Tuesday, October 8, 2013

Eastman Kodak Co. v. Image Tech. Servs case brief summary

Eastman Kodak Co. v. Image Tech. Servs case brief summary
504 U.S. 451

In an antitrust suit initiated by respondent independent service corporations, petitioner, a film company, appealed from a judgment of the United States Court of Appeals for the Ninth Circuit, which reversed the trial court's decision granting petitioner summary judgment.

Respondents sued, alleging, among other things, that petitioner's attempts to preclude them from servicing its equipment constituted a tying arrangement that violated 15 U.S.C.S. § 1. Although the trial court granted petitioner's motion for summary judgment, the lower court determined that respondents had presented sufficient evidence to raise a genuine issue concerning petitioner's market power. In doing so, it rejected petitioner's claim that competition in the equipment market would necessarily prevent it from engaging in a tying arrangement in the service and parts markets.

The Supreme Court affirmed the lower court's judgment after determining that petitioner had not met its burden under Fed. R. Civ. P. 56(c).

Specifically, it held that petitioner's economic theory did not dispel direct evidence that petitioner had used its market power to raise prices and drive out competition. Acknowledging that petitioner's parts service and equipment may have been components of one unified market, the court concluded that it would not reach that conclusion as a matter of law on a record so sparse.

The court affirmed the judgment.
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