Computer & Communication Industry Association
PublishedMay 26, 2026

CCIA Files Comments to FTC and DOJ on HSR Premerger Notification Form Consultation

Washington – The Computer & Communications Industry Association submitted comments to the Federal Trade Commission and the Department of Justice’s Antitrust Division in response to their joint consultation seeking public comment on improvements to the Hart-Scott-Rodino (HSR) premerger notification form. CCIA previously submitted comments in response to the Agencies’ 2023 NPRM regarding the HSR form.

CCIA’s comments emphasize the importance of ensuring that any updates to the HSR form do not unduly increase the notification burden on filers. At a time when U.S. leadership in AI is increasingly contested, expanding the HSR form to include otherwise non-reportable “hire-and-license-out” transactions, or requiring duplicative filings during the Second Request phase, would risk imposing substantial regulatory hurdles on firms competing in highly dynamic markets.

CCIA has advocated for a competitive technology sector for more than 50 years. 

The following can be attributed to CCIA’s Vice President of Global Competition and Regulatory Policy, Krisztian Katona:

“Any updates to the HSR form should remain focused on identifying transactions that may raise genuine antitrust concerns. The premerger notification process works best as an efficient screening mechanism for potentially harmful transactions, not as a broad regulatory burden on the vast majority of transactions that raise no competitive concerns.”

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