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William Hallett Efron

Partner

Bill Efron, former Director of the Northeast Region of the Federal Trade Commission, is a member of the firm’s Antitrust/Competition practice.  With more than two decades of experience, Bill focuses on antitrust and consumer protection with an emphasis on merger reviews, government investigations, and litigation. His practice encompasses anticompetitive conduct matters, government enforcement actions, private litigation, and counseling.

Bill has deep senior government experience in both antitrust and consumer protection.  Prior to joining Arnold & Porter, he served as Director of the FTC’s Northeast Region for over 12 years. In that role, he was responsible for enforcing federal antitrust laws through merger and anticompetitive conduct investigations and litigation. On behalf of the FTC’s Bureau of Competition, Bill led and supervised antitrust matters across an array of industries, including healthcare, digital platforms, retail, medical devices, radiopharmaceuticals, and industrial products.

During his tenure at the FTC, Bill handled high-profile, cutting-edge, and highly complex matters. His experience includes serving as lead trial and appellate counsel in the FTC’s successful challenge to the proposed $2.4 billion merger of Penn State Hershey Medical Center and PinnacleHealth System. Bill argued the FTC’s appeal before the Third Circuit Court of Appeals, which issued a precedential opinion related to the analysis of hospital mergers. Bill and the litigation team received the FTC’s Janet D. Steiger Award for their work on the case. While his industry experience is broad, Bill has particular strength in healthcare and possesses significant experience with respect to digital platforms.

As Director of the FTC’s Northeast Region, Bill was also responsible for the investigation and litigation of consumer protection matters. On behalf of the FTC’s Bureau of Consumer Protection, he oversaw complex cases involving a range of alleged unfair, deceptive, and fraudulent practices, including deceptive internet marketing, unauthorized billing, misleading earnings claims, false advertising online, and credit card laundering.

Prior to joining the FTC, Bill practiced as an antitrust and commercial litigator at an Am Law 100 law firm.

Experience

  • Lead trial and appellate counsel in the FTC’s challenge to the proposed hospital merger of Penn State Hershey Medical Center and PinnacleHealth System. After the district court denied the FTC’s request for a preliminary injunction, the Third Circuit Court Appeals unanimously reversed and issued an opinion directing the district court to preliminarily enjoin the transaction. Thereafter, parties abandoned the deal.
  • Led and supervised the FTC’s investigation of Amazon’s proposed $1.4 billion acquisition of iRobot, which focused on Amazon’s ability and incentive to favor its own products and disfavor rivals’, and associated effects on innovation, entry barriers, and consumer privacy.  Parties abandoned the transaction.
  • Led the FTC’s investigation of Cardinal Health’s alleged illegal monopolization of 25 radiopharmaceutical markets across the country, which resulted in a federal court approved settlement requiring the payment of $26.8 million. Case marked the FTC’s first disgorgement settlement in an antitrust case in over a decade and at the time, the second highest monetary amount obtained by the FTC in a competition matter.    
  • Led and supervised the FTC’s investigation of the proposed merger of Atrium Health Navicent and Houston Healthcare System. After staff recommended challenging the transaction, the parties abandoned.    
  • Supervised investigation of Becton, Dickinson’s proposed $24 billion acquisition of C.R. Bard resulting in the divestiture of two medical device product lines.
  • Supervised investigation of Emerson’s $3.15 billion acquisition of industrial valve manufacturer Pentair resulting in the divestiture of Pentair’s switchbox business.

Credentials

Education

  • J.D., University of Virginia School of Law, 1999
  • B.A., University of Pennsylvania, 1996, magna cum laude

Admissions

  • New York
  • U.S. District Court, Eastern District of New York
  • U.S. District Court, Southern District of New York

Government & Military Service

  • Director of the Northeast Region, Federal Trade Commission (2012-2024) 
  • Attorney, Northeast Region, Federal Trade Commission (2009-2012)

Activities

  • Executive Committee, Antitrust Section, New York State Bar Association (2012-present)
Overview