On April 20, 2015, the FTC and Cardinal Health, Inc. entered into a settlement agreement to resolve charges that Cardinal violated Section 5 of the FTC Act by:

The FTC alleged that Cardinal, which owns the largest chain of radiopharmacies in the US, used anticompetitive tactics to prevent other radiopharmacies from entering its markets. The proposed settlement requires Cardinal to pay $26.8 million in disgorgement, which is the second largest monetary settlement the FTC has obtained in an antitrust case. The proposed settlement also includes behavioral remedies to prevent future violations and restore competition. The Commission vote was three to two. Commissioners Wright and Ohlhausen dissented, arguing that disgorgement was not appropriate.

In the complaint, the FTC alleged that Cardinal unfairly competed in the market for the sale and distribution of single photon emission tomography radiopharmaceuticals, also known as low energy radiopharmaceuticals. Radiopharmaceuticals are used in nuclear medicine to diagnose and treat many diseases. Radiopharmacies compete to provide hospitals and clinics with their radiopharmaceutical requirements. The FTC alleged that there were no close substitutes for radiopharmaceuticals.

The FTC alleged that 25 cities were relevant geographic markets. Radiopharmaceuticals contain rapidly decaying radioisotopes and must be delivered and administered within hours of being compounded by a radiopharmacist. As a result, hospitals and clinics need or strongly prefer radiopharmacies located in close proximity to their facilities that can deliver doses within a short time frame.

After acquisitions in 2003 and 2004, Cardinal became the largest operator of radiopharmacies in the US and the sole radiopharmacy operator in the 25 relevant geographic markets. The FTC alleged that after each of the acquisitions and through 2008, Cardinal sought to unlawfully preserve its acquired dominant position in those markets, which would have otherwise seen entry from rival radiopharmacies. Cardinal achieved this by blocking potential entrants from gaining rights to distribute radiopharmaceuticals containing heart perfusion agents (HPAs). Physicians use HPAs to perform heart stress tests, the most common radiopharmaceutical procedure. Radiopharmaceuticals containing HPAs are indispensable to the operation of a competitive and profitable radiopharmacy.

From 2003 to 2008, Bristol-Myers Squibb (BMS) and Amersham plc, which was later acquired by General Electric Co. (GE-Amersham), were the only two manufacturers of HPAs. During that time, a radiopharmacy could not profitably operate and compete without obtaining the right to distribute HPAs from either BMS or GE-Amersham. The FTC alleged that between 2003 and 2008, Cardinal employed various tactics to pressure BMS and GE-Amersham to refuse to grant HPA distribution rights to new competitors in the relevant markets, including by threatening or actually:

As a result, the FTC found that Cardinal's actions caused harm in the 25 relevant markets by preventing entrants from gaining access to radiopharmaceuticals and being able to compete directly with Cardinal.

To settle the FTC's allegations, Cardinal agreed to an order requiring it to:

Commissioners Ohlhausen and Wright individually dissented from the FTC's order, stating that they do not believe that disgorgement is an appropriate remedy in this case due to larger policy concerns.