How a Section 8 interlock becomes a DOJ case One director on two competing boards can form a per se Section 8 violation, which the agency finds and inquires over, resolving either by quiet resignation or civil penalty. one seat on two boards Company A competing board Company B competing board shared seat Section 8 gate size + overlap per se violation Grace-period hook older seat + later overlap flips it later overlap Agency finds the interlock proactive HSR filings tips other probes Inquiry opens de minimis dominant route Director resigns dissolves the interlock no admission of liability Civil penalty per violation, per seat plus injunction No violation de minimis: 2% / 4% History's dominant end is quiet resignation, not a headline trial