While Monopolization claims hold up, court trims claims of conspiracy to restrain trade.
A recent decision from Judge Naomi Reice Buchwald in the Southern District of New York has set the framework for a closely watched antitrust case in the $13 billion digital health records space. The case, Particle Health Inc. v. Epic Systems Corp., pits a health tech startup against the largest provider of electronic health record (EHR) software in the United States, raising critical questions about competition, data access, and market power in healthcare technology.
Epic Systems, a dominant force in EHR software, launched its Epic Payer Platform (EPP) in 2021, enabling health insurers (“payers”) to efficiently retrieve and analyze medical records at scale. Particle Health, a startup, entered the market in 2023 with its own platform, targeting “payviders”—entities that both pay for and provide healthcare services. The dispute centers on Epic’s alleged efforts to block Particle’s access to EHRs, slow onboarding of Particle’s customers, and disparage Particle’s business practices.
The Companies
Particle Health is a venture-backed health data interoperability startup founded in 2018. Its estimated annual revenue is $20.5 million as of 2025. The company has raised more than $39 million in funding and employs between 45 and 70 people, depending on the source. (Sources:CompWorth, PitchBook, and Tracxn.)
Epic Systems, founded in 1979 and headquartered in Verona, Wisconsin, is one of the largest and most dominant EHR software vendors in the United States. Epic’s annual revenue is reportedly $4.9 billion for 2024. Epic employs approximately 13,000 to 14,000 people and controls a significant share of the U.S. hospital EHR market. (Sources: Forbes, KLAS Research, and Datanyze.)
The Allegations: Anticompetitive Conduct and Market Exclusion
Particle alleges that Epic used its market power to:
1) Cut off access to Epic-stored EHRs for Particle’s customers unless they stopped using Particle’s platform.
2) Slow the onboarding process for new Particle customers, requiring burdensome approvals and information not demanded of others.
3) Launch a “market-wide disparagement campaign” against Particle, including public statements raising privacy and security concerns.
4) Initiate a dispute within the Carequality interoperability framework, allegedly manipulating the outcome to Particle’s detriment.
These actions, Particle claims, led to lost customers, revenue decline, and a chilling effect on new business opportunities.
The Court’s Findings
Judge Buchwald’s decision grants in part and denies in part Epic’s motion to dismiss. The key outcomes:
1) Section 1 Sherman Act and Donnelly Act claims dismissed: The court found insufficient evidence of agreements or conspiracies between Epic and other entities to restrain trade.
2) Section 2 Sherman Act claims survive: The court held that Particle plausibly alleged monopolization, attempted monopolization, and monopoly leveraging. Epic’s alleged conduct—cutting off access, slowing onboarding, and disparaging Particle—could constitute exclusionary behavior not justified by legitimate business concerns.
3) Tortious interference with contract survives: Epic’s alleged inducement of Particle’s customer XCures to breach its contract was sufficiently pled.
4) Other state law claims (business relations, defamation, trade libel) dismissed: The court found the allegations too generalized or lacking in special damages.
Why This Matters: Competition and Data Access in Healthcare
This case highlights the tension between innovation and market power in healthcare technology. As EHR platforms become central to data-driven healthcare, the ability of startups to compete—and of payers to access records—depends on fair market practices. The court’s decision signals that dominant firms cannot use their position to exclude rivals without facing antitrust scrutiny.
The EHR Market at a Glance
The U.S. electronic health records (EHR) market is valued at nearly $13 billion in 2024 and is expected to grow steadily over the next several years, according to market research firms such as Grand View Research and MarketsandMarkets. Growth is driven by government incentives, technological innovation, and the increasing need for centralized healthcare data management.
EHR adoption is nearly universal among U.S. healthcare providers, with the Office of the National Coordinator for Health Information Technology reporting that 88% of office-based physicians use EHR systems. Adoption rates are similarly high in hospitals and clinics nationwide.
The market is highly consolidated, with Epic Systems and Oracle Cerner controlling roughly half of the U.S. market, as noted in industry analyses by KLAS Research and Becker’s Hospital Review. Other significant vendors include MEDITECH, Allscripts, NextGen Healthcare, McKesson, eClinicalWorks, Greenway Health, and CPSI. Large-scale client portfolios, high switching costs, and regulatory requirements reinforce the dominance of these established vendors.
EHR systems are segmented by deployment (cloud-based vs. on-premise), application (clinical, administrative, reporting), and end-user (hospitals, clinics, ambulatory centers). Cloud-based solutions are gaining market share due to their cost-effectiveness and scalability, as highlighted in recent reports from HIMSS and HealthIT.gov.
Key industry trends include ongoing government initiatives such as the HITECH Act, which accelerated EHR adoption, and technological advancements like AI integration and improved interoperability. Mergers and acquisitions among vendors and healthcare organizations continue to reshape the competitive landscape, according to coverage in Modern Healthcare and Fierce Healthcare. Security and privacy remain top concerns, with HIPAA and HITECH regulations driving investment in compliance and data protection.
Despite widespread adoption, challenges persist. Interoperability remains a major issue, with many systems still struggling to communicate seamlessly, impacting care coordination. High switching costs discourage competition, and privacy breaches continue to be a concern for providers and vendors.
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