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AAI Urges D.C. Circuit to Vacate District Court’s Market Definition and Monopoly Power Errors in FTC Challenge to Meta’s Instagram, WhatsApp Acquisitions (FTC v. Meta Platforms)

On May 29, 2026, the American Antitrust Institute (AAI) filed an amicus brief in FTC v. Meta Platforms, Inc., No. 26-5028, asking the D.C. Circuit to vacate a district court judgment in favor of Meta and remand for a proper analysis of the relevant market and Meta’s alleged monopoly power in the FTC’s Section 2 challenge to Meta’s acquisitions of Instagram and WhatsApp.

After a six-week bench trial, the district court ruled in Meta’s favor, finding that the FTC had failed to prove a relevant market for personal social networking services—centered on friends-and-family broadcast sharing—and that Meta lacked monopoly power even within the market the FTC alleged. The court placed dispositive weight on Meta’s experiments purporting to show diversion of consumer time between Facebook and Instagram on the one hand and TikTok and YouTube on the other, defining a broader market than the FTC alleged. It declined to find monopoly power based on Meta’s market shares, which the FTC’s expert calculated at between 54% and 62%.

AAI’s brief argues that the district court committed two independent categories of reversible error. First, it misapplied foundational market definition principles in four related but distinct ways. It bypassed analysis of functional interchangeability—whether consumers use TikTok and YouTube for the same purpose as Meta’s apps—and instead credited substitution evidence untethered from consumer purpose, effectively defining the market based on firms rather than products. It also misapplied the Hypothetical Monopolist Test because the evidence it relied on, including consumer behavior in response to temporary app outages and India’s permanent ban of TikTok, which modeled price increases ranging from 12% to infinity, did not properly approximate the small but significant and non-transitory price increase (SSNIP) the test requires. The court further failed to apply the “narrowest market principle,” which requires defining markets from the inside out rather than the outside in, and it drew the wrong inference from evidence of Meta’s sustained economic profits, which, properly understood, shows that TikTok and YouTube do not constrain Meta’s market power.

Second, the district court independently erred by applying an improper standard for measuring monopoly power. It treated a 65% market share as a de facto threshold for inferring monopoly power when the better-reasoned authorities hold that a market share above 50% can support a monopoly power finding. The FTC’s evidence cleared this threshold even in the district court’s overbroad market.

The brief was written by Brendan Benedict and Michael Altebrando of Benedict Law Group PLLC, a generalist litigation boutique with a focus on antitrust and consumer protection. AAI thanks Mr. Benedict and Mr. Altebrando for serving as pro bono counsel.

Read the full amicus brief: AAI Amicus Brief in FTC v. Meta Platforms, Inc.

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AAI Urges Ninth Circuit Not to Second Guess Jury Verdicts Defining Single-Brand Product Market and Awarding Half-Billion Dollars in Treble Damages (Innovative Health, LLC v. Biosense Webster, LLC)

The American Antitrust Institute (AAI) recently filed an amicus brief in Innovative Health, LLC v. Biosense Webster, LLC, No. 25-6024, urging the Ninth Circuit to affirm jury verdicts that a Johnson & Johnson Company, Biosense Webster, violated Sections 1 and 2 of Sherman Act and the Cartwright Act through unlawful tying, monopolization, and attempted monopolization.

Biosense manufactures cardiac mapping machines, which are used by electrophysiologists to help treat irregular heart rhythms. Biosense also provides clinical support for the machines and sells catheters needed for mapping procedures. The FDA permits used catheters to be reprocessed for re-use. Innovative is a reprocessor that competes against Biosense by selling what the evidence showed are lower-priced, higher-quality catheters.

Biosense adopted a tying policy conditioning its provision of clinical support on a hospital’s purchase of Biosense catheters. Innovative alleged that Biosense’s conduct excluded reprocessors from the catheter market, thus depriving hospitals of the choice to buy superior catheters on better terms. In finding that Biosense’s policy represented an unlawful tie, the jury agreed with Innovative that clinical support for Biosense’s mapping machines, the tying product, represented a single-brand aftermarket under the so-called Kodak/Epic lock-in standards. The jury awarded Innovative over $147 in damages for lost sales, an amount subject to trebling under the Clayton Act.

