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August 27, 2020

Antitrust Agency Insights: Developments at the US Antitrust Enforcement Agencies—August 2020

Antitrust/Competition Newsletter
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Successfully navigating antitrust agency investigations requires a familiarity with Department of Justice and Federal Trade Commission processes, as well as insight into those agencies and their leaderships' current priorities for enforcement and competition policy. This newsletter will provide periodic updates on both, offering an analytical look at how the antitrust agencies are approaching important competition issues and what current investigations may mean for potential future enforcement. We hope our experience—both inside and outside these agencies—will provide insights that help you make more informed decisions for your business.

Letter From the Editors

DOJ Reorganizes the Antitrust Division's Civil Enforcement Teams

Assistant Attorney General Makan Delrahim announced on August 20, 2020, that the Antitrust Division will make a number of changes designed to provide more effective civil enforcement and to develop deeper expertise regarding technology trends. Read the DOJ's press release. Specifically, the DOJ is creating the Office of Decree Enforcement and Compliance. Lawrence Reicher, who most recently served as Counsel to the Assistant Attorney General, will lead the new office, which will have primary responsibility for enforcing civil consent decrees and judgments. DOJ is also creating a new Civil Conduct Task Force, which will work across the civil sections to and provide additional resources to those investigations that require it.

The DOJ also announced that it is realigning certain responsibilities within the six civil sections to help it adapt to evolving technology trends. The realignment includes shifting the focus of the Media, Entertainment, and Professional Services Section to fintech, banking, and financial services; expanding the portfolio of the Telecommunications and Broadband Section to include coverage of the media and entertainment industries; and narrowing the focus of the Technology and Financial Services Section to technology markets and platform business models. Assistant Attorney General Delrahim stated that the "realignment recognizes how technology trends have changed the way Americans consumer financial services as well as media and communications services. It will make the Antitrust Division more efficient and more effective enforcing the antitrust laws . . . . This result is better for companies under investigation and, more importantly, leads to outcomes that benefit the American consumer."

DOJ Prevails in Arbitration to Resolve Merger Dispute

The DOJ engaged in a "first-of-its-kind" arbitration that ultimately resolved its civil lawsuit challenging Novelis, Inc.'s proposed merger with Aleris Corporation. Prior to filing its federal complaint in September 2019, the DOJ reached an agreement with Novelis and Aleris to refer the DOJ's civil lawsuit to binding arbitration if the parties could not resolve the DOJ's competitive concerns within a certain period of time. The ten-day arbitration focused on the issue of product market definition, ending in March 2020 with the arbitrator finding for the DOJ and ruling that aluminum automotive body sheets constitute a relevant antitrust market. DOJ then announced on May 12, 2020 that Novelis would divest Aleris' entire aluminum automotive body sheet operations in North America to move forward with its acquisition. This marked the first time the DOJ's Antitrust Division utilized its authority under the Administrative Dispute Resolution Act of 1996 to resolve a merger dispute. Read the DOJ's press release on required divestiture.

Agencies Continue Enforcement Without Interruption During COVID-19 Pandemic

The DOJ and FTC remain open for business, and have taken pains to communicate their view that the COVID-19 pandemic does not excuse otherwise anticompetitive conduct. Read the agencies' Joint Antitrust Statement. But like most, the agencies have adjusted to the pandemic by instituting new processes. In March, the FTC and the DOJ each announced a series of procedural changes, including accepting Hart-Scott-Rodino (HSR) filings only through new e-filing systems and conducting meetings over the phone or via videoconference. The DOJ and FTC also announced an expedited procedure for antitrust guidance related to COVID-19 public health efforts. Businesses seeking to collaborate on projects related to protecting the health and safety of Americans during the COVID-19 pandemic can avail themselves of this expedited review process. Three collaborations have been approved through this expedited procedure to date.

Most recently, the DOJ approved the proposed collaborative efforts of Eli Lilly and Company, AbCellera Biologics, Amgen, AstraZeneca, Genentech, and GlaxoSmithKline to share information necessary to expedite the production of COVID-19 treatments. Anticipating an overwhelming demand for any safe and effective monoclonal antibody treatments, the DOJ explained in its letter that the proposed efforts will "enable firms with successful therapeutics to increase output and markets served." Assistant Attorney General Makan Delrahim commented that "[t]his critical collaboration will help Americas get access to potentially life-saving therapeutics sooner than otherwise would be possible."

