Sarah Pugh represents clients in diverse antitrust matters before the US courts, US Federal Trade Commission and Department of Justice, state attorneys general and Congress. She has experience securing international merger clearance, advising on HSR Act compliance, defending state and federal civil antitrust investigations and litigating antitrust cases including class actions. She has also represented clients in antitrust policy matters including investigations under Section 6(b) of the FTC Act.

Ms. Pugh has represented companies across a variety of industries, including biotechnology, pharmaceutical, healthcare, private equity, financial services, agriculture, retail, automotive parts and transportation.

Prior to joining WilmerHale, Ms. Pugh worked for another international law firm, where she also focused on antitrust and government investigations. During law school, Ms. Pugh was an intern in the Department of Justice’s Antitrust Division and a judicial intern for the Honorable Reggie B. Walton of the US District Court for the District of Columbia. She was also a research assistant for Professor Jonathan B. Baker.

Professional Activities

Ms. Pugh is a member of the American Bar Association’s Antitrust Section, and currently serves as a Young Lawyer Representative on the Editorial Board of the Antitrust Law Journal. She also served as an adjunct professor at the American University Washington College of Law for the 2021–2022 academic year.

Ms. Pugh has an active pro bono practice in which she has represented clients in immigration matters before state and federal courts. 

Insights & News


  • Education

    • JD, American University, Washington College of Law, 2018

      magna cum laude

      Order of the Coif

      Note & Comment Editor, American University Law Review

    • BA, Political Science, Northeastern University, 2015

      Honors Program 
  • Admissions

    • District of Columbia

    • US District Court for the District of Columbia



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