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ARTICLE · 14 MARCH 2025

GT Newsletter | Competition Currents | March 2025

Greenberg Traurig
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On Jan. 7, 2025, the FTC, in conjunction with the Department of Justice (DOJ) Antitrust Division, settled allegations that sister companies Verdun Oil Company II LLC and XCL Resources Holdings, LLC exercised unlawful...

GlobalAntitrust/Competition Law
Tonya M. Esposito
Tonya M. Esposito
Justin Hedge
Justin Hedge
Stephen Pepper
Stephen Pepper
Janis Clements
Janis Clements
Alan W. Hersh
Alan W. Hersh
Rebecca Tracy Rotem
Rebecca Tracy Rotem
Sarah-Michelle Stearns
Sarah-Michelle Stearns
Alexa Minesinger
Alexa Minesinger
Hans Urlus
Hans Urlus
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In This Issue1

United States | The Netherlands | Poland | Italy | European Union | Japan

United States

A. Federal Trade Commission (FTC)

1. FTC secures $5.68M HSR gun-jumping penalty from 2021 deal.

On Jan. 7, 2025, the FTC, in conjunction with the Department of Justice (DOJ) Antitrust Division, settled allegations that sister companies Verdun Oil Company II LLC and XCL Resources Holdings, LLC exercised unlawful, premature control of EP Energy LLC while acquiring EP in 2021. This alleged "gun-jumping" violation involved Verdun and XCL exercising various consent rights under the merger agreement and coordinating sales and strategic planning with EP during the interim period before closing. In settling, the parties agreed to pay a total civil penalty of $5.68 million, appoint or retain an antitrust compliance officer, provide annual antitrust trainings, use a "clean team" agreement in future transactions involving a competing product, and be subject to compliance reporting for a

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