Jeremy D. Kernodle

Rule Changes

Issued February 12 ruling vacating the expanded HSR form

The Hart-Scott-Rodino premerger notification form went largely unchanged for 48 years. When the Federal Trade Commission tripled its compliance burden in 2024, business groups sued, and a Texas federal judge just agreed.

Updated May 29

Rule Changes

Presiding over HSR rule challenge

The United States raised the federal antitrust review threshold to $133.9 million on February 15, 2026—up from $126.4 million the previous year. Companies planning mergers or acquisitions above this threshold must file premerger notifications with the FTC and DOJ and await government clearance before closing.

Updated May 29

Rule Changes

Issued and later lifted Smith injunction

Congress passed the Corporate Transparency Act in 2021 to crack down on shell companies used for money laundering and terrorist financing, requiring 33 million U.S. businesses to report their true owners to FinCEN. Courts in Alabama and Texas declared it likely unconstitutional.

Updated May 19