COREY ROUSH is a Chambers USA-ranked District of Columbia Antitrust practitioner (2018–2024) who focuses his practice on guiding clients through contentious antitrust and consumer protection litigation and investigations, as well navigating the antitrust regulatory aspects of merger clearance. He has extensive experience representing clients before the Federal Trade Commission (FTC), the Antitrust Division of the U.S. Department of Justice (DOJ), and various state attorneys general. Corey has also represented clients in antitrust cases in federal district and appellate courts throughout the United States.
On the merger clearance front, The Legal 500 US ranks Corey as a “Leading Lawyer” in Merger Control (2023–2024). Recently, he led teams in response to four publicly announced Second Requests and a fifth non-public Second Request before the Antitrust Division at the DOJ and three different merger shops at the FTC. For each deal, Corey crafted tailored strategies based on whether he represented the buyer or seller, the primary objectives of his clients (speed versus no divestiture), the industry, and the specific group of antitrust enforcers involved. His bespoke approach led to creative, time and cost-saving solutions that satisfied the regulators and accomplished his clients’ goals.
While Corey’s foremost goal in merger clearance is to get the deal cleared without litigation, his strong litigation background has positioned him well to assist clients when the government sues to block their transactions. To that end, he has litigated several cases against the FTC and the DOJ to uphold proposed and consummated mergers. For instance, in 2018, Corey led the trial team that defended a global merger of two marine chemical providers against the FTC’s challenge. He was also part of the trial team that handled the first live merger trial following COVID.
On the non-merger litigation front, Corey has won several dismissals at the motion to dismiss and summary judgment stages, as well as defeated class certification in many class action cases. He has also assisted in achieving favorable settlements of federal antitrust and consumer protection claims, as well as false claims and anti-kickback cases. Corey’s experience spans numerous industries, including technology, healthcare, defense, aeronautics, direct selling, and medical devices, with a particular focus on the life sciences, retail, chemicals, and energy industries.
Additionally, Corey offers compliance counseling on marketing and pricing laws, agency regulations, FTC interpretations and guidelines, as well as industry self-regulating guidelines. He has represented clients before almost all divisions of the FTC’s Bureau of Consumer Protection and has litigated several matters against the Bureau of Consumer Protection.
Corey also provides comprehensive counsel to clients across various industries on compliance with federal and state laws and regulations, such as the Sherman Act, the FTC Act, the Clayton Act, the Anti-Kickback Statute, and the False Claims Act. He has represented clients in federal, state, and congressional investigations concerning:
- Sales and marketing practices
- Reimbursement issues
- Pricing issues
- FDA promotional issues, including off-label marketing
- General fraud and abuse theories
Corey’s work also includes conducting internal investigations related to his areas of focus and responding to administrative subpoenas, civil investigative demands, and other government requests for information for targets, third parties, and individuals.