Deidre Johnson Discusses Court Decision Vacating Expanded HSR Filing Rules in The National Law Journal

U.S. District Judge Jeremy Kernodle of the Eastern District of Texas vacated the Federal Trade Commission’s expanded Hart-Scott-Rodino (HSR) merger filing requirements, ruling that the agency failed to demonstrate that the revised disclosure framework would prevent unlawful transactions beyond those already addressed under the prior rules.

In The National Law Journal, antitrust partner Deidre Johnson discussed the implications of the 2025 HSR rules in light of the court's decision, noting that the expanded filing requirements imposed significant timing and compliance burdens on dealmaking parties, particularly given the breadth of disclosures required across transactions.

“The district court ruling recognizes the extreme burden of the new rules in terms of time to comply, and the speed at which you are able to get your deal through,” Deidre said.