Antitrust & Competition Technology 1H 2026 Update

The first half of 2026 brought a more permissive environment for technology M&A in the United States and a more mature, assertive phase of digital enforcement in Europe, against a backdrop of shifting legal frameworks, agency leadership changes, and procedural uncertainty. In the United States, the period was defined less by new merger challenges than by structural change to the enforcement apparatus itself: a federal court’s decision to vacate the expanded Hart-Scott-Rodino (HSR) premerger notification rules, the abrupt departure of the head of the Department of Justice (DOJ) Antitrust Division, and a fresh round of agency guidance projects. Against that backdrop, the agencies cleared or declined to challenge a series of large technology, AI, and cybersecurity transactions while signaling that the talent-and-licensing structures driving the AI deal market are now squarely on their radar.

Across the Atlantic, the story was one of digital regulation coming of age. The European Commission published the first statutory review of the Digital Markets Act (DMA) and a sweeping draft overhaul of its merger guidelines — the first in two decades — and took the rare step of imposing interim measures against Meta in its first abuse-of-dominance case centered on AI. In the United Kingdom, the Competition and Markets Authority (CMA) moved its new digital-markets regime from designation into implementation, resolved its long-running, cloud-market investigation, and opened a fresh probe into Microsoft’s software licensing.

For technology companies, the throughline is AI, which now shapes nearly every strand of competition policy — from how deals are structured and reviewed to the theories enforcers are developing around data, compute, and talent. This update surveys the principal developments of the first half of 2026 in the United States and then across the United Kingdom and the European Union.

United States

The Expanded HSR Rules Are Vacated

On February 12, 2026, the U.S. District Court for the Eastern District of Texas vacated the 2024 amendments to the HSR premerger notification rules, which had taken effect only a year earlier.¹ The expanded form, finalized in the closing weeks of the prior administration, had significantly increased the volume of documents and disclosures required of filing parties, adding meaningful time and expense. Ruling on a challenge brought by the U.S. Chamber of Commerce, the court held that the Federal Trade Commission (FTC) had exceeded its statutory authority and had not adequately justified the new requirements. The FTC sought an emergency stay from the Fifth Circuit, but after an initial administrative pause, that stay was denied, and by March 2026, the agencies were again accepting filings on the pre-2025 form that had governed merger notification for nearly 50 years.

The reprieve may prove temporary. In March 2026, the FTC and DOJ jointly opened a public-comment process to assess which elements of the vacated form delivered genuine analytical value and which simply imposed cost, with comments due by late May.² The FTC made clear that it regards the decades-old legacy form as inadequate for reviewing modern transactions and that it is weighing a fresh rulemaking that could reintroduce some of the vacated requirements through a more defensible process. For now, dealmakers benefit from a materially lighter filing burden, but the long-term fate of the US premerger notification remains unsettled.

A parallel trend bears watching: Colorado and Washington have enacted their own “mini-HSR” statutes requiring parallel state filings for certain deals, with other states considering similar measures. This is a development that adds cost and complexity to multistate transactions and reflects a broader appetite among state enforcers for an independent role in merger review.

Turnover at the Antitrust Division and a Reshaped FTC

The period also brought significant personnel upheaval at the federal agencies. On February 12, 2026, Assistant Attorney General Gail Slater announced her departure as head of the DOJ Antitrust Division (the “Division”), less than a year after taking office.³ Her exit followed the departure days earlier of a senior deputy and came amid reporting of friction between the Division and the broader administration over the handling of specific matters.

At the FTC, the president nominated David MacNeil, the founder and chief executive of an automotive-accessories manufacturer, to fill the seat vacated by former Commissioner Melissa Holyoak.⁴ The leadership flux underscores a theme that has become a fixture of US merger-risk assessment: For high-profile transactions in politically salient sectors, the universe of relevant decision-makers may extend beyond the career staff and agency heads who traditionally drove outcomes, and counsel should plan accordingly.

