Antitrust Trends in Technology, Life Sciences, and Healthcare

The first quarter of 2025 brought a surge of high-profile merger activity in the technology and artificial intelligence (AI) space, offering an early test of how antitrust regulators under the new Trump administration will handle technology deals. Initial signals indicate that US enforcers remain willing to challenge deals they view as anticompetitive under traditional horizontal theories of harm — particularly mergers between direct competitors with leading market positions.

While M&A activity has slowed in the tail end of the first quarter of 2025, including in healthcare, there have been several noteworthy developments in the antitrust space in the first 100 days of the Trump Administration. The Federal Trade Commission (FTC), under new Chairman Andrew Ferguson, has already launched its first merger challenge, affirmed its acceptance of the 2023 Merger Guidelines, reinstituted early termination of HSR filings, and allowed the new HSR filing rules to take effect. Further, President Trump fired the two sitting Democratic Commissioners in March 2025, leaving the leadership of the FTC in the hands of the three sitting Republican Commissioners. Meanwhile, in addition to joining the FTC in affirming the Merger Guidelines and HSR filing rules, the Department of Justice Antitrust Division (DOJ) under Assistant Attorney General Gail Slater announced an “Anticompetitive Regulations Task Force,” which will seek to identify regulations that undermine competition and promote overbilling and consolidation in healthcare, among other industries.

While M&A activity slowed in the first quarter of 2025, including in life sciences, there have been plenty of noteworthy developments in the antitrust space in the first 100 days of the Trump administration. The Federal Trade Commission (FTC) under new Chairman Andrew Ferguson has already launched its first merger challenge while also signaling a more deal-friendly approach by reinstituting the “early termination” process, whereby the FTC uses its discretion to terminate a Hart-Scott-Rodino (HSR) review prior to the expiration of the statutory review period in instances in which the transaction does not present any competitive issues.

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