The DOJ also approved the collaborative efforts of McKesson Corporation, Cardinal Health Inc., AmerisourceBergen Corporation, and other distributors to address supply shortages of personal-protective equipment (PPE) and coronavirus-treatment-related medication. In the expedited business review letters, the DOJ agreed not to challenge the collaborative efforts and explained that the COVID-19 pandemic "will require unprecedented cooperation . . . among private businesses to protect Americans' health and safety." While most of the work at issue will be done under the supervision of FEMA, HHS, and other governmental agencies, the DOJ also signed off on collaboration that will occur without direct participation of government representatives.

Finally, the DOJ approved the National Pork Producers Council's (NPPC) request to share information with and between its hog farming members regarding best practices for euthanizing hogs that have become unmarketable because of the business conditions created by the pandemic.

Beyond the expedited review of potential collaboration agreements, the DOJ and FTC remain focused on protecting competition in markets that may be affected by the COVID-19 crisis. In a joint statement issued in April, the agencies warned employers, staffing companies, and recruiters that they are closely monitoring for any collusive activity in the labor markets for essential workers, such as nurses, first responders and grocery clerks.1

Finally, the FTC has been explicit that the crisis will not affect the FTC's stringent requirements for a credible "failing firm" defense. In a blog post, Bureau of Competition Director, Ian Conner, cautioned merging parties to "think twice before making apocalyptic predictions of imminent failure during a merger investigation."

COVID-19

Business Review Letters

Additional Agency Updates

Cases and Proceedings

  • FTC amends complaint against Vyera Pharmaceuticals, Martin Shkreli, and other defendants to add six more states as plaintiffs. On April 14, 2020 the FTC filed an amended complaint in its case against Vyera Pharmaceuticals (alleging the pharmaceutical company developed an elaborate scheme to preserve its monopoly for the life-saving drug, Daraprim). The new states named in the amended complaint include California, Illinois, North Carolina, Ohio, Pennsylvania, and Virginia. The original complaint was filed on January 27, 2020, by the FTC and the New York attorney general.
  • Safariland, LLC agrees to settle FTC's claim that its non-compete and customer non-solicitation agreements with acquired competitor are anticompetitive. On April 17, 2020, the FTC announced that the leading manufacturer of law-enforcement equipment, Safariland, agreed to settle FTC allegations that agreements it entered into when it sold its VieVu body-worn camera division to competitor Axon Enterprise, Inc., substantially lessened actual and potential competition for body-worn camera systems. The FTC issued an administrative complaint challenging the consummated deal back in January 3, 2020.
  • FTC finalizes settlement with rent-to-own companies over charges that they entered into reciprocal purchase agreements that restrained competition. On May 12, 2020, the FTC approved final orders prohibiting three rent-to-own operators (Aaron's Inc., Buddy's Newco, LLC, and Rent-A-Center) and their franchisees from entering into reciprocal agreements to allocate markets. The settlement also prohibits them from enforcing non-complete clauses in effect from past agreements.
  • DOJ files suit to block Geisinger Health's partial acquisition of Evangelical Community Hospital. On August 5, 2020, the DOJ filed a lawsuit in the U.S. District Court for the Middle District of Pennsylvania, attempting to block Geisinger Health's partial acquisition of Evangelical Community Hospital. The DOJ alleges that the proposed acquisition would significantly entangle the business and operations of the hospitals and reduce their incentives to compete aggressively for inpatient hospital services in central Pennsylvania.

