Saturday, November 9, 2013

Volvo North Amer. Corp. v. Men’s Int’l Professional Tennis Council (MIPTC) case brief

Volvo North Amer. Corp. v. Men’s Int’l Professional Tennis Council (MIPTC) case brief summary
857 F.2d 55 (1988)


CASE SYNOPSIS
Plaintiffs appealed an order from the United States District Court for the Southern District of New York dismissing plaintiffs' claims involving federal antitrust violations, tortious interference with prospective business relations, and unfair competition on the ground that plaintiffs failed to state a claim upon which relief could be granted.

CASE FACTS
Plaintiffs were owners, producers, and sponsors of certain men's professional tennis events. Plaintiffs alleged that defendants conspired in violation of §§ 1 and 2 of the Sherman Act, 15 U.S.C.S. §§ 1 and 2, to monopolize and restrain trade in the markets for the production of such events. Plaintiffs claimed that defendants dissuaded tournament owners and producers from associating with plaintiffs or permitting participation by plaintiffs. As a result of restrictions imposed on tournament participants by defendants, plaintiffs claimed that they were limited in their ability to freely compete with defendants' events.

PROCEDURAL HISTORY
The district court granted defendants' motion to dismiss on the basis that plaintiffs failed to state claims upon which relief could be granted.

DISCUSSION
  • The court reversed, holding that plaintiffs' complaint adequately alleged that defendants engaged in price fixing, horizontal market division, and a threatened concerted refusal to deal with plaintiffs. 
  • The complaint also properly alleged that defendants engaged in monopolization.


CONCLUSION
The court reversed the district court's judgment dismissing plaintiffs' antitrust claims where plaintiffs adequately alleged price fixing, horizontal market division, threatened boycott, and monopolization in their complaint against defendants. The court vacated the dismissal of plaintiff management services' common law claims and remanded with instructions to dismiss the claims with leave to replead.

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