The ultimate winner in the U.S. Supreme Court's decision that pharmaceutical pay-for-delay settlements are subject to antitrust review might not be the Federal Trade Commission or drug manufacturers, but rather the attorneys who represent them.

The court's ruling in FTC v. Actavis found a middle ground on the interplay between patent and antitrust law and created what lawyers in that space said was a subjective standard that made litigation over such settlements all the more likely.