On November 6, 2019, the FTC unanimously found that a consummated 2017 merger of prosthetics manufacturers violated United States antitrust law, ordering the purchaser to divest completely the acquired assets. Though the merger was not reportable under the Hart-Scott-Rodino Act, the FTC nevertheless reviewed the transaction. Thus, this case serves as a reminder that non-reportable transactions may be subject to post-closing investigation and action.


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