On appeal, Biosense argues that courts extremely rarely define single-brand aftermarkets due to a legal presumption against them, and that the damages award should be disaggregated to remove conduct that Biosense claimed was lawful.

AAI’s brief pushes back on Biosense’s challenges to the jury verdicts. AAI showed that there is no such presumption against single-brand markets in aftermarkets, and that courts regularly recognize such markets where, as here, real-world economic evidence demonstrates that competition in a foremarket fails to discipline anticompetitive conduct in the aftermarket. On the issue of damages disaggregation, AAI showed that Biosense’s position lacked both factual and legal support given the jury’s finding that hospitals were coerced into purchasing Biosense catheters and the jury’s conclusion that all of Biosense’s conduct was unlawful.

The brief was written by AAI General Counsel Mark S. Hegedus with assistance from AAI President Randy M. Stutz.

Read the full amicus brief: AAI Amicus Brief in Innovative Health, LLC v. Biosense Webster, LLC

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AAI Corrects the Record on the Use of Circumstantial Evidence to Prove a Section 1 Violation (In re Libor-Based Financial Instruments Antitrust Litigation)

On May 26, 2026, the American Antitrust Institute (AAI) filed an amicus brief in In re Libor-Based Financial Instruments Antitrust Litigation, No. 25-2756, asking the Second Circuit to reverse a district court’s opinion granting summary judgment to defendant banks in investors’ Section 1 claim arising out of the London Interbank Offered Rate (LIBOR) bid-rigging scandal uncovered in the wake of the 2008 financial crisis.

The plaintiffs, a large group of investors, brought Section 1 claims against 16 major banks for conspiring to manipulate the U.S. dollar LIBOR to depress interest payments and improve public perceptions of their financial health between 2007 and 2010. In 2016, after the district court dismissed the case for failing to allege antitrust injury, the Second Circuit reversed, relying on arguments presented in an AAI amicus brief to hold that the plaintiffs properly alleged horizontal price fixing and antitrust injury.

In 2025, after discovery, the district court granted summary judgment for the defendant banks, reasoning that, because the record contained no direct evidence, the plaintiffs had to show parallel conduct and “plus factors” establishing the existence of an illegal conspiracy. The court held that their evidence failed to rule out the possibility that the banks acted unilaterally, without conspiring.

AAI’s brief argues that the district court was wrong to force the plaintiffs’ claims into the so-called parallel-plus framework and that, in addition, it misapplied the standard for assessing parallel conduct within that framework. To prove their Section 1 claim, the plaintiffs relied on both economic evidence of the banks’ parallel offering-rate submissions and non-economic evidence of verbal communications that independently supported an inference that the banks coordinated their submissions. The district court held that the written communications, because they did not qualify as direct evidence of an agreement, were ambiguous and therefore lacked probative value under Matsushita. It further held that, because the plaintiffs relied only on circumstantial evidence, they could prove a Section 1 claim only using the parallel-plus framework.

The AAI brief explains that evidence similar to the evidence in this case has been deemed direct evidence by other courts, and even if the evidence is circumstantial, it is not rendered ambiguous or insufficient under Matsushita simply because it is subject to competing inferences. The distinction between direct and circumstantial evidence is often illusory and does not support a legal rule that formulaically forces parties into alternative modes of analysis.

AAI also argued that Section 1 plaintiffs can independently prove their claims outside the parallel-plus framework by relying on non-economic evidence of an actual agreement, and under the summary judgment standard, courts may not take the case from a jury if a reasonable juror could draw one of multiple competing inferences in the plaintiffs’ favor.

AAI also explained that, even under the parallel-plus framework, the plaintiffs’ cumulative evidence should have been more than enough to establish parallel conduct, and the district court failed to follow the Second Circuit’s guidance on examining plus factor evidence holistically.

The brief was written by AAI President Randy Stutz and AAI Senior Counsel David O. Fisher.

Read the full brief: AAI’s Amicus Brief (In re Libor-Based Financial Instruments Antitrust Litigation

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AAI Provides Comprehensive Analysis of Competitor Collaborations to FTC and DOJ

On May 21, 2026, AAI filed detailed public comments in response to a joint notice of public inquiry from the Federal Trade Commission and Department of Justice regarding potential revisions to the April 2000 Antitrust Guidelines for Collaborations Among Competitors.

