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Farrah Short

Special Counsel

[email protected]



Farrah advises on all aspects of antitrust and competition law, including merger review, competitor collaborations, government investigations, private class action litigation, and general antitrust compliance.

Farrah specializes in counseling clients through the Hart-Scott-Rodino (HSR) merger review process at the U.S. Federal Trade Commission and the U.S. Department of Justice, including responding to Second Requests and providing substantive antitrust risk analysis for strategic acquisitions. She has obtained antitrust clearance for major, multi-billion dollar transactions in a variety of industries. Farrah also regularly advises on HSR reporting triggers for securities investors and provides strategic advice for non-reportable transactions with significant competitive implications.

She also has significant experience counseling clients on a wide range of other antitrust compliance issues, including information exchanges, competitor collaborations, joint ventures, licensing deals, exclusive dealings, and the creation of internal antitrust compliance programs. In addition, Farrah represents clients in state antitrust investigations, and provides guidance on navigating ex-U.S. merger control requirements.

Outside of her antitrust practice, Farrah serves as chief outside counsel to the National Network to End Domestic Violence. She also actively supports the firm’s pro bono program, representing indigent clients in immigration matters, including successful asylum and U visa applications. She previously served as chief outside counsel for a nonprofit that provides need-based education scholarships for the families of U.S. military personnel.

Prior to her legal career, Farrah was a program associate for the launch of the Women and Public Policy Program at Harvard’s Kennedy School.


  • Served as antitrust counsel to one of the largest American retail pharmacies. Our team represented the corporation in its transactions, litigation, and other matters before both state and federal antitrust authorities.
  • Represented one of the nation’s leading hospital and physicians networks in connection with its acquisitions of three community hospitals and a large physician group.
  • Represented a market leading producer and distributor of environmentally-safe household products in its acquisition by another transnational consumer goods company.
  • Represented a leading provider of sample and assay technologies in the antitrust aspects of its $1.5 billion acquisition of another life sciences company.
  • Served as antitrust counsel for a hospital in its merger with another medical center.
  • Served as antitrust counsel for a leading provider of sample and assay technologies, and are currently involved in counseling and representing the company in merger and acquisition activities.
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FTC Announced Increased HSR Thresholds & Revised Filing Fee Schedule

January 23, 2024 | Alert | By Bruce Sokler, Robert Kidwell, Farrah Short, Sherwet H. Witherington, Payton Thornton

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In with the Old, Out with the New: DOJ and FTC Issue Much-Anticipated Draft Merger Guidelines

July 26, 2023 | Blog | By Bruce Sokler, Joseph Miller, Robert Kidwell, Farrah Short, Evelyn French, Sherwet H. Witherington, Payton Thornton

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Proposed Overhaul of HSR Premerger Notification Process

June 28, 2023 | Blog | By Farrah Short, Bruce Sokler, Joseph Miller, Robert Kidwell

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FTC Announced Increased HSR Thresholds & Publication of New Filing Fees

January 24, 2023 | Alert | By Bruce Sokler, Robert Kidwell, Farrah Short

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New Law Hikes HSR Merger Filing Fees for Large Deals and Imposes Foreign Subsidy Disclosure Requirement

January 3, 2023 | Alert | By Bruce Sokler, Joseph Miller, Robert Kidwell, Farrah Short

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FTC Policy Paper Supports Agency’s Long-Held Position in Opposition to COPAs

August 18, 2022 | Alert | By Bruce Sokler, Joseph Miller, Farrah Short

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Increased HSR Notification Thresholds for 2022

January 24, 2022 | Alert | By Bruce Sokler, Robert Kidwell, Farrah Short

This alert covers the FTC’s increased jurisdictional thresholds for premerger notification filings under the Hart-Scott-Rodino Antitrust Improvements Act of 1976 (HSR Act), as amended.
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FTC, DOJ Launch Proceeding to Revise Antitrust Merger Guidelines

January 19, 2022 | Blog | By Bruce Sokler, Joseph Miller, Robert Kidwell, Farrah Short

As has been expected, on January 18, 2022, the Federal Trade Commission (“FTC”) and Antitrust Division of the Department of Justice (“DOJ”) announced in a joint press conference an initiative to review and revise the antitrust merger guidelines.  In his competition Executive Order last summer, President Biden announced a policy calling for increased scrutiny of mergers.  Against this backdrop, one would expect the effort would result in the toughening of standards over what currently is found in the existing guidelines.
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FTC Issues Fines Totaling Nearly $2 Million For Failures To File HSR Notifications

