergers & Acquisitions, Monopolization/Abuse of Dominance
The US Department of Justice’s (DOJ) announcement of the formation of a new healthcare task force signals an even stronger emphasis on addressing competition issues in the healthcare industry. Large, multisided platforms involved in multiple sectors (e.g., insurance companies acquiring physician practices and/or essential healthcare IT and data services) are a key target for enforcement....
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Heard at the 2024 Antitrust Law Section Spring Meeting: Part II
By Lisa P. Rumin, Anthony S. Ferrara, Reese Poncia, Noah Feldman Greene, Zachary Sproull, Han Cui, Graham Hyman, Glenna Siegel, Alex Grayson, Betty Zhang and Gregory E. Heltzer on Apr 12, 2024
Posted In Agriculture, DOJ Developments, FTC Developments, Healthcare Antitrust, Mergers & Acquisitions, Monopolization/Abuse of Dominance
The American Bar Association Antitrust Law Section’s annual Spring Meeting concluded on April 12. The annual Spring Meeting featured updates from federal, state and international antitrust enforcers and extensive discussion on priority antitrust issues affecting various industries. In this article, we highlight takeaways from the final two days of the Spring Meeting. Read more here.
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Proposed Merger Guidelines Outline Fundamental Change of Approach to Merger Investigation and Enforcement
By Nicole Castle, Jon B. Dubrow, Noah Feldman Greene, Gregory E. Heltzer, Joel R. Grosberg, Raymond A. Jacobsen, Jr., Lisa P. Rumin, Ryan Tisch and Stephen Wu on Jul 25, 2023
Posted In DOJ Developments, FTC Developments, Mergers & Acquisitions
Mergers and acquisitions will continue to face strong headwinds at the Federal Trade Commission and the US Department of Justice under new proposed Merger Guidelines released on July 19, 2023. The Proposed Guidelines embody the antitrust agencies’ aggressive posture toward merger enforcement under the Biden administration. This On the Subject highlights the most significant changes...
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DOJ Signals Heightened Scrutiny on Information Exchanges and Competitor Collaborations
By Noah Feldman Greene, Gregory E. Heltzer, Ashley Fischer and Stephen Wu on Feb 15, 2023
Posted In DOJ Developments, Healthcare Antitrust
WHAT HAPPENED On February 3, 2023, the US Department of Justice’s (DOJ) Antitrust Division announced the withdrawal of three policy statements related to antitrust enforcement in healthcare. Although the withdrawn statements focus on healthcare, DOJ’s decision to withdraw these statements will have broad impacts across industries. The three policy statements, issued in 1993, 1996, and 2011, relate to competitor collaboration...
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DOJ to Merging Parties: The Time of “Underenforcement” is Over; Fix-It-First or Risk Being Challenged
By Jon B. Dubrow, Gregory E. Heltzer and Noah Feldman Greene on Sep 20, 2022
Posted In DOJ Developments, FTC Developments, Mergers & Acquisitions
WHAT HAPPENED During a conference last week, Ryan Danks, Director of Civil Enforcement at the US Department of Justice’s Antitrust Division (DOJ), suggested that merging parties—not the antitrust enforcement agencies—should devise fixes for allegedly anticompetitive transactions. Danks stated “that something is broken about the way that the antitrust community talks about remedies in the context...
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