The start of the Obama administration in 2009 brought with it predictions of stepped-up antitrust enforcement activity by the Department of Justice’s (DOJ) Antitrust Division, particularly in the area of mergers. To the surprise of many observers, those predictions proved largely overstated. While the US Federal Trade Commission (FTC) continued to be very aggressive in its antitrust enforcement, and the DOJ vigorously pursued cartels in the United States and around the world (as it has for the last two decades), civil non-merger challenges and merger enforcement have barely increased over the last two years. Instead, the DOJ’s enforcement actions typically involved settlements—particularly in the

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