Remedies Return, and a Rethink of How the Agencies Litigate

A defining feature of enforcement in early 2026 was the agencies’ continued willingness to resolve competitive concerns through negotiated remedies rather than litigation. This is a marked departure from the prior administration, which had largely abandoned consent decrees in favor of outright challenges. The Boeing/Spirit AeroSystems settlement, which paired a structural divestiture with behavioral commitments requiring continued supply to Boeing’s rivals, exemplified the renewed openness to remedy packages, including behavioral terms that had been out of favor for the better part of a decade. FTC Commissioner Mark Meador reinforced the point in a March 2026 address, describing remedies as an essential part of the merger-enforcement tool kit and a corrective to the prior leadership’s skepticism.⁵

The FTC also moved to recalibrate how it litigates merger challenges, announcing changes to its use of Section 13(b) preliminary injunction proceedings. The change is intended to give merging parties earlier access to review before a neutral federal judge and to address criticism that the agency’s administrative process has sometimes been used to delay or effectively block transactions before the merits are fully tested.⁶ And in February 2026, the FTC and DOJ jointly launched a public inquiry into potential new guidance on collaborations among competitors, seeking input on how to update guidance dating to 2000 for an economy in which joint ventures, data-sharing arrangements, and research collaborations — many of them in AI — are central to innovation.⁷ Taken together, these initiatives reflect an enforcement philosophy the agencies have described repeatedly as “law enforcement, not regulation”: continued vigilance where the facts support a conventional theory of harm, paired with a deliberate effort to avoid chilling procompetitive dealmaking.

The Deals Keep Clearing

The permissiveness of the current environment continued to show up in deal outcomes. In February 2026, Palo Alto Networks completed its roughly $25 billion acquisition of CyberArk, combining a leader in privileged-access identity security with a broad network- and cloud-security platform. Despite the potential for bundling and platform-lock-in theories, the transaction drew no US challenge.⁸ The same month, the DOJ granted unconditional clearance to the merger of Getty Images and Shutterstock, the two largest stock-photography and visual-content platforms, after an extended review.⁹ The decision reflected an assessment that the market for visual content is broader and more dynamic than a narrow share analysis would suggest and, in particular, that generative-AI image tools represent a real and growing competitive constraint. The CMA reached a more cautious conclusion, conditionally clearing the deal in May 2026 subject to divestiture of Shutterstock’s editorial business,¹⁰ a familiar instance of transatlantic divergence on concentrated digital-media markets.

These outcomes are consistent with a pattern that hardened over the prior year: Large, vertically inflected technology and AI transactions — deals that secure inputs, infrastructure, distribution, or data — have drawn limited in-depth review but not enforcement.

The Acqui-Hire Question Comes Into Focus

If a question hangs over the AI deal market, it is how enforcers will treat the talent-and-licensing arrangements that have become a signature feature of dealmaking. In these deals — sometimes called “acqui-hires” or “reverse acqui-hires” — an established company hires a start-up’s founders and core technical team and acquires a nonexclusive license to its technology. This structure falls outside the HSR Act’s notification thresholds, which are keyed to acquisitions of voting securities, assets, or noncorporate interests. Because a nonexclusive license paired with employment terms does not fall within those categories, many such arrangements are not reportable as presently structured.

Through the first half of 2026, the US agencies moved from observation toward active interest. In January 2026, FTC Chairman Andrew Ferguson acknowledged that the prevalence of these structures was, in part, a response to the prior administration’s hostility to acquisitions and said the agency had begun to examine closely whether particular arrangements are reportable under the HSR Act or were structured to evade notification.¹¹ Commissioner Meador struck a similar note in public remarks, pointing to research suggesting that talent acquisitions can be used to neutralize nascent competitive threats.¹² Lawmakers weighed in as well: In February 2026, a group of senators urged both agencies to investigate specific arrangements involving leading AI and chip companies, characterizing them as devices to “evade scrutiny by antitrust regulators.”¹³ The debate has crystallized around transactions such as Nvidia’s announced $20 billion arrangement with AI-inference start-up Groq, under which Nvidia licensed the start-up’s technology and brought aboard its leadership without triggering a merger filing.¹⁴

