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Maureen Ohlhausen
Partner
Antitrust and Competition
Washington, D.C.
mohlhausen@wsgr.com

D202-973-8808

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  • Respected Regulatory Leader

    Maureen has held the highest-ranking position at the Federal Trade Commission (FTC), having served as Acting Chairman and Commissioner. She also served as the head of Policy Planning at the FTC, leading key initiatives in digital commerce issues. To date, she is the only FTC Commissioner to have received the Robert Pitofsky Lifetime Achievement Award in recognition of her contributions to the FTC.

  • Recognized by the Market

    Chambers USA consistently recognizes Maureen as a leading practitioner in its antitrust rankings, and Lawdragon has named her to its 500 Leading Litigators in America guide. Global Competition Review (GCR) honored Maureen on its “Women in Antitrust 2025” list and shortlisted her as a "Lawyer of the Year" finalist at its 2025 GCR Awards. The American Bar Association's Antitrust Law Section named Maureen to its 2025 "Hall of Fame-inism," honoring contributions to advancing women in the antitrust, consumer protection, and data privacy fields.

  • Influential Voice

    Maureen is a frequently published author and speaker, and leading media outlets often quote her on antitrust, FTC, privacy, and data security matters. She has testified before Congress more than two dozen times, including before the Senate Commerce Committee. U.S. courts of appeals and the U.S. Supreme Court have cited her scholarship approvingly. A prime example is the "Bob" test for algorithmic coordination, which she coined while serving as acting chair of the FTC.

Maureen Ohlhausen co-chairs Wilson Sonsini Goodrich & Rosati's antitrust and competition practice. A former acting chairman of the Federal Trade Commission (FTC), and the only FTC commissioner to receive the Robert Pitofsky Lifetime Achievement Award, she advises clients on complex antitrust and consumer protection matters. Sought after for her depth of experience on antitrust and FTC-related issues, Maureen is known for her relationships with officials in the U.S. and abroad.

Maureen advises clients on their most consequential antitrust and consumer protection challenges, spanning merger clearance, FTC investigations, and congressional inquiries. As one client told Chambers in 2024, she “sees the big picture and adeptly translates how all the various moving legal, policy, and regulatory pieces fit together on the antitrust landscape.”

She has guided companies through complex merger reviews, representing Ampere Computing in its $6.5 billion sale to SoftBank Group Corp. and HashiCorp in its $6.4 billion acquisition by IBM, both following Second Requests, as well as BrightSpring Health Services as the approved divestiture buyer in the UnitedHealth/Amedisys merger, which was named “Merger Control Matter of the Year (Americas)” at the 2026 GCR Awards. She also represents companies in government antitrust conduct investigations. On the enforcement side, she represents leading online companies in FTC investigations addressing children's privacy, online safety, billing, and advertising practices, including under statutes such as the Children’s Online Privacy Protection Act and the Restore Online Shoppers' Confidence Act.

Clients consistently point to her results. As one told Chambers in 2026, "Maureen is exceptional. We've yet to encounter an issue she wasn't able to work with us to resolve."

The Senate unanimously confirmed Maureen as an FTC Commissioner in 2012, and she became acting chairman in January 2017, a role she held until May 2018. As acting chairman, she directed all aspects of the agency's antitrust work, including merger review and conduct enforcement, as well as all consumer protection enforcement, with an emphasis on privacy and technology issues. Under her leadership, the FTC won several influential merger challenges in court and reached key digital privacy settlements. She previously served at the FTC as the Director of the Office of Policy Planning and headed the agency’s Internet Access Task Force.

A recognized thought leader, Maureen writes and speaks frequently and is regularly quoted by leading media on antitrust, FTC, and consumer protection matters. She has published dozens of articles spanning antitrust, privacy, intellectual property, regulation, FTC litigation, telecommunications, and international law. Courts, including the U.S. Supreme Court, have cited her policy analysis favorably. A prime example is the "Bob" test for algorithmic coordination, which she coined while serving as Acting Chair of the FTC and which the Department of Justice (DOJ) and courts have cited widely over the past year, including in the DOJ's statement of interest in In re RealPage, Inc.

