The July 2025 decision by the Ninth Circuit Court of Appeals in Epic Games v. Google marks a landmark development in the ongoing evolution of antitrust remedies for unilateral conduct in the technology sector. The court’s willingness to affirm not just prohibitory, but also mandatory, forward-looking injunctions—requiring Google to take affirmative steps to open its Android app ecosystem to competition—signals a vigorous approach to restoring competition in digital platforms.

Federal enforcers at the FTC and DOJ Antitrust Division often receive much of the focus for antitrust enforcement, but state enforcers play a key role in the antitrust landscape.