Second Request compliance expertise

Bates White is a leading provider of Second Request compliance services for mergers under review by the Department of Justice (DOJ) or the Federal Trade Commission (FTC). We draw on decades of experience and established credibility with the agencies and with private clients. Our professionals parse Second Requests, identify and review responsive datasets and documentation, and work hand in hand with our attorney clients, end clients, and agency representatives to achieve compliance.

We help identify data specifications and compliance requirements; identify all relevant databases; prepare and package database descriptions, data samples, and full data pulls for submission; and engage with the agencies to address any questions. In parallel, our team will also analyze data to determine whether it can be used to advance advocacy workstreams.

Select cases for which we have provided Second Request services include support for the Interpublic Group of Companies (IPG) during the FTC’s investigation of Omnicom’s $13.5 billion acquisition of IPG; for U.S. Steel throughout the DOJ’s antitrust review of Nippon Steel Corp.’s acquisition of U.S. Steel; and for both parties in Beaumont Health’s $13 billion acquisition of Spectrum Health. Other industries we have worked in include airlines, petroleum, software, media, health insurance, technology, technology, and insurance.