During her tenure at the FTC and in private practice, she testified more than two dozen times before Congress, including before the Senate Commerce Committee and the House Energy and Commerce Antitrust Sub-Committee. She also testified before the Antitrust Modernization Commission.

 

 

Experience

Maureen Ohlhausen co-chairs Wilson Sonsini Goodrich & Rosati's antitrust and competition practice. A former acting chairman of the Federal Trade Commission (FTC), and the only FTC commissioner to receive the Robert Pitofsky Lifetime Achievement Award, she advises clients on complex antitrust and consumer protection matters. Sought after for her depth of experience on antitrust and FTC-related issues, Maureen is known for her relationships with officials in the U.S. and abroad.

Maureen advises clients on their most consequential antitrust and consumer protection challenges, spanning merger clearance, FTC investigations, and congressional inquiries. As one client told Chambers in 2024, she “sees the big picture and adeptly translates how all the various moving legal, policy, and regulatory pieces fit together on the antitrust landscape.”

She has guided companies through complex merger reviews, representing Ampere Computing in its $6.5 billion sale to SoftBank Group Corp. and HashiCorp in its $6.4 billion acquisition by IBM, both following Second Requests, as well as BrightSpring Health Services as the approved divestiture buyer in the UnitedHealth/Amedisys merger, which was named “Merger Control Matter of the Year (Americas)” at the 2026 GCR Awards. She also represents companies in government antitrust conduct investigations. On the enforcement side, she represents leading online companies in FTC investigations addressing children's privacy, online safety, billing, and advertising practices, including under statutes such as the Children’s Online Privacy Protection Act and the Restore Online Shoppers' Confidence Act.

Clients consistently point to her results. As one told Chambers in 2026, "Maureen is exceptional. We've yet to encounter an issue she wasn't able to work with us to resolve."

The Senate unanimously confirmed Maureen as an FTC Commissioner in 2012, and she became acting chairman in January 2017, a role she held until May 2018. As acting chairman, she directed all aspects of the agency's antitrust work, including merger review and conduct enforcement, as well as all consumer protection enforcement, with an emphasis on privacy and technology issues. Under her leadership, the FTC won several influential merger challenges in court and reached key digital privacy settlements. She previously served at the FTC as the Director of the Office of Policy Planning and headed the agency’s Internet Access Task Force.

A recognized thought leader, Maureen writes and speaks frequently and is regularly quoted by leading media on antitrust, FTC, and consumer protection matters. She has published dozens of articles spanning antitrust, privacy, intellectual property, regulation, FTC litigation, telecommunications, and international law. Courts, including the U.S. Supreme Court, have cited her policy analysis favorably. A prime example is the "Bob" test for algorithmic coordination, which she coined while serving as Acting Chair of the FTC and which the Department of Justice (DOJ) and courts have cited widely over the past year, including in the DOJ's statement of interest in In re RealPage, Inc.

During her tenure at the FTC and in private practice, she testified more than two dozen times before Congress, including before the Senate Commerce Committee and the House Energy and Commerce Antitrust Sub-Committee. She also testified before the Antitrust Modernization Commission.

 

 

