Rahul Rao
Biography
Overview
Rahul Rao brings extensive experience in antitrust enforcement, litigation, and policy. He served as Deputy Director of the Federal Trade Commission's Bureau of Competition from 2022 to 2025 and Managing Assistant Attorney General in the Antitrust Division of the Washington State Attorney General's Office from 2018 to 2022.
He draws on this background to help clients navigate high-stakes competition matters, including federal and state government antitrust investigations and litigation defense, private antitrust and complex commercial litigation, merger clearance and internal investigations.
While at the FTC, Rahul led investigatory and litigation strategy across multiple enforcement divisions, including those focused on retail, labor, consumer goods, private equity, healthcare, pharmaceuticals, and biotech. He oversaw teams responsible for several high-profile merger challenges, including matters involving horizontal overlaps, vertical foreclosure, portfolio leveraging, and acquisitions by private equity sponsors.
He also played a leadership role in conduct investigations into competition issues in the pharmaceutical distribution system, rebating practices, price discrimination, and restrictions on independent repair.
Rahul was a key contributor to major FTC policy initiatives, including the 2023 Merger Guidelines, 2025 Hart-Scott-Rodino (HSR) rule changes, and Section 5 enforcement. His work helped shape the FTC's approach to merger remedies, litigating the fix, and enforcement priorities in evolving markets such as AI and digital platforms. He also represented the FTC in White House-led competition policy efforts and engagements with international and state-level antitrust authorities.
Rahul helped establish the Washington State Office of the Attorney General as a leading state antitrust enforcer. He spearheaded Washington State's nation-leading No-Poach Initiative and served as senior litigator on several litigations. His experience gives him unique insight into the increasing role of state attorneys general in competition enforcement.
From 2013-2014, Rahul served as a law clerk for the Honorable Eric T. Washington, the then-Chief Judge of the District of Columbia Court of Appeals.
In private practice, Rahul advises clients on merger clearance, government investigations, and compliance strategies, helping them anticipate regulatory scrutiny and mitigate enforcement risks.
A recognized thought leader in antitrust enforcement and competition policy, Rahul has delivered keynote addresses, testified before Congress, and spoken at major industry forums, including the ABA Antitrust Law Spring Meeting, Financial Times Live, and conferences on healthcare, technology, and labor markets.
Experience
Panelist, Antitrust Enforcement: Where We Are and Where Do We Go from Here?, 40th Annual Antirust & Trade Regulation Seminar, NERA (Park City, Utah, July 1, 2024)
Keynote, U.S. Pharma and Biotech Summit, Financial Times (FT) Live (New York, NY, May 16, 2024)
Keynote Fireside Chat, Antitrust West Coast 2024, Informa Connect (San Francisco, CA, May 3, 2024)
Panelist, The Fix is In?, 72nd Annual Antitrust Law Spring Meeting, American Bar Association (Washington, DC, April 10, 2024)
Conversation with the Hon. Yvonne Gonzales Rogers, U.S. District Court Judge for the Northern District of California, Diversity Dialogue, 72nd Annual Antitrust Law Spring Meeting, American Bar Association (Washington, DC, April 10, 2024)
Speaker, Healthcare and Hospital Mergers, 2024 Enforcers Summit (Washington, DC, April 8, 2024)
Keynote Speaker, Antitrust and Consumer Protection Session of FCBA Diversity Pipeline—TMT Law & Policy Certificate Program, Federal Communications Bar Association (April 6, 2024)
Speaker, 2024 Hot Topics in Healthcare Antitrust, American Health Law Association (March 19, 2024)
Keynote Speaker, The Trust Busters: Insights on Competition from FTC Officials, Association of Business Trial Lawyers (abtl) Northern California (San Francisco, CA, March 12, 2024)
Speaker, Mergers in an Age of Heightened Antitrust Scrutiny: International, Federal, and State Perspectives, Penn Carey Law Antitrust Association's Third Annual Symposium, University of Pennsylvania (Philadelphia, PA, February 16, 2024)
Fireside Chat, Exploring Paths to Collaboration and M&A: FTC Perspectives on Innovation and More, Goodwin + KPMG 5th Annual Symposium @ JP Morgan Healthcare Conference 2024 (San Francisco, CA, January 10, 2024)
Panelist, Everything You Ever Wanted to Know About Venue, National Antitrust Seminar, National Association of Attorneys General (Portland, OR, November 30, 2023)
Speaker, Federal Enforcer Update—Merger Guidelines, HSR Forms and More—What Does it Mean for State Enforcement?, National Antitrust Seminar, National Association of Attorneys General (Portland, OR, November 29, 2023)
Panelist, FTC's Foray into Orange Book Listings: Challenges or Challenging?, American Bar Association Antitrust Law Section (November 28, 2023)
Speaker, Hospital Consolidation: Mergers, Antitrust & Health Equity, Affordability Roadmap Webinar Series, NIHCM Foundation (November 16, 2023)
Panelist, Non-Competes in the Eyes of the FTC and the NLRB: Necessary for Data Protection or Just Anti-Worker?, Trade Secrets Symposium, Georgetown Law (Washington, DC, November 8, 2023)
