On June 25, 2021, WLF filed formal comments with the Federal Trade Commission urging it to scrutinize pharmaceutical mergers no more or less than mergers in other industries. Despite no statutory or case law support, the FTC has requested input on whether it should treat pharmaceutical mergers differently than mergers in other industries. WLF’s comments remind the FTC how focusing on competition, not competitors, has been central to American antitrust law for decades. Changing that focus would likely lead to unintended and disastrous results for pharmaceutical innovation. FTC should stay the course and use the same antitrust standards across the board.