Sarah Pugh advises clients on matters involving all aspects of antitrust and competition law, including government investigations, merger reviews, litigation, and congressional inquiries. She regularly defends clients in investigations by the US Department of Justice, Federal Trade Commission, and state attorneys general in cases involving allegations of algorithmic collusion, price fixing, group boycott, information sharing, monopolization, and wage-fixing. She also has extensive experience counseling clients on compliance with the Hart-Scott-Rodino (HSR) Act, and she is a member of the firm’s cross-functional New HSR Form Working Group.

Ms. Pugh represents clients in a wide range of industries, including technology, finance, healthcare, biotechnology, real estate, agriculture, energy, and private equity.

Prior to joining WilmerHale, Ms. Pugh worked for another international law firm, where she also focused her practice on antitrust and government investigations.

Professional Activities

Ms. Pugh is an active member of the American Bar Association’s Antitrust Section, currently serving as a Young Lawyer Representative on the Editorial Board of the Antitrust Law Journal. She is also a member of the Women’s Bar Association of the District of Columbia. Ms. Pugh has also taught as an adjunct professor at the American University Washington College of Law and regularly mentors first-generation law students.

Ms. Pugh is committed to public service and maintains an active pro bono practice, primarily representing children and young adults in immigration matters.

Experience

  • Investigations

    • Representing advertising agency in FTC investigation regarding alleged group boycott.
    • Represented large property owner in investigation by DOJ and various state attorneys general regarding use of algorithmic pricing software.
    • Represented client in concurrent DOJ and Congressional investigations regarding COVID-19 supply chain disruption and pricing coordination.
    • Represented private equity company in investigation by the Attorney General of the State of Colorado regarding alleged serial acquisition strategy in healthcare staffing markets.
    • Represented waste management company in investigation by New York Office of the Attorney General regarding alleged serial acquisition strategy.
    • Represented independent grocery wholesaler in the FTC’s 6(b) study regarding COVID-19 supply chain disruption.
     
  • Merger Clearance

    • Advised automotive retail group in $2.9 billion acquisition of regional automotive dealerships.
    • Advised cargo airline company in connection with joint venture.
    • Advised large life sciences company in $9.6 billion acquisition of biotechnology company.
    • Represented waste management company in merger through Second Request and divestiture.
    • Ms. Pugh regularly advises clients on HSR Act compliance, including executive HSR filing obligations.
     
  • Litigation

    • Represented technology company in class action lawsuits alleging unlawful monopolization in the Northern District of California.
    • Represented medical device company in response to non-party subpoena in Federal Trade Commission v. Edwards, 25-cv-025959 (D.D.C.).
    • Representing technology company in response to non-party subpoenas issued in Federal Trade Commission v. Amazon, 23-cv-01495 (W.D. Wash), and related matters.
    • Representing financial institution in response to non-party subpoenas in United States v. Visa, Inc., 24-cv-7214 (S.D.N.Y), and related matters.
     

Insights & News

Credentials

  • 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

Credentials

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