The underlying legal question — whether a nonexclusive license coupled with targeted hiring amounts to an acquisition of “assets” within the meaning of the HSR Act — has no settled answer, and the analysis is intensely fact-specific, turning on the nature of the license and any indication that the structure was chosen to avoid review. The absence of any US enforcement action to date, despite the proliferation of these deals, is itself informative. It suggests the agencies may regard a challenge under existing rules as difficult absent evidence of deliberate circumvention. Whether forthcoming guidance leans toward the administration’s stated view that M&A is vital to AI innovation or toward the more skeptical instinct that talent absorption can entrench incumbents will be one of the most consequential questions for technology dealmaking in the year ahead.

The Big Tech Cases Shift to Remedies

The marquee monopolization cases against the largest platforms increasingly turned on the question of relief rather than liability. In the FTC’s long-running challenge to Meta’s acquisitions of Instagram and WhatsApp, the agency filed a notice of appeal to the D.C. Circuit on January 20, 2026, following the November 2025 trial ruling that Meta does not hold monopoly power in personal social networking once TikTok and YouTube are counted as competitors.¹⁵ The appeal will test an issue of broad significance for digital markets: the extent to which a relevant market can exclude adjacent platforms that compete for the same user attention and the difficulty of mounting retrospective challenges to acquisitions cleared years earlier in markets that have since transformed.

In the Google search monopolization case, the behavioral remedies that Judge Mehta imposed in September 2025 — barring exclusive default agreements and requiring data sharing and syndication with qualified rivals but stopping short of a Chrome divestiture — moved into the appellate phase, with Google challenging the underlying liability finding and seeking to pause implementation and with the government cross-appealing the refusal to order structural relief.¹⁶ Briefing is expected to extend through the second half of 2026, with argument unlikely before late in the year.

The Google ad-technology case, in which Judge Brinkema found in April 2025 that Google had unlawfully monopolized two publisher-side markets, remained in its remedies phase. After a two-week remedies trial in the fall of 2025 and closing arguments in November, a decision was awaited through the first half of 2026.¹⁷ During the hearings, the court pressed the DOJ hard on the feasibility and timing of its central demand — a forced divestiture of Google’s ad exchange — and questioned whether a years-long structural process would serve the small publishers the case was meant to protect, signaling at least some skepticism toward the government’s most aggressive proposals. However, the court rules, the practical impact will turn on appellate review and could take years to materialize, which is a recurring pattern in the platform cases where a liability win on paper is only the opening chapter.

Ex-US Developments

EU Merger Guidelines: The Commission Redraws Its Assessment Framework

On April 30, 2026, the European Commission (the “Commission”) published its draft new merger guidelines for consultation, the first substantive revision of EU merger assessment guidance in over two decades. Once adopted, the guidelines will replace the 2004 Horizontal Merger Guidelines and 2008 Non-Horizontal Merger Guidelines, consolidating them into a single text organized around theories of harm rather than merger type. The substantive test is untouched — the Commission must still establish a significant impediment to effective competition — but the framing is new: The draft opens by expressly acknowledging the role of merger control in supporting the EU’s competitiveness and resilience objectives and explains that scale, innovation, investment, and resilience must be given adequate weight as potentially pro-competitive factors. The consultation closed on June 26, 2026, and the Commission intends to finalize the text before the end of the year, with the new analytical approaches likely to influence cases under review in the interim.

The most significant change for merging parties is the treatment of efficiencies. Under the current guidelines, these are rarely relied on in practice, given the high standard of proof. The draft moves them to the center of the assessment: Parties are encouraged to articulate a “theory of benefit,” distinguishing between direct efficiencies (such as cost savings and improved products) and dynamic efficiencies (such as an increased ability and incentive to invest and innovate). Early engagement is clearly encouraged and appears to be working in practice: The Commission is reported to have engaged with the efficiency claims submitted by the Airbus/Air France joint venture parties before clearing the transaction unconditionally. The draft also introduces an “innovation shield,” a soft safe harbor under which acquisitions of start-ups and small R&D-driven companies will not in principle raise competition concerns, provided certain conditions are met. Notably for the technology sector, these include that the acquirer is neither the largest firm in the relevant market nor a gatekeeper designated under the DMA. The shield should give acquirers a degree of comfort against “killer acquisition” allegations and, indirectly, against the Article 22 referral risk that has persisted since Illumina/Grail.

