Wilson Sonsini partners Michelle Yost Hale and Matthew McDonald recently authored a Law360 article examining what the Federal Trade Commission’s (FTC) proposed consent order in Publicis Groupe SA’s $2.2 billion acquisition of LiveRamp means for data infrastructure mergers and acquisitions. The piece explains that the October 19 order resolves a purely vertical theory of harm centered on Publicis’ potential control over LiveRamp’s previously neutral data connectivity services, and requires Publicis, for five years, to provide nondiscriminatory access, maintain firewalls for customer data, and submit to compliance audits.

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