In 2016, the Antitrust Division of the U.S. Department of Justice (“DoJ”) announced that it intended to proceed criminally against “naked wage-fixing or no-poaching agreements.” Four years later, the DoJ has followed through on that announcement, with indictments returned (1) in December 2020 against an individual for allegedly agreeing to fix the prices paid to physical therapists and physical therapist assistants, (2) in January 2021 against an outpatient care facility for allegedly agreeing not to poach the senior-level employees of two of its competitors, and (3) in March 2021 against a health care staffing company and its former manager for allegedly agreeing to fix the wages of nurses and not to poach nurses from a competitor.