Several companies and industry associations have also filed lawsuits challenging the price negotiation provisions of the IRA on various constitutional grounds. We will continue to follow the trends in this area as they develop. FTC Scrutiny Over Life Sciences Transactions In 2023, the Federal Trade Commission (FTC) continued its aggressive approach to reviewing life sciences acquisition transactions, notably challenging (1) Amgen Inc.'s $27.8 billion acquisition of Horizon Therapeutics plc and (2) Sanofi's exclusive license to Maze Therapeutic Inc.'s product candidate for the treatment of Pompe disease for up to $755 million. The FTC's argument in the Amgen case was unique as it focused on Amgen's theoretical use of bundled rebating to pressure insurers and pharmacy benefit managers into preferring two Horizon products that did not have any current competition on the market. Amgen was eventually allowed to move forward with the Horizon acquisition subject to entry into a consent decree with the FTC.