In last month's antitrust column, we discussed the Department of Justice's (DOJ) reiteration of its commitment to enforcement of Section 1 of the Sherman Act through its willingness to litigate such cases in the context of alleged no-poach violations. A week later, on April 28, the DOJ again failed to secure a conviction in a criminal no-poach case in United States v. Patel. This time, a Connecticut federal judge granted the criminal defendants' motion for judgment of acquittal after a four-week trial before it went to the jury, ruling that the case did not involve market allocation subject to the per se rule of illegality under Section 1 of the Sherman Act. The defendants were six aerospace engineering managers from an aerospace engineering company and competing aerospace employee outsourcing companies that provided employees for-hire to work on its projects. The outsourcing companies compete with each other to recruit and hire engineers in pursuit of aerospace engineering projects. The DOJ alleged that the defendants conspired to restrict the hiring and recruiting of engineers and other aerospace employees between their companies, specifically agreeing not to hire employees of each other's companies or to contact, interview, or recruit applicants who were employed by the other co-conspirators.