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Federal Judge Vacates Biden-Era HSR Overhaul, Temporarily Staying Ruling

The brief stay leaves companies preparing for either an appellate pause or a return to the prior filing form on February 20.

Overview

  • A federal court in the Eastern District of Texas on February 12 vacated the 2025 Hart-Scott-Rodino premerger notification form in full.
  • The judge found the FTC failed to show the expanded requirements’ benefits reasonably outweighed their costs and did not perform an adequate cost-benefit analysis.
  • The court cited an FTC 2024 statement calling the longstanding system a success and noted FTC counsel could not identify an unlawful merger the new rules would have prevented.
  • The vacatur applies nationwide and is not limited to the plaintiff organizations, rejecting the FTC’s request to confine relief.
  • The ruling is stayed until February 20, during which the new form remains in effect; absent emergency relief from the Fifth Circuit, filings on or after that date are expected to revert to the prior form, while a granted stay would keep the new form in place during appeal.