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Lily Rudy

Lily Rudy
  1. People

Lily Rudy

Lily Rudy

Counsel


Washington
Lily Rudy
  1. People

Lily Rudy

Lily Rudy

Counsel


Washington

Lily Rudy

Counsel

Washington

T: +1 202 508 6075

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  • Biography

Biography

Lily Rudy is a counsel in the firm’s Antitrust and Competition Practice Group. She is an experienced antitrust attorney with a strong track record in complex investigations and litigation. Lily was a key member of the Federal Trade Commission’s (FTC) Amazon monopolization investigation and litigation team. She also investigated and litigated multiple high-profile merger challenges in federal court and administrative proceedings, including Tronox/Cristal, Axon/VieVu, and Nvidia/ARM.

With active courtroom experience, Lily has first chaired over a dozen depositions and investigational hearings, conducted direct and cross examinations, and drafted motions, complaints, and Commission recommendations. She has worked alongside leading economic experts and interacted with several international enforcement agencies.

Before entering private practice, Lily was a Staff Attorney at the FTC, where she was actively involved in recruitment and led her group’s law school intern program, demonstrating a commitment to mentorship and talent development in the antitrust field. Lily clerked for the Honorable Charles Lettow of the United States Court of Federal Claims. She earned her J.D. from The George Washington University Law School, where she served as production editor for The George Washington Law Review, and her undergraduate degree from the University of Michigan.

Admissions

  • District of Columbia, 2015

Education

  • The George Washington University, J.D., cum laude, 2013
  • University of Michigan, B.S.E., summa cum laude, 2010

Related Capabilities

Antitrust & Competition Antitrust & Competition

Investigations Investigations

Litigation Litigation

  • Antitrust & Competition

  • Investigations

  • Litigation

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Mar 23, 2026

“I’m Not Dead Yet”: Is the Demise of the FTC’s Click-to-Cancel Exaggerated?

The Federal Trade Commission’s 2024 amendments to the Negative Option Rule (commonly called “Click-to-Cancel”) may have been vacated by the Eighth Circuit for failing to comply with required rulemaking procedures, but the FTC is already moving to revive the rule through a new rulemaking. In practice, the rule was never entirely off the table: the FTC has continued to challenge negative option practices on a case-by-case basis under its other statutory authorities, especially the Restore Online Shoppers’ Confidence Act (ROSCA), which remains good law.
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Feb 23, 2026

HSR in Flux: New Filing Requirements Collide with Federal Court Ruling

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FTC Chairman Issues Warning Letters Relating to Diversity Initiatives to Law Firms Which Have Implications to Corporate Employers as Well

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Jan 06, 2026

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Sep 30, 2025

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In Media Matters v. Federal Trade Commission, the Federal Trade Commission (FTC) suggested that issues surrounding the scope, validity, and enforceability of a civil investigative demand (CID) should be addressed during an enforcement action. This position could have significant implications for the FTC’s ability to conduct investigations due to the public nature of enforcement actions, limited FTC resources, and the potential for an increased number of challenges to the FTC’s authority to start investigations in the first place.

Related Insights

Insights
Mar 23, 2026
“I’m Not Dead Yet”: Is the Demise of the FTC’s Click-to-Cancel Exaggerated?
The Federal Trade Commission’s 2024 amendments to the Negative Option Rule (commonly called “Click-to-Cancel”) may have been vacated by the Eighth Circuit for failing to comply with required rulemaking procedures, but the FTC is already moving to revive the rule through a new rulemaking. In practice, the rule was never entirely off the table: the FTC has continued to challenge negative option practices on a case-by-case basis under its other statutory authorities, especially the Restore Online Shoppers’ Confidence Act (ROSCA), which remains good law.
Insights
Feb 23, 2026
HSR in Flux: New Filing Requirements Collide with Federal Court Ruling
On February 12, 2026, a federal district court in the Eastern District of Texas vacated the Federal Trade Commission’s new Hart‑Scott‑Rodino Act premerger notification form, concluding that in its 2025 comprehensive overhaul of the nearly 50-year old form, the agency exceeded its statutory authority and acted arbitrarily and capriciously under the Administrative Procedure Act. Although the court ordered the new form set aside, the Fifth Circuit has issued an administrative stay while it considers the FTC’s emergency motion for a stay pending appeal. As a result, the new HSR form remains in effect at this time. Parties preparing HSR filings should be aware that filing requirements may shift quickly depending on the Fifth Circuit’s forthcoming decision.
Insights
Feb 04, 2026
FTC Chairman Issues Warning Letters Relating to Diversity Initiatives to Law Firms Which Have Implications to Corporate Employers as Well
Summary: On Friday, January 30, 2026, Andrew Ferguson, the Chairman of the Federal Trade Commission (FTC), sent warning letters to over 40 law firms about their purported involvement in the Mansfield Certification program, a diversity initiative pursuant to which law firms commit to considering diverse applicant pools. The warning letters characterize the Mansfield Certification program as an illegal collusion scheme, often referred to as a “hub and spoke” cartel. The current administration has used this type of “cartel” claim frequently. Several of us predicted last year (in the context of U.S. antitrust challenges to environmental sustainability initiatives) that the cartel type claims would be increasingly invoked. But significant challenges exist between these warning letters and legal action sufficient to withstand a motion to dismiss. Clients, whether law firms or other entities that participate in the Mansfield Certification program, should review their hiring practices to ensure that they are making independent hiring decisions, even if those actions parallel other firms’ decisions.
Insights
Jan 06, 2026
Early Reviews Are In: FTC Flags Potential Violations of Consumer Reviews Rule
Insights
Sep 30, 2025
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In Media Matters v. Federal Trade Commission, the Federal Trade Commission (FTC) suggested that issues surrounding the scope, validity, and enforceability of a civil investigative demand (CID) should be addressed during an enforcement action. This position could have significant implications for the FTC’s ability to conduct investigations due to the public nature of enforcement actions, limited FTC resources, and the potential for an increased number of challenges to the FTC’s authority to start investigations in the first place.

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