The second quarter saw significant enforcement and dealmaking in
the life sciences space. The Federal Trade Commission (FTC)
announced its attempt to block Amgen/Horizon, the first such
challenge to a life science transaction since 2009, and issued a
second request in Pfizer's proposed $43 billion acquisition
of Seagen. In contrast, however, several sizable deals announced
and closed within the normal waiting period, while the status of
others is unknown at the time of publication.
Elsewhere, the FTC and the Department of Justice (DOJ) published
a revised set of draft Merger Guidelines, which “describe and
guide” the agencies' evaluation of mergers. Although
not specifically aimed at life sciences, the Merger Guidelines
embody many of the administration's policy priorities, as
well as novel theories that have not traditionally been the basis
for antitrust enforcement. The FTC and DOJ also announced
significant proposed changes to the HSR form. If formally
