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FTC and DOJ Allow Electronic HSR Filings

Client Alert | 1 min read | 06.21.06

The Federal Trade Commission and the Department of Justice have announced the implementation of an electronic filing system that allows parties to a transaction to submit via the Internet premerger notification filings required by the Hart-Scott-Rodino ("HSR") Act.

Under the new system, filing parties will have three options:

  1. Parties may complete and submit the Form and all attachments in hard copy;
  2. Parties may complete the electronic version of the Form and submit the Form and all attachments electronically; or
  3. Parties may complete the electronic version of the Form and submit it electronically while submitting all documentary attachments in paper copy.

More detailed information on the electronic filing system is available at https://www.hsr.gov/.  Please let us know if you have any questions, or if we can be of further assistance.

Insights

Client Alert | 3 min read | 11.21.25

A Sign of What’s to Come? Court Dismisses FCA Retaliation Complaint Based on Alleged Discriminatory Use of Federal Funding

On November 7, 2025, in Thornton v. National Academy of Sciences, No. 25-cv-2155, 2025 WL 3123732 (D.D.C. Nov. 7, 2025), the District Court for the District of Columbia dismissed a False Claims Act (FCA) retaliation complaint on the basis that the plaintiff’s allegations that he was fired after blowing the whistle on purported illegally discriminatory use of federal funding was not sufficient to support his FCA claim. This case appears to be one of the first filed, and subsequently dismissed, following Deputy Attorney General Todd Blanche’s announcement of the creation of the Civil Rights Fraud Initiative on May 19, 2025, which “strongly encourages” private individuals to file lawsuits under the FCA relating to purportedly discriminatory and illegal use of federal funding for diversity, equity, and inclusion (DEI) initiatives in violation of Executive Order 14173, Ending Illegal Discrimination and Restoring Merit-Based Opportunity (Jan. 21, 2025). In this case, the court dismissed the FCA retaliation claim and rejected the argument that an organization could violate the FCA merely by “engaging in discriminatory conduct while conducting a federally funded study.” The analysis in Thornton could be a sign of how forthcoming arguments of retaliation based on reporting allegedly fraudulent DEI activity will be analyzed in the future....