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FTC Announces New HSR and Section 8 Thresholds

Client Alert | 1 min read | 01.20.17

On January 19, the Federal Trade Commission announced that it will increase the jurisdictional thresholds applicable to both the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the HSR Act) and Section 8 of the Clayton Act. These dollar thresholds are indexed annually based on changes in the U.S. gross national product.

The HSR Act requires that certain large transactions be notified prior to their consummation. This year, the minimum "size-of-transaction" threshold for reporting mergers and acquisitions will increase from $78.2 million to $80.8 million. In addition, the "size-of-person" and filing fee thresholds will also increase. These revisions will become effective thirty days after their publication in the Federal Register.

The Commission also issued revised thresholds relating to the prohibition of certain interlocking directorates under Section 8 of the Clayton Act. These revisions will take effect immediately upon their publication in the Federal Register.

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Client Alert | 2 min read | 07.01.25

DoD Establishes New DOGE Approval Process for ITC&MS and A&AS Contracts

On June 23, 2025, the DoD issued a memorandum, “Implementation of Department of Government Efficiency Cost Efficiency Initiative,” to establish a new DOGE approval process for unclassified IT consulting and management services (ITC&MS) contracts or task orders (TOs), and advisory and assistance services (A&AS) contracts or TOs.  The memorandum establishes a formal approval process, which directs DOGE to review and provide input for certain contract requirement packages included in Defense Secretary Pete Hegseth’s May 27, 2025 directive, “Implementation of Executive Order 14222 – Department of Government Efficiency Cost Efficiency Initiative” (“Contract Guidance”). ...