Merger Enforcement

  • FTC approves final order imposing conditions on Bristol-Myers Squibb Company's proposed acquisition of Celgene Corporation. On January 13, 2020, the FTC announced that the Commission voted 3-2 to approve the final order requiring Bristol-Myers Squibb to divest Celgene's Otezla to Amgen, Inc., for $13.4 billion. Commissioners Rohit Chopra and Rebecca Kelly Slaughter dissented. The FTC reported that it was the largest divestiture the FTC or DOJ has ever required in a merger enforcement proceeding.
  • DOJ imposes conditions on merger between ZF Friedrichshafen AG and WABCO Holdings Inc. On January 23, 2020, the DOJ announced that ZF and WABCO agreed to divest WABCO's steering components business in order to proceed with ZF's acquisition of WABCO. The DOJ claims the two companies are the only suppliers of steering gears used for large commercial vehicles and that the proposed acquisition would eliminate competition in that market.
  • Edgewell Personal Care Company abandons proposed acquisition of Harry's, Inc. after FTC files suit to block the deal. On February 3, 2020, the FTC filed suit challenging the proposed acquisition of Harry's by Edgwell, claiming that Harry's entry had disrupted efforts by Edgewell (and Procter & Gamble) to raise prices. On February 10, 2020, Daniel Francis, Deputy Director of the Bureau of Competition, released a statement regarding Edgewell's decision to abandon the deal, stating that "[a]llowing Edgewell to bring that disruptor under control by acquiring Harry's would have represented a big step back for competition."
  • DOJ imposes conditions on Liqui-Box's acquisition of plastics division of DS Smith. On February 19, 2020, the DOJ announced that Liqui-Box Inc., a portfolio company of Olympus Fund VI, and DS Smith plc agreed to divest DS Smith's wine bag-in-box (BiB), dairy, post-mix, and smoothie product lines in order to proceed with Liqui-Box's proposed acquisition of DS Smith's Plastics Division.
  • FTC issues administrative complaint and files lawsuit to block proposed joint venture between Arch Coal and Peabody Energy Corporation. On February 26, the FTC commenced an administrative proceeding and filed suit in the Eastern District of Missouri, challenging the consummation of a joint venture between the two largest producers of coal in the Southern Powder River Basin of Wyoming. The FTC claims that Arch Coal and Peabody Energy Corporation account for more than 60% of all coal produced in the area and that eliminating head-to-head competition between them would increase their incentives and ability to increase prices and reduce output.
  • FTC issues administrative complaint and files lawsuit to block proposed merger of Jefferson Health and Albert Einstein Healthcare Network. On February 27, 2020, the FTC commenced an administrative proceeding and, joined by the Commonwealth of Pennsylvania, filed suit challenging the proposed merger of two major providers of inpatient general acute care and inpatient acute rehabilitation services in greater Philadelphia. The FTC alleges that the merged network would control over 60% of inpatient general acute care services in North Philadelphia and over 70% of inpatient acute rehabilitation services in the Philadelphia area.
  • DOJ imposes conditions on merger between United Technologies Corporation (UTC) and Raytheon. On March 26, 2020, the DOJ announced that the parties agreed to divestitures to address the agency's concerns about horizontal and vertical effects in the supply of military airborne radios and military GPS systems, and the merged firm's ability to diminish innovation for large space-based reconnaissance satellites. The DOJ required UTC to divest its military GPS systems and large space-based optical systems businesses and Raytheon to divest its military airborne radios business.
  • FTC requires divestitures of veterinary clinics. On April 10, 2020, the FTC announced a consent order under which Compassion First agreed to divest three veterinary clinics in North Carolina, Connecticut, and Virginia in order to eliminate FTC opposition to its proposed $5 billion acquisition of National Veterinary Associates (NVA). The FTC stated that the divestitures alleviate its concerns in those local geographic markets for various specialty and emergency veterinary services.
  • J&J abandons proposed acquisition of surgical patch unit from Takeda. On April 10, 2020, the FTC announced that Johnson & Johnson abandoned its proposed acquisition of Takeda's surgical patch unit, TachoSil, in response to FTC plans to challenge the deal based on concerns that patients and surgeons would be harmed by the loss of competition between the only two fibrin sealant patch producers.
  • Polyurethane foam producers agree to divest plants to alleviate FTC concerns. On April 21, 2020, the FTC approved a final order requiring two producers of polyurethane foam, FXI Holdings, Inc. and Innocor, Inc., to divest foam-pouring plants in Kent, Washington; Elkhart, Indiana; and Tupelo, Mississippi. The FTC claimed that absent divestitures, the merger likely would lessen competition for the low-density conventional polyurethane foam used in home furnishings in those regional areas.
  • DOJ requires divestitures of three fluid milk processing plants from Dean. On May 1, 2020, the DOJ announced that Dean Foods Company (Dean) agreed to divest three fluid milk processing plants located in northeastern Illinois, Wisconsin, and Massachusetts in order to proceed with its bankruptcy sale to Dairy Farmers of America Inc. (DFA). The DOJ also announced that it would not challenge the sale of other Dean plants located in the South and Midwest to Prairie Farms Dairy Inc.
  • Textbook manufacturers abandon merger after DOJ raises concerns. On May 4, 2020, the DOJ announced that Cengage Learning Holdings II Inc. and McGraw-Hill Education Inc. abandoned their plans to merge in light of DOJ concerns about the potential anticompetitive effects of the three-to-two merger.
  • FTC requires divestitures in AbbVie Inc.'s Acquisition of Allergan plc. On May 5, 2020, AbbVie Inc. and Allergan plc agreed to divest assets related to three drugs to address the FTC's concerns with AbbVie's proposed $63 billion acquisition of Allergan. AbbVie and Allergan will divest Allergan's Zenpep and Viokace, two drugs used to treat exocrine pancreatic insufficiency (EPI), and Allergan's branzikumab drug used to treat moderate-to-severe Crohn's disease and ulcerative colitis.
  • FTC approves conditions imposed on Össur Hf's acquisition of College Park. On May 28, 2020, the FTC approved a final order requiring two producers of prosthetic limbs, Össur Hf and College Park Industries, Inc., to divest College Park's myoelectric elbow business to settle the FTC's challenge to the transaction. Even though the transaction was not reportable under the Hart-Scott-Rodino Act, the FTC claimed it was likely to harm consumers of myoelectric elbows, because absent the proposed acquisition Össur Hf would have likely developed its own myoelectric elbow. College Park will divest its myoelectric elbow business to UK- and San Antonio, Texas-based prosthetics company, Hugh Steeper Ltd.
  • FTC approves conditions on Danaher Corporation's acquisition of GE Biopharma. On May 29, 2020, the FTC approved a consent agreement requiring that Danaher divest to Sartorius AG eight products that companies use to manufacture biopharmaceutical drugs, including microcarrier beads, chromatography resins and others.
  • FTC requires divestiture in Tri Star's proposed acquisition of assets from Hollingsworth. On June 24, 2020, Tri Star Energy, LLC and Hollingsworth Oil Company, Inc., agreed to divest retail fuel assets to address the FTC's concerns that Tri Star's proposed acquisition would harm competition in two local Tennessee markets for retail gasoline and retail diesel. The FTC claimed that without the remedy, the acquisition would result in a merger to monopoly in those local markets.
  • FTC requires Eldorado Resorts to divest regional assets in its proposed acquisition of Caesars Entertainment Corporation. On June 26, 2020, the FTC announced that it will require Eldorado to divest casino-related assets in the Bossier City-Shreveport area of Louisiana and the South Lake Tahoe area of Nevada to alleviate concerns that the acquisition of Caesars would harm competition for casino services in the areas. Twin River Worldwide Holdings will buy the divested assets.

