## Reality check from the *latest* disclosure: U.S. review is not described as “cleared” yet In Getty Images’ most recent merger-related filing (Feb. 19, 2026), the company’s disclosed update is centered on the UK Competition and Markets Authority (CMA) and explicitly frames the U.S. Department of Justice (DOJ) process as still ongoing (“as its review progresses”), rather than concluded. ["DOJ as its review progresses"](0001213900-26-018177|1) ["statement on the UK Competition"](0001213900-26-018176|0) **Alpha “between the lines”:** if DOJ/HSR had cleanly cleared, companies typically *say so plainly* because it is a major de-risking catalyst. The fact pattern in the newest disclosure suggests management isn’t ready (or able) to characterize U.S. antitrust as unconditional clearance yet—meaning the market may be over-reading “quiet” as “cleared.” ["work cooperatively with the U.S. Department of Justice as its review progresses"](0001213900-26-018177|1) --- ## What the paper trail implies about DOJ/HSR: this was a real second-request process, not a routine rubber stamp The merger has already gone through the “hard” U.S. antitrust path historically: the proxy materials disclose HSR filings, a pull-and-refile, and then a DOJ “Second Request,” which extends the statutory waiting period until substantial compliance (plus 30 days), unless terminated sooner. ["received a Request for Additional Information"](0001213900-25-037645|0) The companies publicly announced receipt of the DOJ Second Request in April 2025 and described continued cooperation to obtain regulatory clearance—confirming the review reached an advanced scrutiny phase. ["Receive Second Request from the U.S. Department of Justice"](0001628280-25-016275|1) ["extend the waiting period imposed by the HSR Act"](0001628280-25-016275|1) **Alpha “between the lines”:** second requests tend to compress “easy upside” and increase the value of (i) strong deal rationale, (ii) credible remedy/defense strategy, and (iii) stamina on timing. That generally favors better-prepared operators—and penalizes anyone underwriting a fast, clean close without reading the procedural history. ["Second Request… extend the waiting period"](0001213900-25-037645|0) --- ## The *current* gating item being emphasized: UK CMA remedies risk is the headline, not the U.S. In the most recent press release furnished with the Feb. 19, 2026 filing, Getty Images highlights the CMA’s provisional finding that the merger is *not expected* to create competition issues in the global stock content market, but also flags disagreement with a provisional concern in the UK editorial market. ["not expected to result in competition issues"](0001213900-26-018177|1) ["substantial lessening of competition"](0001213900-26-018177|1) **Alpha “between the lines”:** this reads like a company steering investor attention to the *most actionable* near-term regulator dialogue (CMA timeline, response process), while keeping U.S. antitrust commentary tightly worded and non-committal—consistent with a process still live or not yet at the “victory lap” stage. ["expect to file our response… in line with the CMA’s timeline"](0001213900-26-018177|1) --- ## Impactful takeaway for investors: de-risking is happening—but it’s uneven across jurisdictions **What you can say confidently from the latest disclosures:** - Getty Images is actively managing multi-jurisdiction regulatory review and, as of Feb. 19, 2026, is publicly engaged with the CMA’s provisional findings while describing DOJ review as ongoing. ["statement on the UK Competition"](0001213900-26-018176|0) ["DOJ as its review progresses"](0001213900-26-018177|1) - The U.S. process has historically involved a Second Request under HSR, which is not consistent with a “routine” review. ["received a Request… (Second Request)"](0001213900-25-037645|0) **Hidden-alpha framing:** the market opportunity is less about a single binary “clearance headline” and more about *sequencing*: if/when a clean U.S. outcome becomes explicitly disclosed, the re-rating could be sharper precisely because the latest filings still avoid characterizing DOJ/HSR as unconditional clearance. ["work cooperatively with the U.S. Department of Justice as its review progresses"](0001213900-26-018177|1)

## Reality check from the *latest* disclosure: U.S. review is not described as “cleared” yet In Getty Images’ most recent merger-related filing (Feb. 19, 2026), the company’s disclosed update is centered on the UK Competition and Markets Authority (CMA) and explicitly frames the U.S. Department of Justice (DOJ) process as still ongoing (“as its review progresses”), rather than concluded. ["DOJ as its review progresses"](0001213900-26-018177|1) ["statement on the UK Competition"](0001213900-26-018176|0) **Alpha “between the lines”:** if DOJ/HSR had cleanly cleared, companies typically *say so plainly* because it is a major de-risking catalyst. The fact pattern in the newest disclosure suggests management isn’t ready (or able) to characterize U.S. antitrust as unconditional clearance yet—meaning the market may be over-reading “quiet” as “cleared.” ["work cooperatively with the U.S. Department of Justice as its review progresses"](0001213900-26-018177|1) --- ## What the paper trail implies about DOJ/HSR: this was a real second-request process, not a routine rubber stamp The merger has already gone through the “hard” U.S. antitrust path historically: the proxy materials disclose HSR filings, a pull-and-refile, and then a DOJ “Second Request,” which extends the statutory waiting period until substantial compliance (plus 30 days), unless terminated sooner. ["received a Request for Additional Information"](0001213900-25-037645|0) The companies publicly announced receipt of the DOJ Second Request in April 2025 and described continued cooperation to obtain regulatory clearance—confirming the review reached an advanced scrutiny phase. ["Receive Second Request from the U.S. Department of Justice"](0001628280-25-016275|1) ["extend the waiting period imposed by the HSR Act"](0001628280-25-016275|1) **Alpha “between the lines”:** second requests tend to compress “easy upside” and increase the value of (i) strong deal rationale, (ii) credible remedy/defense strategy, and (iii) stamina on timing. That generally favors better-prepared operators—and penalizes anyone underwriting a fast, clean close without reading the procedural history. ["Second Request… extend the waiting period"](0001213900-25-037645|0) --- ## The *current* gating item being emphasized: UK CMA remedies risk is the headline, not the U.S. In the most recent press release furnished with the Feb. 19, 2026 filing, Getty Images highlights the CMA’s provisional finding that the merger is *not expected* to create competition issues in the global stock content market, but also flags disagreement with a provisional concern in the UK editorial market. ["not expected to result in competition issues"](0001213900-26-018177|1) ["substantial lessening of competition"](0001213900-26-018177|1) **Alpha “between the lines”:** this reads like a company steering investor attention to the *most actionable* near-term regulator dialogue (CMA timeline, response process), while keeping U.S. antitrust commentary tightly worded and non-committal—consistent with a process still live or not yet at the “victory lap” stage. ["expect to file our response… in line with the CMA’s timeline"](0001213900-26-018177|1) --- ## Impactful takeaway for investors: de-risking is happening—but it’s uneven across jurisdictions **What you can say confidently from the latest disclosures:** - Getty Images is actively managing multi-jurisdiction regulatory review and, as of Feb. 19, 2026, is publicly engaged with the CMA’s provisional findings while describing DOJ review as ongoing. ["statement on the UK Competition"](0001213900-26-018176|0) ["DOJ as its review progresses"](0001213900-26-018177|1) - The U.S. process has historically involved a Second Request under HSR, which is not consistent with a “routine” review. ["received a Request… (Second Request)"](0001213900-25-037645|0) **Hidden-alpha framing:** the market opportunity is less about a single binary “clearance headline” and more about *sequencing*: if/when a clean U.S. outcome becomes explicitly disclosed, the re-rating could be sharper precisely because the latest filings still avoid characterizing DOJ/HSR as unconditional clearance. ["work cooperatively with the U.S. Department of Justice as its review progresses"](0001213900-26-018177|1)