Education
  • J.D., George Mason University School of Law

    With Distinction

  • B.A., University of Virginia

    With Honors

Associations and Memberships
  • Co-chair, ABA Tech Summit, 2019
  • Senior Editor, Antitrust Law Journal, 2008-2012
  • Board Member, Better Business Bureau National Programs
  • Board of Advisors, Washington Legal Foundation
  • Board Member, Federal Communications Bar Association Foundation, 2019-2022
  • Member, ABA Competition and Public Policy Task Force, 2008-2010
  • Vice Chair, Advocacy Committee, American Bar Association, Section of Antitrust Law, 2007-2008
  • Adjunct Faculty, George Mason University School of Law: Unfair Trade Practices, 2007; Emerging Law of Internet Privacy, 2006
Honors
  • Inducted into the 2025 ABA Antitrust Law Section’s Hall of Fame-inism
  • Named to GCR’s 2025 “Women in Antitrust” list
  • Named as a “Lawyer of the Year” finalist at the 2025 GCR Awards
  • Recognized as a leading antitrust practitioner by Chambers USA, 2020-2026
  • Recognized as a leading antitrust practitioner by Chambers Global, 2022-2023
  • Named among Lawdragon’s 2025-2026 “500 Leading Global Antitrust & Competition Lawyers”
  • Recognized in the 2025 edition of GCR/Lexology Index's Competition guide
  • Recognized among the 2025 Lawdragon "100 Leading AI & Legal Tech Advisors" 
  • Selected for inclusion in the 2024-2026 editions of the Lawdragon’s "500 Leading Global Cyber Lawyers" guide
  • Named a "Leading Lawyer" by The Legal 500 U.S., 2021-2023
  • Recognized as a leading U.S. litigator by Lawdragon "500 Leading Litigators in America"
  • FTC Robert Pitofsky Lifetime Achievement Award
  • Touchstones of Leadership Public Policy Award
  • Phoenix Center Public Service Award
  • George Mason University Distinguished Alumni Award
  • Internet Association's Internet Freedom Award, 2017
Admissions
  • Bar of the District of Columbia
  • State Bar of Virginia
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Supreme Court
Credentials
Education
  • J.D., George Mason University School of Law

    With Distinction

  • B.A., University of Virginia

    With Honors

Associations and Memberships
  • Co-chair, ABA Tech Summit, 2019
  • Senior Editor, Antitrust Law Journal, 2008-2012
  • Board Member, Better Business Bureau National Programs
  • Board of Advisors, Washington Legal Foundation
  • Board Member, Federal Communications Bar Association Foundation, 2019-2022
  • Member, ABA Competition and Public Policy Task Force, 2008-2010
  • Vice Chair, Advocacy Committee, American Bar Association, Section of Antitrust Law, 2007-2008
  • Adjunct Faculty, George Mason University School of Law: Unfair Trade Practices, 2007; Emerging Law of Internet Privacy, 2006
Honors
  • Inducted into the 2025 ABA Antitrust Law Section’s Hall of Fame-inism
  • Named to GCR’s 2025 “Women in Antitrust” list
  • Named as a “Lawyer of the Year” finalist at the 2025 GCR Awards
  • Recognized as a leading antitrust practitioner by Chambers USA, 2020-2026
  • Recognized as a leading antitrust practitioner by Chambers Global, 2022-2023
  • Named among Lawdragon’s 2025-2026 “500 Leading Global Antitrust & Competition Lawyers”
  • Recognized in the 2025 edition of GCR/Lexology Index's Competition guide
  • Recognized among the 2025 Lawdragon "100 Leading AI & Legal Tech Advisors" 
  • Selected for inclusion in the 2024-2026 editions of the Lawdragon’s "500 Leading Global Cyber Lawyers" guide
  • Named a "Leading Lawyer" by The Legal 500 U.S., 2021-2023
  • Recognized as a leading U.S. litigator by Lawdragon "500 Leading Litigators in America"
  • FTC Robert Pitofsky Lifetime Achievement Award
  • Touchstones of Leadership Public Policy Award
  • Phoenix Center Public Service Award
  • George Mason University Distinguished Alumni Award
  • Internet Association's Internet Freedom Award, 2017
Admissions
  • Bar of the District of Columbia
  • State Bar of Virginia
  • U.S. Court of Appeals for the District of Columbia Circuit
  • U.S. Court of Appeals for the Fifth Circuit
  • U.S. Court of Appeals for the Ninth Circuit
  • U.S. Supreme Court

Select Transactional Matters

  • Represented BrightSpring Health Services as the approved divestiture buyer in the UnitedHealth/Amedisys merger (named “Merger Control Matter of the Year (Americas),” 2026 GCR Awards)
  • Represented HashiCorp in its $6.4 billion acquisition by IBM, following a Second Request by the DOJ and Phase I review by the CMA
  • Represented Ampere Computing in its $6.5 billion sale to SoftBank Group Corp., following a Second Request by the FTC
  • Represented Alto Pharmacy in its acquisition by Paulus Holdings, overseeing federal merger review by the FTC and several state merger reviews
  • Represented Excellergy, a biotechnology company developing a novel class of allergy therapeutics, in its $2 billion acquisition by Novartis
  • Represented Metronome, a usage-based billing platform, in its acquisition by Stripe, a deal valued at approximately $1 billion
  • Represented Google in its acquisition of Photomath, following a Phase I review by the EC*

*Experience prior to joining Wilson Sonsini.