Criminal Enforcement

Generics Conspiracy Cases

  • DOJ announces indictment of former Taro Pharmaceuticals executive. On February 4, 2020, the DOJ announced that a federal grand jury indicted former Taro Pharmaceutical Industries Ltd. marketing executive, Ara Aprahamian, for his role in generic drug conspiracies affecting multiple products.
  • DOJ announces former Sandoz Inc. senior executive pleads guilty. On February 14, 2020, former Sandoz Inc. senior executive, Hector Armando Kellum, pleaded guilty for his role in generic drug conspiracies affecting multiple products, including clobetasol and nystatin triamcinolone cream.
  • DOJ announces Sandoz Inc. agrees to pay a $195 million criminal penalty. On March 2, 2020, the DOJ announced that Sandoz Inc. agreed to enter into a deferred prosecution agreement, pay a $195 million criminal penalty, and admit to certain facts to resolve charges that it participated in four antitrust conspiracies involving certain generic pharmaceuticals.
  • DOJ announces Apotex Corp. agrees to pay a $24.1 million criminal penalty. On May 7, 2020, the DOJ announced that Apotex Corp. agreed to enter into a deferred prosecution agreement, pay a $24.1 million criminal penalty, and to admit that it conspired with other generic drug manufacturers to raise the price of generic pravastatin, a commonly prescribed cholesterol medication.
  • DOJ announces Taro Pharmaceuticals U.S.A., Inc. agrees to pay over $205 million in criminal penalties. On July 23, 2020, the DOJ announced that Taro Pharmaceuticals U.S.A., Inc. (Taro U.S.A.) agreed to enter into a deferred prosecution agreement, pay a $205,653,218 criminal penalty, and to admit that it participated in two antitrust conspiracies that affected the prices of numerous generic drugs used to treat a variety of conditions.
  • DOJ obtained guilty plea from insulation contracting firm and co-owner for roles in bid-rigging scheme. On February 3, 2020, Langan Insulation LLC and its co-owner Thomas F. Langan pleaded guilty to criminal antitrust and fraud charges for participating in a conspiracy to rig bids on contracts for installing insulation at universities, hospitals, and other facilities in Connecticut. This is the fifth conviction in this ongoing investigation.
  • DOJ charges Missouri businessman with participating in a conspiracy to rig bids for surplus government equipment at online auctions. On February 5, 2020, the DOJ announced that a federal grand jury had indicted Alan Gaines on bid-rigging charges relating to bids submitted to the General Services Administration (GSA) during its online auctions. Gaines's two co-conspirators pleaded guilty earlier in the DOJ's investigation.
  • DOJ charges manufacturing executive with conspiring to rig bids for commercial flooring products and services. On February 5, 2020, the DOJ filed a two-count felony charge in US District Court in Chicago, Illinois, against account executive Carter Brett for orchestrating a bid-rigging conspiracy among three commercial flooring installation companies. The second count charges Carter Brett with money laundering and accepting kickbacks from his co-conspirators.
  • Former executives at NHK Spring Co. Ltd. indicted for their role in conspiracy to fix prices for hard disk drive components. On February 14, 2020, the DOJ announced that a federal grand jury indicted Hitoshi Hashimoto and Hiroyuki Tamura for participating in a conspiracy with their competitors to fix prices of suspension assemblies used in hard disk drives. NHK Spring had already pleaded guilty to conspiracy charges.

