January 20, 2009

Hart-Scott-Rodino Act Developments: New Filing Thresholds, New Penalties and New Enforcement Activities

January once again brings news of adjustments to Hart-Scott-Rodino Act filing thresholds for mergers, acquisitions and investments, as well as a steep increase in civil penalties for HSR violations. These adjustments come hard on the heels of two December HSR enforcement actions resulting in $800,000 in civil penalties. Those actions stem from the failure of two investment funds to make required HSR notifications with respect to "follow on" investments.

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