'We Should Be Pragmatic': Meet the Possible Next FTC Chair
“We’re holding them hostage,” Republican Commissioner Melissa Holyoak of the Federal Trade Commission said of merging parties affected by FTC Chair Lina Khan’s strategic use of consent orders. “This is an extreme abuse of our authority. It is so troubling to me.”
November 14, 2024 at 07:01 PM
4 minute read
AntitrustWhat You Need to Know
- Antitrust attorneys say President-elect Donald Trump may name Melissa Holyoak as the next chair of the Federal Trade Commission.
- President Joe Biden appointed Holyoak as a Republican FTC commissioner.
- Holyoak has written a number of dissents on the FTC led by Democratic Chair Lina Khan.
Melissa Holyoak, a GOP commissioner on the Federal Trade Commission, has seen her profile rise since the Nov. 5 presidential election.
As one of the two Republicans serving on the FTC, President-elect Donald Trump may name Holyoak as the next FTC chair.
American Bar Association members looked on attentively Thursday as Holyoak spoke at an antitrust forum in Washington, D.C.
“My approach generally with remedies, I think we should be pragmatic,” Holyoak said, forecasting how FTC enforcement may change if the commission adopts her regulatory worldview. “Everything should be kept on the table.”
The current FTC, led by Democratic Chair Lina Khan, has a “dogmatic approach” favoring litigation and “no remedies,” Holyoak said.
“If it is a problematic deal, we should scrutinize,” Holyoak said of mergers and acquisitions. “We’re not in the business of trying to stop deals just to stop deals.”
Freshfields Bruckhaus Deringer partner Christine S. Wilson, a former FTC commissioner, moderated the "fireside chat" with Holyoak at the American Bar Association’s annual Antitrust Fall Forum.
Wilson mentioned Trump’s selection of Rep. Matt Gaetz, R-Florida, to be the next U.S. attorney general. Gaetz, who was reelected to his congressional seat, resigned from his current term in the House on Trump's announcement.
Holyoak did not address the news of Gaetz' selection, but acknowledged that the FTC generally works closely with the Department of Justice.
Boasting two decades of legal experience, Holyoak entered the FTC’s orbit in July 2023 when President Joe Biden’s administration announced her nomination to serve as an FTC commissioner. She has issued several dissents since assuming the role in March on a regulatory body led by Khan.
Holyoak and fellow Republican Commissioner Andrew Ferguson dissented in April when the FTC voted 3-2 on party lines to finalize its ban on most noncompete agreements. Texas U.S. District Judge Ada Brown set the rule aside as arbitrary and capricious in August.
“I certainly agree with the district court,” Holyoak said Thursday, “because most of her opinion really followed what I said in my dissent.”
The FTC has appealed Brown’s ruling to the U.S. Court of Appeals for the Fifth Circuit. Holyoak said she believes the FTC will lose the appeal.
Holyoak and Ferguson recused themselves when the FTC in September voted 3-0-2 to take action against the three largest pharmacy benefit managers and their affiliated group purchasing organizations.
The FTC demonstrated bipartisan action in July when the commission voted 5-0 authorizing an FTC lawsuit seeking to block Tempur Sealy’s proposed $4 billion acquisition of retailer Mattress Firm.
Before joining the FTC, Holyoak served as solicitor general in the Office of the Utah Attorney General. She oversaw criminal appeals, civil appeals, constitutional defense and special litigation and antitrust and data privacy during her three years as Utah’s solicitor general.
If appointed as the next FTC chair, Holyoak’s prior experience shows she is not afraid to go after Big Tech. She previously played a lead role in the Utah v. Google antitrust lawsuit challenging Google’s alleged exclusionary conduct concerning Google Play. The case ended with a settlement.
After graduating from the University of Utah S.J. Quinney College of Law in 2003, Holyoak joined O’Melveny & Myers as a litigator for five years. She later served as president and general counsel of Hamilton Lincoln Law Institute, a Washington, D.C.-based public-interest law firm.
Holyoak’s prior experience also includes eight years of legal work at the Center for Class Action Fairness, where she advocated on behalf of consumers and helped reach large settlements.
Ropes & Gray partner Jane E. Willis, who specializes in health care antitrust litigation, told the National Law Journal in October that Trump may name Holyoak or Ferguson as the next FTC chair if the 45th president became the 47th.
An FTC led by Holyoak likely would not approve consent orders as a tactic for preventing merging parties from appointing a CEO to a board of directors, such as what happened in September concerning Chevron Corp.’s acquisition of Hess Corp.
“We’re holding them hostage,” Holyoak said of merging parties affected by Khan’s strategic use of consent orders. “This is an extreme abuse of our authority. It is so troubling to me.”
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