 Varney has also been critical of "reverse payment patent settlement" or "pay-for-delay" agreements, in which a potential generic competitor delays entry of a generic drug in exchange for a payment from a branded drug manufacturer with market power.A brief signed by Varney argues that such agreements are "presumptively unlawful", signifying a departure from the previous DOJ positions, aligning the DOJ's position with that of the FTC.As a Commissioner at the FTC, Varney was outspoken about monopolies in innovation markets and about the possibility that vertical mergers create unfair barriers to entry in networked industries.