FTC Issues New HSR Thresholds
Client Alert | 1 min read | 01.16.07
Today the Federal Trade Commission released its annual revisions to the jurisdictional and filing fee thresholds applicable under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (the “HSR Act”). The dollar thresholds of the HSR Act and Rules are indexed on an annual basis, based on changes in the U.S. gross national product. As a result of these changes, the size-of-transaction threshold will increase from $56.7 million to $59.8 million. In addition, the size-of-parties thresholds, the filing fee thresholds and the thresholds applicable to certain exemptions will also increase. These revisions will become effective thirty days after their publication in the Federal Register.
To read a full copy of the Commission's announcement, including all of the revised thresholds, click here
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Client Alert | 3 min read | 11.21.25
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.
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