State Attorney General Antitrust
Experience, credibility, trust, and access in State Attorney General matters.
Our attorneys offer firsthand experience from both sides of the table — as government enforcers and as in-house and outside counsel representing companies in investigations, litigation, and advocacy before state AG offices.
Paul Moore spent over a decade as a senior Deputy Attorney General in the California Department of Justice’s Antitrust Section. While there he initiated and led conduct and merger investigations and prosecuted law enforcement actions.
Paul served as lead counsel on several of the State’s most significant antitrust matters. These include People v. Vitol, the parens patriae action against global gasoline trading firms that resulted in a $50 million settlement, and California v. Valero Energy Partners / Plains All American Pipeline, the first successful vertical merger challenge in the United States in more than 40 years. Paul also led a coalition of California, 48 other states, and the District of Columbia in objecting to the proposed settlement in the Payment Card Interchange Fee and Merchant Discount Antitrust Litigation. Paul regularly advised executive management on state and national policy issues and served as liaison to other states’ attorneys’ general and federal enforcement agencies.
Pat Pascarella was recently retained by the California Attorney General to lead a team of Bona Law attorneys supporting the AG’s Office in the prosecution of a significant price-fixing matter. As former Chief Antitrust Counsel at AT&T, Pat defended and challenged significant mergers and acquisitions, often in concentrated industries, and represented his client in constant investigations and advocacy involving state AG offices. His time at the U.S. Department of Justice’s Antitrust Division also involved regular interaction with state enforcers across the country.
Luke Hasskamp served as special outside counsel to the Louisiana Attorney General in a series of high-profile healthcare and pharmaceutical cases, including Medicaid fraud and unfair trade practices cases. This includes State ex rel. Caldwell v. Takeda Pharmaceuticals America, Inc. (Actos), as well as actions against Abbott Laboratories (Depakote), Pfizer (Neurontin), and AstraZeneca (Toprol-XL).
Bona Law represents companies across the full range of state AG antitrust matters including: internal investigations, civil investigative demands and subpoenas; merger investigations and challenges; multistate investigations coordinated through the National Association of Attorneys General or ad hoc executive committees; parens patriae litigation; investigations such as algorithmic pricing and no-poach; antitrust and constitutional challenges to certificate of need laws; and healthcare consolidation matters under California’s Office of Health Care Affordability as well as the inevitable follow-on private class action and competitor litigation.
Featured Analysis
California’s “Mini-HSR” Antitrust Filing Arrives in 2027: A Practical Compliance Checklist →
Authors: Paul Moore and Steven Cernak. A practical, deal-team-ready checklist for SB 25 compliance under California’s Uniform Antitrust Premerger Notification Act, effective January 1, 2027. Covers who gets caught under the 20%-of-threshold California sales test, what each filer must submit and when, the one-business-day filing deadline, the $25,000-per-day penalty exposure, the fee schedule, and how California is authorized to share filings with other state attorneys general — Washington, Colorado, and the next wave of state premerger statutes. Includes a deal-team checklist for incorporating the California filing into standard HSR workflows.
Companion analysis: Inside State Enforcement — Tracking Key Developments in California Competition and AG Enforcement (Paul Moore). The firm’s monitor of the California Attorney General’s antitrust enforcement program — the California DOJ Antitrust Section’s recent expansion, its hiring of in-house economists, and the parallel California legislative pipeline alongside SB 25: AB 325 (algorithmic pricing), SB 763 (enhanced criminal and civil penalties), the pending AB 1776 (COMPETE Act), and AB 1415 / SB 351 (Office of Health Care Affordability healthcare-transaction notice regime).
Recent State Attorney General matters
A selection of state AG and state-AG-adjacent antitrust matters that Bona Law has handled as a firm:
• People v. Vitol, Inc., et al. (Cal. Super. Ct.; settled July 2024 for $50 million) — The California Attorney General’s Office retained Bona Law to assist the State in this antitrust action against global gasoline trading firms alleging manipulation of California gasoline price indices under the Cartwright Act and the Unfair Competition Law. Pat Pascarella led the Bona Law team on the engagement. Paul Moore was the State’s lead counsel during his service as senior Deputy Attorney General before joining Bona Law.
• Critical Internet Infrastructure — DOJ and State Attorney General antitrust representation. Representation of a Bona Law client in a Section 1 and Section 2 antitrust matter arising from the governance and control of critical internet infrastructure, before the U.S. Department of Justice (Antitrust Division) and various state attorneys general.
• University Medical-Center Entry — Certificate of Need antitrust and constitutional analysis. Bona Law analyzed and advised a university seeking to establish a medical center on the viability of antitrust and constitutional challenges to state Certificate of Need (CON) laws and the conduct of incumbent market participants who used those laws to impede competing market entrants.
Recent analysis from Bona Law
A selection of recent Bona Law writing on State Attorney General antitrust enforcement, California competition law, state-action immunity, and related subject matter:
→ California’s “Mini-HSR” Antitrust Filing Arrives in 2027: A Practical Compliance Checklist | Paul Moore and Steven Cernak | Bona Law Legal Resources.
→ Inside State Enforcement — Tracking Key Developments in California Competition and AG Enforcement | Paul Moore| Bona Law Legal Resources (Issue No. 1, April 28, 2026).
→ Best Practices for Merger Reviews before the Federal Agencies and the California Attorney General’s Office | The Antitrust Attorney Blog.
→ How Do I Seek Judicial Review of a California Administrative Agency or State Licensing Board Decision? | Bona Law Legal Resources — California administrative writ-of-mandate procedure.
Facing a State Attorney General matter?
Whether you need a dedicated state AG antitrust team alongside your trial counsel, or you want a defense-side antitrust boutique that the State has itself trusted with its own prosecutions, we can help. Contact Paul Moore, Pat Pascarella, or Luke Hasskamp to discuss your matter.