In FTC v. Actavis, Inc., 570 U.S. 136, 133 S. Ct. 2233 (2013), the Supreme Court addressed whether reverse-payment settlements in the Hatch-Waxman context are subject to antitrust scrutiny. The Court concluded that such settlements can sometimes violate the antitrust laws. 133 S. Ct. at 2227. That is so, the Court held, because [a]n unexplained large reverse payment itself would normally suggest that the patentee has serious doubts about the patents survival, thus suggest[ing] that the payments objective is to maintain supracompetitive prices to be shared among the patentee and the challenger rather than face what might have been a competitive market. Id. at 2237.