Honoring Excellence in Antitrust Law: Thomas Naif Dahdouh Named 2025 Antitrust Lawyer of the Year

The Antitrust and Consumer Protection Section of the California Lawyers Association is pleased to honor Thomas Naif Dahdouh as the 2025 Antitrust Lawyer of the Year.  He has dedicated his career to public enforcement of federal antitrust, consumer protection and privacy laws.  For 33 years at the FTC, he sought to protect the American public by advancing these laws.  In 2024, he was awarded the FTC’s Robert Pitofsky Lifetime Achievement Award. 

Tom was most recently Attorney Advisor to FTC Chair Lina M. Khan. Before that, he served as Regional Director of the Western Regional Office, with offices in San Francisco and Los Angeles, from 2013 to 2019, and then Regional Director of the Western Region San Francisco Office from 2020 to 2021. Before those positions, he served as an Attorney Advisor to two FTC Commissioners in the 1990’s, Counsel to Bureau of Competition Director William Baer, and then was a staff attorney for many years in the San Francisco office before becoming Regional Director. Tom joined the Federal Trade Commission in 1992, after having clerked for Judge Irving R. Kaufman of the Second Circuit and Judge Michael B. Mukasey of the Southern District of New York as well as working at Debevoise & Plimpton in New York. He earned his JD from Harvard Law School, and his BA at Yale.   

While working for Chair Khan, Tom was part of a team reforming competition policy at the FTC, including:

• The 2021 Policy Statement on Prior Approval and Prior Notice in Merger Orders.
• The 2022 Policy Statement on Unfair Methods of Competition.
• Major consumer protection rulemakings including those addressing deceptive and unfair practices relating to telemarketing to small businesses, online reviews, earnings claims, business opportunities, negative options, funeral industry and auto dealers. 
• A major administrative tribunal opinion, Illumina/GRAIL, blocking an anticompetitive vertical merger involving innovation markets, a decision that was upheld in large part by the Fifth Circuit, leading to the deal’s abandonment.      

As Regional Director, Tom oversaw the litigation and successful settlement of:

• A challenge to collusion between the two largest suppliers of propane-filled cylinders for gas grills, AmeriGas/Blue Rhino. The complaint alleged that the companies conspired to reduce the amount of propane in cylinders, and jointly pressured a key customer, Walmart, to force Walmart to accept what was effectively a significant price increase.
• Charges that a large hospital system in the Reno, Nevada, area acquired nearly all the cardiologist practices in that area, Renown Health. 
• A complaint against the three largest distributors of products for dentist offices, Schein/Benco/Patterson, accusing them of colluding to refuse to sell to or discount to group purchasing organizations. After a trial on the merits in the FTC’s administrative tribunal, a final decision by the ALJ upheld charges against two of the three companies.

On the consumer protection side, the offices obtained federal court judgments totalling $652 million and returned at least $145 million to consumers nationwide through redress campaigns, including: 

• FTC v. DeVry University, a challenge to deceptive post-graduate employment and income claims by a for-profit school, resulting in a $100 million settlement.
• FTC v. AT&T Mobility, alleging that AT&T deceptively and unfairly throttled data users who thought they were purchasing an “unlimited” plan, leading to a $60 million settlement.  That case went up to the Ninth Circuit on a question of jurisdiction over AT&T, which the FTC won in an en banc opinion.
• FTC v. Jerk.com, allegingmisrepresentations by a reputational website.  The matter, filed in the FTC’s administrative tribunal, led to a Commission opinion upholding the allegations in the complaint, which was affirmed in substantial part by the First Circuit. 

As a staff attorney in the San Francisco office, Tom worked on numerous antitrust investigations including:

• FTC v. Aloha Petroleum, a challenge to an acquisition in Hawaii involving wholesaling and retailing gasoline.
• Two administrative court monopolization complaints against Intel, one filed in 1999 and one in 2009. 
• FTC v. Staples/Office Depot merger, a seminal merger challenge to big box office supply retailers won in 1997.

Over his career, Tom has written several articles on antitrust law, including:

• An article on monopolization law, “Restoring Balance in the Test for Exclusionary Conduct,” Competition (Spring 2015)
• An article on unfair methods of competition under Section 5 of the FTC Act,  “Section 5, the FTC, and its Critics: Just Who Are the Radicals Here,” Competition (Fall 2011)
• Co-authored an article on innovation markets — “The Shape of Things to Come: Innovation Market Analysis in Merger Cases,” 64 Antitrust Law Journal 405 (Winter 1996).

Tom has been on the Executive Committee of the Section since 2009, and served as Chair from 2014-15.  Before that, he served as Editor of the Committee’s journal, Competition, from 2012 to 2014.