The DOJ’s Antitrust Division announced updates late last week to its Civil Investigative Demand (CID) form, explicitly codifying it intent to potentially use materials received in response to CIDs to launch secondary investigations or refer matters to other government enforcement authorities or agencies. In-house lawyers should be sensitive to three key takeaways. Key Takeaways First, expansive enforcement actions can arise from unrelated investigations. Costly investigations and even criminal prosecutions have recently arisen from routine civil conduct investigations. The Antitrust Division may refer cases to other divisions within the DOJ or even other government agencies. Second, the approach companies’ take in responding to CIDs can reduce their risk. Responding to a CID can involve
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