At the same time, the draft expands the Commission’s analytical tool kit. Entrenchment of a dominant position, the theory applied in Booking/eTraveli, becomes a standalone theory of harm, capturing transactions that would make a dominant position less contestable regardless of the merged entity’s future conduct and without the need to demonstrate exclusionary effects under the usual foreclosure framework. Portfolio effects are likewise recognized as a distinct theory of harm that does not require foreclosure, and foreclosure itself is broadened to include degrading interoperability, as considered in Google/Fitbit. The draft guidelines also bring previously peripheral areas expressly within the purview of the Commission’s assessment. Noncontrolling minority shareholdings and common institutional ownership are identified as potential sources of competitive harm in their own right or as factors capable of amplifying the anticompetitive effects of a transaction — a development consistent with the direction of enforcement noted in our Q2 2025 update, where the Commission’s Delivery Hero/Glovo decision sanctioned the anticompetitive use of a minority stake for the first time. Labor markets are addressed for the first time in EU merger guidance: Harm in purchasing markets, including for labor, is expressly treated as capable of producing an SIEC, with the Commission assessing whether a merger creates or strengthens buyer power over labor, leading to lower wages or worse working conditions, even in the absence of any adverse effect in downstream product markets. Countervailing factors, including collective bargaining and applicable labor regulation, may limit these effects, and it remains unclear how such assessments will work in practice or how they will be reflected in the notification process.

Taken together, the draft guidelines give the Commission broader grounds for intervention alongside broader grounds for clearance. How that balance resolves will emerge only through decisional practice, and the first decisions under the new framework will be closely watched, in particular, for the depth of the Commission’s engagement with theories of benefit, the frequency with which entrenchment is deployed against platform acquisitions, and the resilience of the innovation shield where a referral is in contemplation.

Meta/WhatsApp: The Commission Reaches for Interim Measures in AI

On June 9, 2026, the Commission ordered Meta to restore access to WhatsApp for rival AI assistants, only the second interim measures decision it has adopted under Regulation 1/2003 — the first being Broadcom in 2019. The order arises from the abuse-of-dominance investigation opened in December 2025 into Meta’s policy of October 15, 2025, which barred third-party general-purpose AI assistants from the WhatsApp for Business API with effect from January 15, 2026, leaving Meta AI as the only assistant available on the platform. A Statement of Objections followed in February; Meta’s revised policy of March 4, 2026, readmitted third-party assistants but attached a fee that the Commission preliminarily found equivalent in effect to the original ban, prompting a supplementary Statement of Objections in April. The Commission’s provisional findings are that Meta has held a dominant position in the EEA-wide market for consumer communication applications since at least January 2023 and that the exclusion amounts to a refusal to provide access to an infrastructure developed for, and previously open to, third parties.

The decision requires Meta to reinstate access for third-party general-purpose AI assistants on the terms that applied before October 15, 2025 — that is, without charge — and to maintain those conditions until the investigation concludes or June 2029, whichever is earlier. Meta has characterized the decision as regulatory overreach and confirmed it will appeal. The substantive investigation continues, but the procedural move is telling: A tool used once in two decades has been deployed in what the Commission considers necessary to protect competition in general-purpose AI assistants, on its express reasoning that in fast-moving markets, competition can be lost long before a final decision is reached. The decision treats messaging platforms as distribution infrastructure for AI services — a framing with evident implications for any key platform that integrates a proprietary assistant while setting the terms of third-party access.