Competitor collaborations—which may include joint ventures, trade or professional associations, licensing arrangements, or strategic alliances—are contractual arrangements among rivals that may produce benefits to consumers by enabling firms to offer superior goods or services, bring products to market faster than they otherwise could, facilitate better use of existing assets, or create incentives for output-enhancing investments. But they also present serious risk of anticompetitive harm, particularly where they mask per se violations of the Sherman Act that would otherwise generate criminal liability.

The Agencies withdrew the 2000 Guidelines in December 2024, committing to enforcement on a case-by-case basis and directing businesses contemplating competitor collaborations to review the relevant statutes and caselaw. In their recent notice of public inquiry, the Agencies sought comments on an array of issues that arise in analyzing competitor collaborations.

AAI’s comments make the following recommendations:

General Drafting Principles

  • The Agencies should make the revised guidelines accessible not only to businesses and their counsel but the courts, private enforcers, and the public. 
  • The Agencies should eliminate the suggestion in the 2000 Guidelines that antitrust enforcement may deter procompetitive collaborations. 
  • Throughout the revised guidelines, the Agencies should give equal attention to sell-side and buy-side conduct, horizontal and vertical restraints, and exclusionary and collusive effects. 
  • The Agencies should forgo safe harbors and eliminate “safety zones.”


Applying the Rule of Reason

  • The Agencies should clarify that the rule of reason has four steps, not three. 
  • The Agencies should clarify that the plaintiff’s burden at Step 1 of the rule of reason is satisfied by a direct or indirect showing of anticompetitive effects. 
  • The Agencies should clarify that the defendant’s burden at step 2 is a burden of proof. 
  • The Agencies should clarify that the defendant has the burden at Step 2 to show procompetitive justifications that are nonpretextual. 
  • The Agencies should specify that cognizable efficiencies must be “in the relevant market.” 
  • The Agencies should emphasize the heightened importance of relying on the per se rule when a competitor collaboration’s horizontal restraints lack cognizable procompetitive justifications. 
  • The Agencies should recognize that vertical restraints that have collusive effects and no cognizable efficiencies can be condemned under the quick-look standard.


Applying the Ancillary Restraints Doctrine

  • The Agencies should specify that the ancillary restraints doctrine is an affirmative defense. 
  • The Agencies should specify that a putatively ancillary restraint is not removed from the per se category simply because it is part of an otherwise efficiency-enhancing integration. 
  • The Agencies should specify that ancillary restraints can be reviewed under the quick-look rule of reason, not just the comprehensive version. 
  • The Agencies should reiterate that two or more restraints are “assessed together” only if they are intertwined “inextricably.” 
  • The Agencies should clarify that the ancillary restraints doctrine does not countenance multi-market balancing for the same reason the rule of reason does not.


Concerted Action

  • The Agencies should clarify that every single competitor collaboration—including those that form single entities—constitutes concerted action subject to Section 1 scrutiny.


Collaborations with Both Vertical and Horizontal Elements

  • The Agencies should specify that collaborations with both horizontal and vertical elements may be reviewed under the per se rule and may be evaluated for both collusive and exclusionary effects.


Platforms

  • The Agencies should address competitor collaborations in markets involving platforms.


Group Purchasing Organizations (GPOs)

  • The Agencies should treat GPOs as a distinct structural category of competitor collaboration and provide the dedicated analytical framework their scale and competitive risks warrant. 
  • The Agencies should explicitly build on the buyer-side market power framework developed in the 2023 Merger Guidelines, according GPOs’ buy-side effects coequal analytical treatment alongside their sell-side effects. 
  • The Agencies should specifically address the information sharing risks associated with GPO membership. 
  • The Agencies should address the particularly significant role of exclusionary contracting in GPOs. 
  • The Agencies should recognize that fee structures can create anticompetitive effects.


Algorithmic Pricing Agreements

  • The Agencies should emphasize that an anticompetitive agreement among competitors need not be express and may be inferred from conduct enabled by modern technologies.
  • The Agencies should make clear that there is no exhaustive list of plus factors and that the absence of any particular plus factor is not fatal to the inference of concerted action.
  • The Agencies should clarify that competitors’ use of the same pricing algorithm may amount to concerted action.