Select Regulatory and Counseling Matters

  • Representing several large online companies in major FTC investigations focused on children’s privacy and online safety, the Take It Down Act, the Restore Online Shoppers Confidence Act (ROSCA), and other billing and advertising practices
  • Representing a group of medical providers in an FTC investigation into the competitive effects of private equity-sponsored alleged roll-up of provider market in several geographic markets
  • Advising the Frontier Model Forum on various issues, including the antitrust considerations associated with cooperation among the largest U.S. AI companies to establish safety and security best practices
  • Counseling platform, e-commerce, and other technology clients on a host of consumer protection matters and advising on specialized statutes and regulations such as ROSCA, the  Children’s Online Privacy Protection Act (COPPA), and the One Fair Price Act

Select Congressional Investigations and Testimony Matters

  • Testified before Congress more than two dozen times, including in a April 2024 hearing on Legislative Solutions to Protect Kids Online; in a June 2022 hearing on Legislation to Strengthen Data Privacy and Security; and in front of the Committee five times on consumer protection topics
  • Representing clients in congressional investigations in three  ongoing matters, including providing written responses and documents and preparing witnesses for testimony
Matters

Select Transactional Matters

  • Represented BrightSpring Health Services as the approved divestiture buyer in the UnitedHealth/Amedisys merger (named “Merger Control Matter of the Year (Americas),” 2026 GCR Awards)
  • Represented HashiCorp in its $6.4 billion acquisition by IBM, following a Second Request by the DOJ and Phase I review by the CMA
  • Represented Ampere Computing in its $6.5 billion sale to SoftBank Group Corp., following a Second Request by the FTC
  • Represented Alto Pharmacy in its acquisition by Paulus Holdings, overseeing federal merger review by the FTC and several state merger reviews
  • Represented Excellergy, a biotechnology company developing a novel class of allergy therapeutics, in its $2 billion acquisition by Novartis
  • Represented Metronome, a usage-based billing platform, in its acquisition by Stripe, a deal valued at approximately $1 billion
  • Represented Google in its acquisition of Photomath, following a Phase I review by the EC*

*Experience prior to joining Wilson Sonsini.

Select Regulatory and Counseling Matters

  • Representing several large online companies in major FTC investigations focused on children’s privacy and online safety, the Take It Down Act, the Restore Online Shoppers Confidence Act (ROSCA), and other billing and advertising practices
  • Representing a group of medical providers in an FTC investigation into the competitive effects of private equity-sponsored alleged roll-up of provider market in several geographic markets
  • Advising the Frontier Model Forum on various issues, including the antitrust considerations associated with cooperation among the largest U.S. AI companies to establish safety and security best practices
  • Counseling platform, e-commerce, and other technology clients on a host of consumer protection matters and advising on specialized statutes and regulations such as ROSCA, the  Children’s Online Privacy Protection Act (COPPA), and the One Fair Price Act

Select Congressional Investigations and Testimony Matters

  • Testified before Congress more than two dozen times, including in a April 2024 hearing on Legislative Solutions to Protect Kids Online; in a June 2022 hearing on Legislation to Strengthen Data Privacy and Security; and in front of the Committee five times on consumer protection topics
  • Representing clients in congressional investigations in three  ongoing matters, including providing written responses and documents and preparing witnesses for testimony

Select Publications

  • Co-author, “The Trump FTC Takes New Action Against Non-Competes, While Abandoning Defense of the Biden-Era Non-Compete Clause Rule,” Wilson Sonsini Alert, September 12, 2025

  • Co-author, “White House Releases America’s AI Action Plan,” Wilson Sonsini Alert, July 25, 2025

