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 2025

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

The association’s Australian group has filed a formal complaint against the choice of venue, citing Dubai as an unsafe environment for the LGBTQIA+ community
Firm says appointment of Nick McDonald will boost its expertise in cross-border disputes, including at the Unified Patent Court
In the final episode of a podcast series celebrating the tenth anniversary of IP Inclusive, we discuss the IP Inclusive Charter and the senior leaders’ pledge
Law firms are integrating AI to remain competitive, and some are noticing an impact on traditional training and billing models
IP partners are among those advising on Netflix's planned $82.7bn acquisition of Warner, which has been rivalled by a $108.4bn bid by Paramount
Sheppard Mullin’s Jennifer Ayers reviews modifications to the rules of practice for IPR petitions and considers what practitioners need to know
News of the EUIPO launching a GI protection system, and WIPO publishing a review of the UDRP were also among the top talking points
A team from Addleshaw Goddard secured victory for the changing robe brand, following a trial against competitor D-Robe
Bird & Bird, Brinkhof and Bardehle Pagenberg were successful at the Court of Appeal, while there was a partial victory for Amazon in a case concerning audio recordings
Following the anniversary of Venner Shipley and AA Thornton's merger, Ian Gill recalls the initial trepidation about working for his spouse and offers tips for those who may find their personal and professional worlds colliding
Gift this article