Read the complete comments here: AAI Comments on Revised Competitor Collaboration Guidelines

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AAI Urges FTC to Vigorously Defend Rule Revising Merger Filing Form

On May 8, 2026, the American Antitrust Institute (AAI) submitted a letter to the Directors of the Bureau of Competition and the Bureau of Consumer Protection of the Federal Trade Commission (“FTC”) urging them to recommend that the FTC pursue its appeal of the Eastern District of Texas’s opinion invaliding the Agency’s 2024 rule revising the Hart-Scott-Rodino (“HSR”) Act merger filing form, Chamber of Commerce of the United States v. FTC, No. 6:25-cv-9-JDK, 2026 U.S. Dist. LEXIS 29274 (E.D. Tex. Feb. 12, 2026).

The HSR Act, 15 U.S.C. § 18a, requires merging parties to file a premerger notification form with the FTC and DOJ if their deal exceeds certain dollar and size thresholds. The HSR Form has not been significantly updated since 1978, and a consensus has formed that it is outdated. In 2024, a bipartisan FTC voted unanimously to promulgate a new rule governing the documents and information that merging parties must submit. The U.S. Chamber of Commerce and several co-plaintiffs challenged that rule in the Eastern District of Texas, which invalidated the rule on the grounds that the estimated $39,644 additional costs it imposed on filing parties is not justified. Although the FTC appealed, it subsequently issued a request for public comment on a revised form, suggesting that it may abandon its defense of the 2024 form on appeal.

AAI’s letter urges the FTC to vigorously appeal the Eastern District of Texas’s ruling regardless of whether it proceeds with a further revision. It explains the serious implications of the district court’s approach, which failed to account for antitrust law’s focus on stopping illegal mergers in their incipiency, before their high costs are imposed on consumers and businesses. It also explains how the district court’s improper standing analysis will allow future rulemaking challenges in the district, ensuring that the FTC will continue to face rule challenges which will be held to the same improper standard.

On May 18, 2026, the FTC filed a motion seeking to hold the appeal in abeyance pending a further revision to the rule.

The letter was written by AAI Senior Counsel David O. Fisher.

Read the letter: AAI’s Letter to the Directors of the Bureau of Competition and the Bureau of Consumer Protection of the Federal Trade Commission

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Making Big Tech Antitrust Remedies Stick Beyond the Courtroom: A Conversation with Ron Schnell

In this episode of Ruled by Reason, AAI Vice President and Director of Legal Advocacy Kathleen Bradish talks with Ron Schnell, a computer scientist, startup entrepreneur, and former general manager of the Technical Committee created to monitor Microsoft’s compliance with the U.S. v. Microsoft consent decrees. Their conversation explores what the antitrust bar still hasn’t fully absorbed from one of the most consequential post-remedy enforcement undertakings in U.S. antitrust history. Three themes run through the conversation: the need for early and deep technical engagement in remedy implementation; the informational asymmetry between enforcer and defendant that monitors must work to overcome; and the predictable incentive problems that shape how companies respond to conduct obligations.

The conversation begins with the decree’s main provisions, including the communications protocol obligations (Section 3E) and the middleware access requirements (Section 3H) (4:37). Schnell quickly zeroes in on a central problem: the gap between Microsoft’s and others’ expectations about what compliance entailed and the reality on the ground. Bradish and Schnell then discuss the origins and rapid expansion of the Technical Committee, which grew from a three-person panel into a 93-person nonprofit corporation across three offices, a scaling that reflects the flexibility monitors must build in from the start to respond to challenges that no decree can fully anticipate (9:55).

The conversation turns to the communications protocols project, designed to enable competing servers to interoperate with Windows desktops. Schnell first describes how Microsoft’s initial declaration of compliance was found inadequate, leading to the eventual decision to scrap years of work and start over (13:12). Schnell then walks through the tools the Technical Committee developed to verify documentation accuracy and completeness, including building competing servers from scratch and instrumenting Microsoft’s own test labs to capture network activity. He argues that closing the informational gap requires technical expertise deep enough to go toe-to-toe with the company’s own engineers, and describes situations where TC staff did exactly that (34:33).