The DMA Review: AI and Cloud Move to the Centre

On April 28, 2026, ahead of the May 3 deadline set by Article 53, the Commission published its first statutory review of the DMA, concluding that the regime remains fit for purpose and does not require revision. The more telling signal lay in the priorities identified for the next phase: AI and cloud computing. Rather than expanding the DMA’s perimeter through legislation, the Commission intends to enforce the existing framework more rigorously (cloud-designation decisions are flagged for later in 2026, and the Commission is examining whether the Article 6(7) interoperability obligation could extend to cloud services) while keeping open whether generative AI should be drawn in as a core platform service over time.

That scrutiny is already materializing through the two specification proceedings opened against Google in January. In April 2026, the Commission issued preliminary findings setting out draft measures requiring Google to give third-party AI assistants equally effective access to the Android features used by Gemini (Article 6(7)) and to share anonymized search ranking, query, and click data with rivals — including, notably, AI-chatbot providers — on FRAND terms (Article 6(11)). Final decisions in both proceedings are due by July 27, 2026. The approach effectively treats AI assistants as functional equivalents of search, extending data-access and interoperability obligations to AI systems without amending the DMA’s text — an extension with obvious transatlantic sensitivities given continued US objections to the regime.

Other EU Developments: Below-Threshold Deals, AI Investigations, and Labor Markets

The Commission also continued to press the boundaries of its jurisdiction over transactions that fall below EU notification thresholds. Nvidia’s challenge to the Commission’s acceptance of an Italian call-in referral in the Run:ai matter — a test of whether national discretionary powers can be used to pull below-threshold deals into EU review after the Court of Justice’s Illumina/Grail ruling curtailed the Article 22 route — proceeded to a hearing in March 2026, with a judgment (expected later this year) that will shape the reviewability of strategically sensitive technology acquisitions across Europe.¹⁸ 

The Meta interim-measures decision is not the only front on which the Commission is examining how dominant platforms deploy AI. A parallel Article 102 investigation, opened in December 2025, is assessing Google’s use of publisher and video content to power its AI overviews and AI-mode search features, including whether the terms imposed on content providers are unfair.¹⁹ On the compliance front, Meta moved to address the Commission’s objections to its “consent or pay” advertising model by offering EU users a less personalized advertising option. These matters confirm that AI has become the central battleground of European platform enforcement, even as the legislative perimeter remains under debate.

Labor-market competition remained a live enforcement theme with particular resonance for talent-intensive technology firms — now reinforced by the draft merger guidelines’ express treatment of labor-market harm described above. Building on the EU’s first labor-market cartel decision in 2025, the Commission’s investigation into suspected no-poach arrangements in the data-center construction sector continued. For technology companies competing intensely for AI and engineering talent, hiring restraints and the exchange of compensation information carry real antitrust exposure.

United Kingdom: From Designation to Implementation

The UK’s bespoke digital-competition regime under the Digital Markets, Competition and Consumers Act (“DMCC Act”), which took effect at the start of 2025, entered its operational phase in 2026. Having issued its first Strategic Market Status (SMS) designations in late 2025 — covering Google in search and search advertising and Google and Apple in mobile ecosystems — the CMA turned in 2026 to the harder work of designing and consulting on the conduct requirements that give the designations teeth. SMS designations last five years and expose firms to conduct rules backed by penalties of up to 10% of global turnover, so the substance of those requirements and the pace at which the CMA moves will determine whether the UK regime proves as consequential in practice as the EU’s DMA.

The most significant UK development of the period was the resolution of the CMA’s three-year cloud-services market investigation. On March 31, 2026, rather than designating the two largest providers, the CMA took a calibrated, two-track approach.²⁰ It accepted nonbinding commitments from Amazon Web Services and Microsoft to reduce or remove data egress fees and improve interoperability between cloud platforms — concerns the investigation had identified as barriers to switching and multi-cloud adoption — with the CMA board to review progress within six months. At the same time, it declined to pursue AWS further but launched a fresh SMS investigation into Microsoft’s business software ecosystem, set to begin in May 2026, focused on whether Microsoft’s licensing of products such as Windows Server and SQL Server makes them more costly to run on rival clouds and thereby steers customers toward Azure.²¹ CMA Chief Executive Sarah Cardell framed the action partly in forward-looking terms, emphasizing the need to ensure a level playing field as AI capabilities are embedded into everyday business software. The episode illustrates the CMA’s evolving tool kit: a willingness to accept voluntary commitments where they resolve discrete concerns, reserving formal designation for issues — like software-licensing leverage — unique to a single firm.