  • Co-author, “New York Requires Disclosures for Personalized Pricing,” Wilson Sonsini Alert, July 14, 2025
  • Co-author, “DOJ Carries Through on Revitalization of Merger Remedies,” Wilson Sonsini Alert, June 16, 2025
  • Co-author, “How Trump Administration's Antitrust Agenda is Playing Out,” Law360, June 12, 2025
  • Co-author, “States Expand Premerger Filings Family by Adopting “Baby-HSR” Laws to Review More Transactions,” Wilson Sonsini Alert, April 15, 2025
  • Co-author, “Antitrust Heads Offer Enforcement Insights to Legal Industry, Sidestepping Traditional ABA Gathering,” Wilson Sonsini Alert, April 4, 2025
  • Co-author, “Gail Slater Confirmed to Lead DOJ Antitrust Division,” Wilson Sonsini Alert, March 17, 2025
  • Co-author, “Enforcement Priorities of President Trump’s DOJ and FTC Begin to Take Shape,” Wilson Sonsini Alert, February 26, 2025
  • Co-author, “FTC Appoints New Bureau Directors: What to Expect from Directors Christopher Mufarrige and Daniel Guarnera,” Wilson Sonsini Alert, February 13, 2025
  • Co-author, “2025 Year in Preview: Pending Decisions at the U.S. Antitrust Agencies,“ Wilson Sonsini Alert, January 24, 2025
  • Co-author, “Whither Antitrust Enforcement Under Trump 2.0?” Wilson Sonsini Alert, November 15, 2024
  • Co-author, "What About Bob? Revisiting the Intersection of Antitrust Law and Algorithmic Pricing in 2024," Artificial Intelligence and Competition Policy (Concurrences), September 2024

Select Speaking Engagements

  • Speaker, "Global State of Play: Antitrust and AI Series - Part 2: Global Transactions Involving AI Assets," Webinar, October 8, 2025
  • Speaker, “FTC: Past, Present, and Future,” ABA Antitrust Law Spring Meeting 2025, April 4, 2025
  • Speaker, "Antitrust in the US:  Past, Present, and Future: Spotlight with Maureen Ohlhausen," CRA Brussels Conference, December 10, 2024
  • Guest Speaker, “The End of the Chevron Doctrine,” Inside Today’s Boardroom Podcast, Diligent, November 27, 2024 
  • Speaker, "Restrictive Covenants and the FTC’s Non-Compete Rule: The Current State of Play and Preparing for the Future for In-House Counsel," In-House Connect, September 11, 2024
  • Panelist, "Global Private Litigation in the Digital Economy," ABA Spring Meeting 2024, April 10-12, 2024
  • Speaker, "The Global Dimension," GCR Live: Antitrust in the Digital Economy, April 9, 2024
Insights

Select Publications

  • Co-author, “The Trump FTC Takes New Action Against Non-Competes, While Abandoning Defense of the Biden-Era Non-Compete Clause Rule,” Wilson Sonsini Alert, September 12, 2025

  • Co-author, “White House Releases America’s AI Action Plan,” Wilson Sonsini Alert, July 25, 2025

  • Co-author, “New York Requires Disclosures for Personalized Pricing,” Wilson Sonsini Alert, July 14, 2025
  • Co-author, “DOJ Carries Through on Revitalization of Merger Remedies,” Wilson Sonsini Alert, June 16, 2025
  • Co-author, “How Trump Administration's Antitrust Agenda is Playing Out,” Law360, June 12, 2025
  • Co-author, “States Expand Premerger Filings Family by Adopting “Baby-HSR” Laws to Review More Transactions,” Wilson Sonsini Alert, April 15, 2025
  • Co-author, “Antitrust Heads Offer Enforcement Insights to Legal Industry, Sidestepping Traditional ABA Gathering,” Wilson Sonsini Alert, April 4, 2025
  • Co-author, “Gail Slater Confirmed to Lead DOJ Antitrust Division,” Wilson Sonsini Alert, March 17, 2025
  • Co-author, “Enforcement Priorities of President Trump’s DOJ and FTC Begin to Take Shape,” Wilson Sonsini Alert, February 26, 2025
  • Co-author, “FTC Appoints New Bureau Directors: What to Expect from Directors Christopher Mufarrige and Daniel Guarnera,” Wilson Sonsini Alert, February 13, 2025
  • Co-author, “2025 Year in Preview: Pending Decisions at the U.S. Antitrust Agencies,“ Wilson Sonsini Alert, January 24, 2025
  • Co-author, “Whither Antitrust Enforcement Under Trump 2.0?” Wilson Sonsini Alert, November 15, 2024
  • Co-author, "What About Bob? Revisiting the Intersection of Antitrust Law and Algorithmic Pricing in 2024," Artificial Intelligence and Competition Policy (Concurrences), September 2024