Bradish and Schnell then discuss the incentive dynamics that will resonate with anyone versed in behavioral antitrust remedies: any company subject to a consent decree will naturally gravitate toward minimum-effort compliance, making robust technical monitoring a necessity (34:33). They also take up the difficulty of setting enforceable technical milestones without inside knowledge of the project’s scope. On enforcement teeth, Schnell draws a striking contrast between the U.S. approach of relying on the threat of structural remedy and the European Commission’s parallel enforcement of similar protocol documentation requirements against Microsoft, where daily fines proved far more effective at producing timely results than anything in the U.S. decree’s toolkit. Issues that had languished for years in the U.S. proceeding were resolved within days once the EC began imposing fines (39:48).

The conversation also addresses the tension between competition remedies and privacy. Schnell notes that consumer privacy was not a significant factor in the Microsoft decree, where the protocol obligations ran largely business-to-business. But he cautions that privacy will be a much more live issue in remedies touching search, advertising, and data access. While decree drafters and implementers must take these concerns seriously, they must remain alert to defendants invoking privacy as a shield against compliance obligations they would prefer to avoid (43:44).

The episode closes with Schnell’s reflections on what still surprises him about the Microsoft experience, the challenges of recruiting technical talent to monitor work, and his view that AI and automation could substantially accelerate future compliance monitoring, but only if technical committees with the right expertise are built in from the start (53:30).

GUEST

Ron Schnell is Keystone Distinguished Technology Fellow and Expert with over 40 years of experience in software development, cybersecurity, and IT forensics. He began his career as an operating system kernel programmer at Bell Labs, IBM, and Sun Microsystems, and went on to found three technology startups as an entrepreneur. From 2005 to 2011, he served as General Manager and chief executive of the Technical Committee, the private corporation established by the U.S. Courts to monitor Microsoft’s compliance with the 2002 antitrust Final Judgments, a role that drew praise from the U.S. Attorney General across three administrations, multiple state Attorneys General, and the presiding federal court judge. He is also co-author, with antitrust expert Jay Himes and Columbia computer science professor Jason Nieh, of Antitrust Enforcement and Big Tech: After the Remedy Is Ordered, published in the Stanford Computational Antitrust Journal.

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“Don’t Let the Fox Guard the Hen House”: AAI Files Comments Urging FTC to Close Loopholes in Express Scripts PBM Settlement

The American Antitrust Institute (“AAI”) filed public comments with the Federal Trade Commission (“FTC”) on March 16, 2026, weighing in on the agency’s proposed settlement with Express Scripts, one of the country’s largest pharmacy benefit managers (“PBMs”). While AAI applauds the FTC for using Section 5 of the FTC Act to pursue PBMs for anticompetitive insulin pricing practices that have driven up out-of-pocket drug costs for patients, AAI argues the proposed settlement falls short of providing meaningful, lasting relief.

AAI’s comments identify three key flaws in the proposed settlement. First, its core prohibitions apply only to Express Scripts’ “Standard Offering,” leaving a significant loophole that allows insurance companies and employers to negotiate around the settlement’s protections by creating customized offerings. Second, the settlement relies on “Plan Sponsors,” including Cigna, which is vertically integrated with Express Scripts, to act as enforcers on behalf of patients, despite well-documented incentives for those same sponsors to profit from the very practices the settlement aims to curb. AAI draws a cautionary parallel to the Hatch-Waxman experience, where a similar “proxy-enforcer” structure ultimately failed consumers for decades.

Finally, AAI raises concerns that the settlement includes provisions, such as crediting patient payments through the TrumpRx platform and requiring Express Scripts to “re-shore” its purchasing organization from Switzerland, that are unrelated to the harms alleged in the complaint. AAI urges the FTC either to remove those provisions and replace them with alternative relief that protects competition and patients or to explain their connection to the underlying conduct, and it recommends strengthening the consent order by making its prohibitions apply to all Express Scripts plans, not just the Standard Offering.

Read the comments: AAI’s Comments on the Proposed Consent Agreement with Express Scripts, Inc.

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AAI Tells Third Circuit to Be Practical About Substantial Foreclosure in Exclusive Dealing Cases (Reading Hospital v. Hill-Rom Holdings)

On February 5, 2026, the American Antitrust Institute (AAI) filed an amicus brief in Reading Hospital v. Hill-Rom Holdings, Inc., No. 25-2969, asking the Third Circuit to reverse a district court’s dismissal of an exclusive dealing claim for failure to adequately allege substantial foreclosure.

