Antitrust Trends in Technology, Life Sciences, and Healthcare

While M&A activity has slowed in the tail end of the first quarter of 2025, including in healthcare, there have been several noteworthy developments in the antitrust space in the first 100 days of the Trump Administration. The Federal Trade Commission (FTC), under new Chairman Andrew Ferguson, has already launched its first merger challenge, affirmed its acceptance of the 2023 Merger Guidelines, reinstituted early termination of HSR filings, and allowed the new HSR filing rules to take effect. Further, President Trump fired the two sitting Democratic Commissioners in March 2025, leaving the leadership of the FTC in the hands of the three sitting Republican Commissioners. Meanwhile, in addition to joining the FTC in affirming the Merger Guidelines and HSR filing rules, the Department of Justice Antitrust Division (DOJ) under Assistant Attorney General Gail Slater announced an “Anticompetitive Regulations Task Force,” which will seek to identify regulations that undermine competition and promote overbilling and consolidation in healthcare, among other industries.

While M&A activity slowed in the first quarter of 2025, including in life sciences, there have been plenty of noteworthy developments in the antitrust space in the first 100 days of the Trump administration. The Federal Trade Commission (FTC) under new Chairman Andrew Ferguson has already launched its first merger challenge while also signaling a more deal-friendly approach by reinstituting the “early termination” process, whereby the FTC uses its discretion to terminate a Hart-Scott-Rodino (HSR) review prior to the expiration of the statutory review period in instances in which the transaction does not present any competitive issues.

As we look back on 2024, one thing is clear: Antitrust enforcement in the technology sector continued at a steady pace, with global agencies showing no signs of relenting in their scrutiny of Big Tech companies. Perhaps most notably, artificial intelligence emerged as a central focus for antitrust authorities, who launched investigations into the rapidly evolving industry and began developing regulatory positions. These agencies grappled with complex questions around market power and jurisdiction as they worked to apply existing frameworks to generative AI technology and strategic partnerships that often defied traditional regulatory boundaries. Regulators have also pursued numerous high-profile antitrust cases against digital platforms for alleged anticompetitive practices while implementing significant new pieces of legislation. These included the EU’s Digital Markets Act (DMA) and the UK’s Digital Markets, Competition and Consumers Act (the DMCC Act), both representing major attempts at addressing competition concerns in the digital economy.

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