On the merger-control side, the CMA continued the recalibration that characterized 2025, when it blocked no deals and cleared fewer transactions with remedies than in prior years, under government pressure to align competition policy with growth. That recalibration extends to multijurisdictional deals: Consistent with its updated jurisdiction and procedure guidance, the CMA will generally adopt a “wait and see” approach to mergers concerning exclusively global markets, deferring to proceedings elsewhere where remedies agreed upon in other jurisdictions would address any UK concerns. However, where a transaction has a UK-specific dimension, or where global remedies carve out the UK or lack UK monitoring and enforcement, the CMA retains — and will exercise — its ability to open a formal investigation at any point within the four-month statutory window and will then consider all theories of harm, not merely the UK-specific ones. Early, UK-specific engagement therefore remains important for deals with a genuine UK nexus. Procedural reform is also in train, including a consultation on concentrating Phase 2 decision-making authority at the CMA board level — part of a broader streamlining of the regime whose practical effect on merging parties will depend on the final design. The DMCC Act’s parallel, mandatory merger-reporting obligations for SMS-designated firms add a further layer of execution risk for global technology deals, particularly those involving minority investments, partnerships, or nontraditional structures.

Outlook

The first half of 2026 leaves the technology sector with a more navigable, but less predictable, competition-law landscape than a simple narrative of deregulation would imply. In the United States, the practical environment for technology M&A is more permissive than during the prior administration. Large deals are clearing, remedies are once again available, and the filing burden has, for now, eased. Yet the legal architecture is in flux, agency leadership is unsettled, and the treatment of AI talent-and-licensing structures remains open. In Europe, the direction of travel is toward more assertive enforcement of maturing digital regimes and a modernized, innovation-focused approach to merger control, even as the EU’s competitiveness agenda introduces new flexibility and new uncertainty in equal measure.

Several questions will define the remainder of the year. Will the FTC pursue a new HSR rulemaking, and how much of the vacated form will return? Will the agencies bring a test case or issue guidance on acqui-hires, or will these structures remain largely outside premerger review? How will the courts resolve the remedies and appeals in the Google cases, and what will the ad-tech decision mean for structural relief in platform markets? How will the Commission’s July decisions in the Google specification proceedings and Meta’s appeal of the interim-measures order define platform obligations around AI? Will the EU’s draft merger guidelines and the CMA’s Microsoft investigation translate into materially different outcomes for technology transactions and conduct? And across all of these, how will the deepening entanglement of antitrust with AI policy, national security, and transatlantic trade tensions shape enforcers’ choices?

For companies operating in technology and AI markets, the watchwords for the period ahead are engagement and evidence: early, jurisdiction-specific regulatory engagement; a disciplined, well-documented procompetitive narrative; and careful attention to deal structure and timing in a landscape where the rules themselves are being rewritten. We will continue to track these developments in future updates.

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1. ^[1] Chamber of Commerce of the United States of America v. FTC, No. 6:25-cv-00009 (E.D. Tex. Feb. 12, 2026) (vacating the 2025 amendments to the HSR Premerger Notification and Report Form). ↩

2. ^[2] FTC & DOJ, “Federal Trade Commission and Department of Justice Seek Public Comment on the Premerger Notification and Report Form,” (Mar. 25, 2026), https://www.ftc.gov/news-events/news/press-releases/2026/03/federal-trade-commission-department-justice-seek-public-comment-premerger-notification-report-form (comments due May 26, 2026). ↩

3. ^[3] See, e.g., CBS News, “Trump Officials Oust Abigail Slater as DOJ’s Antitrust Chief, Sources Say,” (Feb. 12, 2026). Acting AAG Omeed Assefi assumed leadership of the Antitrust Division. ↩

