FTC changes premerger notification rules for drug patents

Managing IP is part of Legal Benchmarking Limited, 1-2 Paris Gardens, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

FTC changes premerger notification rules for drug patents

The FTC has issued final changes to the premerger notification rules governing how pharmaceutical companies must report the acquisition of exclusive patent rights to the FTC and the Antitrust Division of the Department of Justice (DOJ)

Under the Hart-Scott-Rodino (HSR) Act, drug companies must report certain mergers and acquisitions of assets, including patents and exclusive patent licences, over a certain amount to the FTC and DOJ. The current threshold is $70.9 million.

The change will revoke the existing “make, use and sell” standard governing which licences are reportable. Under the current rules, companies are only required to report transfers of patent licences if they allow the buyer to develop, manufacture and sell a product without restriction.

Under the new rules, pharmaceutical companies will have to report transfers falling under the scope of the more stringent “all commercially significant rights” test.

According to the FTC, this will mean that “an exclusive license is substantively the same as buying the patent or part of the patent outright, and carries the same potential anticompetitive effects".

The FTC claims the “make, use and sell” test is “no longer adequate” because some drugs companies were transferring most but not all of the rights under a licence in order to avoid the reporting requirement.

The FTC received four public comments on the rule, including an objection to it from industry organisation Pharmaceutical Research and Manufacturers of America.

The new rules will take effect 30 days after publication in the Federal Register.

more from across site and SHARED ros bottom lb

More from across our site

Counsel for SEP owners and implementers are keeping an eye on the case, which could help shape patent enforcement strategy for years to come
Jacob Schroeder explains how he and his team secured victory for Promptu in a long-running patent infringement battle with Comcast
After Matthew McConaughey registered trademarks to protect his voice and likeness against AI use, lawyers at Skadden explore the options available for celebrities keen to protect their image
The Via members, represented by Licks Attorneys, target the Chinese company and three local outfits, adding to Brazil’s emergence as a key SEP litigation venue
The firm, which has revealed profits of £990,837, claims it is the disruptive force in the IP-legal industry
In the first of a two-parter, lawyers at Santarelli analyse the patentability of therapeutic inventions where publication of clinical trial protocols occurs before the application's filing date
Arun Hill at Clarivate assesses the Top 100 Global Innovators 2026 list, including why AI has assumed a strategic importance for innovation
Practitioners and law firms should keep their eyes peeled for the shortlists for our annual awards
Despite a broader slowdown in US IP partner hiring in 2025, litigation demand drove aggressive lateral expansion at select firms
Winston Taylor is expected to launch in May 2026 with more than 1,400 lawyers across the US, UK, Europe, Latin America and the Middle East
Gift this article