Select Speaking Engagements

  • Speaker, "Global State of Play: Antitrust and AI Series - Part 2: Global Transactions Involving AI Assets," Webinar, October 8, 2025
  • Speaker, “FTC: Past, Present, and Future,” ABA Antitrust Law Spring Meeting 2025, April 4, 2025
  • Speaker, "Antitrust in the US:  Past, Present, and Future: Spotlight with Maureen Ohlhausen," CRA Brussels Conference, December 10, 2024
  • Guest Speaker, “The End of the Chevron Doctrine,” Inside Today’s Boardroom Podcast, Diligent, November 27, 2024 
  • Speaker, "Restrictive Covenants and the FTC’s Non-Compete Rule: The Current State of Play and Preparing for the Future for In-House Counsel," In-House Connect, September 11, 2024
  • Panelist, "Global Private Litigation in the Digital Economy," ABA Spring Meeting 2024, April 10-12, 2024
  • Speaker, "The Global Dimension," GCR Live: Antitrust in the Digital Economy, April 9, 2024
Focus Areas
  • Antitrust Civil Enforcement
  • Antitrust Compliance and Business Strategy
  • Antitrust Litigation
  • Antitrust Merger Clearance
  • Antitrust and Competition
  • Antitrust and Intellectual Property
  • Data, Privacy, and Cybersecurity
  • Federal Trade Commission
  • Government Investigations
  • Litigation
  • State Attorneys General
  • Supreme Court and Appellate
  • Third-Party Merger and Non-Merger Antitrust Representation
Recent Insights
Alerts
The FTC After Slaughter: What Businesses Need to Understand
On June 29, 2026, the U.S. Supreme Court issued its opinion in Trump v. Slaughter, where the six-Justice majority held that appointed agency officials who wield executive power are subject to presidential removal. In so holding, the Court overruled its 1935 decision in Humphrey’s Executor v. United States, 295 U.S. 602 (1935), which for nearly a century stood for the principle that Congress can create independent agencies whose leaders can only be removed for cause.
Learn More
Alerts
New York Legislature Passes Ban on Personalized Pricing
Last week, the New York State Legislature passed the One Fair Price Act (S.8623B/A.9349B) (the Act), a bill that prohibits businesses from using personal data—such as purchase history, browsing history, real-time location, income, or inferred household size—to generate individual prices for consumers. While the Act bans so-called “surveillance pricing,” or personalized pricing, companies may still use “dynamic pricing” algorithms, subject to a modified disclosure requirement, so long as the algorithm does not set prices based on consumer personal data. The bill now awaits the signature of Governor Kathy Hochul, who has until December 31, 2026, to act.
Learn More
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Recent Events
Speaking Engagements
Notice & Comment: Regulatory Litigation Trends Conference 2026
Wilson Sonsini partner Maureen Ohlhausen will be a featured speaker on the panel "The FTC at a Crossroads?" at the upcoming Notice & Comment: Regulatory Litigation Trends conference, hosted by the C. Boyden Gray Center. Maureen will join other distinguished panelists to discuss key regulatory developments involving the Federal Trade Commission.
Learn More
Speaking Engagements
2026 FTC Workshop: Eleventh-Hour Antitrust Remedy Proposals and Litigating the Fix
Wilson Sonsini partner Maureen Ohlhausen will be a featured speaker at the upcoming Federal Trade Commission workshop titled “Eleventh-Hour Antitrust Remedy Proposals and Litigating the Fix.” Maureen will join FTC Commissioners, officials from both the FTC and the Department of Justice, leading scholars, and other antitrust experts to discuss how federal enforcers and the courts should respond to this evolving enforcement challenge.
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