4. ^[4] The president nominated David MacNeil to the FTC seat previously held by former Commissioner Melissa Holyoak (nominated Jan. 13, 2026). ↩

5. ^[5] Mark R. Meador, Commissioner, FTC, Remarks at the Antitrust for Digital Markets Forum (Mar. 23, 2026) (describing remedies as “an essential part of the merger-enforcement toolkit”). ↩

6. ^[6] See Andrew N. Ferguson, Chairman, FTC, Remarks at the George Mason Law Review 29th Annual Antitrust Symposium (Feb. 20, 2026) (stating a preference for challenging mergers by seeking permanent injunctive relief in federal court rather than pairing federal-court preliminary injunction proceedings with Part 3 administrative litigation). ↩

7. ^[7] FTC & DOJ, joint public inquiry on potential guidance regarding collaborations among competitors (Feb. 23, 2026) (revisiting the 2000 Antitrust Guidelines for Collaborations Among Competitors). ↩

8. ^[8] See, e.g., “Palo Alto Networks Closes $25B Acquisition of Identity Security Company CyberArk,” (Feb. 2026). ↩

9. ^[9] Getty Images Holdings, Inc., & Shutterstock, Inc., “Getty Images and Shutterstock Receive Unconditional Antitrust Clearance from U.S. Department of Justice,” (Feb. 23, 2026). The CMA cleared the transaction subject to remedies (May 2026). ↩

10. ^[10] CMA, Getty Images/Shutterstock merger inquiry, Final Report (May 15, 2026). ↩

11. ^[11] Bloomberg, “FTC Will Review Acquihires, Chair Ferguson Says,” (Jan. 16, 2026). ↩

12. ^[12] Mark R. Meador, Commissioner, FTC, Keynote Address, Tech Antitrust Conference (Concurrences) (Jan. 15, 2026). ↩

13. ^[13] Letter from Senators Elizabeth Warren, Ron Wyden & Richard Blumenthal to FTC Chairman Ferguson and the DOJ Antitrust Division (Feb. 4, 2026). ↩

14. ^[14] See, e.g., MarketWatch, “Groq execs to join Nvidia as part of AI-chip licensing deal,” (Dec. 2025) https://www.marketwatch.com/story/groq-execs-to-join-nvidia-as-part-of-ai-chip-licensing-deal-1d155338?eafs_enabled=false ↩

15. ^[15] FTC v. Meta Platforms, Inc., Notice of Appeal to the U.S. Court of Appeals for the DC Circuit (Jan. 20, 2026). The trial court ruled for Meta on Nov. 18, 2025. ↩

16. ^[16] United States v. Google LLC (search), remedies opinion (D.D.C. Sept. 2025). The parties have appealed and cross-appealed, and Google has sought a stay pending appeal. ↩

17. ^[17] United States v. Google LLC (ad tech), liability ruling (E.D. Va. Apr. 17, 2025). The remedies trial concluded in November 2025, with a decision awaited; during the hearings the court questioned the feasibility of the government’s proposed divestiture of Google’s ad exchange. ↩

18. ^[18] Nvidia’s challenge to the Commission’s acceptance of an Italian call-in referral in Nvidia/Run:ai proceeded to a hearing in March 2026; see also Case C-611/22, Illumina/Grail. ↩

19. ^[19]  European Commission, Article 102 TFEU proceedings concerning Google’s use of publisher and video content to power its AI Overviews and AI-mode search features (opened Dec. 2025). ↩

20. ^[20] CMA, cloud services market investigation — final package of actions (Mar. 31, 2026) (accepting commitments from AWS and Microsoft on cloud egress fees and interoperability). ↩

21. ^[21] CMA, “CMA launches strategic market status investigation into Microsoft’s business software ecosystem,” (investigation commencing May 2026). ↩

This informational piece, which may be considered advertising under the ethical rules of certain jurisdictions, is provided on the understanding that it does not constitute the rendering of legal advice or other professional advice by Goodwin or its lawyers. Prior results do not guarantee similar outcomes.