December 27, 2021 | Blog | By Bruce Sokler, Farrah Short

The Federal Trade Commission is closing out the year with vigorous enforcement of the Hart Scott Rodino Antitrust Improvements Act of 1976 (“HSR Act”) by imposing fines totaling nearly $2 million.  On December 22, 2021, the FTC settled charges in two separate matters for repeated violations of the HSR Act. In one, investment fund operator Biglari Holdings Inc. will pay $1.4 million to settle charges that it failed to file the required HSR notification for stock acquisitions it made in 2020.  In the other, Clarence L. Werner, founder of Werner Enterprises, Inc. will pay $486,900 to settle charges that he failed to file for acquisitions between May 2007 and February 2020 of his company’s stock.
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Webinar Recording: Cutting Through the Antitrust Noise — What’s Actually Going On?

October 7, 2021 | Webinar | By Robert Kidwell, Joseph Miller, Farrah Short, Bruce Sokler

Mintz’s antitrust team discussed what you should know as you conduct your business and plan your transactions and investments.
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News & Press

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San Francisco Managing Member Stephen Osborn and Member Robert Burwell led Mintz’s advisory team in facilitating a transformative combination for Muse Group with Hal Leonard, securing growth investment from Francisco Partners. This impactful collaboration merges Muse’s leadership in music content and creation with Hal Leonard’s renowned sheet music and music-learning expertise. The deal underscores Mintz’s commitment to supporting innovative technology companies in the Bay Area’s Private Equity landscape.
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An article published by The Deal featured remarks made by Mintz Member and Co-chair of the firm’s Antitrust Practice Bruce Sokler, Member Robert Kidwell, and Special Counsel Farrah Short during a firm webinar held earlier this month focused on recent antitrust developments and what companies should know as they conduct business and plan transactions and investments.
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Firm plays a key role in the largest health care acquisition to date in 2020.
In this article, authors Bruce Sokler and Farrah Short discuss a long-running anti-trust case, the Eleventh Circuit recently denied defendant Blue Cross Blue Shield’s interlocutory appeal of the district court’s ruling that certain allegedly restrictive practices of defendants must be analyzed under the per se standard rather than the more lenient rule of reason standard.

Mintz is proud to be recognized by JD Supra in its 2018 Reader’s Choice awards. The annual program highlights the most widely read authors and articles throughout the past year. Five Mintz attorneys were named JD Supra Top Authors in four different industries.
Mintz advised GPB Capital on its acquisition of a majority equity stake in Westwood, Massachusetts-based Prime Motor Group. The acquisition by Capstone Automotive Group, an affiliate of GPB, expands the group’s footprint throughout New England.
Chair of Mintz’s Antitrust section Bruce Sokler, along with Member Rob Kidwell and attorneys, Farrah Short Shawn Skolky collaborated on an article regarding the Washington state attorney general’s office suit against the expansion efforts of Franciscan Health System.  
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JD Supra has recognized Mintz in its 2017 Reader’s Choice awards, highlighting the most widely read authors and articles over the past year. Eleven Mintz attorneys were named JD Supra Top Authors in four industries and Mintz was recognized as the Top Firm with readers in the Energy Industry.
A team of Mintz attorneys author this column discussing the Korean Fair Trade Commission’s steep fine against Qualcomm for antitrust violations and the continued antitrust concerns raised by Qualcomm’s licensing practices.
Mintz attorneys represented Seventh Generation, Inc. in its recent sale to Unilever. Based in Vermont, Seventh Generation is a pioneer in corporate responsibility and sustainable product innovations, including plant-based detergents and household cleaners.
Farrah Short, Special Counsel on antitrust matters in Washington, DC, is quoted in a Cook County Record article on the U.S. District Court for the Central District of Illinois ruling in a matter involving OSF Saint Francis Medical Center and Unity Point Health-Methodist.
Mintz Members Bruce Sokler and Robert Kidwell, and Special Counsel Farrah Short, authored this Law360 column about the war being waged between businesses that accept payment cards and payment card fees and protective network rules.
Farrah Short, Special Counsel, is quoted in a Legal Newsline article on a lawsuit brought against the NCAA by a former Northern Illinois University football player. The plaintiff claimed that the NCAA’s scholarship and transfer rules violate antitrust laws.
Chair of Mintz’s Antitrust Practice Bruce Sokler and Farrah Short, Antitrust Special Counsel, authored this Law360 column on a legal battle between two rodeo associations.
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Events & Speaking

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Recognition & Awards

  • Washington D.C. Super Lawyers: Rising Star - Antitrust Litigation (2015)

  • City Year Idealist of the Year (2015)

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