A wave of consolidations among pharmaceutical companies in recent years (see Figure 1) has prompted increased scrutiny from antitrust agencies. Some commentators have observed that the so-called “third wave” of mergers in the pharmaceutical industry – which began around 2010 – has been marked primarily by larger companies acquiring startups with innovative products. In this landscape, antitrust agencies under the Biden administration have raised novel concerns about future competition and incentives to innovate, in order to challenge some of these deals.