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WASHINGTON, D.C. - The Federal Trade Commission on March 23 filed a petition for a writ of certiorari seeking review of an 11th Circuit U.S. Court of Appeals ruling that although a merger between two Georgia hospitals would substantially lessen competition or tend to create a monopoly, the state-action doctrine immunized the conduct from a challenge by the FTC (Federal Trade Commission v. Phoebe Putney Health System, Inc., et al., No. 11-1160, U.S. Sup.; See December 2011).