DOJ/FTC Amicus Activity & Other Third-Party Filings

  • DOJ files statement of interest urging court to dismiss Apple Inc. and Intel Corp.'s antitrust claims against Fortress Investment Group LLC. Apple and Intel's lawsuit against Fortress alleges that Fortress used a web of patent assertion entities (PAEs) to launch a campaign of meritless patent litigation that enabled Fortress to skirt commitments to license standard essential patents (SEPs) on fair, reasonable and non-discriminatory (FRAND) terms. On March 20, 2020, the DOJ filed the statement arguing that supra-FRAND royalties do not by themselves violate the antitrust laws. The DOJ also argues that Apple and Intel's claims are based on an overbroad product market that indiscriminately lumps together complementary and substitute products. Earlier in the year, the DOJ filed a similar statement of interest in Continental Automotive Systems, Inc.'s lawsuit against Avanci, LLC and others asking the court to dismiss Section 2 claims based on breaches of FRAND commitments in the standard-setting process.

Other Enforcement

  • FTC requires big tech companies to provide information regarding past acquisitions. On February 11, 2020, the FTC issued Special Orders to Alphabet Inc. (including Google), Amazon.com Inc., Apple Inc., Facebook, Inc., and Microsoft Corp., requiring the firms to provide documents and information on certain past transactions that did not trigger an HSR filing. The FTC will examine whether these past transactions harmed competition in technology markets.
  • FTC issues summary of the agency's 2019 Annual Highlights. On April 23, 2020, FTC Chairman Joe Simons released a summary of 2019 annual highlights, noting that the FTC recovered over $232 million in refunds for consumers under its consumer protection authority. The FTC's Highlights summarize some of the agency's most significant enforcement actions in the past year.
  • DOJ issues statement on Third Circuit's decision to vacate District Court's denial of DOJ's attempt to block Sabre's acquisition of Farelogix Inc. On April 7, 2020, the DOJ's effort to block Sabre Corporation's acquisition of Farelogix, Inc. in the U.S. failed after the US District Court for the District of Delaware denied the DOJ's request to enjoin the deal. On May 1, 2020, the UK's Competition & Markets Authority (CMA) voted to block the merger, and Sabre and Farelogix subsequently abandoned the deal. On May 12, 2020, the DOJ filed a motion with the Court of Appeals for the Third Circuit to vacate the District Court's decision. On July 21, 2020, the Third Circuit granted the DOJ's motion to vacate, and the DOJ issued a statement saying that "[b]ecause of the Court of Appeals' decision, the District Court's errors should not influence the analysis when these important issues [concerning two-sided markets] are litigated in future cases."
  • FTC and DOJ release the 42nd Annual Hart-Scott-Rodino Report. On July 8, 2020, the agencies released the report, providing data from HSR Premerger Notification filings in 2019. The report also summarizes merger enforcement activities from 2019, including the 38 merger challenges brought by the agencies.

