Kristen Limarzi

Kristen Limarzi is a partner in the highly-acclaimed Antitrust and Competition Practice Group of Gibson, Dunn and Crutcher, LLP, based in the Washington, D.C. office. Prior to joining the firm, she served as a top enforcement official in the U.S. Department of Justice’s Antitrust Division, where, as Section Chief, she helped shape and implement the agency’s enforcement priorities and policies for both mergers and other business practices across industries.

Leveraging her experience as a top government enforcer, Ms. Limarzi’s current practice focuses on representing clients in merger and non-merger investigations before the DOJ, the Federal Trade Commission, and foreign antitrust enforcers, as well in as appellate and civil litigation. Her experience in merger matters spans the gamut of sectors, including consumer products, healthcare, oil and gas, telecommunications, financial and other data services, transportation, and high tech products. Ms. Limarzi brings a practical approach to helping clients navigate the increasingly complex antitrust enforcement environment, employing her deep experience with agency practice to achieve successful results in an efficient manner. Since joining Gibson Dunn, Ms. Limarzi has represented:

• NewsCorp.’s Dow Jones subsidiary in its billion dollar acquisition of assets from S&P Global and IHS Markit, proposed by the latter in connection with DOJ and foreign enforcers’ review of their global merger;
• Hershey Co. in its acquisition of chocolate manufacturer Lily’s;
• General Electric in its proposed acquisition of BK Medical;
• Welbilt in its proposed acquisition by Middleby and then in the topping bid acquisition by Ali Group;
• Berkshire Hathaway Energy in its proposed acquisition of certain pipeline assets of Dominion Energy;
• Hologic in its acquisition of Biotheranostics;
• The Hut Group in its acquisitions of DermStore and Bentley Laboratories;
• A major European financial institution in defending class actions alleging price fixing in European Government Bonds;
• AT&T, as a non-party, in the DOJ’s investigation and lawsuit against Google.

Prior to joining Gibson Dunn, Ms. Limarzi twice received the U.S. Attorney General’s Distinguished Service Award. As DOJ Antitrust Division Section Chief, she was responsible for a team of more than a dozen professionals litigating appeals in the Division’s civil and criminal enforcement actions and participating as amicus curiae in private antitrust actions. While serving in the Antitrust Division, Ms. Limarzi also helped to develop Division policies on a wide range of issues. She was a principal drafter of the agency’s Antitrust Guidance for Human Resources Professionals in 2016, and she led the team revising the agency’s Antitrust Guidelines for International Enforcement and Cooperation in 2017.

In recognition of her expertise in merger matters and competition policy, she was also a member of the small team of attorneys and economists from the Antitrust Division and the Federal Trade Commission that revised the Horizontal Merger Guidelines in 2010. Her litigation experience as a government enforcer included appeals of merger challenges in United States v. AT&T and United States v. Anthem.

Ms. Limarzi also advised Division leadership and investigative teams on merger matters involving novel antitrust issues across a variety of industries, including in:

• CVS/Aetna (2018) (healthcare)
• Energy Solutions/Waste Control Specialists (2016) (low-level radioactive waste disposal)
• Westinghouse Air Brake Technologies Corp./Faiveley (2016) (brakes)
• Aetna/Humana (2016) (health insurance)
• Twin America/City Sights/Coach (2016) (bus sightseeing)
• Anheuser Busch/‌InBev (2016) (beer) (settled with divestitures)
• National Cinemedia/Screenvision (2016) (cinema advertising)
• Verso Paper/New Page Holdings (2015) (coated paper)
• Norbord Inc./Ainsworth Lumber Co. (2015) (oriented strand board)
• Comcast Corp./Time Warner Cable (2015) (broadband and video distribution)
• S. Airways/AMR Corp. (2015) (air passenger service)
• Bazaarvoice/PowerReviews Inc. (2015) (on-line reviews)
• Delta Air/US Airways (2013) (airport slots)
• AT&T/T-Mobile (2012) (telecommunications)
• TicketMaster Entertainment/Live Nation Inc. (2012) (ticket distribution services)
• Dean Foods/Foremost Farms (2012) (fluid milk)
• Comcast/NBC Universal (2011) (video programming & distribution)
• Blue Cross Blue Shield of Michigan/Physicians Health Plan of Mid-Michigan (2010) (health insurance)
• Microsemi/Semicoa (2010) (semiconductors)
• Bemis/Rio Tinto (2010) (flexible packaging)
• Nuance Communications/Multimodal Technologies (2009) (voice recognition engines)
• JBS/National Beef Packaging (2009) (beef and cattle)

Ms. Limarzi clerked for Judge Leonie M. Brinkema of the U.S. District Court for the Eastern District of Virginia from 2002 to 2003. She received her law degree, magna cum laude, in 2002 from Georgetown University Law Center, where she was elected to the Order of the Coif. Ms. Limarzi earned a Bachelor of Arts degree with high honors from Swarthmore College in 1997.

Ms. Limarzi is admitted to practice in the District of Columbia.