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Rachel G. Gray
Associate
Antitrust and Competition
Washington, D.C.
rgray@wsgr.com

D202-920-8715

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Rachel Gray is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s antitrust practice. Her work encompasses a variety of civil antitrust matters, including litigation and mergers and acquisitions.

During law school, Rachel worked as a summer law clerk in the Mergers I division of the Bureau of Competition at the FTC. While at the FTC, Rachel gained experience with government investigations and litigation of mergers and acquisitions.

Experience

Rachel Gray is an associate in the Washington, D.C., office of Wilson Sonsini Goodrich & Rosati, where she is a member of the firm’s antitrust practice. Her work encompasses a variety of civil antitrust matters, including litigation and mergers and acquisitions.

During law school, Rachel worked as a summer law clerk in the Mergers I division of the Bureau of Competition at the FTC. While at the FTC, Rachel gained experience with government investigations and litigation of mergers and acquisitions.

Education
  • J.D., University of Virginia School of Law, 2020Business Manager, Virginia Journal of Social Policy and the Law (2019-2020); Economic and Consumer Law Clinic (2019-2020)
  • B.A., Geography, Dartmouth College, 2015Cum Laude
Admissions
  • Bar of the District of Columbia
Credentials
Education
  • J.D., University of Virginia School of Law, 2020Business Manager, Virginia Journal of Social Policy and the Law (2019-2020); Economic and Consumer Law Clinic (2019-2020)
  • B.A., Geography, Dartmouth College, 2015Cum Laude
Admissions
  • Bar of the District of Columbia

Select Publications

  • Co-author with J. Ferris and S. Sher, "Antitrust Enforcement in the Biden Administration: Assessing the M&A Risk," Wilson Sonsini Alert, August 24, 2021

  • Co-author with J. Bank, B. Coffman, N. Mendelsohn, and S. Silber, “Fifth Circuit Upholds Federal Trade Commission Ruling in Impax Laboratories, Inc. v. Federal Trade Commission and Grants Substantial Deference to the FTC,” Wilson Sonsini Alert, April 20, 2021
  • “Vertical Mergers in the Healthcare Industry: Summary of the June 12, 2019, Hearing Before the United States Senate Judiciary Subcommittee on Antitrust, Competition, Policy, and Consumer Rights,” Antitrust Health Care Chronicle, October 20, 2019
Insights

Select Publications

  • Co-author with J. Ferris and S. Sher, "Antitrust Enforcement in the Biden Administration: Assessing the M&A Risk," Wilson Sonsini Alert, August 24, 2021

  • Co-author with J. Bank, B. Coffman, N. Mendelsohn, and S. Silber, “Fifth Circuit Upholds Federal Trade Commission Ruling in Impax Laboratories, Inc. v. Federal Trade Commission and Grants Substantial Deference to the FTC,” Wilson Sonsini Alert, April 20, 2021
  • “Vertical Mergers in the Healthcare Industry: Summary of the June 12, 2019, Hearing Before the United States Senate Judiciary Subcommittee on Antitrust, Competition, Policy, and Consumer Rights,” Antitrust Health Care Chronicle, October 20, 2019
Focus Areas
  • Antitrust Litigation
  • Antitrust Merger Clearance
  • Antitrust and Competition
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Wilson Sonsini Advises Recursion on Definitive Agreement with Exscientia
On August 8, 2024, Recursion and Exscientia announced the companies have entered into a definitive agreement, combining Recursion, a leading clinical stage technology-enabled biotech company decoding biology to industrialize drug discovery, with Exscientia, a technology-driven clinical stage drug design and development company, committed to creating more effective medicines for patients, faster. Wilson Sonsini Goodrich & Rosati advised Recursion on the transaction.
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Seventh Circuit Affirms Denial of Claims Brought Against AbbVie
The Seventh Circuit recently confirmed that Actavis is the appropriate framework to assess biosimilar patent settlements, despite the differences in the regulatory structure—the first appellate court ruling on this issue. In a decision authored by Judge Easterbrook, the Seventh Circuit affirmed the Northern District of Illinois Court's decision dismissing antitrust claims brought against AbbVie and biosimilar Humira manufacturers by indirect purchasers of Humira. Mayor and City Council of Baltimore, et al. v. AbbVie Inc. et al., No. 20-2402 (7th Cir. 2022). In a short and pointed opinion the court held that AbbVie's obtaining and invoking of 132 patents did not constitute monopolization under Section 2 of the Sherman Act, and that AbbVie's patent settlements with biosimilar Humira manufacturers in Europe and the United States were not unlawful reverse payments under FTC v. Actavis, 570 U.S. 136 (2013) because they were separate settlements under distinct patent regimes, and not part of one global settlement that exchanged early entry in one jurisdiction for delayed entry in another, as the plaintiffs alleged.
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