Keynote Speaker, The Year Ahead in Healthcare Antitrust Enforcement, Fall Health Law Conference, Washington State Society of Healthcare Attorneys (Vancouver, Canada, November 4, 2023)
Guest Lecturer, Industrial Organization and Public Policy Seminar, Professor Mary Kelly, Villanova University (Villanova, PA, October 24, 2023)
Panelist, Federal and State Antitrust Enforcement, Antitrust Counseling and Compliance 2023, Practicing Law Institute (New York, NY, October 11, 2023)
Speaker, PBM Price Transparency Bill and Perspectives on the FTC's Renewed Look at PBMs, Medicaid Drug Rebate Program (MDRP) Summit 2024, Informa Connect (Chicago, IL, September 20, 2023)
Conversation with New Hampshire Attorney General John Formella and Rhode Island Attorney General Peter Neronha, Healthcare & Antitrust: Beyond the Traditional Markets, 2023 Eastern Region Meeting, National Association of Attorneys General, (Uncasville, CT, August 3, 2023)
Conversation with Maine Attorney General Aaron Frey, Agreeing to Compete—Cases, Legislation and Guidance Honing in on Noncompete, No-Poach Agreements, and Information Exchanges, 2023 Eastern Region Meeting, National Association of Attorneys General, (Uncasville, CT, August 2, 2023)
Guest Lecturer, Antitrust Law and Policy, Professor Douglas Ross, University of Washington (Seattle, WA, February 15, 2023)
Fireside Chat, Healthcare Provider Non-Compete Restrictive Covenants: Recent Developments for Employment and Transactions, Washington Health Law Summit, American Bar Association (Washington, DC, December 13, 2022)
Panelist, Private Equity: Villain or Bogeyman?, 71st Annual Antitrust Law Spring Meeting, American Bar Association (Washington, DC, March 30, 2023)
Moderator and Program Planner, Challenges in Monopolization Cases, a discussion with Director-General Olivier Guersent (DG Comp), Chairman Ki-Jeong Han (KFTC), Deputy Assistant Attorney General Hetal Doshi (US DOJ), and Senior Deputy Attorney General Paula Blizzard (CA DOJ), 2023 Enforcers Summit (Washington, DC, March 27, 2023)
Keynote Speaker, "The Implications of the FTC's Proposed Ban on Noncompete Agreements," A Regulatory Transparency Project Webinar, The Federalist Society (March 1, 2023)
Keynote Speaker, Panelist, and Moderator, Eastern States Common Grounds Conference (Washington, DC, January 26, 2023), Middle States Common Grounds Conference (Chicago, IL, December 1, 2022), and Western States Common Grounds Conference (Seattle, WA, October 13, 2022)
Panelist, Briefing with the State Enforcers, 70th Annual Antitrust Law Spring Meeting, American Bar Association (Washington, DC, April 7, 2022)
Moderator and Program Planner, Labor Competition Issues, NAAG Antitrust Seminar, National Association of Attorneys General (Philadelphia, PA, October 27, 2021)
Kickoff Speaker, Antitrust and Labor Enforcement Fireside Chat, American Bar Association Antitrust Section (Washington, DC, June 15, 2021)
Guest Lecturer, Economics of Labor Seminar, Professor Orley Ashenfelter, Princeton University (Princeton, NJ, September 16, 2020)
Panelist, No-Poach: Assessing Risk in Uncertain Seas, 68th Annual Antitrust Law Spring Meeting, American Bar Association (April 28, 2020) (presented as an episode of the ABA's Our Curious Amalgam podcast)
Speaker, Developments in the Application of the Per Se Standard, American Bar Association Joint Conduct Committee (March 9, 2020)
Testimony before United States Congress, Hearing on Antitrust and Economic Opportunity: Competition in Labor Markets, U.S. House of Representatives, Judiciary Committee, Subcommittee on Antitrust, Commercial and Administrative Law (Washington, DC, October 29, 2019)
Panelist, Anti-Poaching Issues in Franchising, 42nd Annual Forum on Franchising, American Bar Association (Denver, CO, October 17 & 18, 2019)
Panelist, Effective Settlement Strategies, NAAG Antitrust Seminar, National Association of Attorneys General (San Antonio, TX, September 26, 2019)
Panelist, DOJ Antitrust Division Panel on Ancillarity, Collaborations, and Contractual Arrangements: Assessing Antitrust Harms in Complex Business Settings, Public Workshop on Competition in Labor Markets, U.S. Department of Justice (Washington, DC, September 23, 2019)
Labor is Local: State Enforcement of Labor Markets, "Briefing with the State Enforcers," American Bar Association (April 7, 2022)
When Competition Meets Labor: The Washington Attorney General's Initiative to Eliminate Franchise No-Poaching Provisions, Competition Policy International Chronicle (August 2020)*
Freeing Competition for Franchise Workers: The Washington Initiative that Brought Nationwide Change, "Competition Torts News," American Bar Association, Section of Antitrust Law, Competition Torts Committee (Vol. 17, Issue 1, Summer 2020)
Washington State's Initiative to Eliminate Franchise No-Poach Provisions, "No Poach: Assessing Risk in Uncertain Seas," American Bar Association (April 22, 2020)
Written Testimony before U.S. Congress, "Hearing on Antitrust and Economic Opportunity: Competition in Labor Markets," U.S. House of Representatives, Judiciary Committee, Subcommittee on Antitrust, Commercial and Administrative Law (Washington, DC, October 29, 2019)
Anti-Poaching Issues in Franchising, American Bar Association (October 2019) (co-author)
* Winner of the 2021 National Association of Attorneys General Antitrust Task Force Chair's Writing Award