The plaintiff, a Pennsylvania hospital, alleged that the defendant, Hill-Rom, which is a dominant supplier of hospital beds, monopolized national markets for standard hospital beds, ICU beds, and birthing beds by leveraging its large market share to force exclusivity arrangements on major hospital systems, known as Integrated Delivery Networks (IDNs), throughout the United States. Although the plaintiff alleged hundreds of contracts covering the full scope of Hill-Rom’s large market share, which allegedly exceeded 70% in each market, the district court dismissed the complaint because it identified specific exclusivity provisions in only two contracts with major IDNs, which together accounted for only as much as 20% of the relevant markets—well below the 40% foreclosure share that other courts have treated as a guidepost for substantial foreclosure in exclusive dealing cases.

AAI’s brief argues that the district court committed at least three reversible errors. First, it failed to consider the complaint allegations holistically, which led it to demand specificity in fact pleading that goes far beyond what Rule 8 requires. Second, it focused unduly narrowly on the known foreclosure percentage from the two agreements, ignoring accompanying allegations of many other agreements and about the long duration of the agreements relative to industry norms and their imposition by fiat rather than pursuant to competitive bidding. Third, it departed from well established pleading law by penalizing the plaintiff for failing to allege specific contract language, effectively treating factual allegations that were not pled with specificity as though they were not pled at all. Among other things, AAI’s brief emphasizes that precedent requires trial courts to focus on the “practical effect” of challenged exclusive dealing agreements and that plaintiffs cannot be required to ferret out and plead the specific terms of confidential contract provisions prior to discovery.

AAI thanks Fairmark Partners, LLP for serving as pro bono counsel. The brief was written by Fairmark’s Co-Founding Partner Jamie Crooks and Associate Mike Goldberg, with assistance from AAI President Randy Stutz and AAI General Counsel Mark S. Hegedus.

Read the full amicus brief: AAI Amicus Brief (Reading Hospital v. Hill-Rom Holdings, Inc.)

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Commentary by Fisher: Closing Costs: A Critical Examination of the DOJ’s Proposed RealPage Settlement

The American Antitrust Institute’s (AAI) Senior Counsel David O. Fisher has published a commentary critically examining the DOJ’s proposed agreement settling its antitrust suit against algorithmic software provider RealPage, United States v. RealPage, No. 1:24-cv-00710-WLO-JLW (M.D.N.C.). In the commentary, Fisher examines the theoretical purpose of the agreement and what its terms mean in practice, raising important questions regarding the settlement’s ability to achieve its goals.

Fisher explains that RealPage serves as an algorithmic cartel manager, allowing multifamily housing landlords to coordinate pricing decisions by collecting each competitors’ pricing information and setting common pricing rules. Although the proposed settlement appears aimed at preventing RealPage from carrying out these functions, Fisher notes that the actual terms of the agreement may allow RealPage to continue to serve this role in practice. In particular, there is some ambiguity about whether RealPage may continue to use the real-time data of all of its software licensees as an input to make price recommendations to any one licensee. In addition, the scope and quantity of competitor data that property owners can collect and use to request price recommendations remains unclear. It is also unclear whether, notwithstanding the agreement’s data use restrictions, RealPage may continue to recommend higher prices to competing landlords in a way that raises market prices above the competitive level.  Fisher concludes that the settlement is likely to influence future agreements and business models, and that DOJ must address these questions so that renters and the public can properly evaluate the settlement’s efficacy.

Read the full commentary: Closing Costs: A Critical Examination of the DOJ’s Proposed RealPage Settlement

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AAI Files Comments with DOJ on Proposed RealPage Settlement

The American Antitrust Institute (AAI) has filed Tunney Act comments with the Department of Justice (DOJ) regarding the proposed settlement agreement in its antitrust suit against algorithmic software provider RealPage, United States v. RealPage, No. 1:24-cv-00710-WLO-JLW (M.D.N.C.).

As part of its submission, AAI appended a commentary by AAI Senior Counsel David O. Fisher. The commentary provides critical analysis of specific terms of the proposed settlement. It raises important questions regarding the settlement’s ability to prevent RealPage from continuing to serve as an algorithmic cartel manager in multifamily housing markets, and it urges the DOJ to address those questions so that renters and the public can properly assess the proposed settlement.

Read AAI’s letter: United States v. RealPage, Inc., No. 1:24-cv-00710-WLO-JLW