Antitrust and Consumer Protection

Competition: Spring 2016, Vol 25, No. 1

CONSIDERATIONS, NOT LIMITATIONS: AN ARGUMENT AGAINST DEFINING THE ANTICOMPETITIVE HARM UNDER F. T.C. VACTAVIS AS THE "ELIMINATION OF THE RISK OF POTENTIAL COMPETITION"

By Anna M. Fabish1

I. INTRODUCTION

Litigants agree on little when it comes to reverse payment settlements and the interpretation of F.T.C. v. Actavis. Notably, neither litigants nor the courts have reached consensus on how to define the anticompetitive harm that underlies a reverse payment antitrust violation.

Plaintiffs and the Federal Trade Commission have attempted to convince courts to narrowly define the relevant anticompetitive harm as the mere "elimination of the risk of potential competition." Under this proposed definition, the harm to competition giving rise to an antitrust violation is complete at the time a reverse payment settlement is executed: executing the settlement either eliminates the risk of potential competition or it does not, regardless of actual outcomes later on.

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