On 20 June 2013, the European Commission imposed fines on the Danish pharmaceutical company Lundbeck (EUR 93.8 million) and four generic manufacturers (EUR 52.2 million) for 'pay-for-delay' agreements relating to generic versions of citalopram, an antidepressant. A few days earlier, the US Supreme Court held in the FTC v. Actavis case that reverse payment settlement agreements are not per se anticompetitive, but must be analysed on an individual basis under the rule of reason test.