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

AI, cybersecurity and data practice group will provide clients with legal guidance around AI alongside a 'deep technical foundation’ in IP
Lawyers at Vondst and Biopatents say a ruling concerning the protected status of trade secrets could see the UPC flooded with requests to prevent access to confidential information
Sharad Vadehra of Kan & Krishme discusses why older IP firms still have an edge over up-and-coming boutiques and how the firm is using AI to provide quick and cost-effective service
Lawyers at Appleyard Lees share how they picked apart a plant breeder’s infringement claims concerning the ‘Tango’ mandarin
A further decision on long-arm status, and a new hire for Pentarc in Germany from Taylor Wessing were also among top developments
The US decision marks a rare grant of a request under the Uniform Fraudulent Transfer Act in a patent case
Stobbs has applied to strike out a contempt of court application filed against the firm and two of its lawyers
With trademark volumes surging, trademark teams need to think beyond traditional clearance searches, towards a continuous, intelligence-led workflow, says Meghan Medeiros of Corsearch
Brazilian in-house counsel say law firms’ technology investments have not translated into tangible benefits, meaning tech use is a minor factor when selecting advisers
A lack of comfort among some salaried partners shows why law firms must actively foster inclusion, not merely focus on diversity mandates
Gift this article