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4.30.26
Wilson Sonsini Global Cartel Law Quarterly Q4 2025/Q1 2026
The firm is pleased to distribute the Wilson Sonsini Global Cartel Law Quarterly Q4 2025/Q1 2026, which provides a summary of key cartel enforcement trends across the U.S., Europe, and beyond. A “cartel” under competition law is typically reserved for agreements between competitors to restrict competition, such as price-fixing, bid-rigging, and market allocations.
Alerts
2.17.26
DOJ Antitrust Division Makes First Whistleblower Payment for Reporting Antitrust Crime
On January 29, 2026, the U.S. Department of Justice’s (DOJ) Antitrust Division announced the first payment made under its Whistleblower Rewards Program. The whistleblower received a reward of $1 million for providing information that led to a company agreeing to pay a $3.28 million criminal fine to resolve antitrust and fraud charges.
Newsletters
11.25.25
Wilson Sonsini Global Cartel Law Quarterly Q3 2025
The firm is pleased to distribute the Wilson Sonsini Global Cartel Law Quarterly Q3 2025, which provides a summary of key cartel enforcement trends across the U.S., Europe, and beyond. A “cartel” under competition law is typically reserved for agreements between competitors to restrict competition, such as price-fixing, bid-rigging, and market allocations. This quarterly report provides updates on how competition law applies to company collaborations generally. In doing so, the authors hope this quarterly helps companies structure legitimate collaborations and avoid “cartel” behavior. In this edition, the authors examine the key developments in Q3 2025 and lay out their expectations for what the remainder of 2025 is likely to look like in the area of cartel enforcement.
Alerts
10.20.25
Poultry Processing Information Exchange Settlement Sheds Light on Agency Enforcement Views
On October 10, 2025, a settlement was filed in an information sharing case that highlights the antitrust risks of exchanging information with competitors and sheds light on the relatively aggressive view of such risks by the current U.S. Department of Justice (DOJ) Antitrust Division. The following examines the risks of information pools in the context of that case as well as a parallel DOJ case concerning the same players. We also identify guideposts for identifying and mitigating antitrust risks when sharing information with competitors both directly and through third-party exchanges.
Alerts
10.09.25
California Gets Tough on Algorithmic Pricing and Lowers Conspiracy Pleading Standards
On October 6, 2025, Governor Gavin Newsom expanded the scope of California’s antitrust laws by signing Assembly Bill 325, an amendment to the Cartwright Act, California’s primary antitrust statute. AB 325 prevents the use of algorithms to coordinate pricing among competitors, creates liability for efforts to coerce compliance with pricing tool recommendations, and clarifies the bar for plaintiffs pleading conspiracies under the Cartwright Act. The original author of AB 325, Majority Leader Cecilia Aguiar-Curry, stated that the purpose of the bill is to “stop big corporations from using digital tools to collude and drive up costs for our working families and small businesses.”1
Alerts
8.18.25
Ninth Circuit Clarifies (Somewhat) the Antitrust Risk of Pricing Algorithms
On August 15, 2025, the U.S. Court of Appeals for the Ninth Circuit raised the bar for bringing antitrust claims against companies that provide or use pricing algorithms. The decision begins to clarify an area of antitrust law that has been tested recently by several civil cases and the U.S. Department of Justice (DOJ). In sum, the Ninth Circuit held that independently subscribing to a pricing algorithm alone does not constitute the requisite “restraint of trade” under the antitrust laws, even when the subscriber knows its competitors are using the same algorithm.1
Alerts
8.04.25
Blowing the Whistle on Antitrust Crimes: DOJ’s Antitrust Division Announces First Whistleblower Rewards Program
Individuals now have a new incentive to blow the whistle on an antitrust cartel—the possibility of a monetary reward. The U.S. Department of Justice’s (DOJ) Antitrust Division has established its first whistleblower rewards program whereby individuals who report certain types of antitrust crimes can potentially receive a monetary reward in return for information.
Newsletters
7.23.25
Wilson Sonsini Global Cartel Law Quarterly Q2 2025
The firm is pleased to distribute the Wilson Sonsini Global Cartel Law Quarterly Q2 2025, which provides a summary of key cartel enforcement trends across the U.S., Europe, and beyond. A “cartel” under competition law is typically reserved for agreements between competitors to restrict competition, such as price-fixing, bid-rigging, and market allocations. This quarterly report provides updates on how competition law applies to company collaborations generally. In doing so, the authors hope it helps companies structure legitimate collaborations and avoid “cartel” behavior. In this edition, the authors examine the key developments in Q2 2025 and lay out their expectations for what the remainder of 2025 is likely to look like in the area of cartel enforcement.
Alerts
6.05.25
Cartel Facilitated by a Minority Stake in a Competitor Sanctioned by the European Commission
On June 2, 2025, the European Commission (EC) announced that it had fined food delivery companies Delivery Hero and Glovo a total of €329 million for participating in a cartel in the online food delivery sector in violation of Article 101(1) of the Treaty on the Functioning of the European Union (TFEU).1
Alerts
4.17.25
Perseverance Pays Off for DOJ in Labor Market Criminal Trial
After several unsuccessful attempts to convict a company or individual at trial for wage-fixing or a no-poach agreement, the Department of Justice’s (DOJ) Antitrust Division has secured its first conviction in a labor market criminal trial. On April 14, 2025, a jury found the owner of a home healthcare company, Eduardo Lopez, guilty of agreeing to fix the wages for home healthcare nurses in Las Vegas and for fraudulently failing to disclose the criminal antitrust investigation during the sale of his home healthcare staffing company.1 This marks the first time the Antitrust Division has convicted an individual in a labor market criminal trial and serves as a reminder that labor-related agreements still present a risk to both companies and individuals.
Alerts
3.03.25
FTC on the Job: Chairman Ferguson Announces Labor Task Force
Since at least the October 2016 publication of the Federal Trade Commission’s (FTC) and U.S. Department of Justice’s (DOJ) joint Antitrust Guidance for Human Resource Professionals, federal antitrust enforcers have prioritized investigations and litigations involving alleged antitrust violations in labor markets, namely no-poach and wage-fixing agreements. Following several losses at trial, however, and with the recent change in administration, there was some question whether the current administration would continue to prioritize labor markets matters. On February 24, 2025, FTC Chairman Andrew Ferguson answered that question with a resounding “yes” by announcing a “labor markets task force.” The task force is aimed at investigating conduct in labor markets that may violate antitrust and consumer protection laws. As we head into this new era of enforcement, with new leadership at the helm, companies should take care to familiarize themselves with these new developments.