Policy

  • FTC increases dollar thresholds for both HSR premerger filings and interlocking directorates. On January 28, 2020, the FTC announced its annual revision of the filing thresholds under the Hart-Scott-Rodino Antitrust Improvements Act (HSR Act), increasing the threshold for a reportable transaction from $90 million to $94 million. On January 21, 2020, the FTC also announced revisions to thresholds relating to prohibitions on interlocking directorates under Section 8 of the Clayton Act.
  • FTC and DOJ submit letter to California State Assembly Member raising concerns that new state bill would lessen competition among California beer wholesalers. On March 23, 2020, the FTC and DOJ submitted a joint letter detailing the agencies' concerns with and urging the California legislature to reject California Assembly Bill 1541, which would impose new restrictions making it more difficult for beer manufacturers to terminate their distribution agreements with wholesalers.
  • FTC reviews its Prohibition of Energy Market Manipulation Rule and seeks public comment. On May 18, 2020, the FTC announced that it is seeking public comment on whether it should revise its Prohibition of Energy Market Manipulation Rule. The rule prohibits fraudulent or deceptive conduct relating to purchase or sale of wholesale gasoline, crude oil or petroleum distillates.
  • DOJ and FTC issued new vertical merger guidelines. For the first time since 1984, on June 30, 2020, the DOJ and FTC issued a revision to the agencies' guidance on vertical mergers. Earlier this year, the agencies had released draft revised guidelines, and FTC Commissioner Christine S. Wilson offered her views on the draft vertical merger guidelines at a DOJ's workshop.
  • DOJ works with the International Competition Network (ICN) on release of new International Leniency Guidelines. On July 10, 2020, the DOJ issued a press release on the ICN "Guidance on Enhancing Cross-Border Leniency Cooperation." The guidance is meant to help competition agencies around the globe coordinate efforts when dealing with leniency applicants in cross-border investigations.

Speeches

  • FTC Commissioners discuss antitrust implications of non-compete clauses at FTC workshop. On January 9, 2020, the FTC hosted a workshop on non-compete clauses in the workplace. Commissioners Noah Joshua Phillips and Rebecca Kelly Slaughter both delivered remarks reaffirming the agency's commitment to antitrust enforcement in labor markets.
  • Delrahim delivers remarks on the merger review landscape. On February 5, 2020, at the Media Institute luncheon, Assistant Attorney General Makan Delrahim reported on the DOJ's efforts to modernize the merger review process, and expressed his concerns with states "undercutting" federal enforcement decisions. Delrahim highlighted the T-Mobile/Sprint transaction as an example of a smaller group of state attorneys general trying to undo nationwide relief that the DOJ and others negotiated with the merging parties.
  • DOJ reiterates importance of cooperation in criminal antitrust investigations. On February 7, 2020, at the GCR Live 9th Annual Antitrust Law Leaders Forum, Deputy Assistant Attorney General Richard A. Powers reflected on recent antitrust criminal trials and enforcement efforts, and commented on the importance of the cooperation of companies and individuals during an investigation.
  • FTC Bureau Director explains breadth and flexibility of FTC's remedial powers. On February 8, 2020, at the GCR Live 9th Annual Antitrust Law Leaders Forum, Bureau of Competition Director Ian Conner discussed the various remedial tools that the FTC can wield to solve competitive merger issues, address IP issues, and to remedy anticompetitive conduct.
  • DOJ presents the Procurement Collusion Strike Force (PCSF) at Organization for Economic Cooperation and Development (OECD) Competition Committee's virtual meeting. On June 16, 2020, Assistant Attorney General Makan Delrahim presented the PCSF, an interagency partnership, to the international competition law enforcement community. Delrahim remarked, "We hope the Strike Force can serve as a model for other countries looking for innovative ways to more effectively fight bid rigging and other anticompetitive schemes that impact public procurement, and cheat taxpayers, all over the world."

© Arnold & Porter Kaye Scholer LLP 2020 All Rights Reserved. This newsletter is intended to be a general summary of the law and does not constitute legal advice. You should consult with counsel to determine applicable legal requirements in a specific fact situation.

  1.  The agencies did, however, recognize that the COVID-19 pandemic may require some cooperation among governments, private businesses and individuals.

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