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Antitrust & Trade Reg.

Jan. 2, 2026

AB 325 and SB 763: Amending the Cartwright Act to address algorithmic price fixing

Sheila R. Adams James

Partner
Davis Polk & Wardwell LLP

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Gil Ohana

Counsel
Davis Polk & Wardwell LLP

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Caroline Ziser Smith

Counsel
Davis Polk & Wardwell LLP

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AB 325 and SB 763: Amending the Cartwright Act to address algorithmic price fixing

On Oct. 6, 2025, California amended its antitrust law, the Cartwright Act, to explicitly address the use of algorithms. While other states and cities have focused on the use of algorithmic pricing recommendations in residential real estate (e.g., New York's AB A1417B), California's amendments--AB 325 and SB 793--address the use of algorithms more generally.

AB 325: same prohibited conduct, new lower pleading standard

AB 325 amends the Cartwright Act in three ways....

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